Privacy Policy

Last updated: June 13, 2025

 

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words with initial letters capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Emotion Logic Ltd, 2 Ha’ofe street, Kadima, Israel.

For the purpose of the GDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to: Israel

Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.

Do Not Track (DNT) is a concept promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism allowing users to control tracking of their online activities across websites.

Personal Data is any information that relates to an identified or identifiable individual.

 – For GDPR: any information relating to You such as a name, an identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.

 – For CCPA: any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwisecommunicating a Consumer’s personal information to another business or third party for monetary or other valuable consideration.

Service refers to the Website and all provided services.

Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analyzing how the Service is used. For the purpose of GDPR, Service Providers are considered Data Processors.

Third-party Social Media Service refers to any website or social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to the Emotion Logic network of sites, accessible from www.emotionlogic.ai and/or its subdomains and reference sites, including the Emotion Logic hub portal, docker and cloud services under https://www.emlo.cloud, and any subdomains or branded URLs operated by Emotion Logic Ltd or its authorized partners providing access to the same services (such as feelgpt.emlo.cloud or regional subdomains). 

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personal Data may include, but is not limited to:

 – Email address

 – First name and last name

 – Phone number

 – Address, State, Province, ZIP/Postal code, City

 – Credit card information or Bank account information in order to pay for products and/or services within the Service

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device’s IP address, browser type, pages visited, time/date, time spent on pages, device identifiers, and other diagnostic data.

When You pay for a product and/or a service via bank transfer, We may ask You to provide additional identity and payment information as required by law (e.g., date of birth, national ID, or documents linking you to an address).

Information from Third-Party Social Media Services

The Company may allow You to create an account and log in to use the Service through the following Third-party Social Media Services:

  • Google
  • Facebook
  • Twitter
  • LinkedIn

 

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

 

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Information from Third-Party Social Media Services

The Company may allow You to create an account and log in to use the Service through Third-party Social Media Services including Google, Facebook, Twitter, and LinkedIn. If You register through or grant us access to a Third-Party Social Media Service, we may collect Personal Data associated with that account (such as name, email address, activities, or contacts).

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies (beacons, tags, scripts) to track activity on Our Service and store certain information. The technologies We use may include:

-Cookies or Browser Cookies

-Web Beacons

-Session and Persistent Cookies

Types of Cookies Used:

Necessary / Essential Cookies

-Cookies Policy / Notice Acceptance Cookies

-Functionality Cookies

-Tracking and Performance Cookies

 

We use analytics and tracking services including Google Analytics 4 (GA4), Google Tag Manager, Microsoft Clarity, and others to understand how users interact with our Website and EMLO.Cloud and to improve functionality and performance. We do not use these tools for advertising, cross-site tracking, or remarketing purposes.


A detailed list of cookies used is provided in the Appendix: Cookies Used section of this Privacy Policy.For more information about cookies and how to opt out, please visit our Cookies Policy or the Cookies section of this Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

-To provide and maintain our Service, including monitoring usage

-To manage Your Account and registration

-For the performance of a contract (including purchases)

-To contact You for notifications, support, or updates

-To provide You with news, offers, or marketing materials (unless you opt-out)

-To manage Your requests and customer support

-For business transfers (such as merger, sale, bankruptcy)

-For data analysis, usage trends, service improvement, and marketing evaluation

-For compliance with legal obligations and law enforcement requests

-For any other purpose with Your consent

Payments

We may provide paid products and/or services within the Service. In such cases, we may use third-party services for payment processing, including but not limited to:

  • Payoneer (for bank transfers): https://www.payoneer.com/legal/privacy-policy/
  • Cardcom (Israel): https://www.cardcom.solutions/%D7%A4%D7%A8%D7%98%D7%99%D7%95%D7%AA-%D7%9E%D7%93%D7%99%D7%A0%D7%99%D7%95%D7%AA/
  • Stripe: https://stripe.com/us/privacy
  • PayPal: https://www.paypal.com/webapps/mpp/ua/privacy-full
  • Alipay: https://render.alipay.com/p/f/agreementpages/alipayglobalprivacypolicy.html
  • Wise: https://wise.com/us/legal/privacy-policy
  • WePay: https://go.wepay.com/privacy-policy

 

We do notstore or collect your payment card details ourselves; they are handled directly by these payment processors under their respective privacy policies.

Sharing of Personal Data

We may share Your personal information in the following situations:

-With Service Providers (e.g., analytics, payment processing, customer support)

-With Affiliates (parent, subsidiaries, joint ventures)

-With business partners for co-branded services or promotions

-With other users, if you post content publicly

-In connection with business transfers (merger, acquisition, bankruptcy, etc.)

-As required by law or to protect rights, property, or safety

-With your consent

* We do not trade or sell client data to unrelated third parties.

Retention, Transfer, and Deletion of Data

We retain Your Personal Data only as long as necessary for the purposes set out in this Policy, to comply with legal obligations, resolve disputes, and enforce agreements.You may request deletion of your data at any time by contacting [email protected] or using account tools. We may need to retain certain information when legally obligated to do so.Your data may be transferred and processed outside your jurisdiction; we use safeguards such as Standard Contractual Clauses and EU–US Data Privacy Framework where required. Your consent to this Policy represents your agreement to such transfers.

Disclosure of Your Personal Data

We may disclose Your Personal Data:

-In connection with a business transaction (merger, acquisition, asset sale). Notice will be given if data is transferred and becomes subject to a different policy.

-To comply with a legal obligation, court order, or governmental request.

-To protect and defend the rights or property of the Company.

-To prevent or investigate possible wrongdoing in connection with the Service.

-To protect the personal safety of Users or the public.

-To protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us. While We strive to use commercially acceptable means to protect Your Personal Data, no method of transmission or electronic storage is 100% secure. We cannot guarantee its absolute security.

Your Rights under GDPR

If you are in the EU/EEA, you have the right to:

-Access, update, or delete your Personal Data

-Correct incomplete or inaccurate information

-Object to processing, request restriction, or withdraw consent

-Receive a copy of your data in a portable format

-Lodge a complaint with your local Data Protection Authority

You may exercise these rights by contacting [email protected]. We may ask You to verify Your identity before responding.

Your Rights under CCPA (for California Residents)

If you are a California resident, you have rights to:

-Be informed about data collection and use

-Request access, deletion, and portability of your data

-Opt out of the sale of your personal data

-Not be discriminated against for exercising your rights

Categories of Personal Information Collected/Disclosed/SoldWe may collect and/or disclose the following categories as defined by CCPA:

-Identifiers (e.g., name, address, email)

-Personal information underCal. Civ. Code § 1798.80(e)

-Commercial information (products/services purchased)

-Internet or other similar network activity

CATEGORYEXAMPLESSOURCEPURPOSERETENTIONSOLD/SHARED
IDENTIFIERSName, email, address, IPDirectly from userAccount, support, complianceAs neededNo
COMMERCIAL INFOPurchase history, transactionsDirect/user activityBilling, fraud preventionAs neededNo
INTERNET ACTIVITYPages visited, device dataCollected automaticallyAnalytics, security, troubleshootingAs neededNo
SENSITIVE DATAVoice samples, biometric data (see below)Directly from userService delivery, analyticsPer contractNo


We do not sell personal information of our Users.To exercise any of these rights, contact us at [email protected].

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect information from children under 13. If you believe we have collected such data, contact us and we will promptly delete it.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before collecting or using that information.

Voice Data and Processing on Behalf of Business Customers

As part of our services, including but not limited to FeelGPT, AppTone, and the Emotional Diamond Video Maker, we may process voice recordings and associated emotional analysis data (such as transcripts, emotion scores, and session metadata). This processing occurs only in the following contexts:

-When you, as a direct user of our services, provide such voice data yourself; or

-When we process voice data on behalf of our direct business customers (Licensees), for the purpose of analyzing interactions between the Licensee and its own customers, employees, or end-users who are interacting directly with the Licensee.

 

We do not support or permit the use of our services for the analysis of personal data from third parties who are not in direct interaction with the Licensee unless such data subjects have been properly informed and have given legally valid consent where required.

 

When processing personal data on behalf of a Licensee, we act as a Data Processor under GDPR. The Licensee is responsible for ensuring that personal data submitted to our services is collected and processed lawfully and transparently, and that all required notices and consents have been obtained.

Retention of voice data:

Voice recordings and associated data are retained strictly in accordance with theLicensee’s retention settings (as configured in their account), and are subject to automatic deletion policies after 12 months unless otherwise required by law.

Sub-processors:

We use reputable cloud service providers and sub-processors to deliver our services securely. Our core hosting is provided via AWS (EU), and selected services (such as Speech-to-Text and Large Language Model processing) may use Microsoft Azure, Deepgram, Speechmatics, or OpenAI, subject to appropriate data protection agreements, Standard Contractual Clauses (SCCs), or participation in the EU–US Data Privacy Framework.

Appendix: Cookies Used

COOKIE NAMESERVICEPURPOSEDURATION
_GCL_AUGoogle Tag Manager / AdsStores campaign/user interaction info~3 months
_GAGoogle Analytics 4 (GA4)Distinguishes users for analytics tracking2 years
_GA_0KJ9GXXBSGGoogle Analytics 4 (GA4)Stores session state & engagement metrics2 years
GOOGLE RECAPTCHA COOKIES (NID, CONSENT)Google reCAPTCHA v3Bot protection and user validationSession or varies
_CLCKMicrosoft ClarityStores Clarity user ID & preferences1 year
_CLSKMicrosoft ClarityConnects page views into single session recording1 day

Automated Decision-Making and Profiling

Emotion Logic services, including FeelGPT and AppTone, use AI and statistical models to analyze voice and generate insights.No decisions with legal or similar effect are made automatically—all results are reviewed by a human or explained in full transparency. AI is used to interpret LVA (non-AI) results and present them in user-friendly terms. Users can request human intervention, contest any output, and obtain further explanation.

International Data Transfers and Safeguards

Personal data may be processed outside your country.We ensure transfers comply with GDPR and other applicable law using Standard Contractual Clauses, the EU–US Data Privacy Framework, and equivalent measures. For details, contact [email protected].

Exercising Your Rights

You may exercise your data protection rights at any time by emailing [email protected] provide enough information for us to verify your identity. We will respond within 30 days. If additional time is needed, we will inform you.

Supervisory Authority (EU/UK)

If you are in the EEA, Switzerland, orUK, you may lodge a complaint with your local Data Protection Authorit

Marketing and Newsletter Opt-Out

You may opt out of marketing emails at any time by clicking the unsubscribe link in any message, or by contacting [email protected]

Biometric and Special Category Data

We may process special categories of personal data as defined by applicable laws, including biometric data such as voice recordings, when such data is provided as part of our services (including emotion analysis, risk assessment, and compatibility insights).

  • Purpose: This data is used solely for providing our services, improving accuracy, and fulfilling contractual obligations.
  • Legal Basis: Where required by law (such as under GDPR), we process such data only with your explicit consent or as necessary for the establishment, exercise, or defense of legal claims.
  • Security: All biometric and special category data is handled with heightened security, is not used for unrelated purposes, and is never sold or disclosed except as required to deliver the service or by law.
  • Your Rights: You have the right to withdraw consent at any time and to request deletion or restriction of processing of your biometric or special category data by contacting [email protected]

Version and Changes

This Privacy Policy replaces all previous versions. Changes will be posted to this page and, where material, users will be notified via email or prominent notice.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, contact us at:[email protected]