Privacy Policy

1. Scope

This Privacy Policy describes how Iris Assistant, Inc., a Delaware corporation doing business as Persona ("Persona," "we," "us"), collects, uses, discloses and retains personal information in connection with Persona through text messaging (including SMS and iMessage), our websites and web-based services, any Persona mobile application, and other products, features and services we make available (collectively, the "Service").

2. Information We Collect

The information we collect depends on how you use Persona and which accounts, permissions and features you enable.

Account and communications information. Contact and account information; messages and other content you send to or receive through Persona; timestamps, delivery information, consent and opt-out records; and preferences and settings.

Connected accounts. If you connect email, calendar, messaging, contacts, files or another third-party service, we process information made available through that connection as needed to provide the Service. This may include message content and attachments, calendar events, contacts, files, account metadata, and credentials, tokens, cookies or session information needed to maintain access you authorize.

Device and permission-based information. Depending on the platform, permissions and features you use, we may collect device and usage information, IP address, approximate location, contacts, photos and files, precise or background location, microphone or camera information, notification tokens and similar technical information.

Calls and meetings. If you use calling or meeting features, we may process telephone numbers, participant and speaker information, call or meeting metadata, transcripts, summaries, action items and audio where recording or audio processing is enabled.

Tasks, browsing and transactions. We collect information about tasks Persona performs for you, including communications sent, calendar changes, browser activity, searches, bookings, orders, purchases and related transaction information. Where you authorize a purchase or payment, we may process payment-method information and transaction details needed to carry it out. Memory and inferences. Persona creates and maintains persistent memory from your conversations, connected accounts and prior tasks so it can act with context. This may include preferences, relationships, commitments, observations, summaries, embeddings and other inferences. Some of this information may be considered sensitive personal information under applicable law. Information about others. Because Persona may work with your communications, contacts, calls, meetings, photos and files, it may process information about people who are not Persona users. We may also obtain information from public web sources and third-party services when relevant to a task you ask Persona to perform.

3. Sources of Personal Information

We collect personal information directly from you; automatically when you use the Service; from devices and accounts you choose to connect; from people and businesses with whom Persona interacts at your direction; from service providers that support the Service; and from public sources and third-party services used to complete tasks you request.

4. How We Use Personal Information

We use personal information to:

• provide, personalize and operate the Service and carry out requests, permissions and standing instructions you authorize;
• read, organize, draft and send communications; manage calendars, reminders and tasks; place or participate in calls; browse and interact with third-party services; and complete bookings, purchases and payments;
• authenticate users, maintain connected-account access, build and use Persona memory;
• generate AI-assisted responses and actions;
• send service, transactional and informational communications and, where you consent, marketing and promotional text messages;
• secure, troubleshoot, analyze and improve the Service; prevent fraud and abuse; enforce our Terms; and evaluate quality and performance;
• measure advertising and marketing effectiveness without using the contents of your connected mail, messages, files or calls for advertising;

comply with law and establish, exercise or defend legal claims.

5. AI Processing

Persona uses artificial intelligence and related technologies to answer requests and carry out tasks. Depending on the task, information sent for AI processing may include your instructions, Persona memory and context, connected-account content, messages, transcripts, documents, images or audio. We use third-party AI and related service providers to help provide the Service. Those providers process information under their applicable contracts, terms, policies and technical configurations. We do not use your connected content to train our own general-purpose AI models. A third-party provider's permitted use may include service or model improvement or training unless a contractual, technical or legal restriction prohibits that use. Google and Microsoft user data is subject to the additional restrictions in Section 12.

6. Calls and Text Messaging

Calls. Persona may place or participate in calls at your direction and may call you where you enable or request calling features. Calls may use an artificial or AI-generated voice. We process the telephone numbers, call metadata, instructions, transcripts, summaries and other information needed to provide the feature. Audio recording occurs only where enabled. Persona provides automated-assistant disclosures where required by law.

Text messaging. We process your mobile number or messaging address, message content, timestamps, delivery and status information, and consent, opt-out and help records. We may send service, transactional and informational messages as described in our SMS Terms. If you separately consent to marketing, we may send recurring automated marketing or promotional messages. Marketing consent is optional and is not a condition of purchasing or using Persona. You may withdraw marketing consent as described in the SMS Terms, including by texting STOP where supported. We do not sell your mobile number or share it with third parties for their own marketing purposes.

7. Credentials, Browsing and Payments

Credentials and browsing. To act inside services you authorize, Persona may store passwords, access and refresh tokens, messaging sessions, cookies and other credentials or session information. Persona may operate a browser to complete tasks you request and may retain information about browser requests and responses as needed to complete, support and secure those tasks. If a feature you enable routes requests through your device or network, a third-party site may receive your network or IP address.

Purchases and payments. Where you enable purchasing or payment features, Persona may order, book, purchase and pay for products or services on your behalf using payment methods you provide or authorize. We and applicable payment providers or merchants may process payment-method, merchant, order, booking and transaction information as needed to complete and support the transaction.

8. How We Disclose Personal Information

We do not sell your personal information. We may disclose personal information:

• to service providers that help us operate the Service, including cloud hosting and storage, AI model and inference, telephony and messaging, speech-to-text, authentication and security, email delivery, web-search and browsing infrastructure, analytics and payment providers;
• to people and businesses Persona interacts with for you, to the extent needed to carry out your request;
• to authorized personnel where needed to operate, support, secure or investigate misuse of the Service;
• to government authorities or other parties where disclosure is required by law or reasonably necessary to protect rights, safety or security;
• to an acquirer, successor, affiliate or financing counterparty in connection with a financing, reorganization, merger, acquisition, sale of equity or assets, or similar transaction, subject to applicable law.

9. Advertising and Analytics

We collect usage and operational information to understand, secure and improve the Service and to measure marketing effectiveness. We may provide advertising or analytics providers with conversion events and hashed or otherwise permitted identifiers for attribution and measurement. We do not use the contents of your connected mail, messages, files or calls for advertising. Where applicable law treats an advertising or measurement activity as a sale, sharing or targeted advertising, you may exercise the applicable opt-out right through a control we make available or by contacting support@yourpersona.com. We honor legally recognized opt-out preference signals, including Global Privacy Control, where required by applicable law.

10. Retention, Disconnecting and Deletion

We retain personal information for as long as reasonably necessary to provide the Service and for legitimate business, security and legal purposes. Retention varies by category and may depend on whether your account remains active, whether information is held by a service provider, and applicable legal requirements.

Persona memory is persistent and does not expire or delete automatically. Disconnecting a connected account stops Persona from retrieving new information from that account but does not automatically delete information previously obtained or derived from it, including memories, summaries, embeddings and inferences.

You may request deletion of your Persona account or correction or deletion of specific personal information or memories through available Service controls or by contacting support@yourpersona.com. A complete account deletion is intended to remove Persona memory and other account-associated information through our deletion process, subject to legal, security, technical and service-provider retention requirements. Some information may remain temporarily or may be retained where permitted or required by law.

11. Security

We use reasonable technical and organizational safeguards designed to protect personal information, including encryption in transit, access controls and protections for stored credentials and tokens. No system is completely secure, and we cannot guarantee absolute security. Please report suspected security issues to support@yourpersona.com.

12. Google and Microsoft User Data

Persona's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. With respect to Google user data, we:

• use it only to provide or improve user-facing features of the Service;
• transfer it only as necessary to provide or improve those features, comply with applicable law, or as otherwise permitted by the Google API Services User Data Policy;
• do not use it for advertising, including retargeting or interest-based advertising;
• do not transfer, sell or use it to create, train or improve a generalized or personalized machine-learning or artificial-intelligence model;
• do not allow humans to read it except where permitted by the Google API Services User Data Policy.

We apply equivalent Limited Use commitments to data we obtain through Microsoft Graph where required by our applicable Microsoft commitments.

13. Your Privacy Rights

Depending on where you live and subject to applicable law and exceptions, you may have rights to access or know about personal information we process; correct or delete it; obtain a portable copy; withdraw consent; opt out of sale, sharing, targeted advertising or certain profiling; limit certain uses of sensitive personal information; and appeal a denied request. We will not unlawfully discriminate against you for exercising a privacy right.

To exercise a privacy right, contact support@yourpersona.com or use a privacy control we make available through the Service. We may verify your request by confirming control of the relevant account, telephone number or email address and may request additional information where reasonably necessary. An authorized agent may submit a request where permitted by law and with appropriate proof of authority.

14. U.S. State Privacy Disclosures

Depending on the features you use, categories of personal information we may collect include identifiers; customer-record information; commercial information; internet or other electronic network activity; geolocation information; audio, visual or similar information; professional or education information; communications content; and inferences. Sensitive personal information may include precise geolocation and the contents of communications where Persona is not the intended recipient. We collect personal information from the sources described in Section 3; use it for the purposes described in Section 4; and disclose it to the categories of recipients described in Section 8. We do not sell personal information. Where applicable law treats advertising measurement or similar activity as sharing, targeted advertising or a sale, the applicable opt-out rights described in Sections 9 and 13 apply.

15. Children

Persona is for users age 18 and older. We do not knowingly collect personal information directly from children as Persona users. Content an adult user authorizes Persona to process may incidentally contain information about children.

16. Changes and Contact

We may update this Privacy Policy as the Service changes. Where a change is material, we will update the effective date and provide any notice required by applicable law, which may be delivered through the Service, in an app, by email, by text message or by posting on our website. Questions, privacy requests and security reports may be sent to legal@yourpersona.com.

Iris Assistant, Inc. (d/b/a Persona) 801 S Miami Ave Miami, FL 33131 United States