Privacy Policy

Privacy Policy

This Privacy Policy explains how Vallige, Inc. (‘Vallige,’ ‘we,’ ‘us,’ ‘our’) collects, uses, discloses, and protects your personal information through our platform and services (collectively, ‘Services’), currently offered only in the United States. We are not a healthcare provider and do not comply with HIPAA (see our Terms of Service, Section 12). For California residents, we comply with the CCPA/CPRA as a ‘business.’ If we expand to the EEA, we will adhere to the EU GDPR as a ‘controller.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Vallige, Inc., located at 2261 Market Street, Suite 22554, San Francisco, CA 94114
Data Protection Contact	Matthew Tullis, reachable at support@vallige.com
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, trade union membership, or health data (e.g., mood or anxiety screening), genetic and biometric data (e.g., voice or facial recognition for AI Clones), or other sensitive traits as defined by GDPR, if applicable.
Sensitive Personal Information	Personal information revealing health data (e.g., Caregiver Journal entries), biometric data (e.g., voice recordings, video imagery), or other sensitive identifiers as defined by CCPA/CPRA.
Biometric Information	Voice recordings and video imagery used to generate AI Clones (e.g., voiceprints, facial recognition data).

Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	Names, aliases, postal addresses, unique personal identifiers, online identifiers, Internet Protocol address, email address, account name, phone numbers, names of relatives
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information	Name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	Credit or debit card numbers, bank account numbers
Characteristics of protected classifications under California or federal law	Race, religion, gender, sex, ethnicity, age
Biometric information	Voice recordings, video imagery, facial/voice recognition data for AI Clones
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement)	Device type, operating system, network types, cookies, and information regarding a consumer’s interaction with the Vallige platform or advertisements
Geolocation data	Approximate location (if enabled)
Audio, electronic, visual, thermal, olfactory, or similar information	Call recordings, Village Feed photos, audio and visual information
Professional or employment-related information	Employment related information, such as job history and experience
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)	Education history and information
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status	Racial and ethnic origin, religion and philosophical beliefs, union membership information and history, citizen and immigration status
Processing of biometric information to uniquely identifying a consumer	Facial and voice recognition data
Health information	Health history and information, including but not limited information related to mental health; Caregiver journal entries
Sex life or sexual orientation	Sex, sexual orientation, gender identification

If you do not provide personal information required to provide products AND/OR services to you, it may delay or prevent us from providing products AND/OR services to you.

How Your Personal Information is Collected. We may collect personal information from the following categories of sources:

You, directly in person, by telephone, text, or email, and/or via via our Platform/app (e.g., account signup, AI Clone training, Village Feed posts).
Third-party AI providers (e.g., Eleven Labs, Tavus) with your consent during feature use
Advertising networks
Device data (e.g., IP addresses, usage patterns) via cookies and analytics tools
Operating systems and platforms
Social networks
Cookies on our website

How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party –or–
Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide Services (e.g., AI Clones, Village Feed)	For the performance of our contract with you or to take steps at your request before entering into a contract
To generate and operate AI Clones	For contract performance (e.g., processing voice/video data)
To analyze call/screening data for improvement	For our legitimate interests (e.g., enhancing Services)
To prevent and detect fraud against you or Vallige	For our legitimate interests (e.g., minimizing fraud risks)
To improve efficiency, training, and quality control	For our legitimate interests (e.g., delivering the best service)
Ensuring business policies are adhered to, e.g., policies covering security and internet use	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: Existing and former customers Third parties who have previously expressed an interest in our services Third parties with whom we have had no previous dealings	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

We process biometric and health data only with your consent or as necessary to provide the Services.

For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.

We use AI technologies to generate data (e.g., mood inferences, AI Clone outputs) to enhance the Services. This AI-generated data is owned by Vallige or its licensors (per TOS Section 11.6) but used only to provide and improve the Services, not for unrelated purposes.

EEA Data Subjects: Promotional Communications. If we offer Services in the European Economic Area (EEA), we may use your personal information to send you updates (e.g., by email, text) about our Services, including offers or new features, based on our legitimate interest in promoting our business. You can opt out at any time by contacting us at support@vallige.com or using settings in our app. We will treat your information with respect and will not sell or share it with third parties for their marketing purposes. Where consent is required by law, we will request it separately and clearly. For U.S. Customers, promotional communications, if any, are managed under our Terms of Service (Section 16) and applicable U.S. laws.
Who We Share Your Personal Information With. We routinely share personal information with:

Service providers we use to help deliver our products and/or services to you, such as payment service providers, and vendors that contribute to our product suite (e.g., payment processors, AI vendors like Eleven Labs, Tavus, OpenAI)
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
Law enforcement or regulators to comply with legal obligations.
Potential buyers during a business sale (anonymized where possible).

Third-party AI providers (e.g., Eleven Labs, Tavus) may process your data (e.g., voice, video) under their own privacy policies, which we do not control. Review their terms before using AI features (see TOS Section 9).

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

Personal Information We Sold or Shared. In the preceding 12 months, we have not sold or shared your personal information for marketing or advertising purposes. We only disclose data for business purposes, such as to service providers, as described in Section 8.
Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers)
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Characteristics of protected classifications under California or federal law
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Biometric information
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement)
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Professional or employment-related information
Education information, defined as information that is not publicly available personally identifiable information as defined in the FERPA
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes –and–
Sensitive personal information

How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products AND/OR services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf
To show that we treated you fairly –or–
To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it. For example, biometric data (e.g., voice/video for AI Clones) is deleted upon account closure unless retained for legal purposes (e.g., dispute resolution). We anonymize data where possible after its purpose ends.

California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge. As a non-healthcare provider (see TOS Section 12), we handle sensitive data outside HIPAA. We do not sell/share your data for marketing; disclosures are for business purposes only (Section 8):

Disclosure of Personal Information We Collect About You	You have the right to know, and request disclosure of: The categories of personal information we have collected about you, including sensitive personal information The categories of sources from which the personal information is collected The categories of third parties to whom we disclose personal information, if any –and– The specific pieces of personal information we have collected about you Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or– Provide the personal information to you more than twice in a 12-month period
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose	In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and– The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. We do not sell/share your data, so opt-out is inapplicable, but you can limit sensitive data use at [insert URL].
Right to Limit Use of Sensitive Personal Information	You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, if the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and– As authorized by further regulations You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, visit our homepage and click on the "Limit the Use of My Sensitive Personal Information" link here: [url].
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records –and– Delete your personal information from our records –and– Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort Please note that we may not delete your personal information if it is reasonably necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes Debug to identify and repair errors that impair existing intended functionality Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law Comply with the California Electronic Communications Privacy Act Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us Comply with an existing legal obligation –or– Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Right of Correction	If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation	You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: Deny goods or services to you Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties Provide a different level or quality of goods or services to you –or– Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services Please note that we may charge a different price or rate or provide a different level or quality of products and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

Children’s Privacy. Our Services are intended for users 18 and older, as stated in our Terms of Service (Section 2). We do not knowingly collect personal information from children under 13, or under 16 for California-specific protections. If we learn that a child’s data has been collected without verifiable parental consent, we will delete it as soon as practicable. Contact us at support@vallige.com if you believe we’ve collected a child’s data.
EEA Data Subjects: Your Rights Under the EU GDPR. If we offer Services in the EEA, you’ll have the following GDPR rights.

Right to Be Informed	The right to know or be notified about the collection and use of your personal information
Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: At any time to your personal information being processed for direct marketing (including profiling) In certain other situations to our continued processing of your personal information, e.g., processing carried out for our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so here: vallige.com/privacy-rights. You may also email us at support@vallige.com or write to us at 2261 Market Street, Suite 22554, San Francisco, CA 94114.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly by website/email/phone/in writing, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number)
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
A description of what right you want to exercise and the information to which your request relates

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

EEA Data Subjects: Where Your Personal Information is Held. If we operate in the EEA, data may be held at our U.S. offices and with third-party providers as described above (see above: “Who We Share Your Personal Information with”).
EEA Data Subjects: Transferring Your Personal Information Out of the EEA. If we expand to the EEA, we may transfer data outside the EEA, e.g.:

With our offices outside the EEA
With your and our service providers located outside the EEA
If you are based outside the EEA –or–
Where there is an international dimension to the services we are providing to you

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: The United States of America.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses, visit https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

If you would like further information, please contact us OR our Data Protection Officer (see “How To Contact Us” below).

Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so within legally required timeframes (e.g., 72 hours under GDPR if applicable, or as per California law).

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

EEA Data Subjects: How to File a GDPR Complaint. We hope that we OR our Data Protection Officer can resolve any query or concern you raise about our use of your information.

Under the General Data Protection Regulation (GDPR), you have the right to lodge a complaint with a supervisory authority in the EEA. You may do so in the EEA country where you reside, work, or where an alleged infringement of data protection laws occurred. The relevant supervisory authority depends on the country involved.

A full list of EEA supervisory authorities and their contact information is available on the European Data Protection Board’s website at https://edpb.europa.eu/about-edpb/about-edpb/members_en]. We encourage you to reach out to us first to resolve any issues, but you retain the right to contact a supervisory authority at any time.

Changes to This Privacy Notice. This privacy notice was published on April 14, 2025 and last updated on April 14, 2025.

We may change this privacy notice from time to time–when we do, we will inform you via our website or other means of contact such as email.

How to Contact Us. Please contact us and/or our Data Protection Officer by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details	Our Data Protection Officer's contact details
2261 Market Street, Suite 22554, San Francisco, CA 94114	2261 Market Street, Suite 22554, San Francisco, CA 94114
support@vallige.com (mailto:support@vallige.com)	support@vallige.com (mailto:support@vallige.com)
650-977-1880	650-977-1880

Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

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