Privacy Policy

1. Information We Collect

1.1 Information You Provide to Us

• Account Information: Name, email address, phone number, company name, and password when you create an account.
• Payment Information: Billing details processed securely through Stripe (we do not store complete credit card numbers).
• Business Data: Information about your business operations, including customer contacts, conversation logs, calendar appointments, and CRM data.
• Integration Data: When you connect third-party services (e.g., Shopify, GoHighLevel, Facebook, Google Ads), we collect data necessary to provide our services.
• Communications: Messages, support tickets, and feedback you send to us.
• Voice Data: Audio recordings of voice calls made through our platform for transcription, analysis, and quality assurance purposes.

1.2 Information Collected Automatically

• Usage Data: Log data, IP addresses, browser type, device information, pages visited, and time spent on our platform.
• Tracking Pixel Data: When you install our tracking pixel on your website, we collect visitor behavior, UTM parameters, click IDs (fbclid, gclid), and conversion data.
• Cookies: We use cookies and similar technologies to track activity and enhance user experience.
• Analytics: We collect aggregated usage statistics to improve our services.

1.3 Information from Third Parties

• Data from integrated platforms (Shopify orders, GoHighLevel contacts, Meta lead forms, etc.)
• Advertising platform data for attribution and conversion tracking
• Publicly available business information

2. How We Use Your Information

We use the information we collect to:

• Provide Services: Operate our AI agents, process conversations, schedule appointments, track conversions, and deliver the core functionality of our platform.
• Process Payments: Bill your account and process transactions through Stripe.
• AI Processing: Use AI service providers to process text and voice data for automation purposes (we do not train our own models on your data).
• Analytics & Attribution: Track ad performance, attribute conversions, and provide insights into your marketing campaigns.
• Improve Our Platform: Analyze usage patterns to enhance features and user experience.
• Communications: Send service updates, billing notifications, and respond to support requests.
• Security: Detect fraud, prevent abuse, and protect the security of our platform.
• Legal Compliance: Comply with applicable laws and regulations.

3. How We Share Your Information

We share your information only in the following circumstances:

3.1 Service Providers

We work with trusted third-party service providers who help us operate our platform:

• Payment Processing: Stripe for payment processing
• Cloud Infrastructure: Amazon Web Services (AWS) and Google Cloud Platform for hosting and storage
• Database Services: PlanetScale (US-based) for data storage
• AI Services: Third-party AI providers for natural language processing and voice capabilities
• Analytics: Analytics platforms to understand platform usage
• Communication Services: Email and SMS providers for transactional messages

3.2 Business Integrations

When you connect third-party platforms (Shopify, Meta, Google Ads, etc.), we share data as necessary to provide the integration functionality you requested.

3.3 White Label Partners

If you access Cortana through a white-label partner, that partner is the data controller and is responsible for their own privacy practices. We process data on their behalf as a service provider.

3.4 Legal Requirements

We may disclose your information if required by law, court order, or government request, or to protect our rights, property, or safety.

3.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Maintain your login session and remember your preferences
• Analyze platform usage and performance
• Track conversions and attribute marketing campaigns
• Enable our tracking pixel functionality for your websites

Types of Cookies We Use:

• Essential Cookies: Required for platform functionality and security
• Analytics Cookies: Help us understand how users interact with our platform
• Tracking Cookies: Used for conversion tracking and attribution (for your tracking pixel installations)

You can control cookies through your browser settings, but disabling certain cookies may limit platform functionality.

5. Data Security

We implement industry-standard security measures to protect your information:

• Encryption in transit (HTTPS/TLS) and at rest
• Secure password hashing (bcrypt)
• Role-based access controls
• Regular security audits and monitoring
• Secure API authentication and authorization
• Database access restrictions and logging

However, no method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

6. Data Retention and Deletion

How Long We Keep Your Data:

• Active Accounts: We retain your data for as long as your account is active and you use our services.
• Deleted Accounts: When you delete your account, we automatically delete your data within 30 days.
• Voice Recordings: Call recordings are stored while your account is active. They are deleted when you delete your account or when you manually delete specific recordings through the platform.
• Backup Data: Deleted data may remain in encrypted backups for up to 90 days for disaster recovery purposes.
• Legal Requirements: We may retain certain data longer if required by law or to resolve disputes.

How to Delete Your Data:

1. Delete your account through the platform settings
2. Contact us at hello@usecortana.ai to request manual deletion
3. For voice recordings, you can delete them individually through the call logs interface

7. Your Privacy Rights

You have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Update or correct inaccurate information through your account settings
• Deletion: Request deletion of your account and personal data
• Portability: Receive your data in a structured, machine-readable format
• Opt-Out: Unsubscribe from marketing communications (service notifications will continue)
• Restriction: Request that we limit how we use your data
• Object: Object to processing of your data for certain purposes

To exercise these rights, contact us at hello@usecortana.ai. We will respond within 30 days.

8. Children's Privacy

Cortana is not intended for use by individuals under the age of 13 years old. We do not knowingly collect personal information from children under 13.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at hello@usecortana.ai, and we will delete that information from our systems.

9. International Data Transfers

Cortana is operated from the United States. If you are accessing our services from outside the U.S., please be aware that your information will be transferred to, stored, and processed in the United States.

Our primary infrastructure is hosted on U.S.-based servers (AWS/PlanetScale). We do not intentionally transfer data to servers outside the United States.

By using our services, you consent to the transfer of your information to the United States and processing in accordance with this Privacy Policy and U.S. law.

10. California Privacy Rights (CCPA)

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

• Right to Know: Request details about the personal information we collect, use, and disclose
• Right to Delete: Request deletion of your personal information (subject to legal exceptions)
• Right to Opt-Out: We do not sell personal information, so there is nothing to opt out of
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights

Categories of Information We Collect (CCPA):

• Identifiers (name, email, IP address)
• Commercial information (purchase history, billing)
• Internet activity (usage data, logs)
• Professional information (company name, business details)
• Audio/visual data (voice call recordings)

To exercise your CCPA rights, email hello@usecortana.ai with the subject line "CCPA Request."

11. GDPR Rights (European Users)

If you are located in the European Economic Area (EEA) or United Kingdom, you have rights under the General Data Protection Regulation (GDPR):

• Legal Basis for Processing: We process your data based on (a) contract performance, (b) legitimate business interests, or (c) your consent
• Data Controller: Visionary Creations Inc. is the data controller for your personal information
• Right to Withdraw Consent: You can withdraw consent at any time (where consent is the legal basis)
• Right to Lodge a Complaint: You can file a complaint with your local data protection authority
• Data Protection Officer: Contact hello@usecortana.ai for data protection inquiries

We comply with GDPR principles, including data minimization, purpose limitation, and security. However, please note that your data will be processed in the United States.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will:

• Update the "Last Updated" date at the top of this policy
• Notify you via email if you have an active account
• Post a notice on our platform

Your continued use of Cortana after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

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