Emponaut Inc. Privacy Policy

Version 1.0

Last Updated: September 3, 2025

Please read this Privacy Policy (“Privacy Policy”) and the related Terms of Use (“Terms”) carefully before using this website. Emponaut Inc. (“Emponaut”, “Company”, “we”, “our”, or “us”), a Delaware corporation, is committed to protecting your privacy. The website located at www.emponaut.com (the “Interface,”, the “Platform”, the “Site,” or the “App”), which provides a web-hosted user interface, is a copyrighted work belonging to Emponaut. The Interface provides tools that capture conversations and personal audio reflections to improve individual and team communication skills. This Privacy Policy applies to you (“you,” or “user”) and your use of the Site as a user of the Interface, including all the products, services, tools, features, functionality, and information made available on Site, as described in our Terms (collectively, the “Service”).

We are committed to protecting your privacy. This Privacy Policy includes guidelines for protecting your information and, depending on your jurisdiction, describing your rights under applicable data protection laws. This Privacy Policy discloses what type of information is collected, the methods used to collect it, how we utilize the information to better serve all interested parties and the choices you have about the way your information is collected and used.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, your choice is not to use our Service. By accessing or using the Service, you agree to this Privacy Policy. This Policy may change from time to time (see Changes to this Privacy Policy section below). Your continued use of the Service after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

This Privacy Policy describes how we collect, store, use and disclose the following types of personal data:

1. Information We Collect

Collected Information. We collect Personal Data, Anonymous Data, Emponaut User Data, and Emponaut Website, CRM & Prospect Data as described below. For purposes of this Privacy Policy “Personal Data” means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. and “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data. Anonymous Data does not, by itself, permit the identification of individual persons. “Emponaut User Data” means account, contact and activity data relating to individuals who use the Emponaut Platform. “Emponaut Website, CRM & Prospect Data” means data relating to our customers, visitors of our Site, participants at our events, and any other prospective customer or partner who visits or otherwise interacts with any of our websites, online ads and content, emails or communications under our control.
Information You Provide Us.
1. Account Information. You may be required to have a user account to use the Site or the Service. When you use our Service, update your account profile, create or update your user account, or contact us, we may collect Personal Data from you, such as email address, first and last name, user name, and other information you provide.
2. User Preferences. Our Service lets you store preferences like how your content is displayed, notification settings, and favorites. We may associate these choices with your browser or mobile device.
3. User Communications. If you provide us with feedback or contact us, we will collect your name and contact information, as well as any other content included in the message.
4. Other User Provided Information. We may also collect Personal Data at other points within the Service where you voluntarily provide it or where it is indicated that Personal Data is being collected. For example, you may be asked to provide contact details—such as your name, email address, phone number, job title, or company name—when you request a demo, subscribe to updates, participate in a webinar, complete a survey, engage with our sales or support teams, or register for access to certain features of the Platform.
5. User Provided Information is Voluntary. Providing us with Personal Data about yourself is voluntary, and you can always choose not to provide certain information; however, you may not be able to take advantage of or participate in some of the Site's features or our Service.
Information Collected via Technology.
1. Automatic Data Collection. As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including the information discussed in the rest of this Section.
2. Information Collected by Our Servers. To provide our Service and make it more useful to you, we (or a third party service provider) collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, and date/time stamps.
3. Log Files. We gather certain information automatically and may store it in log files. This information may includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We may use this information to analyze trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information can be used to personalize your experience.
4. Cookies. A cookie is a small file that asks permission to be placed on your computer's hard drive; you may control whether or not you permit the use of cookies. Cookies help us analyze web traffic and lets you know when you have visited a particular site. They allow us to respond to you as an individual. Our Site access is improved by identifying your likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used; this helps us analyze data about web page traffic and improve our Site. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer (as discussed in Section 8 below). Please note that if elect to not permit cookies this may prevent you from taking full advantage of our Service.
5. Pixel Tag. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow us to analyze how users find our Service, make the Service more useful to you, and tailor your experience with us to meet your particular interests and needs. Our systems do not currently recognize "do not track" signals or other mechanisms that might enable users to opt out of tracking on our Site.
6. Analytics Services. In addition to the tracking technologies we place like cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services (“Analytics Services”) that we engage to help analyze how users use the Service. The information generated by the cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on the behalf of the Analytics Services. Each Analytics Services' ability to use and share Analytics Information is restricted by such Analytics Services' terms of use and privacy policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
Information Collected from Third-Party Companies. We may receive Personal and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with our Service or whose products and/or services may be linked from our Service.

2. How We Use This Data

Personal Data Use. We process your Personal Data, Emponaut User Data and Emponaut Website, CRM & Prospect Data to run our business, provide the Service, personalize your experience on the Service, and improve the Service. Specifically, we use your Personal Data to:

Provide you with access to our Site and the Service;
enhance our Service;
improve the functionality and user-friendliness of the Service;
provide customer support and respond to your requests, inquiries, and feedback;
detect, prevent, and address fraud, violations of our terms or policies, including this Privacy Policy and the Terms, and/or other harmful or unlawful activity;
send you administrative notifications and security, support, and maintenance advisories;
send you newsletters, promotional materials, and other notices related to our Services or third parties' goods and services (subject to your preferences discussed in Section 7.1 below);
comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and
act in any other way we may describe when you provide the Personal Data.

Anonymous Data. We may create Anonymous Data records from Personal Data. We use this Anonymous Data to analyze request and usage patterns so that we may improve our Services and enhance Service navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction (subject to applicable law, if any).

3. How Long We Keep Your Data

We keep your data if it is necessary to process your requests, operate our business and provide our Service, or as long as we are legally required to do so. For as long as we have your data, we will continue to protect the privacy and security of such data consistent with the Privacy Policy.

4. How We Protect Your Information

Precautions We Take. We take precautions to protect your personal information, including reasonable physical, administrative, and technical safeguards to preserve the integrity and security of information collected through our Service. When you submit personal information via our Site and Service, your personal information is transmitted using secure sockets layer (SSL) encryption technology. We restrict access to your personal information to our authorized personnel and/or third-party providers as appropriate and necessary to provide our Site and products. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
No Guarantee. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted using the Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

5. How We Share Your Information

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

Third-Party Service Providers. We may share your Personal Data with third party service providers to: provide technical infrastructure services; conduct quality assurance testing; analyze how our Service is used; prevent, detect, and respond to unauthorized activities; comply with regulations; provide technical and customer support; and/or to provide other support to us and to the Service.
Affiliates. We may share some or all of your Personal Data with any subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
Professional Advisors. We share information with our professional advisors for purposes of audits and compliance with our legal obligations.
Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
Legal Requirements. We may have to share your Personal Data to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
Other Disclosures. We may also disclose your Personal Data to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide it, or with your consent.
We Do Not Sell Your Data. We do not sell or share your personal information with any unaffiliated third party for marketing purposes.

6. Links To Third-Party Websites

Our Service may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

7. Your Choices Regarding Information

You have several choices regarding the use of information on our Services:

Email Communications. We may periodically send you newsletters and/or emails that directly promote the use of our Service or third parties' goods and services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving these communications from us by following the unsubscribe instructions provided in the email you receive or through the "Notifications" preferences in your Settings page. Despite these preferences, we may send you occasional transactional service-related informational communications.
Service Communications. We may send you important communications relating to the operation and administration of the Service. These may include notifications regarding account activity (such as login attempts or password resets), billing matters, updates to the Service, or other essential service-related notices, and may be delivered via any contact method available to us. In addition, other authorized users or administrators within your customer account may send you notifications, messages, or updates in connection with their or your use of the Service. Customers may also use the Service to communicate directly with their own end users—for example, by sending invitations, sharing recordings, or distributing meeting summaries. You may manage certain communication preferences through your Emponaut User profile settings or as directed within specific messages; however, please note that certain service-related communications—such as those necessary for security or account administration—are required for use of the Service and cannot be disabled.
Cookies. If you decide at any time that you no longer wish to accept cookies from our Service for any of the purposes described above, you can change your browser's settings to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Service or all functionality of the Service.

8. Your Rights

You can view, access, edit, or delete your Personal Data for certain aspects of the Service via an email to support@emponaut.com. Depending on where you live, you may have certain legal rights under applicable law, including but not limited to, the European and UK General Data Protection Regulations (“GDPR”). For example, you may have the following rights:

Right to limit – means you can ask us to restrict or stop processing your Personal Data, if it not necessary for the purpose you provided it to us.
Right to access – means you can ask us for a copy of any Personal Data we have about you, if any.
Right to correct – means you may ask us to change and/or correct any Personal Data we have about you.
Right to delete – means you may ask us to delete any Personal Data we have about you and we will be happy to do so unless we are required to retain such information by law or regulation, or we have a right to retain subject to a user agreement for our internal business purposes.
Right to transfer – means you may request a copy of your Personal Data, in a commonly used and machine-readable format, be provided to you or to a third party you specify.

You may contact us at any time about any of these rights or any concern or question you have about our use of your Personal Data. If you wish to exercise your rights under the GDPR or other applicable data protection or privacy laws, please contact us at support@emponaut.com, specify your request, and reference the applicable law. We may ask you to verify your identity, or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights. Please note that if you choose to delete your information or opt-out of the collection and use of your information, certain features of our Service or the Site may no longer be available to you.

If your inquiry concerns Personal Data that we process on behalf of a customer for example and you are a customer’s prospect, end user, or representative using the Service at the direction of that customer, you should direct your request to the applicable customer, who acts as the data controller of such data. In these circumstances, Emponaut operates solely as a data processor or service provider and is not authorized to respond directly to data subject rights requests relating to customer-controlled data. If you contact us directly in connection with customer-controlled data, we may refer your request to the appropriate customer or share your communication with them. We may also provide the contact information of the customer’s account administrator, as necessary to facilitate your request.

9. Children

Our Site is not intended for children under the age of 13 (or 16 where applicable). We do not knowingly collect information from children under the age of 13 (or 16 where applicable). No one under the age of 13 (or 16 where applicable) may provide any information to or on the Site. If you are under the age of 13, do not use or provide any information on this Site. If we learn we have collected or received personal information from a child under 13 (or 16 where applicable) without verification or parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13 (or 16), please contact us at support@emponaut.com and provide us sufficient detail to enable us to delete that information from our databases.

10. Data Protection Laws

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.

Emponaut is the “data controller” of Emponaut Website, CRM & Prospect Data. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.

Emponaut is both a “data controller” and “data processor” of Emponaut User Data. Such data is processed by Emponaut for its own purposes, as an independent ‘controller’; while those certain portions of it which are included in Personal Data will be processed by us on our customer’s behalf, as a ‘processor’.

Accordingly, Emponaut processes Personal Data strictly in accordance with such customer’s reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such customer. The customer, as controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).

For the avoidance of doubt, each customer is solely responsible for providing adequate notice to their account users and customers whose data may be contained in Personal Data – including sufficient reference to the processing of their Personal Data via the Service, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.

11. Changes to This Privacy Policy

We reserve the right, in our sole discretion, to modify, update, add to, discontinue, remove or otherwise change any portion of this Privacy Policy, in whole or in part, at any time. When we amend this Privacy Policy, we will revise the "Last Updated" date located at the top of this Privacy Policy. For changes to this Privacy Policy that we consider to be material, we will notify you through a notice on the Site's homepage requesting a click-through consent. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.

12. Questions; Contacting Us; Reporting Violations

If you have any questions, concerns, or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at support@emponaut.com.