Privacy Policy

AKAPULU LABS PRIVACY POLICY Last updated: 2026-10-21 This Privacy Policy explains how Akapulu LLC, doing business as Akapulu Labs ("Akapulu Labs," "we," "us," or "our") collects, uses, discloses, and retains personal information when you use our websites, applications, APIs, and related services (collectively, the "Services"). By using the Services, you acknowledge this Privacy Policy. In this Privacy Policy, words and phrases such as "including," "for example," and "such as" mean "including, without limitation." 1. Scope This Privacy Policy applies to: - individual users of Akapulu Labs websites and applications, and - individuals who submit contributor, talent, or contractor inquiries or applications through Akapulu Labs websites (including before they create a Services account), and - developer/API users and organizations using Akapulu Labs APIs and integrations. When Akapulu Labs provides Services to a business customer under a separate contract, Akapulu Labs may process information on that customer's behalf as a service provider/processor. In those cases, that customer's contract with Akapulu Labs may control certain processing terms. If your data is processed on behalf of one of our business customers, requests about that data may need to be directed to that customer first. Website usage terms are addressed separately at https://akapulu.com/website-terms. 2. Information We Collect We may collect the following categories of information: 2.1 Account and profile information - account identifiers and contact information (such as first name, last name, and email address), - authentication/account metadata, - plan and account configuration details. 2.2 Avatar information - generated avatar images, video, and related processing artifacts, - avatar metadata (such as description and public/private settings). Catalog avatars are generated. They are not a recording of a particular person. We do not record a person to create an avatar of that person. If you choose to make an avatar public, that avatar may be displayed in catalog/public contexts within the Services and made available for use by other logged-in Akapulu Labs users in live sessions and hosted links. If your avatar is enabled as public, we may also use, reproduce, display, and distribute that public avatar and related output for Akapulu Labs marketing and promotional purposes (for example on our website, social media, product demos, and sales materials). Akapulu Labs may also publish catalog avatars that we created or generated (including avatars that are not a recording of a particular person). 2.3 Conversation and interaction information - live-session and hosted-link metadata (such as the avatar, the room reference, whether the session is a hosted link, and whether the picture showed an on-screen "This is AI" label), - hosted-link prompts, - audio you send to an avatar so it can render a face, - audio and video from a landing-page demo, including the caller's face and voice, - recording-related metadata, including recording identifiers, references, links, and status data for recordings processed or stored by third-party media providers. 2.4 Developer and integration information - API key metadata, - request/response operational metadata, - videos you upload to read an authenticity mark, the check identifier, and the read result. We keep the uploaded video until that read finishes, and we delete the video when the read finishes. 2.5 Knowledge base and document information The Services do not collect knowledge-base documents or embeddings. 2.6 Billing and usage information - billing/customer and subscription metadata, - usage metrics (for example minutes, concurrency, and usage limits), - payment-related metadata from billing processors. 2.7 Device, log, and operational data - service logs, timestamps, performance/error diagnostics, and security events, - technical metadata such as IP address, device/browser details, request metadata, and general usage telemetry. 2.8 Information about other people you upload or configure If you upload or submit personal information about another person (for example contact details or identifying information), you represent that you have all rights and permissions required to do so. 2.9 Contributor and talent applications When you apply or inquire through a web form about paid or unpaid contributor, public-avatar, talent, or similar opportunities, we may collect: - contact and identifying information you submit (such as name and email address), - optional free-text you provide (for example time zone, links to a reel or portfolio, or brief messages), - application or screening materials you upload (for example a photo of your proposed recording setup, which may show your likeness), - technical metadata related to that submission (as described in section 2.7). This information may be collected and processed before you create a Services account. If you later create an account, sign a separate agreement, or use in-product avatar workflows, additional categories of information may be collected as described elsewhere in this Policy. 2.10 Marketing and attribution information When you visit our websites, we may collect information about how you arrived, such as the referring website or link, campaign parameters contained in the URL you clicked (for example UTM parameters), and advertising click identifiers (for example a Google Click ID ("gclid") and similar identifiers from advertising platforms). We may also ask how you heard about us. If you create an account, submit an inquiry, or subscribe to a newsletter, we may associate this acquisition-source information with your account, inquiry, or subscription to understand how people discover the Services and to measure the effectiveness of our marketing. This information is collected using first-party, essential website mechanisms (such as our own session), and where required by law we rely on legitimate interests or your consent as the applicable legal basis. 3. Biometric Information Akapulu Labs records a landing-page demo. The recording includes the caller's face and voice when the camera or microphone is on. That face and voice recording is biometric information. Akapulu Labs uses the recording for internal quality assurance of the conversation experience and to train and improve Akapulu Labs' own models. Akapulu Labs does not use the recording to create an avatar of the caller. Catalog avatars are generated. They are not a recording of a particular person. Akapulu Labs does not record a person to create an avatar of that person. Akapulu Labs does not sell landing-page demo recordings and does not share them for other companies to train their models. A recording may still be stored or processed by infrastructure and storage providers that host the call or store the recording for Akapulu Labs. Photos or other images you submit for contributor screening or setup verification may contain visual likeness. Akapulu Labs uses those images to review an application. Akapulu Labs does not use them to create an avatar. The Biometric Information Notice describes the landing-page demo recording. By connecting to a landing-page demo, you agree to this Privacy Policy and consent to that recording as described in this Policy and the Biometric Information Notice. Earlier versions of the notice described recording a person to create an avatar of that person. Akapulu Labs no longer offers that workflow. Acceptances of an earlier version stay on record. 4. How We Use Information We use personal information to: - provide, operate, maintain, and improve the Services, - create and run avatars and related AI features, - render avatar faces for live sessions, run hosted-link conversations, and read authenticity marks from videos you upload, - review landing-page demo recordings for internal quality assurance and train Akapulu Labs' own models on them, - support developer and API functionality, - evaluate and respond to contributor, talent, or contractor applications and inquiries, and communicate with you about opportunities and next steps, - send account-related, transactional, and service communications (for example security alerts, billing notices, and support messages), - send product update and promotional communications about the Services (for example new features, platform announcements, and company news), - understand how visitors discover the Services and measure the effectiveness of our marketing and campaigns (including acquisition source, referral, and campaign information), - enforce safety, abuse prevention, fraud prevention, and security, - manage billing, metering, and account limits, - comply with legal obligations and respond to lawful requests. If you create an account or otherwise provide your email address to us, we may send you emails about the Services, including product updates and announcements about new features. Product update emails may be promotional in nature. You can opt out of product update and other promotional emails at any time by using the unsubscribe link in those emails or by contacting [email protected]. Even if you opt out of promotional emails, we may still send you non-promotional communications related to your account or the Services (for example billing, security, or support messages). We may also use submitted and generated content to develop, evaluate, maintain, and improve our models and platform performance. If you want to opt out of model-improvement use of your content, contact [email protected]. We review and process opt-out requests in good faith according to operational and legal constraints. Opt-out requests may apply prospectively and may not require removal of prior training, derived artifacts, safety records, or previously completed processing. 5. How We Share Information We may share information with: - infrastructure and hosting providers, - realtime media, speech, and AI processing providers, - storage/database and data-processing providers, - payment and billing processors, - email delivery and newsletter providers, - analytics and marketing measurement providers (for example Google Analytics and related Google advertising features, where enabled), - security and compliance providers, - professional advisors and legal/compliance recipients where required. For live sessions, hosted links, and generated-media processing (where used), providers may include third parties used for cloud infrastructure, realtime media, speech processing, model serving, storage, and related operations. On a live session in a room you create, your bot and your providers handle listening and speech. On a hosted link, we may send conversation audio and the prompt to speech and model providers. A landing-page demo recording may be stored with providers that host the call or store the recording for Akapulu Labs. Akapulu Labs uses that recording for internal quality assurance and to train Akapulu Labs' own models. Akapulu Labs does not share those recordings for other companies to train their models. For other service functions, providers may include third parties used for billing, payments, database infrastructure, security, email delivery, analytics/marketing measurement, and AI/ML functionality. A list of subprocessors may be made available upon request. We may also disclose information: - to comply with law, regulation, legal process, or government request, - to protect rights, safety, security, and prevent abuse/fraud, - in connection with a merger, acquisition, reorganization, financing, or sale of all or part of our business. 6. Sales and Advertising We do not sell personal information. We may use analytics and marketing technologies (including cookies and similar tools from providers such as Google) as described in Section 7. Where required by law, we obtain your consent before using non-essential cookies for analytics or marketing. We do not currently share personal information for cross-context behavioral advertising as defined under California law. If that changes, we will update this Policy and provide any required notices or opt-out mechanisms. 7. Cookies and Similar Technologies We use cookies and similar technologies on our websites for: - essential purposes (for example session, security, and preference features needed to operate the Services), - analytics (for example understanding how visitors use our websites), and - marketing purposes (for example measuring campaign effectiveness and supporting advertising features). Our analytics and marketing technologies may include Google Analytics and related Google advertising features. These tools may collect information such as IP address, device/browser details, pages visited, referral information, and similar usage data. Where required (including for visitors in the EEA, UK, and Switzerland), we present a cookie consent banner and only use non-essential analytics and marketing cookies if you accept. You can change your choice later using the "Cookie preferences" link in the website footer. Rejecting non-essential cookies does not prevent you from browsing our public websites, though some measurement and marketing features will be limited. We may also use necessary technical mechanisms (for example session/local storage or equivalent functionality) required to operate core service features. 8. Data Retention We retain information for as long as reasonably necessary for business operations, model/platform improvement, security, safety, abuse prevention, legal compliance, dispute resolution, and enforcement. Akapulu Labs retains landing-page demo recordings for internal quality assurance and to train Akapulu Labs' own models. Retention periods vary by data type and legal/operational requirements. Depending on service operations and legal requirements, some data may be retained long-term or indefinitely unless deletion is requested and applicable law requires or permits deletion. We may delete, de-identify, or aggregate data when no longer needed, subject to legal and operational exceptions. If you request that a public avatar be removed, we will stop future platform-wide use of that avatar. You may also request broader data deletion by contacting us. Certain records may still be retained where required or permitted by law, including conversation recordings, live-session records, and talking clips already created using that avatar. 9. Your Privacy Rights and Requests Depending on your jurisdiction, you may have rights to request: - access to personal information, - correction of inaccurate personal information, - deletion of personal information, - portability of certain data, - information about our data practices, - opt out of promotional or product update emails (for example by using the unsubscribe link in those emails or contacting [email protected]). You may also request that an avatar be switched from public to private by contacting us. To submit a privacy request, contact: [email protected] If your data is processed by Akapulu Labs on behalf of a business customer, we may direct you to submit your request to that customer and coordinate with that customer as required by applicable law and contract. We may request information to verify your identity and authority before fulfilling a request. We respond within timelines required by applicable law. In some cases, we may decline or limit requests where permitted by law, including for security, fraud prevention, legal compliance, or technical/operational reasons. Where permitted by law, you may submit a request through an authorized agent. We may require proof of the agent's authority and may still require identity verification from you directly. If we deny your request, you may contact us to appeal or request additional review at [email protected]. We will not unlawfully discriminate against you for exercising applicable privacy rights. 10. California Privacy Disclosures For California residents, this section summarizes our practices under applicable California privacy law (including CPRA, where applicable): - categories collected: identifiers, account data, application and recruiting information (which may include images submitted for screening), audio/video content (including generated avatar media, live-session audio, landing-page demo recordings of face and voice, videos uploaded to read an authenticity mark, and talking clips already generated), hosted-link prompts, internet/network activity, usage and billing metadata, and other information described in this Policy, - purposes: service delivery, recruiting and contributor onboarding, security/fraud prevention, billing, analytics and marketing measurement, legal compliance, internal quality assurance of landing-page demos, training Akapulu Labs' own models, and service/model improvement, - sources: directly from users, from user-integrated tools/configurations, and from service providers, - disclosures: to service providers, contractors, and other recipients described above for business purposes (including analytics and marketing measurement providers where used), - sale/share: we do not sell personal information and do not currently share personal information for cross-context behavioral advertising. California residents may submit requests using [email protected]. 11. International Data Processing If you access the Services from outside the United States, your information may be processed and stored in the United States or other jurisdictions where our providers operate. Data protection laws in those jurisdictions may differ from those in your location. 11.1 Notice for EEA/UK users If you are located in the EEA or UK, where applicable we process personal data under one or more of these legal bases: contract necessity, legitimate interests, legal obligations, and consent. Where personal data is transferred internationally, we use legally recognized transfer mechanisms where required by applicable law (for example, adequacy decisions, standard contractual clauses, or comparable lawful mechanisms). 12. Security We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. However, no system is completely secure, and we cannot guarantee absolute security. 13. Children's Privacy The Services are not directed to children. You must be 18 or older to use the Services. 14. Changes to This Privacy Policy We may update this Privacy Policy from time to time. For material updates, we may provide notice by email, in-product notice, posting, or similar means. Updates are effective when posted unless otherwise stated. Your continued use of the Services after an update means you acknowledge the updated Policy applies. Previous versions may be available upon request. 15. Contact Akapulu Labs Akapulu LLC Email: [email protected] Mail: c/o UNITED STATES CORPORATION AGENTS, INC. (1505 Corporation), 500 N Brand Blvd, Suite 890, Glendale, CA 16. Other Sites and Services The Services may link to or interoperate with third-party websites, applications, and services. We are not responsible for the privacy practices of third parties, and you should review their policies separately.