PRIVACY POLICY

Last updated: August 3, 2026

This Privacy Policy describes how Altavex LLC, doing business as Spokn ("Spokn," "Company," "we," "us," or "our"), collects, uses, discloses, and protects your information when you use the Spokn mobile application (the "App"), the website usespokn.app (the "Site"), and related products and services (together, the "Services"). By using the Services, you agree to this Privacy Policy. If you do not agree, please do not use the Services.

This Privacy Policy is incorporated into and subject to our Terms of Service. Capitalized terms not defined here have the meaning given in the Terms of Service. The Services are intended only for individuals who are at least 18 years old.

TABLE OF CONTENTS

1. INFORMATION WE COLLECT 2. HOW WE USE YOUR INFORMATION 3. VOICE RECORDINGS AND BIOMETRIC DATA 4. AI PROCESSING AND DATA LICENSING 5. HOW WE SHARE YOUR INFORMATION 6. CREATOR AND COMMUNITY CAMPAIGNS 7. COOKIES AND TRACKING 8. DATA RETENTION AND DESTRUCTION 9. DATA SECURITY 10. YOUR PRIVACY RIGHTS 11. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA) 12. ILLINOIS BIOMETRIC INFORMATION (BIPA) 13. CHILDREN'S PRIVACY 14. INTERNATIONAL USERS AND DATA LOCATION 15. THIRD-PARTY LINKS AND SERVICES 16. CHANGES TO THIS POLICY 17. CONTACT US

1. INFORMATION WE COLLECT

We collect the following categories of information:

2. HOW WE USE YOUR INFORMATION

We use your information to:

3. VOICE RECORDINGS AND BIOMETRIC DATA

Voice is central to the Services, and your voice recordings may be considered biometric information under laws such as the Illinois Biometric Information Privacy Act (BIPA). We handle voice recordings as follows:

4. AI PROCESSING AND DATA LICENSING

By submitting voice recordings, you acknowledge and consent that: (1) your recording is transcribed and analyzed using automated AI services, including OpenAI (Whisper for transcription and GPT models for analysis); (2) only the resulting anonymized transcript and derived insights, not your voice recording, are delivered to brand clients and Creators; (3) your voice recording is deleted after transcription and is not sold, licensed, or distributed, unless you opt in to a specific campaign that shares audio; and (4) anonymized transcripts and derived insights, which do not contain your voice, may be used and licensed for research and AI model training, with any compensation fully satisfied by the per-task payout you receive.

Opt-out: if you do not want your recordings used for AI training or licensing, you may opt out at any time by contacting us at franco@usespokn.app. Opting out does not affect your ability to earn through standard campaigns.

5. HOW WE SHARE YOUR INFORMATION

We share information only as described below. We do not sell your personal information for money. Our use or licensing of anonymized transcripts and insights for AI training (Section 4) may be considered a "sale" or "sharing" under certain laws; you may opt out as described in Sections 4 and 11. We do not sell or share your voice recordings.

6. CREATOR AND COMMUNITY CAMPAIGNS

Some campaigns are created by individual users or other third parties ("Creators") rather than brand partners. When you participate in a Creator campaign, the anonymized transcript of your response and data derived from it may be delivered to the Creator on the same anonymized basis described above. Where a campaign is expressly identified as sharing identified audio, and only where you give specific, per-campaign consent before recording, your voice recording and chosen username may be shared with the Creator and displayed, published, or broadcast in identified form. Participation is always optional. Spokn does not control and is not responsible for a Creator's use of transcripts or recordings; Creators are contractually required to use responses only lawfully and not to re-identify or contact participants, as described in our Terms of Service.

7. COOKIES AND TRACKING

The App does not use third-party advertising cookies. The Site uses strictly necessary tools, including Cloudflare Turnstile, to protect against automated abuse, and may use minimal local storage to remember your preferences. We do not use the Services to serve third-party behavioral advertising.

8. DATA RETENTION AND DESTRUCTION

We retain personal information for as long as necessary to provide the Services, comply with our legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. Voice recordings are retained under the schedule in Section 3 and are permanently deleted or de-identified when no longer needed and no later than three (3) years after your last interaction with the Services. When you delete your account, we delete or de-identify your personal information within a reasonable period, except information we are required or permitted to retain by law (for example, transaction and tax records).

9. DATA SECURITY

We use administrative, technical, and organizational safeguards designed to protect your information, including encryption in transit, access controls, and row-level security on our database. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

10. YOUR PRIVACY RIGHTS

Subject to applicable law, you may:

To exercise any right, contact us at franco@usespokn.app. We will not discriminate against you for exercising your rights.

11. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect, use, and disclose; to request deletion or correction; and to opt out of the "sale" or "sharing" of your personal information. We do not sell personal information for money; our licensing of anonymized recordings for AI training may be treated as a "sale" or "sharing," and you may opt out by emailing franco@usespokn.app with the subject line "Do Not Sell or Share My Personal Information."

The categories of personal information we collect are described in Section 1 and include identifiers, commercial information, internet/network activity, geolocation (city-level), audio/biometric information, and inferences. We collect this information from you and from your use of the Services, for the business purposes described in Section 2, and disclose it as described in Section 5. You may designate an authorized agent to make a request on your behalf. We will not discriminate against you for exercising your rights.

12. ILLINOIS BIOMETRIC INFORMATION (BIPA)

If you are an Illinois resident, the following applies to voice recordings that may constitute biometric identifiers or biometric information under BIPA. We collect and store such information only after obtaining your informed written consent; we use it solely for the purposes described in Section 3 and Section 4; we do not sell, lease, or trade your identifiable biometric information; and we retain it only as long as necessary and no later than three (3) years after your last interaction with the Services, after which it is permanently destroyed, consistent with our written retention and destruction schedule. By consenting before recording, you provide the written release contemplated by BIPA.

13. CHILDREN'S PRIVACY

The Services are intended only for individuals aged 18 and older. We do not knowingly collect personal information from anyone under 18, and we prohibit use by anyone under 18, consistent with the Children's Online Privacy Protection Act (COPPA). If we learn that we have collected information from a person under 18, we will delete it. If you believe a minor has provided us information, contact us at franco@usespokn.app.

14. INTERNATIONAL USERS AND DATA LOCATION

The Services are operated from and hosted in the United States. If you access the Services from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data-protection laws may differ from those in your jurisdiction, and you consent to that transfer and processing.

15. THIRD-PARTY LINKS AND SERVICES

The Services may link to or rely on third-party websites and services (such as Stripe and the Apple App Store or Google Play). We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

16. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date above and, where appropriate, notify you through the App or by other means. Your continued use of the Services after an update constitutes acceptance of the revised Policy.

17. CONTACT US

If you have questions or requests regarding this Privacy Policy or your personal information, contact us at:

Altavex LLC (DBA Spokn)
7409 SW 168th Ter
Palmetto Bay, FL 33157
United States
Phone: (305) 354-6412
franco@usespokn.app