Effective Date: 14th Februrary 2025

At VoxApp Ltd (“we,” “us,” or “our”), we are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your Personal Information in compliance with the New Zealand Privacy Act 2020 (the “Privacy Act”) and other applicable laws. It applies to information collected when you interact with us, use our services, or visit our website.

1. Definitions

• “Personal Information”: Any information about an identifiable individual, as defined under the Privacy Act.
• “Service”: The products, services, and platforms provided by VoxApp Ltd.
• “Website”: www.voxapp.com
• “AI Assistant / AI-based Call Analysis”: A feature that enables call recording, transcription, and automated processing (e.g., to provide call summaries, insights, or other functionalities).
• “Call Data”: Any metadata, recordings, or transcriptions generated through calls facilitated by our Service.
• “Cookies”: Text files placed on your device to collect standard internet log information and visitor behavior information.

2. Not for Use by Minors

Our Service is not intended for individuals under the age of 16 (or any other age threshold applicable in your jurisdiction). We do not knowingly collect or process Personal Information from minors. If you believe a minor has provided us with Personal Information, please contact us immediately at privacy@voxapp.com, and we will take steps to delete such data.

3. Information We Collect

We may collect the following types of Personal Information:

1. Identity Data: Name, username, job title.
2. Contact Data: Email address, phone number, business address.
3. Financial Data: Payment details (processed securely by third-party payment processors).
4. Technical Data: IP address, browser type, device information, and usage data when you access our Website or Service.
5. Interaction Data: Information you provide when you contact us, participate in surveys, or engage with our support team.
6. Marketing Data: Your preferences for receiving marketing communications from us.
7. Call Data: Metadata (e.g., timestamps, duration, dialed numbers) and, if enabled or required by the customer, recordings or transcriptions of calls.

Note: If you choose not to provide certain required Personal Information, we may be unable to provide some or all of our Services.

4. How We Collect Information

We collect Personal Information through:

1. Direct Interactions: When you sign up, contact us, or otherwise provide information directly to us.
2. Automated Technologies: Cookies, server logs, and analytics tools that track usage of our Website or Service.
3. Third Parties: Referrals, business partners, publicly available sources, or integrated services.

5. How We Use Your Information

We use your Personal Information for the following purposes, in line with our legal bases for processing (which may include consent, contract performance, legal obligations, and/or legitimate interests):

1. Service Delivery:
   • To provide, maintain, and improve our Service.
   • To enable features such as AI-based call recording, transcription, and analysis, where configured by the customer.
2. Communication:
   • To respond to your inquiries, provide support, and send administrative or account-related information.
3. Billing and Administration:
   • For billing, payment processing, and internal record-keeping.
4. Marketing:
   • To send you promotional messages, newsletters, and other marketing materials (you can opt out at any time).
5. Legal Compliance and Protection:
   • To comply with legal obligations, respond to legal process, or protect our rights, privacy, safety, or property (and that of our users).

Use of Google Workspace APIs

We do not use Google Workspace APIs to develop, improve, or train generalized AI or machine learning models. Any integrations with Google Workspace (e.g., Gmail, Calendar) are solely for the purpose of delivering or enhancing your direct user experience in accordance with this Privacy Policy.

Customer Responsibilities for Call Recording

If you (as a customer) enable or use the AI-based call recording and transcription feature, you are responsible for informing all call participants that calls may be recorded or transcribed and for obtaining any necessary consents under applicable laws.

6. Sharing Your Information

We may share your Personal Information with:

1. Employees, Contractors, and Service Providers:
   • Who assist us in operating our business (e.g., cloud hosting, payment processors, customer support software).
2. Third-Party Partners:
   • For analytics (e.g., Google Analytics) or other legitimate business purposes, under strict obligations to process data only on our behalf and in compliance with the Privacy Act.
3. Legal or Regulatory Authorities:
   • If required by law, or to protect our legal rights.
4. Business Transfers:
   • In connection with a sale, merger, or acquisition. Any new entity must honor the commitments of this Privacy Policy.

We require all third parties to handle your information in compliance with the Privacy Act and other applicable laws. They are only permitted to process your Personal Information for the specific purposes we specify.

7. International Data Transfers

Your data may be transferred and stored outside New Zealand, including in AWS data centers located in Australia, the United States, and the European Union, depending on your location or the needs of our Service. In these cases, we implement appropriate safeguards in accordance with the Privacy Act (e.g., contractual clauses or equivalent protections) to ensure the security and confidentiality of your Personal Information.

8. Security of Your Information

We use industry-standard measures to protect your Personal Information from unauthorized access, loss, alteration, or misuse. While we strive to safeguard your data, please note that no method of transmission over the internet is entirely secure.

Data Breach Notification: If a privacy breach occurs that poses a risk of serious harm, we will notify you and the New Zealand Office of the Privacy Commissioner, as required by law.

9. Your Rights

Under the Privacy Act, you have the right to:

1. Access: Request access to Personal Information we hold about you.
2. Correction: Request correction of inaccurate or incomplete Personal Information.
3. Withdraw Consent: In situations where we rely on your consent to process certain Personal Information (e.g., marketing communications), you can withdraw this consent at any time.
4. Complain: Lodge a complaint with the New Zealand Privacy Commissioner if you believe your privacy rights have been infringed.

To exercise these rights, please contact us at privacy@voxapp.com. We may need to verify your identity before fulfilling your request.

10. Data Retention

We retain your Personal Information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Generally, we delete or anonymize data within 30 days following closure of your account.

• Call Data: Where AI-based call recording and transcription features are enabled, the retention period is determined by the customer’s configuration or instructions, but will not exceed 30 days post account closure unless otherwise required by law.

11. Cookies and Tracking

We use Cookies to improve your experience on our Website and to gather analytics about overall usage.

• Essential Cookies: Necessary for the Website to function and cannot be switched off.
• Analytics Cookies: Help us understand how users interact with the Website or Service (e.g., Google Analytics).
• Functional Cookies: Remember user preferences and improve functionality.

Managing Cookies

You can manage or disable Cookies through your browser settings. Disabling certain Cookies may affect the functionality of our Website or Service. If you are located in a jurisdiction with specific cookie consent requirements, you may see a cookie banner or pop-up to manage preferences.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on our Website, and the Effective Date at the top will be updated accordingly. Your continued use of our Service after any changes take effect constitutes your acceptance of the revised Privacy Policy.

13. Contact Us & Data Protection Officer

If you have questions, concerns, or complaints about this Privacy Policy or our handling of your Personal Information, please contact our Data Protection Officer at:

• Email: privacy@voxapp.com

We will respond to your inquiry promptly and work to address any concerns you may have.

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