PRIVACY POLICY
Effective Date: July 28, 2025
This Privacy Policy describes how BOET Sp. z.o.o. (“Sluqe,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal information when you use our audio processing and transcription services. This policy complies with applicable privacy laws including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant privacy regulations.
1. Information We Collect
We collect the following types of information:
1.1 Personal Information
- Name, email address, and contact information when you create an account
- Payment information (processed securely through our payment providers)
- Account credentials and authentication data
- Communication preferences and marketing consent
1.2 Audio and Content Data
- Audio recordings captured through our platform and browser extensions
- Transcribed text content generated from your audio
- Analysis and insights derived from your content using LLM technology
- Metadata associated with your recordings (timestamps, file sizes, etc.)
1.3 Technical Information
- Device information (browser type, operating system, device identifiers)
- Usage data (features used, session duration, error logs)
- IP addresses and general location information
- Cookies and similar tracking technologies
2. How We Use Your Information
We use your information for the following purposes:
- Service Provision: To provide, maintain, and improve our audio processing and transcription services
- Account Management: To create and manage your account, process payments, and provide customer support
- Content Processing: To transcribe, analyze, and generate insights from your audio content
- Security: To protect against fraud, abuse, and security threats
- Communication: To send service updates, respond to inquiries, and provide support
- Legal Compliance: To comply with applicable laws, regulations, and legal processes
- Research and Development: To improve our services and develop new features (using anonymized data)
3. Legal Basis for Processing (GDPR)
Under GDPR, we process your personal data based on the following legal grounds:
- Contract Performance: Processing necessary to provide our services under our Terms of Service
- Legitimate Interest: Processing for security, fraud prevention, and service improvement
- Consent: For marketing communications and optional features (you may withdraw consent at any time)
- Legal Obligation: Processing required by applicable laws and regulations
4. Information Sharing and Disclosure
We do not sell, rent, or trade your personal information. We may share your information in the following circumstances:
- Service Providers: With trusted third-party providers who assist in operating our services (payment processors, cloud storage, analytics)
- Legal Requirements: When required by law, court order, or government request
- Business Transfers: In connection with a merger, acquisition, or sale of assets (with appropriate safeguards)
- Safety and Security: To protect our rights, property, or safety, or that of our users or the public
- With Your Consent: When you explicitly authorize us to share your information
5. Data Security
We implement appropriate technical and organizational measures to protect your personal information:
- End-to-end encryption for audio data in transit and at rest
- Secure data centers with physical and digital security controls
- Regular security assessments and penetration testing
- Access controls and authentication mechanisms
- Employee training on data protection and privacy
- Incident response procedures and breach notification protocols
6. Data Retention
We retain your personal information for as long as necessary to provide our services and comply with legal obligations:
- Account Data: Retained while your account is active and for a reasonable period after deletion
- Audio Content: Retained according to your account settings and deletion requests
- Usage Data: Retained for service improvement and security purposes
- Legal Records: Retained as required by applicable laws and regulations
You may request deletion of your data at any time through your account settings or by contacting us.
7. Your Privacy Rights
Depending on your location, you may have the following rights:
7.1 GDPR Rights (EU/EEA)
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your personal data (“right to be forgotten”)
- Portability: Receive your data in a structured, machine-readable format
- Restriction: Limit how we process your data
- Objection: Object to processing based on legitimate interests
- Withdraw Consent: Withdraw consent for consent-based processing
7.2 CCPA Rights (California)
- Disclosure: Know what personal information we collect and how we use it
- Access: Request access to your personal information
- Deletion: Request deletion of your personal information
- Opt-out: Opt-out of the sale of personal information (we do not sell personal information)
- Non-discrimination: Not be discriminated against for exercising your rights
8. International Data Transfers
Your personal information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place:
- Standard Contractual Clauses (SCCs) for EU data transfers
- Adequacy decisions where applicable
- Other appropriate safeguards as required by law
- Transparency about data transfer locations
9. Cookies and Tracking Technologies
We use cookies and similar technologies to:
- Maintain your session and authentication status
- Remember your preferences and settings
- Analyze service usage and performance
- Provide personalized features and content
You can control cookie settings through your browser preferences. Note that disabling certain cookies may affect service functionality.
10. Children's Privacy
Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information promptly.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by email or through our services. Your continued use of our services after such changes constitutes acceptance of the updated policy.
12. Contact Information
For questions about this Privacy Policy or to exercise your privacy rights, please contact us:
Email: support@sluqe.com
Address: BOET Sp. z.o.o. Chmielna 73B / 14, 00-801 Warszawa, Poland
Data Protection Officer: nadim@sluqe.com
EU Representative: If you are in the EU/EEA and have concerns about our data processing, you may also contact your local data protection authority.