Privacy Policy

Effective as of 10/24/2025

This Privacy Policy describes how Skywalk, Inc. d/b/a Subtle Computing (“Subtle Computing,” “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/ 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 Computing 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.

Index

  • Personal information we collect
  • How we use your personal information
  • How we share your personal information
  • Your choices and rights
  • Other sites and services
  • Security
  • International data transfers
  • Changes to this Privacy Policy
  • How to contact us

Personal information we collect

Information You Provide to Us

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.

Information from Third-Party Sources

We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

  • Public sources, including public records, social media platforms, and other publicly available sources
  • Service providers that provide services on our behalf or help us operate the Services
  • Business partners who provide co-branded services or engage in joint marketing activities

Automatic Data Collection

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.

Cookies and Tracking Technologies

We use cookies, pixel tags, local storage, and similar technologies to automatically collect information about your activities over time across the Services, including:

  • Session cookies (deleted when you close your browser)
  • Persistent cookies (remain until deleted or expired)
  • Web beacons and pixel tags
  • Software development kits (SDKs)

How we use your personal information

Service Delivery and Operations

We use your personal information to:

  • Provide, maintain, and improve our Services
  • Process transactions and send related information
  • Send administrative messages, updates, security alerts, and support messages
  • Respond to your comments, questions, and requests
  • Provide customer service and support
  • Authenticate users and prevent fraud

Analytics and Improvement

We analyze usage of our Services to:

  • Understand how users interact with our Services
  • Identify trends and usage patterns
  • Measure the effectiveness of features
  • Diagnose technical issues
  • Develop new products and services

Marketing and Advertising

With your consent where required, we may use your information to:

  • Send promotional communications about our products and services
  • Personalize marketing messages based on your interests
  • Conduct contests, sweepstakes, and promotions
  • Measure the effectiveness of our marketing campaigns

Legal Compliance and Protection

We may use your personal information to:

  • Comply with applicable laws, regulations, and legal processes
  • Respond to government requests and cooperate with law enforcement
  • Enforce our terms and policies
  • Protect our rights, privacy, safety, or property, and that of our users and others
  • Investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of our terms

Aggregated and Anonymized Data

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.

How We Share Your Personal Information

Service Providers

We share personal information with vendors and service providers that perform services on our behalf, including:

  • Payment processing
  • Cloud storage and hosting
  • Analytics and performance monitoring
  • Customer support
  • Marketing and advertising
  • Security and fraud prevention

Legal and Protective Disclosures

We may disclose personal information:

  • To comply with law, regulation, legal process, or government request
  • To protect rights, property, or safety
  • To investigate or prevent suspected fraud or illegal activity
  • To enforce our agreements and policies
  • With your consent or at your direction

Business Transfers

We may transfer personal information in connection with:

  • Merger, acquisition, or sale of all or a portion of our assets
  • Bankruptcy, dissolution, or reorganization
  • Due diligence related to such transactions

We do not sell personal information.

Your Choices and Rights

Data Deletion Rights

You have the right to request deletion of your personal information, including transcription data, at any time by:

  • Accessing the deletion tool in your account settings
  • Contacting us at contact@subtle.co
  • Submitting a request through our privacy portal

Upon receiving a verified deletion request, we will:

  • Delete your personal information from our active databases within 30 days

Important Limitations: We cannot delete:

  • Aggregated or anonymized data that cannot identify you
  • Data we must retain for legal, tax, or regulatory compliance
  • Data necessary to complete transactions you've initiated
  • Information necessary for security, fraud prevention, or to protect against illegal activities

Consent Management

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.

Access and Correction

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.

Data Portability

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.

Additional Jurisdiction-Specific Rights

Depending on your location, you may have additional rights including:

  • Right to object to processing
  • Right to restrict processing
  • Right to withdraw consent
  • Right to non-discrimination for exercising privacy rights
  • Right to designate an authorized agent
  • Right to appeal our decisions regarding your requests

To exercise any of these rights, contact us using the information provided below. We may need to verify your identity before processing your request.

Other Sites and Services

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.

Security

We implement administrative, technical, and physical security measures designed to protect your personal information, including:

  • Encryption of data in transit and at rest
  • Access controls and authentication requirements
  • Regular security assessments and audits
  • Employee training on data protection

However, no security measures are perfect or impenetrable. We cannot guarantee the security of your information. You are responsible for maintaining the confidentiality of your account credentials and for controlling access to your devices.

International Data Transfers

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:

  • Standard contractual clauses
  • Adequacy decisions
  • Your explicit consent

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by:

  • Updating the effective date at the top of this Privacy Policy
  • Posting a notice on our Services
  • Sending you an email notification (if we have your email address)

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.

Limitation of Liability and Indemnification

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL LIABILITY FOR:

  • UNAUTHORIZED CAPTURE, USE, OR DISCLOSURE OF SENSITIVE INFORMATION
  • THIRD-PARTY ACCESS TO YOUR DATA OR TRANSCRIPTIONS
  • DECISIONS OR ACTIONS BASED ON OUR SERVICES
  • VIOLATION OF THIRD-PARTY PRIVACY RIGHTS
  • ANY INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES

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.

How to Contact Us

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.