Distribute Privacy Policy

1. Our Role

We act as a controller when we decide how to use information about website visitors, account owners, prospects, and business contacts. We act as a service provider or processor when a business customer submits or connects Customer Content, such as contacts, recordings, transcripts, emails, calendar data, CRM data, or page-viewer information. In that situation, the customer controls the information and its privacy notice also applies.

If your information appears in Customer Content or on a page created by one of our customers, please contact that customer first. We will support the customer in responding to your request.

2. Information We Collect

3. How We Use Information

We use personal information to:

• provide, personalize, maintain, and support the Services;
• create accounts, process payments, and manage subscriptions;
• process Customer Content and carry out actions you request, including AI-assisted summaries, drafts, research, and follow-ups;
• operate integrations and share content with recipients you select;
• understand usage, troubleshoot, develop features, and improve performance;
• secure the Services, prevent fraud and abuse, and enforce our agreements;
• send service messages and respond to questions;
• send marketing that may interest you, subject to your choices;
• measure campaigns and website performance; and
• comply with law, protect rights and safety, and handle corporate transactions.

Where European or UK data protection law applies, our legal bases are: performance of a contract; our legitimate interests in operating, securing, improving, and marketing our business; your consent where required; and compliance with legal obligations. You may object to processing based on legitimate interests as explained in Section 10.

We do not use solely automated processing to make decisions that create legal or similarly significant effects about individuals.

4. AI Features

When you use an AI feature, we process the prompts, Customer Content, and context needed to provide the feature. We may send that information to AI service providers acting for us. Their use is restricted to providing and securing the service for us, subject to their contractual terms.

AI output can be inaccurate. A person should review output before it is used or sent. Do not submit information to an AI feature unless you have the right to use it for that purpose.

5. Google API Services and Google User Data

If you connect a Google account, we access only the Google data needed for the features you choose. Depending on those choices, this may include your Google account email, calendar events, meeting information, and permission to read or send Gmail messages on your behalf.

We use Google data to provide visible, user-requested features, such as meeting preparation, follow-up drafting, and sending a message you request or approve. We do not use Google user data for advertising, transfer it to advertising platforms or data brokers, or use it to train or improve generalized AI models.

We retain Google authorization credentials while the integration is connected and keep associated data only as needed to provide the feature, maintain security, and comply with law. You can disconnect Google in the Services or revoke access in your Google Account. Disconnecting stops future access. To request deletion of associated Google user data, email legal@distribute.so.

Distribute's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements: https://developers.google.com/terms/api-services-user-data-policy

6. How We Disclose Information

We may disclose personal information to:

• service providers that support hosting, storage, AI, analytics, payments, communications, customer support, security, and other operations;
• third-party integrations you or your administrator enable;
• your organization, account administrators, teammates, and people with whom you choose to share content;
• advertising and measurement partners, such as Meta, if you allow optional advertising technology;
• professional advisers, auditors, insurers, and financing sources under appropriate confidentiality duties;
• a buyer, investor, lender, or successor in connection with a merger, financing, reorganization, or sale of all or part of our business; and
• government authorities or other parties when reasonably necessary to comply with law, protect rights or safety, investigate abuse, or enforce agreements.

We may also disclose information at your direction or with your consent. We do not sell personal information for money.

7. Cookies, Analytics, and Advertising

We use local storage, cookies, and similar technologies for login and security, settings, site operation, analytics, and campaign measurement. Essential technologies operate by default. Our website may use privacy-focused analytics to understand traffic.

With your permission, we use Meta Pixel to measure campaigns and support advertising. Meta may receive identifiers and internet or network activity, such as IP address, device information, the page visited, and event information. Depending on the law where you live, this may be considered a sale, sharing, or targeted advertising.

Use the "Privacy choices" control on our website and select "Necessary only" to stop optional advertising technology. We also honor supported Global Privacy Control signals by not loading it. You can change your choice at any time. Browser settings can block or delete cookies, but some features may not work correctly.

8. U.S. State Privacy Disclosures

Depending on how you use the Services, we may have collected the following categories of personal information in the preceding 12 months: identifiers and contact information; customer records and commercial information; internet or network activity; approximate geolocation; professional or employment information; audio, visual, and communications content; account credentials; and inferences drawn from activity or content.

We collect these categories from the sources in Section 2, use them for the purposes in Section 3, and disclose them to the recipients in Section 6. We may disclose each category to service providers for business purposes. Customer Content may contain additional categories chosen by a customer.

We do not sell personal information for money. If optional advertising technology is enabled, we may disclose identifiers and internet or network activity to advertising and measurement partners in a way that may be considered a sale, sharing, or targeted advertising under some state laws. We do not knowingly sell or share personal information of anyone under 16.

We do not use or disclose sensitive personal information to infer characteristics about you or for purposes other than providing and securing the Services, as directed by a customer, or as permitted by law.

9. Your Choices

• Account information: update certain information in your account or ask your administrator.
• Marketing: use the unsubscribe link in marketing email. We may still send service and account messages.
• Integrations: disconnect an integration in the Services or through the third-party provider.
• Optional advertising: select "Necessary only" in our Privacy choices control or use a browser that sends Global Privacy Control.
• Shared pages and Customer Content: contact the business that created the page or submitted the information.

10. Your Privacy Rights

Depending on where you live, you may have the right to access or know about personal information; obtain a portable copy; correct or delete it; restrict or object to processing; withdraw consent; opt out of sale, sharing, targeted advertising, or certain profiling; and appeal a denied request. You may also have the right not to receive discriminatory treatment for using a privacy right.

To make a request or appeal, email legal@distribute.so and describe your request and relationship with Distribute. We may verify your identity and authority before responding. An authorized agent may submit a request where allowed by law, but we may ask for proof of authority and direct identity confirmation.

If we process the information for a customer, we will direct the request to that customer or help it respond. European and UK residents may complain to the data protection authority where they live or work.

11. International Data Transfers

Distribute is based in the United States, and we and our service providers may process information in the United States and other countries. Those countries may have different data protection laws. Where required, we use recognized transfer safeguards, such as standard contractual clauses, and take supplementary measures appropriate to the transfer. Contact legal@distribute.so to ask about applicable safeguards.

12. Retention

We keep personal information only as long as reasonably needed for the purposes described here. Retention depends on the type of information, account status, customer instructions, contractual commitments, security needs, and legal requirements.

Customer Content is generally kept for the subscription term and a limited period afterward for export and recovery, then deleted according to our schedules. Backup copies expire through normal backup cycles. Account, billing, support, security, and transaction records may be kept longer when needed for tax, audit, fraud prevention, dispute, or legal purposes. Marketing information is kept until you opt out or it is no longer useful, after which we may retain a suppression record so we respect your choice.

13. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information, including controls appropriate to the nature of the data and Services. No system is completely secure. You are responsible for protecting login credentials, managing user and sharing permissions, and using secure devices and networks.

14. Children

The Services are for business users and are not directed to children under 18. We do not knowingly collect personal information directly from children. If you believe a child provided information to us, contact legal@distribute.so.

15. Changes to This Policy

We may update this Policy as our Services or laws change. We will post the updated version and change the "Last Updated" date. If a change materially affects how we use personal information, we will provide additional notice when required.

16. Contact Us

Questions, complaints, and privacy requests may be sent to legal@distribute.so.

Distribute Labs, Inc. Austin, Texas, United States