Introduction This Privacy Policy describes how OCTO AI PTE. LTD. (“Linso,” “we,” or “us”) collects, uses, and handles your personal data (“Personal Data”), and what choices you have when you use our websites, applications, platforms, and services (collectively, the “Services”). By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree to the practices described here, please do not access or use the Services. Capitalized terms not defined herein have the meaning ascribed to them in our Terms of Service.

1. Information We Collect We collect different types of information for the purposes of providing and improving the Services, including Personal Data and Usage Data as set forth below. If you do not provide information when requested, you may be unable to use some or all of our Services if that information is necessary for us to provide the Services or we are legally required to collect it.

A. Personal Data While using our Services, we may ask you to provide certain personally identifiable information that can be used to contact or identify you (“Personal Data”), including without limitation:

• Email address

• First and last name

• Phone number

• Cookies (see “Cookies and Other Tracking Technologies”)

• Usage Data (as defined below)

• Any other Personal Data you voluntarily provide to Linso

B. Usage Data We may collect information related to your interaction with or usage of the Services, including without limitation: IP address, device type, browser type and version, pages of our Services that you visit, the time and date of your visit, time spent on those pages, device language, unique device identifiers, system logs, performance metrics, the application used for dictation/input, and other diagnostic data related to your interaction with the Services. When you access the Services with a mobile device, Usage Data may also include information such as device model, device unique ID, mobile IP address, mobile operating system, mobile browser type, and other diagnostic data.

C. Customer Content You Provide We process the content you provide to make the Services work (“Customer Content”), including audio inputs you submit (which may contain Personal Data you choose to include, e.g., if you speak your name) and contextual information you choose to make available. For example, if you enable Linso Flow’s optional Context Awareness feature, we may collect limited, relevant text from the active app window (such as text on the screen) solely to improve the accuracy of Outputs. This content is processed only to deliver the Services, and you can opt out in Settings where available. By default, Linso does not use Customer Content for model training; if this changes in the future, we will update this Privacy Policy and provide choices in the “Privacy Mode & Data Controls” section of this policy.

D. Third-Party Platforms When you connect to your account using a third-party account (a “Third-Party Account”), we may collect information from that Third-Party Account in accordance with your permissions (e.g., identifiers provided to us by that third party) to help you connect and use our Services. Connecting is optional, and you can revoke permission in the settings of the Third-Party Account.

E. Payment Information When you purchase any of our Paid Services, our third-party payment processors (e.g., Airwallex, Stripe) collect and process your payment-related information such as name, email, billing address, and card/bank details. Processing of such data is governed by the payment processors’ own privacy policies.

F. Other Information You Provide Directly You may choose to provide additional information while using the Services (for example, survey responses or product feedback).

3. How We Use Data Linso may use Personal Data and Usage Data for the following purposes:

• Service Operation: To provide, update, maintain, improve, monitor, and protect our Services.

• Communication: To provide customer and technical support, send service-related communications, and send updates about new features or product news.

• Digital Advertising: To display advertising for our own products and services on our websites or other sites (including via cookies or similar technologies).

• Administration: For transactional, billing, account management, tax, and administrative matters.

• Compliance: To comply with applicable laws and regulations or a court or other legal order.

• Risk Mitigation: To detect violations of our legal terms, enforce the terms that govern your use of the Services, or detect, prevent, and respond to potential fraud or misuse.

• Interaction Improvement: To develop and improve our marketing activities to better match your interests and preferences.

• Marketing: To contact you with marketing or promotional materials and other information that may be of interest to you. You may opt out by following the unsubscribe link or other mechanism provided.

• Other: For other lawful purposes with your consent.

Customer Content and model training: By default, Linso does not use Customer Content to train AI/ML models. If this changes, we will update this Privacy Policy and provide opt-in/out choices in the “Privacy Mode & Data Controls” section below or in Settings (as applicable).

Our legal bases for processing may include performance of a contract with you, our legitimate interests (unless your rights and freedoms override those interests), your consent, and compliance with legal obligations.

4. Cookies and Other Tracking Technologies We and third parties we work with use cookies and other tracking technologies on the Services to collect information about your usage of the Services and your device. You may manage or delete cookies through your browser or device settings; disabling some cookies may affect the availability of certain features.

5. Online Analytics and Tailored Advertising A. Analytics We may use third-party web analytics services on the Services (e.g., Google Analytics) to help us analyze how users use the Services, including by noting the third-party website from which you arrived. Such third parties may directly collect or receive information to evaluate your use of the Services. You may limit certain analytics uses by installing the Google Analytics Opt-Out Browser Add-on (subject to third-party availability and policies).

B. Tailored Advertising We advertise our own products and services and may use cookies or similar technologies to collect information about your use of our Services to optimize and serve our marketing content based on your interactions. We do not sell your data or use it to optimize ads for other companies. You may still receive our advertising content, which may not always be personalized. Please note we do not control third-party opt-out mechanisms and cannot guarantee their continued availability or effectiveness.

6. Retention of Data We retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We retain and use your Personal Data as needed to comply with legal obligations (for example, where we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our agreements and policies. Different categories of data may have different retention periods. We will delete or anonymize Personal Data when it is no longer needed or after the applicable retention periods expire. If we anonymize, aggregate, or de-identify Personal Data, we may use and disclose it for any business purpose. Usage Data related to performance and security may be retained longer (e.g., to enhance security or improve functionality).

7. Transfer of Data Your information, including Personal Data, may be transferred to and processed or stored on servers or systems located outside your jurisdiction (e.g., our cloud services or partners’ regions). Regardless of where processing occurs, we take reasonable and necessary steps to ensure your data is treated securely and in accordance with this Privacy Policy.

8. Sharing With Others We may disclose Personal Data in the following circumstances:

• Service Providers: With service providers working on our behalf (e.g., billing and payment processors, third-party LLM providers, analytics providers, cloud providers, communications providers). To provide certain features, we may share data with third-party LLMs (e.g., OpenAI, Anthropic) and do not allow those third parties to use your data to train their models.

• Customers: If your organization (e.g., your employer) provides you access to the Services, we may share certain information (e.g., account or device information) with that organization to satisfy contractual obligations and for the purposes described herein.

• Protection of Linso and Others: To protect the rights, property, or personal safety of Linso, its affiliates, its users, and the public. This includes exchanging information for fraud protection, spam/malware prevention, and similar purposes. We may also disclose Personal Data to comply with applicable laws and regulations, court orders, or legal processes, and to maintain and enforce our agreements and policies.

• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business, in reliance on our legitimate business interests.

• Affiliates: With our affiliates who use Personal Data as set out in this Privacy Policy.

• Advertising Partners: With advertising networks, exchanges, and social media platforms (e.g., to manage and serve our own ads), and we may disclose necessary information for this purpose.

• Others with Your Consent: With other third parties with your express consent.

9. How We Secure Your Information We implement technical, administrative, and physical safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We use industry-standard encryption (e.g., TLS) to protect your data, including your audio and transcripts, in transit and at rest. Only authorized personnel can access it, and we conduct regular security reviews. However, no method of transmission over the Internet or electronic storage is 100% secure; while we strive to protect your Personal Data, we cannot guarantee its absolute security.

10. Your Rights and Choices Subject to applicable law, you may have the right to access, update, correct, or delete your Personal Data; object to or restrict certain processing; request a copy of your Personal Data in a structured, commonly used, machine-readable format; and withdraw consent where processing is based on consent (without affecting processing based on consent before withdrawal). To protect your account, we may require identity verification before responding. If certain necessary data is missing, we may be unable to provide some features.

To exercise your rights or for privacy-related questions, contact us at [email protected].

11. Children’s Personal Data Our Services are not directed to children, and we do not knowingly collect Personal Data from children. If you are a parent or guardian and become aware that a child has provided us with Personal Data, please contact us at [email protected] and we will take appropriate action (e.g., deletion or other measures).

12. Service Providers We may engage third-party companies, vendors, personnel, and other service providers to facilitate our Services, provide Services on our behalf, analyze how our Services are used, and perform similar services (“Service Providers”). Service Providers may access your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose and only under our instructions.

13. Links to Third-Party Websites The Services may contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. Collection, use, and disclosure of your information by third parties are governed by those third parties’ privacy policies, not this Privacy Policy. We encourage you to review their privacy and security policies before providing information to them.

14. Changes to This Privacy Policy We may update this Privacy Policy from time to time. When we make changes, we will update the date at the top of the Privacy Policy and, where appropriate, notify you (e.g., via email or an in-Service notice) and may set a reasonable effective date. Modifications will not apply retroactively. We encourage you to review this Privacy Policy periodically to understand how we process your Personal Data.

15. Contact Us If you have any questions about this Privacy Policy, please contact us at [email protected].

16. Privacy Mode & Data Controls Privacy Mode

If you enable “Privacy Mode” in Settings → Data and Privacy, none of your Dictation Data (i.e., audio, transcripts, and your edits to transcripts) will be stored or used for model training by us or any third party (zero data retention). We may still collect non-content usage statistics such as the number of words you dictated to improve baseline service quality.

If you choose to disable “Privacy Mode,” we may use your Dictation Data for product quality evaluation and feature improvement, but we do not use it to train any AI/ML models. We never sell your data. Our business model is based on selling software, not your information. You own your data.

Transcription and Processing

To provide higher accuracy and low latency, dictation and transcription generally occur in the cloud. If we later provide local processing options, we will update this policy or product documentation and provide choices in Settings.

Other Notes

• App Context: To better format content (e.g., more formal tone in email, more casual tone in chat), we may use limited context such as the active app’s name. When relevant features are enabled, we may reference surrounding text in the input box to improve capitalization, punctuation, and editing (e.g., Command Mode).

• Personalization and Sync: Your personalization data (e.g., dictionary and custom prompts) may sync across desktop and mobile devices if you enable syncing. If Linso Notes or similar note features are provided, by default only notes are synced, not audio or dictation history.

• Context Awareness: If you enable “Context Awareness” in Settings → Data and Privacy, relevant text from the active app window may be used to improve transcription accuracy. You can turn this on or off at any time.

• Auto-add to Dictionary: If you enable “Auto-add to Dictionary” in Settings → Personalization, Linso monitors the text box where it pastes to detect edits you make to transcribed words. If you change a word’s spelling, it is automatically added to your dictionary. You can turn this off at any time.

Security

We use industry-standard encryption (e.g., TLS) to protect your data in transit and at rest. Only authorized personnel can access it, and we conduct regular security reviews to help keep your data safe.

Third-Party Model Providers

Linso may use a combination of open-source models (e.g., Llama 3.1) and proprietary LLM providers (e.g., OpenAI, Anthropic) to provide features. We have agreements with third-party generative AI providers to ensure they do not store or use your data for model training. If Privacy Mode is enabled, we require zero data retention; even if Privacy Mode is disabled, we do not allow any third party to use your data for model training.