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Privacy policy
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Scripts and page chrome removed; this is what change detection compares.

             Trustlead Privacy Policy
             Last update : 01/06/2026

             Welcome to the Trustlead Mobile Application (the “App”). At Trustlead, your
             privacy is a top priority. This Privacy Policy explains how we collect, process, and
             protect your personal data when you use our App to record, transcribe, and
             integrate your voice notes with CRMs and instant messaging platforms. We are
             committed to handling your data transparently and securely.

             This Privacy Policy applies to all personal data processed by Trustlead, its
             employees, and authorized third-party providers.

             For inquiries regarding this Privacy Policy, you can contact us at
             dpo@trustlead.co.

                   1. Collection and Use of Personal Data
                  Data we collect:
                           Voice Recordings and Transcriptions: Audio recordings captured via the
                           App using the device's near-field microphone. Recordings are processed
                           locally on the user's device and are never transmitted to or stored on
                           Trustlead's servers or AI models. Only the resulting transcription is
                           transmitted for processing.
                           Phone Call Metadata: When users access the voice assistant via phone
                           call, Trustlead collects call metadata (date, time, duration) and the user's
                           professional phone number. No call audio is recorded or stored.

Trustlead Privacy Policy                                                                                  1
                           CRM and Messaging Integration Data: Information shared with connected
                           CRMs (e.g., contact details, structured notes) or instant messaging
                           platforms (e.g., message metadata).
                           Business Intelligence Integration Data: Data exchanged with connected BI
                           tools (e.g., dashboards, reporting data).
                           Knowledge Base Documents: Files uploaded by administrators (PDF, Excel,
                           etc.) which may contain personal data belonging to third parties. Trustlead
                           processes these documents solely to provide its services and acts as a
                           data processor in this context.
                           Account Information: Name, email address, and other details required to
                           create and manage your account.
                           Billing Information: Company name, billing contact name, email address,
                           and billing address, collected for invoicing purposes.
                           Device Information: Data about your device, including IP address, operating
                           system, and app usage statistics.

                   2. Use of Personal Data
                  The personal data collected are used:

                  Trustlead service offer
                  To provide transcription services, convert voice notes into structured data, and
                  enable integration with CRMs, messaging platforms, and BI tools.
                  Privacy by design: Voice recordings are stored exclusively on the user's
                  device and are never uploaded to Trustlead's servers or AI models. Trustlead
                  uses near-field microphone detection to capture only the user's voice,
                  excluding surrounding sounds and third-party conversations.
                           Data categories: Transcription data, CRM/messaging platform integration
                           data, BI integration data, knowledge base documents.
                           Legal basis: Contractual necessity.
                           Retention period: Transcriptions are retained for a maximum period of 12
                           months from the date of creation, unless deleted earlier by the user. Users

Trustlead Privacy Policy                                                                                 2
                           are notified prior to automatic deletion. Voice recordings are stored
                           exclusively on the user's device and are not subject to Trustlead's retention
                           policy.

                  Phone Assistant Feature
                  To enable users to access the voice assistant by calling a dedicated phone
                  number.
                           Data categories: Professional phone number of the user, call metadata
                           (date, time, duration).
                           Legal basis: Contractual necessity.
                           Retention period: Call metadata retained for 3 months.

                  Customer support
                  To respond to support requests and communicate with our customers.
                           Data categories : customer account information (name, email address),
                           and any data voluntarily shared by the user in the context of their support
                           request.
                           Legal basis : legitimate interests to provide effective customer service
                           Retention period : Duration of the account and 3 years after deactivation

                  Service improvement
                  To analyze app usage, improve transcription accuracy, and optimize features.
                           Data categories : app usage data, feature interaction logs, anonymized
                           performance metrics
                           Legal basis: Legitimate interests in improving our services.
                           Retention period: Duration of account and 2 years after deletion.

                  Marketing and Communication
                  To send promotional materials, updates about new features, and newsletters.
                           Data categories: Email address, app usage preferences.

Trustlead Privacy Policy                                                                                   3
                           Legal basis: Consent or legitimate interests, depending on the context.
                           Retention period: Until the user unsubscribes or requests deletion.

                  Compliance with Legal Obligations
                  To comply with legal and regulatory requirements, such as data retention laws.
                           Data categories: Account and usage records.
                           Legal basis: Legal obligations.
                           Retention period: As required by law.

                  Security and Fraud Prevention
                  To ensure app security and detect fraudulent activities.
                           Data categories: Device information, app usage logs.
                           Legal basis: Legitimate interests in ensuring app security.
                           Retention period: 3 months.

                  Invoicing and Payment Processing
                  To generate invoices and process payments for Trustlead services.
                           Data categories: Company name, billing contact name, email address,
                           billing address, transaction details.
                           Legal basis: Legal obligation (accounting law) and contractual necessity.
                           Retention period: 10 years, in accordance with French accounting
                           regulations (Code de commerce, Art. L.123-22).

                   3. Sharing of Personal Data
                  We only share personal data under the following circumstances:
                           With our employees: Authorized employees have access to the collected
                           data, limited to what is necessary for their roles
                           With service providers: Third-party providers assist in delivering our
                           services. Categories include:

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                           Hosting and infrastructure:
                               Ionos SE: Server hosting. Servers located in Germany (Berlin, EU).
                               Retains all data processed by Trustlead for the duration defined by
                               customers.
                               Supabase: Database hosting. Servers located in France (Paris, EU).
                               Retains all data stored by Trustlead for the duration defined by
                               customers.
                           Artificial intelligence:
                               Mistral AI (default): AI processing of transcripts, summaries, and
                               templates. Servers located in France (Paris, EU). No data retention
                               (0 days), only processing.
                               Microsoft Azure (option): AI processing of transcripts, summaries,
                               and templates. Servers located in Sweden (EU). No data retention
                               (0 days), only processing.
                           Payment gateway:
                               Qonto: Invoice generation and financial transaction processing.
                               Data treated: billing contact information (company name, contact
                               name, email address, billing address). Servers located in the
                               European Union. Retention: as required by applicable accounting
                               and tax law (10 years in France).
                           Marketing and CRM:
                               Hubspot: Customer relationship management. Data treated:
                               account and contact information.
                           Performance and Security:
                               Datadog, Inc.: Security logging (user ID, email addresses). Servers
                               located in Germany (Frankfurt, EU). Retention: 15 days.
                               PostHog: Mobile application monitoring (touch events, HTTP calls
                               without payload, errors). Servers located in Germany (Frankfurt,
                               EU). Retention: 21 days. Activated based on your consent.

Trustlead Privacy Policy                                                                             5
                           In case of legal obligation: Personal data may be disclosed if required by
                           law or to comply with a legal request.

                  International Data Transfers
                  All Trustlead service providers currently process data within the European
                  Union. Should this change, Trustlead will ensure appropriate safeguards are in
                  place (including SCCs under Article 46 GDPR) and will update this Policy
                  accordingly.

                   4. Data Security
                  We implement appropriate technical and organizational security measures to
                  protect your personal data against loss, misuse, unauthorized access,
                  disclosure, alteration or destruction.
                  We implement encryption of data in transit and at rest on our servers, including
                  transcription data and integration payloads.
                  For more details, ask for our Trustlead Security WhitePaper by contacting
                  dpo@trustlead.co

                   5. Your rights
                  Under applicable data protection laws, you have the following rights:
                           Right to Information: As outlined in Articles 13 and 14 of the GDPR.
                           Right of Access: Access your personal data at any time (Article 15 of the
                           GDPR).
                           Right to Rectification: Correct inaccurate, incomplete, or outdated
                           personal data (Article 16 of the GDPR).
                           Right to Restriction: Restrict the processing of personal data under certain
                           conditions (Article 18 of the GDPR).
                           Right to Erasure: Request the deletion of personal data (Article 17 of the
                           GDPR).

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                           Right to File a Complaint: File a complaint with a supervisory authority (in
                           France, the CNIL) if data processing violates applicable regulations (Article
                           77 of the GDPR).
                           Post-Mortem Directives: Set instructions for managing personal data after
                           death (Article 40-1 of French data protection law).
                           Right to Withdraw Consent: Withdraw consent for data processing at any
                           time (Article 7 of the GDPR).
                           Right to Data Portability: Receive personal data in a standard machine-
                           readable format and transfer it to another entity (Article 20 of the GDPR).
                           Right to Object: Object to data processing for legitimate reasons or for
                           defending legal claims (Article 21 of the GDPR).
                  To exercise your rights or for any questions regarding this Policy, contact our
                  Data Protection Officer at dpo@trustlead.co.

                   6. Changes to the Privacy Policy
                  We may update this Privacy Policy periodically. Updates will be published on
                  this page with the updated date. We encourage you to review this page
                  regularly to stay informed about our privacy practices.

Trustlead Privacy Policy                                                                                   7