Effective as of 01/04/2026
This Privacy Policy describes how Skywalk, Inc. d/b/a Subtle Computing (“Subtle,” “we,” “us,” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website located at https://www.subtle.co/, our hardware devices, companion mobile applications, and social media pages) as well as our marketing activities, and other activities described in this Privacy Policy (collectively, the "Services").
This Privacy Policy does not apply to information that we process on behalf of our business customers (such as businesses and other organizations) while providing the Subtle platform/services to them. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers, and your agreement with them. If you have questions regarding your personal information that we process on behalf of another business that you have a relationship with, please direct your questions to that business.
We do not sell your personal information.
“Dictation Data” means (i) audio recordings, (ii) text transcriptions, and (iii) edits/corrections or commands associated with your voice interactions.
“Privacy Mode” is an optional setting that limits how Subtle stores and uses Dictation Data, as described below.
“Context Awareness” (if enabled) means Subtle may process limited, relevant content from the active app (e.g., surrounding text in the current text field, app name) to improve transcription accuracy and formatting.
Depending upon the context in which you interact with us, personal information you may provide to us through the Services includes:
Account Information: Name, email address, password, phone number, and other registration details when you create an account.
Communication Information: Information you provide when you contact us, participate in surveys, or engage with our support team.
Payment Information: Billing address, payment card details, and transaction information when you make purchases.
Profile Information: Preferences, interests, and other information you add to your account profile.
When you use our hardware device and companion applications, we process Dictation Data to provide the Services (e.g., transcription and command execution).
Voice Interactions: Voice recordings that are transcribed into text or passed to a conversational AI model.
Transcription Data: Text transcriptions from all voice interactions with our device, including:
Context Awareness (Optional): If enabled, we may process limited relevant text from the active app (e.g., surrounding text in the current field, app name) to improve formatting and transcription accuracy.
Interaction Metadata: Information about your voice interactions including timestamps, device identifiers, session duration, language preferences, and interaction patterns.
Content of Communications: The substance of what you or others say near the device while activated, which may include names, addresses, health information, financial data, or other sensitive information.
If you enable Privacy Mode (Settings → Data and Privacy), we do not store Dictation Data (audio, transcripts, edits) and do not use it for model training.
If you choose to disable Privacy Mode, your Dictation Data may be used to evaluate, train, and improve Subtle’s AI models and features.
Important Notice: Our device may capture conversations of individuals other than you. You are responsible for informing others in your vicinity that the device may be recording and obtaining any necessary consent. You represent and warrant that you have obtained all necessary consents from third parties whose voices may be captured.
We never sell your data. Our revenue comes from selling products and services, not your information. Any stored Dictation Data is encrypted in transit and at rest in our servers.
We may combine personal information we receive from you with personal information that we obtain from other sources, such as:
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, such as:
Device Information: Hardware model, operating system version, unique device identifiers, network information, IP address, and device settings.
Usage Information: Pages or screens viewed, time spent on pages, navigation paths, click data, and other usage statistics.
Location Information: General location derived from IP address and, with your permission, precise geolocation data.
Voice-Activated Collection: Our hardware device continuously monitors for activation commands when powered on. Upon detecting an activation phrase:
We use cookies, pixel tags, local storage, and similar technologies to automatically collect information about your activities over time across the Services, including:
We use your personal information to:
If Privacy Mode is ON, we do not store Dictation Data and do not use it for model training.
We analyze usage of our Services to:
With your consent where required, we may use your information to:
We may use your personal information to:
We may create aggregated, de-identified, or anonymized data from your personal information. We may use and share this data for any lawful business purpose, including analytics, research, and marketing. This data cannot reasonably be used to identify you.
We share Dictation Data with third-party artificial intelligence and large language model providers (such as OpenAI, Anthropic, or similar services) to:
We use enterprise API services from our AI providers that are contractually prohibited from training on your data. Per our agreements, these providers:
While we have contractual protections and monitor for compliance, we cannot provide absolute guarantees about third-party operations.
We share personal information with vendors and service providers that perform services on our behalf, including:
We may disclose personal information:
We may transfer personal information in connection with:
We do not sell personal information.
Privacy Mode ON (no storage, no training). If you enable Privacy Mode, we process your Dictation Data only to provide real-time transcription and command execution, and we do not store your Dictation Data and do not use it for model training. We may still collect limited usage statistics that do not include Dictation Data content (e.g., feature usage counts, performance metrics, and crash logs).
Privacy Mode OFF (storage + improvements, including training). If you disable Privacy Mode, we may store and use your Dictation Data to provide, maintain, protect, troubleshoot, and improve the Services, including evaluating, training, and improving our AI models and features.You can change this setting at any time in Settings. Changes apply going forward
When Privacy Mode is OFF, we retain Dictation Data for as long as needed to provide and improve the Services, unless you delete it earlier. We may retain certain data longer for security, legal compliance, and dispute resolution.
When Privacy Mode is ON, we do not store Dictation Data.
You have the right to request deletion of your personal information, including transcription data, at any time by:
Upon receiving a verified deletion request, we will:
Important Limitations: We cannot delete:
Privacy Mode Control (Training + Storage): Privacy Mode controls whether we store and use Dictation Data for improvements, including model training. When Privacy Mode is ON, we do not store or train on Dictation Data. When Privacy Mode is OFF, we may store and use Dictation Data for improvements, including model training. You may change this at any time in Settings.
Third-Party AI Processing: We use enterprise versions of third-party AI services (currently including OpenAI and Anthropic APIs) configured to:
These contractual protections apply to our enterprise API agreements. We cannot guarantee absolute compliance by third parties but select only providers with appropriate privacy commitments and monitor for compliance where possible.
Voice Activation Controls: You may disable always-listening features through device settings. When disabled, you must manually activate recording for each interaction.
Marketing Communications: You may opt out of promotional emails by following the unsubscribe link in any marketing email or by updating your preferences in account settings.
You may access, review, and update your personal information through your account settings or by contacting us. We may require verification of your identity before processing requests.
Where technically feasible and required by law, you may request a copy of your personal information in a structured, commonly used, and machine-readable format.
Depending on your location, you may have additional rights including:
To exercise any of these rights, contact us using the information provided below. We may need to verify your identity before processing your request.
Activation and Awareness: By activating our device, you acknowledge and consent to:
Sensitive Information Risks: Our device may inadvertently capture sensitive information including but not limited to:
We strongly recommend:
Accuracy Disclaimer: Voice transcription and AI-generated responses may contain errors. We do not guarantee accuracy and are not responsible for:
Third-Party Voice Capture: You are solely responsible for:
The Services may contain links to third-party websites, applications, and services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing them with personal information.
We implement administrative, technical, and physical security measures designed to protect your personal information, including:
However, no security measures are perfect or impenetrable. We cannot guarantee the security of your information, particularly:
You are responsible for maintaining the confidentiality of your account credentials and for controlling access to your devices.
We are headquartered in the United States and process information in the United States and other countries. Your personal information may be transferred to, stored in, and processed in countries other than your own, which may have different data protection laws than your jurisdiction. By using our Services, you consent to the transfer of your information to countries outside of your jurisdiction.
Where required by law, we implement appropriate safeguards for international data transfers, which may include:
Our Services are not intended for use by or around anyone under 18 years of age. We do not knowingly collect personal information from children under 18. Our device may inadvertently capture children's voices. If you become aware that a child's voice or information has been captured:
We will promptly delete any children's data upon becoming aware of its collection, which may impact Service functionality. Parents or guardians who believe we have inadvertently collected information from their child should contact us immediately.
We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by:
Material changes will be effective upon posting or as otherwise indicated. Your continued use of the Services after changes become effective constitutes acceptance of the revised Privacy Policy. We may seek affirmative consent for certain material changes as required by law.
TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL LIABILITY FOR:
You agree to indemnify, defend, and hold harmless Skywalk and its officers, directors, employees, and agents from any claims, damages, losses, liabilities, and expenses (including attorneys' fees) arising from: (i) your use of the Services; (ii) your violation of this Privacy Policy; (iii) your violation of any third-party rights, including privacy rights of individuals whose voices are captured by our device; or (iv) your failure to obtain necessary consents.
For questions about this Privacy Policy or our privacy practices, please contact us at:
Email: contact@subtle.co
Mailing Address:
Skywalk, Inc. d/b/a Subtle Computing
855 El Camino Real, Suite 13A-230
Palo Alto, CA 94301
United States
For data protection inquiries or to exercise your privacy rights, please include "Privacy Request" in the subject line of your email. We will respond to verified requests within the timeframe required by applicable law.