Privacy Policy

1. Information We Collect

1.1 Information you provide directly

• Account information. When you create an account we collect your email address and, if you sign in with Google, your Google profile information (name, email, profile picture).
• Photographs and biometric data. When you create a custom avatar you upload a photograph that is processed by AI to generate a 3D facial model. This process involves the extraction of geometric facial features that may constitute biometric data under applicable law, including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and the Washington My Health MY Data Act. We handle this data in accordance with our Biometric Data Policy. We store the original photograph and the resulting 3D model assets.
• Voice and audio. During video calls, your microphone audio is transmitted in real time to our servers and to AI voice-processing providers for speech recognition and response generation. Voice patterns and characteristics may constitute biometric identifiers under certain state laws. We do not permanently store raw audio recordings. Audio is processed in memory and discarded at the end of each session unless you explicitly save a recording.
• Voice design data. If you use the Voice Design feature, we process voice descriptions and AI-generated voice samples through ElevenLabs. We store the resulting voice configuration (voice ID and settings) linked to your character. Audio preview samples generated during the design process are ephemeral and not retained after selection.
• Conversation content. The text of your conversations is processed to generate responses and extract memory facts. Session transcripts are used to produce memory entries (see Section 1.2) and are not retained beyond the current session.
• Character data. If you create a character we store the character’s name, personality configuration, backstory, voice settings, and associated images.
• Meeting Bot configuration. When you use the Meeting Bot feature, we collect and store the meeting URL, target platform, character assignment, session goal, meeting role, deliverable type, and any meeting context you provide at launch.
• Third-party integration credentials. If you connect third-party services (such as Linear, HubSpot, Gmail, Outlook, Salesforce, or Pipedrive) to your account, we store the OAuth tokens or credentials necessary to authenticate with those services on your behalf. These credentials are encrypted at rest using symmetric encryption. We access the connected services only to fulfill actions you have authorized.
• Payment information. Payment processing is handled entirely by Stripe. We do not store your full card number, CVV, or bank account details. We receive and store your Stripe customer ID, subscription status, plan type, and billing history metadata.
• API keys. If you use the Developer API we generate and store API keys and their associated scopes linked to your account.
• Webhook configurations. If you register webhook endpoints through the Workspace, we store the endpoint URL, signing secrets, and delivery logs.
• Feedback and support communications. If you contact us by email or submit feedback, we retain that correspondence.

1.2 Information generated through use

• Memories and AI-derived inferences. After each conversation our system uses AI to extract key facts (e.g., your name, preferences, topics discussed) and stores them as structured "memory" entries linked to your account and the character. These entries, and any other inferences drawn from your interactions, are treated as personal information.
• Meeting deliverables. When a Meeting Bot session produces a document (such as meeting notes, an investment memo, a legal review, a financial summary, or action items), that document is stored and linked to your account and the associated bot session. You may retrieve it via the API.
• Character blog content. AI-generated blog posts authored under a character’s persona are stored and may be publicly accessible. These posts are linked to the character and your account.
• Usage data. We collect information about how you interact with the Service, including pages visited, features used, session duration, characters interacted with, Meeting Bot sessions, and frequency of use.
• Meeting Bot activity logs. We retain metadata about Meeting Bot sessions: bot ID, platform, session duration, status transitions (starting, in-call, ended, failed), and webhook delivery records. We do not retain the raw audio of other meeting participants. Meeting audio is processed in real time for the bot’s speech recognition and response generation and is discarded at session end.
• Device and connection data. We collect your IP address, browser type, operating system, device identifiers, and network information for security, analytics, and service optimization.
• Error and diagnostic data. We use Sentry to capture application errors and performance events. Sentry may receive your IP address, browser information, and a stack trace of the action that caused the error.

1.3 Information from third-party services

We manage authentication ourselves. Your password is stored only as a salted cryptographic hash; we never store or log the plaintext. Password reset emails are delivered through our email provider (Resend).

When you connect third-party integrations (Section 10 of the Terms), we may access and process data from those services — such as project tickets, CRM records, email drafts, or calendar events — solely to perform the actions you have authorized within those services. We do not use that data for any purpose other than fulfilling your authorized requests.

2. How We Use Your Information

We use the information we collect for the following purposes:

We do not use your personal data for automated individual decision-making that produces legal or similarly significant effects without human review.

3. Third-Party Services and Data Sharing

We share your information with third-party service providers strictly as necessary to operate the Service. We do not sell your personal information to third parties and do not share it for cross-context behavioral advertising.

3.1 Service providers

Each provider processes data in accordance with their own privacy policies and applicable data processing agreements. We select providers that maintain appropriate security standards and limit their use of your data to the services they provide to us.

3.2 User-authorized third-party integrations

When you connect third-party services through the Profile > Integrations page (such as Linear, HubSpot, Gmail, Outlook, Salesforce, or Pipedrive), you authorize SplatChat and its AI systems to interact with those services on your behalf. Data from those services (such as ticket titles, contact records, or email drafts) may be processed by our AI systems to fulfill your requests. We do not share your integration data with unrelated third parties. You can revoke integration access at any time through your account settings or the third-party service’s authorization dashboard.

3.3 Legal and safety disclosures

We may disclose your information if required by law or valid legal process (such as a subpoena, court order, or government request), or where we have a good-faith belief that disclosure is necessary to protect the safety of any person, prevent fraud or abuse, protect our rights, or comply with applicable law. Where permitted, we will notify you of such requests.

3.4 Business transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, your information may be transferred as part of that transaction. We will notify you of any such transfer and describe the choices you may have.

3.5 Aggregated or de-identified data

We may share aggregated or de-identified information that cannot reasonably be used to identify you with third parties for research, marketing, analytics, or other purposes.

4. AI Processing and Automated Systems

The core of our Service involves processing your inputs through AI systems. Specifically:

• Your speech is converted to text (speech-to-text) and sent to AI language models to generate character responses.
• AI-generated text is converted to speech (text-to-speech) and synchronized with 3D avatar facial animation.
• After sessions, AI systems extract factual memories from conversation transcripts.
• Photographs you upload are processed by AI models to extract facial geometry and generate a 3D Gaussian Splat avatar model. This may involve biometric feature extraction.
• When the Meeting Bot feature is used, the bot’s speech recognition system processes audio from all meeting participants in real time. This audio is not permanently stored; it is used solely to enable the AI character to respond within the meeting.
• After Meeting Bot sessions, AI systems may generate structured deliverables (meeting notes, memos, action items) from transcribed content.
• Character blog post pipelines use AI to generate, review, and publish content.
• We may use aggregated, de-identified conversation data and performance metrics to retrain and improve our AI systems. We do not use identifiable personal conversations to train AI models without your explicit consent.

These processes are essential to the functioning of the Service. Where required by applicable law (for example, under the EU AI Act or GDPR Article 22), you have the right to request human review of significant automated decisions that affect you. To exercise this right, contact us at privacy@splatchat.com.

5. Biometric Data

SplatChat collects and processes biometric data as part of the avatar creation feature. A summary is provided here; full details, including state-specific rights and our retention and destruction schedule, are in our Biometric Data Policy.

• What we collect. When you upload a photograph for avatar creation, AI systems extract facial geometry (a biometric identifier) to build your 3D avatar model. Real-time voice processing during calls may also involve voice biometric analysis.
• Purpose. Biometric data is used exclusively to build and operate your avatar within the Service. It is not sold, leased, traded, or used for any purpose other than providing the Service and improving the accuracy of our avatar pipeline.
• Retention and destruction. Biometric data is retained only for as long as the associated avatar character exists or until you delete your account, whichever is earlier. Upon deletion we permanently destroy the biometric data within 30 days.
• Illinois residents (BIPA). If you are an Illinois resident, your biometric data is collected only with your informed written consent (provided when you upload a photo for avatar creation). You have the right to revoke consent, access your biometric data, and request its deletion.
• Texas and Washington residents. Similar protections apply under the Texas CUBI and Washington My Health MY Data Act. Contact us to exercise your rights.

6. Meeting Bots, Embedded Widgets, and Other Participants

The Meeting Bot feature introduces a unique privacy consideration: when a bot joins a meeting, it processes audio from all participants — not just the user who launched it.

• Participant audio. The bot’s speech recognition system processes the audio of all meeting participants in real time. This audio is not recorded to persistent storage. It is used only to enable the AI character to understand and respond within the meeting session, and is discarded when the session ends.
• Meeting deliverables. If a deliverable type is configured, the bot will produce an AI-generated document (e.g., meeting notes or a summary memo) after the session. This document is derived from the meeting conversation and stored in connection with the bot session. The user who launched the bot controls access to and retention of deliverables.
• Disclosure responsibility. The user who deploys a Meeting Bot is responsible for disclosing to all other participants that an AI is present and processing audio. SplatChat does not independently notify meeting participants. SplatChat is not responsible for any privacy violations arising from a user’s failure to make required disclosures.
• Third-party participants. Third parties who participate in meetings where a bot is present are not SplatChat users. If you are a third-party participant and have concerns about your audio having been processed, please contact the user or organization that deployed the bot, or reach out to us at privacy@splatchat.com.

Embedded widget sessions. SplatChat characters can be embedded as a click-to-talk widget on third-party websites. If you talk to a character through such a widget:

• No account, no visitor profile. Widget sessions do not create a SplatChat account or persistent visitor identity, and the character does not store memories about you. Sessions are associated with the SplatChat user who installed the widget (who pays for the conversation time), not with you.
• Host page context. The website that embeds the widget may share the page URL and title (and optionally a short note from the site owner) with the character for that conversation, so the character can speak to what you were looking at. When that page is publicly reachable, we may also read a short extract of its visible text for the same purpose. This context is used only for the live conversation; it is not used to build a visitor profile or to track you across sites. Site owners can disable automatic URL/title sharing in their install.
• Audio processing. Your microphone audio is processed in real time to enable the conversation, exactly as described in Section 1 for voice conversations, and is not used to build a profile of you.
• No cross-site tracking. The widget does not set cross-site tracking identifiers. We process your IP address and browser characteristics transiently for abuse prevention (rate limiting and bot detection, which may include Cloudflare Turnstile) and session-cap enforcement.
• Disclosure. Every widget displays a permanent notice that you are talking to an AI avatar provided by SplatChat.
• The host website is separate. The website embedding the widget has its own privacy practices, which we do not control. Questions about that site’s data handling belong to its operator; questions about the conversation itself can go to privacy@splatchat.com.

7. Data Retention

• Account data is retained for the lifetime of your account. When you delete your account we delete your personal data within 30 days, except where retention is required by law.
• Conversation audio is processed in real time and discarded at the end of each session. It is not permanently stored.
• Meeting audio (processed by Meeting Bots) is processed in real time and discarded at session end. It is not permanently stored.
• Memory entries persist until you delete them individually, delete the associated character, or delete your account.
• Avatar assets and biometric data (3D models, photographs, facial geometry) are retained while the associated character exists. Deleting a character removes its avatar assets and associated biometric data within 30 days.
• Meeting Bot session records (metadata, status history, webhook delivery logs) are retained for up to 90 days after the session ends.
• Meeting deliverables (AI-generated documents) are retained until you delete the associated bot session record or your account.
• Third-party integration credentials are retained while the integration is connected. Upon disconnection, credentials are deleted within 30 days.
• Character blog content is retained while the associated character exists. Deleting a character removes its published content.
• Billing records may be retained for up to 7 years to comply with tax and financial reporting obligations.
• Server and security logs containing IP addresses and request metadata are retained for up to 90 days for security and debugging, and may be retained longer if relevant to an ongoing investigation.
• Legal hold. We may retain data beyond the periods above if required by law, regulation, court order, or to defend against legal claims.

8. Cookies and Similar Technologies

We use cookies and similar local-storage mechanisms. A full description of the cookies we use, how to control them, and your consent choices is available in our Cookie Policy. In summary:

• Strictly necessary cookies are required for authentication and core functionality and cannot be disabled.
• Functional storage includes local-storage entries for user preferences such as theme or last-visited character.

We do not currently use third-party tracking, advertising, or behavioral analytics cookies. If this changes we will update our Cookie Policy and provide appropriate consent mechanisms.

Do Not Track. Some browsers send a "Do Not Track" (DNT) signal. We currently do not respond to DNT signals because no uniform standard exists for how services should honor them. If a standard is adopted we will reassess our practices.

9. Data Security

We implement industry-standard technical and organizational measures to protect your information, including:

• Encryption of data in transit (TLS/HTTPS for all connections) and at rest where applicable.
• Symmetric encryption at rest for third-party integration credentials.
• Row-level security (RLS) policies on our database to enforce per-user access controls.
• Rate limiting and abuse detection on all API endpoints.
• Secrets management: API keys and credentials are stored in encrypted environment configurations, not in source code.
• WebRTC encryption for real-time video and audio streams.
• Periodic security reviews and vulnerability assessments.

No method of electronic storage or transmission is 100% secure. While we strive to protect your data we cannot guarantee absolute security.

9.1 Data breach notification

If we become aware of a data breach that is reasonably likely to result in risk to your rights and freedoms, we will notify affected users without undue delay and in accordance with applicable law. We will also notify relevant supervisory authorities where required (e.g., within 72 hours under GDPR). Notifications will include the nature of the breach, the categories of data affected, and the steps we are taking to address it.

10. Your Rights and Choices

Depending on your jurisdiction you may have some or all of the following rights:

• Access. Request a copy of the personal data we hold about you.
• Correction. Request correction of inaccurate or incomplete data.
• Deletion. Request deletion of your personal data. You can delete individual memories from within the Service, delete characters, disconnect integrations, or delete your entire account to remove all associated data.
• Portability. Request a copy of your data in a structured, machine-readable format.
• Restriction. Request that we restrict processing of your data in certain circumstances.
• Objection. Object to processing of your data for certain purposes, including direct marketing.
• Withdrawal of consent. Where processing is based on consent you may withdraw consent at any time without affecting the lawfulness of prior processing.
• No automated decisions. Request human review of significant decisions made solely by automated means.

To exercise any of these rights contact us at privacy@splatchat.com. We will respond within 30 days (or within the shorter period required by applicable law). We will not discriminate against you for exercising your privacy rights.

10.1 California residents (CCPA / CPRA)

If you are a California resident you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to know. Request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months.
• Right to delete. Request deletion of personal information we have collected from you (subject to certain exceptions).
• Right to correct. Request correction of inaccurate personal information we maintain about you.
• Right to opt out of sale or sharing. We do not sell or share personal information for cross-context behavioral advertising purposes. No opt-out is required, but you may contact us to confirm.
• Right to limit use of sensitive personal information. Photographs, biometric data, voice data, and precise geolocation are "sensitive personal information" under CPRA. You may request that we limit our use of this data to what is necessary to provide the Service.
• Right to non-discrimination. We will not deny you service, charge different prices, or provide different quality of service because you exercised any of your privacy rights.

You may designate an authorized agent to make requests on your behalf. We may require verification of your identity before responding.

10.2 European Economic Area, UK, and Switzerland (GDPR / UK GDPR)

If you are located in the EEA, UK, or Switzerland, our legal bases for processing your data are set out in Section 2 above. You have the right to lodge a complaint with your local supervisory data protection authority at any time.

We do not maintain an establishment in the EEA. Where required by Article 27 of the GDPR, we will appoint an EU representative and publish their contact details here. Until an EU representative is appointed, please direct all GDPR inquiries to privacy@splatchat.com.

10.3 Other U.S. state residents

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), and other states with comprehensive privacy laws have rights similar to those described above, including rights to access, correct, delete, and opt out of certain processing. Contact us at privacy@splatchat.com to exercise any of these rights.

11. International Data Transfers

Your information may be processed in countries other than your country of residence, including the United States, where data protection laws may differ. When we transfer personal data from the EEA, UK, or Switzerland to a country that has not been deemed adequate by the relevant authorities, we rely on approved transfer mechanisms such as Standard Contractual Clauses (SCCs) adopted by the European Commission, or the UK International Data Transfer Agreement (IDTA), to ensure an adequate level of protection. You may request a copy of the applicable transfer mechanism by contacting us at privacy@splatchat.com.

12. Children’s Privacy

The Service is not directed at children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided personal information, we will take prompt steps to delete it.

Users between 13 and 17 may only use the Service with the consent and active supervision of a parent or legal guardian. Parents and guardians who believe their minor child has provided personal information without consent should contact us at privacy@splatchat.com.

We take additional care when processing data relating to minors and will not use data from accounts we know belong to minors for advertising or marketing purposes.

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes we will notify you by posting the updated policy on this page, updating the effective date, and, where required or appropriate, notifying you by email or in-app notice with at least 30 days’ advance notice before changes take effect. For non-material changes the updated policy will be effective upon posting. Your continued use of the Service after changes take effect constitutes acceptance of the revised policy.

We encourage you to review this page periodically. You can always find the current version at splatchat.com/privacy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

For EEA/UK data protection requests you may also have the right to lodge a complaint directly with your local supervisory authority.