Updated on Apr 21, 2026

Welcome to Comulytic! We are deeply committed to protecting your personal information and value the trust you place in our services.

This Privacy Policy (the “Policy”) describes the categories of personal information we collect, how we use it, how and when it may be shared, and how we store and protect it (collectively, “process”), as well as the rights and choices you have with respect to your data when you interact with our services provided by Rymind Inc. (“Rymind,” “we,” “us,” or “our”) (collectively, the “Services”), including when you:

• Download and use our mobile applications (the “App”);
• Visit and use our websites (the “Website”) that link to this Policy;
• Use, control, and administer devices (the “Devices”) paired to your account;
• Engage with us in other related ways, including any marketing, customer support communications or online events.

For the purposes of the General Data Protection Regulation (GDPR), we act as a “Data Controller”. For the purposes of applicable U.S. state privacy laws (such as the CCPA), we act as a “Business” and/or “Data Controller”, as defined in applicable jurisdictions.

By accessing or using our Website, App, and Services, you acknowledge that you have read and understood this Policy. If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

A. What Information Do We Collect?

When you register for an account to access our Services, we require specific personal information to establish your account. Additionally, as you utilize certain functions on our Website or App—such as making purchases, linking a device, or using optional features—you may provide additional information, including voice-related data. If you reach out to us for support or inquiries, we collect the necessary information to provide assistance and resolve your concerns.

B. How Do We Use Your Information?

Your personal information is used to operate, improve, and secure our Services while providing you with a tailored experience, including our features related to account administration, e-commerce, device management, among others. We also process your information to respond to support requests, ensure the safety and integrity of our Services, refine and enhance our offerings, and handle any reports of unlawful content in accordance with applicable laws.

C. How Is Your Information Stored and Protected?

We store your personal information on servers located in the United States and take reasonable steps to ensure it is only retained for as long as necessary to achieve the purposes described in this Policy. To protect your information, we employ suitable technical and organizational safeguards.

D. How Is Your Information Shared and Transferred Internationally?

Your personal information may be shared with our affiliated companies and third-party partners—including those providing IT, business support, and customer service—to help us deliver our Services. In certain situations, such as legal proceedings, regulatory inquiries, audits, mergers, acquisitions, asset transfers, or other business changes, we may be required to disclose your information. Given the global nature of our operations, your information may be accessed or transferred to countries outside your own. When cross-border data transfers occur, we implement appropriate measures to ensure your data remains protected.

E. What Are Your Rights Regarding Your Personal Information?

Depending on your location, you may be entitled to various rights concerning your personal information. These may include the right to access or request a copy of your data (data portability), correct or delete your information, revoke consent where relevant, restrict or object to processing, and submit a complaint to the appropriate data protection authority if you believe your rights have been violated.

F. Contact Information

If you have any questions, comments, or concerns regarding this Policy or our privacy practices, wish to exercise your rights, or need to contact our Data Protection Officer, please refer to the contact information provided.

1. What Information Do We Collect?

1.1 Sources of Personal Information

We obtain personal information from the following categories of sources:

• Directly from you: We collect information that you provide to us directly when you interact with our Services (e.g., registering an account and contacting our customer support team).
• Automatically from your device and usage of our Services (e.g., via cookies and device logs).
• From Third Parties: We may receive data from third parties (e.g., payment service providers).
• Publicly Available Sources: We may collect data from publicly accessible sources, such as open government databases or public internet data.

1.2 Personal Information We Collect

When you browse our Website or use our App, we gather and utilize your personal information solely for the purposes outlined in this Policy. Personal information means any data about an individual, or any detail that could directly or indirectly identify a person. Depending on your interaction with us, we collect the following categories:

• Contract Management Information: Records of the Policy version you have acknowledged, your choices to accept or reject specific services or functionalities, the versions of service agreements you have agreed to or declined, along with the corresponding dates and times.
• Account Information: Information used to create, access, and manage your account, such as your email address, encrypted password, profile image, chosen nickname, country or region selected at registration, email verification code, unique account identifier, and information relating to your chosen sign-in method or linked third-party login account (such as Google or Apple), where applicable.
• Onboarding and Preference Information: Information you choose to provide during onboarding or while using the Services, such as your industry and other preferences or use-case information, which may be used to tailor recommendations, personalize your experience, and improve the relevance of the Services.
• Age Verification Information: We may request that you provide your age or other information to verify your eligibility for certain Services that is available for users with age restrictions. For users without full legal capacity, we may request a written consent of legal guardian.
• Order and Shipping Information: Details on your orders, including total and completed orders, payment amounts, dates of first and latest orders, order notes, and billing information (including first and last name, full name, company name, address, city, state code, postal code, state name, country code, country name, email, and phone number), as well as shipping addresses. For payment transactions, we use third-party payment processors and/or app store operators, as applicable. We do not directly collect or store full payment card information or bank account information, but may receive limited transaction-related information in connection with your orders and subscriptions.
• Service Usage Information: Data such as IP address and activity logs generated while you interact with our Services (for example, clicks, search queries, access times, browsing records, and purchase activity).
• Review and Feedback Information: Information related to your product reviews (including your name, email, review title and content, uploaded photos, ratings history, and records of likes or dislikes), and any details you submit when using feedback features within the Services.
• Security & Analytics Information: We collect device and log data (such as MAC address and IP address) to detect fraud and improve services. Cookies are used for site functionality, security, and performance optimization.
• Customer Service Information: Data required to verify your identity (such as email and order number), logs of communications (including recorded calls), contact details (name, phone number, and address information needed for after-sales services), and other information necessary to address your inquiries.
• Transcripts and Generated Content Information: Information generated, extracted, organized, or otherwise processed through your use of the Services, such as transcripts, summaries, insights, structured notes, speaker labels, tags, and other content or output you provide, import, create, or generate through the Services.
• Voice-Related Data: digital recordings of voices or audio segments collected or processed through the Services, including but not limited to My Voice Setup, Contact Voice Tagging. Voice-Related Data may also include incidental background audio captured during your use of the Services.

Generally, providing your personal information is voluntary. However, specific data is required to enter into a contract with us or to comply with legal obligations (e.g., for tax or fraud prevention purposes), including the following categories:

• Contract Management Information, Account Information and Age Verification Information: Without collecting or using such information, you will be unable to register or access the Services.
• Order and Shipping Information: Without collecting or using such information, we cannot fulfill your purchase in accordance with your request.
• Security & Analytics Information: Without collecting or using such information, we cannot maintain a safe and stable service environment for you.

1.3 Cookies and Similar Technologies

When you access our Services, we may automatically collect personal information and other information from your devices using technologies such as cookies. Cookies are small text files sent by a website to your computer or other internet-connected device that help uniquely identify your browser or store specific information or preferences. For full details, please refer to our Cookie Policy.

1.4 Contacts Function and Third-Party Personal Information

For information regarding the Contacts function and the processing of third-party personal information, including your obligations and responsibilities, please refer to Section 6(d) of our Terms of Use.

1.5 Voice-Related Data

When you use voice-based features, you represent that you have obtained any necessary consent from yourself and any individuals whose voices may be recorded or processed. You acknowledge and agree that audio data captured may be processed to support speaker recognition, speaker labeling, and related functionality within the App, solely for the purposes described in this Privacy Policy. We rely on this consent and are not responsible for obtaining consent on your behalf. Voice recordings are only processed as needed to provide the requested features.

1.6 Children and Minors

Our Services are not directed to minors. If you do not meet the applicable minimum age or legal age requirements in your jurisdiction, please do not use the Services unless your parent or legal guardian has provided any consent or authorization required by applicable law. If we learn that we have collected personal information from a minor in violation of applicable law, we will take appropriate steps to delete or otherwise handle such information in accordance with applicable law. If you are a parent or guardian and believe that a minor has provided personal information to us without the required authorization, please contact us using the contact details provided in this Policy.

2. How Do We Use Your Information?

Subject to applicable laws, we process personal information for the purposes set out below, each relying on the relevant legal basis:

• Contract Management: We use contract management information to keep records of your acceptance or rejection of agreements, including contract and privacy notice versions, associated timestamps, and related decisions. This processing is necessary to perform our contract with you and for compliance with a legal obligation.
• Account Management: We process Account Information to facilitate activities such as creating, deleting, signing into, and updating your account. This processing is necessary to perform our contract with you and for compliance with a legal obligation.
• Transcription, Analysis, and Generated Content Features: We process relevant personal information to provide the features you request through the Services, including AI-powered or automated transcription, summarization, information extraction, structuring, speaker labeling, tagging, and related features. Where required by applicable law, we will do so based on your informed consent, and such processing will be limited to the purposes described in this Policy and the features you choose to use. We may also engage service providers to support these features, as further described in this Policy. This processing is necessary to perform our contract with you and, where required by applicable law, based on your consent.
• Personalization and Communications: We may use your activity and preferences to recommend Services, features, content, and offers that may interest you and personalize your experience. With your consent, we may also send you marketing communications about platform updates, promotions, or partner offers. You can unsubscribe according to the instructions provided in the email.
• Security and Service Stability: Information such as your region, network operator, device model, operating system, app version, access source, access dates, browsing history, time spent, and interactive events is processed to identify suspicious activities, ensure the reliability and security of our Services, and support ongoing improvements. This is based on our legitimate interests in protecting, maintaining, and improving our Services, provided these do not override your rights or freedoms.
• Customer Service and Support: When you reach out through our online support channels or hotlines, we process certain Account Information and Customer Service Information, as well as any other details you provide, to manage troubleshooting, address complaints, and deliver general support. This processing is necessary to perform our contract with you.
• Investigations: We may use certain Account Information to fulfill our legal obligations or to pursue our legitimate interest in detecting and preventing fraud, provided your rights and freedoms are not adversely affected.
• Illegal Content Reporting: If you report unlawful content via our Services, we may collect and retain your name, email address, and any other details necessary to investigate and address the report, as required by law.
• Voice-Related Data: When you use voice-based features, we collect and process voice-related data solely to provide the requested features, including speaker recognition, speaker labeling, My Voice Setup, and Contact Voice Tagging. This data is processed only for requested features and is not used for advertising, profiling, or AI training. We do not sell or share voice-related data with data brokers or unrelated third parties. We will only process the information on the basis of your consent and/or as necessary to enter into and perform our contract with you, as applicable.

3. How Is Your Information Stored and Protected?

Your personal information is processed on servers located in the United States. The retention period for each category of personal information is limited to the time reasonably necessary to fulfill the purposes set out in this Policy and proportionate to those purposes, or for the period required to comply with legal requirements (e.g., tax, audit, or statutory obligations). Where it is not possible to define a fixed retention period, we will determine the retention duration based on documented criteria, such as the nature and sensitivity of the data, legal/audit requirements, and legitimate interests. Once the personal information is no longer needed for these purposes, we will take technical and organizational measures to delete, de-identify, aggregate, or anonymize the data, in accordance with applicable legal requirements.

To help safeguard your personal information from accidental or unlawful destruction, loss, modification, unauthorized disclosure, access, or other forms of improper handling, we have adopted suitable technical and organizational security measures in accordance with the law. You are responsible for keeping your account details confidential, including choosing a secure password and not sharing it with others. If you suspect that your account or personal information has been compromised—such as your password being disclosed without authorization—please contact us immediately using the contact information provided in this Policy.

Voice-related data is stored separately from other account information and encrypted both during network transmission and at rest. This data is retained only as long as necessary to provide the relevant features or as required by applicable law. When you delete your account or manually delete your voice-related data, all such recordings and associated text records will be promptly removed, generally within 7 days, unless a longer retention period is required to fulfill the processing purpose or comply with applicable laws.

Please note that the internet is an open network and transmitting information online is not entirely secure. Although we take reasonable steps to protect your personal information, we cannot guarantee the security of data sent to us over the internet. Any such transmission is at your own risk, and you are responsible for ensuring that any personal information you send is done so securely.

4. How Is Your Information Shared and Transferred Internationally?

4.1 Disclosure of Information

We may engage third-party service providers—including those offering IT solutions (such as cloud services), business operations support, payment processing, and customer service—to process your personal information on our behalf. Where we engage service providers to process personal information on our behalf, we require them to protect such information through appropriate confidentiality, security, and data-use restrictions, in accordance with applicable contractual and legal requirements. Additionally, we may share personal information with our affiliates for legitimate business reasons and to support the operation of the App.

Your personal information may also be disclosed under the following circumstances:

• Legal and Regulatory Compliance: To fulfill obligations under applicable laws, respond to legal proceedings, or comply with requests from regulatory authorities.
• Professional Advisors: To external auditors, legal counsel, or other professional consultants when their expertise is required.
• Business Transactions: We may disclose or transfer your personal information to relevant third parties and their advisors as reasonably necessary in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or transfer of all or part of our business or Services. If such transaction is completed, we will ensure that the relevant successor or receiving entity is bound by privacy commitments that are at least as protective as those described in this Privacy Policy.
• For Affiliates and Subsidiaries: We may disclose your personal information among our affiliates and subsidiaries, for purposes consistent with this Privacy Policy.

Whenever we transfer or disclose your personal information, we do so in line with all applicable legal obligations and implement safeguards to ensure your information is adequately protected, providing a level of security equivalent to what is required in your jurisdiction.

4.2 Cross-Border Transfer of Information

Your personal information may be processed outside of your home country because of our servers located in the United States. For instance, users residing in Europe or Canada may have their personal information stored in the United States. Given the global nature of our operations, your personal information may also be accessed by our affiliates or shared with third-party customer support partners and SDK providers, in line with the purposes described in this Policy. Please note that the United States is not currently subject to a general Adequacy Decision by the European Commission or the UK Government (except for organizations certified under the Data Privacy Framework, where applicable), meaning it may not offer the same level of data protection as your home country.

If we transfer personal information internationally and such transfers are subject to legal requirements, we will put in place appropriate safeguards to ensure your information remains protected. These measures may include, where appropriate, relying on adequacy decisions that recognize the destination country as providing sufficient protection, using the European Commission’s Standard Contractual Clauses (SCCs) and the UK International Data Transfer Agreement (IDTA) for transfers between our affiliates and relevant third parties (where applicable), implementing supplementary technical and organizational measures where necessary, or adopting any other lawful mechanism that allows the cross-border movement of personal information.

For users residing in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have the right to obtain a copy of these safeguards by contacting us using the details provided in the "Contact Information" section.

4.3 Aggregated Data

We may aggregate, anonymize, and/or de-identify information collected from or about you so that such information can no longer be used to identify you individually. Once information has been aggregated or de-identified, it is no longer considered personal information under applicable laws. We may use this aggregated or de-identified data for a variety of legally permissible purposes, including conducting research and analysis on customer demographics, interests, usage patterns, and behaviors in order to improve our services and inform business decisions. We may also share or disclose such aggregated or de-identified information with our affiliates, agents, business partners, research institutions, or other third parties for similar purposes, provided that such information does not identify any individual.

5. What Are Your Rights Regarding Your Personal Information?

5.1 Your Rights and Choices

Subject to applicable law, you may have the following rights and choices regarding your personal information:

• Right of Access: You may ask us to confirm whether we are processing your personal information, provide you with details about such processing, and, subject to applicable laws, give you a copy of your personal information. You can access your personal information associated with your account directly through the Services. For any additional requests to access your personal information, please contact us.
• Right to Rectification: You have the right to ask us to correct any inaccurate or incomplete personal information that we hold about you. You may update certain personal information linked to your account directly. For other correction requests concerning your personal information, please contact us.
• Right to Data Portability: You can request a copy of your personal information that you have provided to us, in a structured, commonly used, and machine-readable format, and, where applicable, request that we transfer it to another data controller.
• Right to Erasure: You may ask us to delete the personal information that we hold about you. You can request the removal of all personal information related to your App account by deleting your account. Upon your request, your personal information will be deleted or irreversibly anonymized, and we will take reasonable steps to inform our service providers to do the same, subject to applicable laws. You may also request the deletion of certain personal information by contacting us. If we are unable to fulfill your request (e.g., due to legal obligations), we will inform you of the specific reasons.
• Right to Withdraw Consent: If our processing of your personal information relies on your consent, you can withdraw your consent at any time by contacting us. You may withdraw consent by contacting us or updating your preference settings. Note that this will not affect the lawfulness of processing based on consent before its withdrawal, nor will it affect processing based on lawful grounds other than consent.
• Right to Object to Processing: Where permitted by law, you may object to our processing of your personal information in certain circumstances. For direct marketing, this is an absolute right; we will immediately cease processing upon your request without requiring justification. For processing based on legitimate interests, you may object on grounds relating to your particular situation; in such cases, we will cease processing unless we demonstrate compelling legitimate grounds overriding your rights or for the establishment, exercise, or defense of legal claims.
• Right to Restrict Processing: You may request that we limit the processing of your personal information in the following situations: (a) If processing is unlawful and you prefer restriction instead of deletion; (b) If you need us to retain your personal information for legal claims, even if we would otherwise delete it; (c) If you have disputed the accuracy of your personal information and verification is pending; (d) If you have objected to processing and a determination of overriding legitimate grounds is pending.

5.2 Other Rights

Depending on your location, you may have additional rights under local laws. For example, you may have the right to file a complaint with a relevant data protection authority if you believe we have violated data protection laws.

5.3 Exercising Your Rights

To exercise any of your rights, ask questions, or submit a complaint regarding our processing of your personal information, please use the contact information provided in this Policy. When submitting a request, please clearly state the scope and legal basis for your request and provide enough information for us to verify your identity. We may request additional details to confirm your identity before responding to your request. We will address your request or complaint within the timeframes required by applicable data protection laws.

5.4 Additional Disclosures for Users in the EEA, United Kingdom, and Switzerland

If you are located in the EEA, the United Kingdom, or Switzerland, the following additional disclosures apply to our processing of your personal information, to the extent required by applicable law. Your personal information may be transferred to and processed in countries outside your country of residence, including the United States. Where required by applicable law, we implement appropriate safeguards for such transfers. You may request additional information about, and where applicable a copy of, the relevant safeguards by contacting us as described in the “Contact Information” section.

If you are located in the EEA, the United Kingdom, or Switzerland, the legal bases for our processing of your personal information and the rights available to you are described in Sections 2 and 5 of this Policy, as applicable. You may also lodge a complaint with a competent supervisory authority in your jurisdiction, including, where applicable, the supervisory authority in the EEA member state of your habitual residence, the UK Information Commissioner’s Office, or the Swiss Federal Data Protection and Information Commissioner.

6. Notice to California Residents

This section applies solely to California residents and supplements our main Privacy Policy. It describes your rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) and explains how we handle your personal information.

(a) Collection and Use of Personal information. Within the past twelve (12) months, we have gathered personal information from and about you as detailed in Section 1 of this Policy.

(b) Collection and Use of Sensitive Personal Information. Certain categories of personal information are considered "Sensitive Personal Information." We collect the following categories of Sensitive Personal Information for the purposes described as detailed in Section 2 of this Policy:

• Account Log-In Credentials.

(c) Disclosure of Personal information. Within the past twelve (12) months, we have shared personal information with third parties for business-related purposes. Specifically:

• We have disclosed all categories of personal information listed in Section 1 of this Policy—except for certain operational data that remains cached only on the user’s device—to cloud storage service providers and our affiliated companies.
• Information that is automatically collected or generated in connection with the use of our hotline services, such as communication records, your name, phone number, email address, and any other data you choose to provide to facilitate your request, has been shared with customer support service providers.
• Audio files may be processed by AI capability service providers that we engage with to support specific features through our Services.
• Customer service-related information, as described in Section 1, has been shared with online customer service SDK providers to support your interactions with our support channels.

(d) Your CCPA Rights. If you are a California resident, you may have the right to exercise the following:

• Right to Know – You may request details about the categories of personal information collected, the sources from which personal information is obtained, the business purposes for collecting, sharing, or selling personal information, and the third parties with whom we share personal information.
• Right to Access – You may request a copy of the specific personal information we hold about you.
• Right to Deletion – You may request the deletion of your personal information, subject to certain exceptions (such as fulfilling benefits, preventing fraud, or complying with legal obligations).
• Right to Correction – You may request the correction of inaccurate personal information.
• Right to Nondiscrimination – You are entitled to exercise these rights without being subject to any form of penalty or discrimination.
• Limiting the Use of Sensitive Personal Information – You have the right to ask us to restrict how we use and disclose your sensitive personal information, except where certain exceptions under applicable law apply. If you wish to make this type of request, please contact us using the information provided in this Policy. We do not “sell” or “share” sensitive personal information, as these terms are defined by the CPRA.
• Right to Opt-Out of Sale or Sharing – You may opt out of the sale or sharing of your personal information (for example, disclosure of personal information to a third party for cross-context behavioral advertising). Under the definitions of “sell” and “share” in the CPRA, we do not, and have not in the past twelve (12) months, sold or shared your personal information as those terms are defined by law.

(e) How to Submit California Consumer Rights Requests. You may exercise your California consumer rights by contacting us using the information provided in this Policy. Before we process your request, we will verify your identity, which may involve requesting additional personal information or asking you to log in to your account, where applicable. There may be instances where we are unable to fulfill or may limit your request, such as when we cannot confirm your identity, cannot locate your information, or are otherwise permitted by law to do so.

(f) Appeal. If your request is denied, you may appeal our decision by contacting us using the contact information provided in this Policy. If you are a California resident and your appeal is unsuccessful, you may file a complaint with the California Attorney General by following the instructions provided at: https://oag.ca.gov/contact/consumer-complaint-against-business-or-company.

(g) California’s “Shine the Light” Law. In accordance with California Civil Code Section 1798.83 (the “Shine the Light” law), California residents who have an established business relationship with us can request information about our sharing of personal information with third parties for their own direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

7. Contact Information

If you have any concerns regarding potential security vulnerabilities, our privacy practices, or your data protection rights, or if you wish to contact our Data Protection Officer, you may do so using the contact details provided below:

Rymind Inc., with its mailing address located at 8 The Green, STE A #18650, Dover, Kent County, Delaware 19901, and email address at dpo@comulytic.ai.

We have appointed the following EU representative to act on our behalf:

• Name: eVatmaster Consulting GmbH
• Address: Raiffeisen Street 2B11, 63110 Rodgau, Hessen, Germany
• Email: contact@evatmaster.com

We have appointed the following UK representative to act on our behalf:

• Name: EVATOST Consulting LTD
• Address: Office 101 32 Threadneedle Street, London, United Kingdom, EC2R 8AY
• Email: contact@evatost.com

8. Miscellaneous

(a) Policy Update. We may update this Policy when necessary. We encourage you to review the latest version by clicking the Privacy Policy link in the footer of our website. If we make any significant changes to this Policy, we will notify you and obtain your consent in advance—depending on the nature of the update and applicable laws of your jurisdiction—through methods such as pop-up notifications, push messages, emails, or other suitable channels.

(b) Applicability of Terms of Use. The Terms of Use continue to govern all legal relationships arising from your use of our Services. In particular, the foregoing provisions relating to indemnification and limitation of liability shall apply to any claims or disputes arising in connection with this Privacy Policy.