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Whisperstream 1.6.x privacy policy

The privacy policy for Whisperstream 1.6.x and earlier. Version 1.8.1, effective October 26, 2026. This is the same text included with Whisperstream 1.6.2. The 1.6.x license agreement is on its own page.

WHISPERSTREAM PRIVACY POLICY
============================

Version 1.8.1

Effective 2026-10-26

Last updated 2026-10-26

This Privacy Policy explains how Lanreal Technologies Inc.
("Lanreal," "we," "us," or "our") collects, uses, shares, and
retains personal information in connection with the private edition
of the Whisperstream desktop application for Microsoft Windows (the
version 1 line, the "Software"). It also describes the rights you
have with respect to that personal information and how to exercise
them. By installing and using the Software, you acknowledge that you
have read and understood this Privacy Policy.

1. INTRODUCTION AND SCOPE
=========================

Whisperstream is a local, on-device dictation application for
Microsoft Windows. It captures microphone audio when you press a
push-to-talk hotkey, transcribes that audio on your own computer
using a speech recognition model that runs entirely on your CPU, and
types the resulting text into the focused window. The Software keeps
your voice recordings and your transcribed text on your device. The
only personal information that leaves your device by default
consists of narrow operational metadata (an IP address, standard
HTTP headers, and the requested file or manifest address) sent for
software update checks to Cloudflare and the required first-run
model download from Hugging Face (or, as a backup, GitHub) (see
Section 3). This version of the Software has no trial, does not
contact Polar, and cannot activate, validate, or deactivate a
license. Additional data may leave your device when you select an
optional model; open the Enhancement page, which can request the
cloud-model list for optional cloud cleanup; open the website's
download page in your browser; send feedback or a Featurebase
request; deliver text to a destination application; or enable
optional cloud cleanup. Imported audio remains local, although its
resulting transcript may enter cloud cleanup if you enabled it.
Agent Speak exchanges content with Claude Code or Codex over the
local loopback interface; the coding agent separately controls any
transmission to its configured model provider. Each flow is
described in detail in this Privacy Policy.

This Privacy Policy covers the private edition of the Whisperstream
desktop application only. The separate open-source edition of
Whisperstream has its own privacy policy, which governs that edition
if you install it (Section 3.2). This Privacy Policy does not cover
the marketing website at whisperstream.io, which is governed by a
separate website privacy notice published at
https://whisperstream.io/privacy-website. If you reached this
document from the marketing site, please refer to the website
privacy notice for information about how the site itself is
operated.

This Privacy Policy also does not cover your relationship with Polar
Software Inc., the Merchant of Record that handled the purchase of
Whisperstream licenses. Lanreal no longer sells licenses. When you
bought a license, Polar separately collected your email address and
payment information through its own checkout flow, and Polar
continues to process records of that purchase and of any refund as
Merchant of Record. That information is governed by your
relationship with Polar and by Polar's own privacy policy at
https://polar.sh/legal/privacy; it is not transmitted by the
Software and is not covered by this Privacy Policy, except as
described in Sections 3.1, 3.13, and 5.

In this Privacy Policy, 'personal information' means information
about an identifiable individual, encompassing 'personal data' as
defined by the GDPR (Article 4(1)), 'personal information' as
defined by the CCPA (Cal. Civ. Code s.1798.140(v)), and 'personal
information' as defined by Canadian federal privacy law (s.2(1)).

2. WHO WE ARE
=============

The data controller responsible for the personal information
described in this Privacy Policy is:

Lanreal Technologies Inc. 18 King Street East, Suite 1400 Toronto,
Ontario M5C 1C4 Canada

Lanreal is a corporation incorporated under the Business
Corporations Act (Ontario). Our registered office is in the Province
of Ontario, and our operations are governed by Canadian federal and
provincial law applicable therein.

Privacy Officer designation. In accordance with Canadian federal
privacy law (the Personal Information Protection and Electronic
Documents Act), Lanreal Technologies Inc. has designated a Privacy
Officer responsible for compliance with this Privacy Policy. The
Privacy Officer can be contacted at support@whisperstream.io.
Throughout the remainder of this document, "Canadian federal privacy
law" refers to the statute named above.

Under the European Union General Data Protection Regulation (GDPR),
Lanreal is the "controller" of the personal information described in
this Privacy Policy. Under the California Consumer Privacy Act
(CCPA), Lanreal is a "business" that collects personal information
about California residents through the Software.

All privacy-related communication, including data subject rights
requests, complaints, and general questions about this Privacy
Policy, should be directed to support@whisperstream.io. This is
Lanreal's single privacy contact channel for the Software.

EU Representative. Lanreal is in the process of designating a
representative in the European Union in accordance with Article 27
of the General Data Protection Regulation. Until a representative
has been designated, individuals in the European Economic Area may
direct any questions or requests relating to the processing of their
personal data under the GDPR to Lanreal directly at
support@whisperstream.io. This policy will be updated with the
representative's contact details once the designation is complete.

3. INFORMATION WE COLLECT
=========================

The Software is intentionally narrow in the information it handles.
This section enumerates every category of information associated
with your use of the Software, in the order in which the underlying
network activity happens.

3.1 License records from earlier versions
-----------------------------------------

This version of the Software makes no license activation,
validation, revalidation, or deactivation request and does not
contact Polar. It cannot activate a license key. Earlier versions
may have saved a license key, an activation identifier, and the
customer name and email address returned by Polar in the protected
local record described in Section 3.9. This version keeps that
record on your device, does not display those values, does not send
them to Lanreal or anyone else, and does not use them for feedback
(Section 3.5 uses the email address you enter).

Earlier versions sent your license key, the Whisperstream
organization identifier, your operating system family, and your
device hostname to Polar's license-key API when you activated a
license, and the license key, organization identifier, and
activation identifier when they validated or deactivated it. Polar
may still hold those records on Lanreal's behalf (see Sections 5 and
8). Polar also continues to process historical purchases and refunds
as Merchant of Record, as described in Section 5 and in Polar's own
privacy policy.

3.2 Update checks
-----------------

Updates to this version line. The Software requests the file at
https://releases.whisperstream.io/latest.json to determine whether a
newer release in this version line is available. The request is a
standard HTTPS GET request to a Cloudflare-hosted endpoint. No
device identifier, Whisperstream application version number, or
other identifying data is sent in the request URL, headers, or body
beyond the standard Accept and User-Agent headers automatically
added by the underlying HTTP library (including your IP address as
seen by the update server). Specifically, the headers are
User-Agent: tauri-plugin-updater/<crate-version> and Accept:
application/json. If you choose to install an update, the installer
download carries the same User-Agent header, Accept:
application/octet-stream, and the connection data visible to
Cloudflare.

When checks occur. The Software attempts an automatic check when it
starts, when its window gains focus, and on an hourly timer, but it
sends no more than one automatic request every 24 hours, backing off
to no more than one every seven days after repeated failures. You
can also check manually from the About page. Checks require
acceptance of the current End User License Agreement and completed
setup, and they do not run while Lockdown Mode is on, whether you
turned it on or your organization manages it.

Your choices. There is no general setting to turn off update checks.
If you decline an amendment to the End User License Agreement, the
Software records that decision in update-opt-out.json in its
application-data directory and suspends automatic update checks for
thirty (30) days; manual checks remain available. Turning on
Lockdown Mode also stops update checks.

The open-source edition. This version does not check the open-source
edition's update channel, show or record acceptance of its terms, or
download or install it. The Software may show a link to
https://whisperstream.io/download. If you choose it, the page opens
in your web browser, and the website's own privacy notice, published
at https://whisperstream.io/privacy-website, governs that visit and
any information the page asks you to provide. If you install the
open-source edition, its own privacy policy governs its processing,
including of the local data that remains on your device.

Update manifests and installers are cryptographically signed using
the minisign signing scheme, and the Software verifies the signature
locally on your device before installing any update. Although the
request headers themselves do not identify you, the update server
sees your IP address as part of the underlying network connection.
Under the GDPR, IP addresses may constitute personal data (see
Section 4 for the lawful basis applicable to this processing).

3.3 Speech-recognition model download data
------------------------------------------

During setup, or after you select a language or speech-recognition
engine, the Software downloads the required model if it is not
already installed. Parakeet, Qwen, and Cohere model files use pinned
public Hugging Face URLs. Requests can redirect through Hugging
Face's file-delivery infrastructure, including its Xet and
content-delivery hosts. For Parakeet v2 and v3, Qwen, and Cohere, if
the Hugging Face source is unavailable, the Software tries the
matching upstream sherpa-onnx release archive at github.com and
release-assets.githubusercontent.com. The archive is verified
against a packaged checksum before extraction, and required files
are verified before installation. Cancellation, disk, integrity, and
download-policy failures do not trigger a backup. The serving hosts
receive your IP address, ordinary HTTP headers including the
download library's User-Agent, and the requested URL, which
identifies the model.

These public downloads connect directly from your device to the
upstream file hosts and their delivery infrastructure. They do not
use your browser session or import your browser cookies or Hugging
Face token cache. A delivery host may set cookies within the
download client's own connection session. The Software does not
attach a Hugging Face authentication token, Lanreal account
identifier, license key, device identifier, microphone audio,
transcript, generated speech, or cloud-provider API key to these
requests. Each file is verified locally against a pinned size and
cryptographic checksum before installation. The local model catalog
is packaged with the Software; this version does not request a
model-file manifest or model files from Lanreal's former
model-distribution service. Already installed compatible models
remain usable without a replacement download. The Software keeps
local, content-free diagnostic events about downloads (such as the
model identifier and whether Hugging Face or GitHub served it) and
does not upload them automatically.

Cohere Transcribe performs speech recognition on your device. Its
model URL identifies the Cohere artifact, but your selected language
remains local and is not included in the request. No audio or
transcript is sent to Cohere, Hugging Face, GitHub, Lanreal, or
Cloudflare for speech recognition. Optional cloud cleanup is
separate (Section 6). Model-host roles and international transfers
are described in Sections 5 and 7.

3.4 Data that stays on your device
----------------------------------

The following information is handled on your own computer and is not
transmitted to Lanreal. User-directed delivery to a destination
application and the optional outbound flows identified below are the
specific exceptions to local-only handling:

- Audio recordings. Microphone audio is held in random-access memory
  while each push-to-talk capture is transcribed on your CPU, and is
  never uploaded to any server. If you keep the local transcript
  history enabled with audio saving on (both are on by default, and
  both can be turned off), a copy of the recording is also stored,
  encrypted, on your own device, as described in the "Local
  transcript history" entry below. No audio data is ever transmitted
  off your device.

Voice data is not biometric data. The speech recognition model
processes your voice solely to convert speech into text. It does not
create a voiceprint, does not perform speaker identification or
authentication, and does not extract or store any biometric
identifier from your voice. Under the GDPR (Article 9), biometric
data is subject to enhanced protections only when processed for the
purpose of uniquely identifying a natural person. Because the
Software processes voice exclusively for transcription and not for
identification, the voice data handled by the Software does not
constitute biometric data within the meaning of Article 9.

- Transcribed text. The text produced by the speech recognition
  model is typed into the window you have focused. If you keep the
  local transcript history enabled (it is on by default and can be
  turned off), the transcribed text (both the raw transcript and, if
  you use the optional AI cleanup feature, the enhanced version) is
  also stored, encrypted, on your own device, as described in the
  "Local transcript history" entry below. Transcribed text is never
  transmitted to Lanreal or retained by Lanreal in any form.
- Local transcript history. The Software keeps a searchable history
  of your past dictations on your own device so that you can review,
  copy, and replay them. This history is enabled by default and can
  be fully disabled. It stores your transcribed text (the raw
  transcript and, where you used AI cleanup, the enhanced version)
  and, when audio saving is enabled, the recorded audio. The
  transcribed text and the audio are encrypted at rest using
  AES-256-GCM. The AES key is itself sealed using the Windows Data
  Protection API, bound to your Windows user account on the specific
  device, so the history can be opened only by the same Windows user
  on the same device. The raw transcript, enhanced transcript, saved
  audio, and waveform peaks used by the player are encrypted
  separately. Lightweight index metadata (such as a record
  identifier, timestamp, duration, model name, source type, and
  relative audio-file location) is stored unencrypted so the list
  can be sorted and displayed without decrypting its content. The
  history is kept inside your Windows user profile under
  %LOCALAPPDATA%\Whisperstream\ (a transcripts.db index and a
  recordings\ folder). Nothing in the history is ever transmitted
  off your device. You control it: a master "Save transcripts"
  toggle and a separate "Save audio" toggle let you keep a text-only
  history or turn history off entirely, and a retention window (1,
  7, or 30 days, or forever, with 7 days as the default)
  automatically removes older entries. You may also delete an
  individual entry or clear the entire history at any time. See
  Section 8 for retention and deletion details.
- Local diagnostic logs. In ordinary use, voluntary Lockdown Mode,
  and administrator-managed Lockdown Mode, the Software writes
  content-free operational events to a local whisperstream.log file
  under %LOCALAPPDATA%\Whisperstream\logs\. The active file and up
  to three backups are each limited to approximately 2 MiB. The
  Software excludes transcript, voice/audio, and Agent Speak
  content; passwords; recovery codes; API, transcript-encryption,
  and license keys or secrets; full email addresses; foreground
  process identity; imported-audio filenames and paths; browser
  hosts; and raw error text that could carry user content. Each
  application window also keeps a bounded in-memory frontend log
  buffer (up to 500 entries, 2 KiB per entry, and 128 KiB total).
  The backend re-sanitizes synchronized frontend entries and keeps
  at most 128 KiB across windows in process memory. A supplemental
  Lockdown diagnostic file accepts only code-defined event and field
  names, retains at most 256 events and 128 KiB, and contains no
  arbitrary user-supplied strings. These logs are never transmitted
  automatically. Lockdown does not pause, clear, or disable the
  diagnostic log, frontend capture, or support export.
- Usage statistics. The Software keeps aggregate counters of how
  many transcriptions you have run, how many words you have
  transcribed, and how much recording time you have accumulated.
  These counters are stored locally in your Windows user profile and
  are never transmitted.
- Configuration. Your settings, including your chosen hotkey, audio
  device, and word-override dictionary, are stored locally in a
  configuration file under your Windows user profile and are never
  transmitted.
- Lockdown access log. While Lockdown Mode is effective, the
  Software keeps a separate content-free access log that records the
  time and an allowlisted operation type for transcript-history
  access and Lockdown state changes, together with a sanitized short
  record identifier when applicable. It never records transcript or
  audio content, your password or recovery code, or health
  information. The active access.log file and up to five backups are
  each limited to approximately 2 MiB. This audit log is stored only
  under %LOCALAPPDATA%\Whisperstream\logs\, is not included in
  support exports, and is not created for ordinary transcript
  operations outside Lockdown Mode.

Lanreal does not automatically receive the local stores described in
this Section 3.4. Particular content may nevertheless leave your
device through a separate, user-directed flow described elsewhere in
this Policy: finished text is delivered to the destination
application under Section 3.10; a transcript may be sent to the
cloud-cleanup provider you configure under Section 6; an Agent Speak
reply is returned to Claude Code or Codex under Section 3.11; and
feedback or Featurebase content is sent only when you submit it
under Sections 3.5 and 3.12. Those recipients control their own
copies under the terms identified in the applicable section. If you
choose to download a diagnostic archive, the backend builds it in
memory and streams it to the destination you select; it does not
write an app-managed ZIP file. That downloaded copy is under your
control. If you then send it to Lanreal as part of a bug report (for
example, by attaching it to an email to support@whisperstream.io),
Lanreal processes the information you send to diagnose the issue as
correspondence under Section 3.13 and retains it as described in
Section 8.

A summary of the categories above, mapped to the CCPA categories of
personal information, is provided in Section 13 of this Privacy
Policy.

3.5 Feedback and earlier ratings and testimonials (voluntary)
-------------------------------------------------------------

Private feedback in this version. You can choose to send private
feedback from the Software's About page. When you send it, the
Software transmits the feedback text you typed, the email address
you entered in the feedback form, the Whisperstream application
version, and the standard HTTP headers automatically sent to
Supabase, including your IP address as seen by Supabase, to
Lanreal's feedback database hosted by Supabase. The Software does
not fill in the email address from a license record.

No ratings in this version. This version does not show the automatic
rating prompt and does not ask for or submit star ratings, so it
does not offer the external review destinations that earlier
versions showed after a five-star rating.

The Software does not transmit your transcribed text, voice, device
hostname, operating system, usage statistics, configuration, or
license key as part of a feedback submission. Lanreal uses submitted
feedback to improve the Software and respond to you. Supabase stores
these submissions in the United States. Lanreal retains them until
you request deletion as described in Sections 8 and 10.

Earlier ratings and written testimonials. Earlier versions of the
Software let an activated Pro user submit a one-tap star rating
together with the customer email received from Polar and the
application version, and, in some earlier versions, testimonial
text, a display name, and a separate consent flag permitting Lanreal
to display the testimonial and display name publicly on the
Whisperstream website. References elsewhere in this Privacy Policy
to ratings and to those testimonial fields and that public-display
consent apply to records collected through those earlier versions.
When an earlier version opened G2 or AlternativeTo after a five-star
rating, that site received ordinary browser and connection data
under its own privacy policy.

If you do not send feedback, nothing is transmitted to Supabase
under this Section.

3.6 Lockdown Mode (optional hardening)
--------------------------------------

Lockdown Mode is an optional setting you can turn on to harden the
Software for privacy-sensitive and HIPAA-conscious workflows. It is
off by default. Lockdown Mode is designed to support HIPAA-conscious
workflows; it is not a HIPAA certification, it does not make the
Software HIPAA compliant, and it does not replace your own
compliance obligations. When Lockdown Mode is on:

- AI cleanup runs on your device only. The cloud providers and
  self-specified endpoints described in Section 6 are disabled, and
  AI cleanup is forced to the on-device model, so Whisperstream does
  not send that transcript to a configured cleanup provider.
- Your transcript history is locked behind a password. A key derived
  from a password you choose additionally wraps the transcript
  encryption key, on top of the AES-256-GCM encryption at rest and
  the Windows Data Protection API sealing already described in
  Section 3.4 (see Section 12 for the details). A one-time recovery
  code is created when you turn Lockdown Mode on and is the only
  other way to unlock your history. The history locks again
  automatically after an idle period you set, and repeated failed
  unlock attempts trigger escalating delays.
- Or you can choose to save nothing. Instead of a password-protected
  history, you may turn Lockdown Mode on without saving transcripts
  at all, in which case no transcript history is written to your
  device.
- Safe diagnostic logging remains available; the content-free access
  log is separate. The bounded local diagnostics described in
  Section 3.4 remain active so you can troubleshoot problems and
  prepare a useful bug report. The separate local access log records
  allowlisted transcript-history and Lockdown operations (never
  their content) and is not included in support exports.
  Whisperstream never uploads either log automatically.
- Agent Speak is disabled. Whisperstream clears active Agent Speak
  state and does not accept new Claude Code or Codex events (Section
  3.11).
- Update checks stop. The update checks described in Section 3.2 do
  not run.

Data-loss warning. Your Lockdown Mode password and your recovery
code are held only on your own device. Lanreal never receives your
password, your recovery code, or your transcripts. If you set a
transcript password and lose both your password and your one-time
recovery code, you will not be able to unlock your transcript
history through the Software, and Lanreal cannot unlock or recover
it for you. There is no Lanreal-side backup. The Software offers a
destructive reset that removes the still-locked transcript history
through ordinary database and file deletion and turns off Lockdown
Mode; it cannot restore the old records or securely overwrite the
storage device.

In Lockdown Mode, Whisperstream's audio, transcription, history, and
AI cleanup pipeline stays on your device and Lanreal never receives
that content. Lockdown Mode does not prevent the text from being
delivered to the destination application you selected. It disables
Agent Speak in Whisperstream, but it does not close Claude Code or
Codex or control their provider connections. Those destinations
handle data under their own terms. Section 14 of the Whisperstream
End User License Agreement sets out the related disclaimers,
including that Lockdown Mode is not a HIPAA certification and that,
for this on-device workflow, Lanreal is not a business associate and
there is no Business Associate Agreement to sign. Turning Lockdown
Mode off and choosing a cloud AI provider would send transcribed
text to that provider and change this; Lockdown Mode blocks the
cloud providers to keep the Whisperstream pipeline on your device.

3.7 Optional voice feature model downloads
------------------------------------------

Whisperstream includes an optional voice feature that reads an
artificial-intelligence coding assistant's text replies aloud on
your device. The feature is off by default and does nothing until
you turn it on.

If you enable it, the Software downloads the Voice Model or Voice
Models needed for your selected or automatically resolved engine
from pinned Hugging Face repositories through Hugging Face's
file-delivery infrastructure. The Supertonic files come from a
public third-party repository; the Kokoro archive comes from a
Hugging Face repository operated by Lanreal. No spoken text,
generated audio, license key, account information, or device
identifier is put in the request. The request includes standard HTTP
headers automatically added by the underlying download library,
including a User-Agent, and your IP address is visible to Hugging
Face and its delivery infrastructure as part of the ordinary network
connection. Each downloaded file or archive is verified against a
cryptographic checksum built into the Software before it is
installed.

The Voice Models run entirely on your device. The Software does not
transmit the text sent to the Voice Models or the audio they
generate off your device for speech synthesis. Lanreal does not
receive that text or audio and sends no separate feature-use
telemetry. The model host can retain the ordinary access-log record
described in Section 8, which can show that a model-specific file
was requested. Turning the feature off stops the Software from using
the Voice Models. You can remove a downloaded model from your device
by deleting its applicable model directory under
%LOCALAPPDATA%\Whisperstream\models\. If you selected a custom model
storage location, delete the corresponding models or local-llm
directory from that custom location instead.

The available Voice Models have different third-party license terms.
Kokoro 82M is distributed under Apache License 2.0 and is not
subject to the behavioural use restrictions described below. If you
download, enable, or use Supertonic 3, your use of that model is
subject to its OpenRAIL-M behavioural use restrictions. Those
restrictions are set out in Section 27 of the Whisperstream End User
License Agreement and reproduced in full in the
THIRD_PARTY_LICENSES.txt file bundled with the Software.

3.8 Optional on-device AI cleanup model download and cloud-model list
---------------------------------------------------------------------

If you select on-device AI cleanup and its Gemma model is not
already installed, the Software downloads the pinned model file from
Hugging Face and its file-delivery infrastructure. The request
contains your IP address and standard HTTP headers, and the
requested URL identifies the selected model to Hugging Face. The
Software does not include transcript text, a license key, account
information, or a device identifier in the model request. The model
is verified locally before installation and then processes
transcribed text entirely on your device.

Curated cloud-model list. When you open the Software's Enhancement
page while a cloud provider is selected for optional cloud cleanup
(Section 6), or when you choose a cloud provider, the Software may
request Lanreal's curated list of supported cloud models from
https://models.whisperstream.io/cloud-models.json, hosted on
Cloudflare. A cloud provider is selected by default, so opening that
page can make this request even if you have not enabled or
configured cloud cleanup. The request contains your IP address and
standard HTTP headers, including Accept: application/json, and no
transcript text, provider credential, license key, or device
identifier. The Software keeps the last valid copy in
cloud-models.json in its application-data directory and otherwise
uses the list included with the Software. While Lockdown Mode is on,
cloud providers are unavailable and this list is not requested for
them.

3.9 Earlier license records and acceptance state stored on your device
----------------------------------------------------------------------

Earlier license and trial record. This version of the Software has
no trial and needs no activation. Earlier versions stored a license
and trial record for the current Windows user, in a packaged Windows
build in the registry under HKCU\Software\Whisperstream and in
development builds in a local file. That record can include a trial
start time, a granted trial extension end date, the latest time
observed for clock-rollback protection, and activation status. If an
earlier version activated a license on the device, it may also
include the license key, activation identifier, activation or last
validation time, and the customer name and email returned by Polar.
A keyed HMAC, derived from your Windows account name and the
device's hostname, detects modification but does not encrypt the
record.

This version never creates, rewrites, or deletes that record. On
your device only, it reads the record to find whether it shows an
activation, shows none, or cannot be verified, and uses that result
only to choose the wording of a notice about the open-source
edition. It does not read your license key, name, or email for this
purpose, and the result does not affect what the Software lets you
do. The result is not sent to Lanreal or anyone else. The local
diagnostic log records only that coarse result, and logs leave your
device only if you export and send them. The record remains until
you remove the registry value or the application data as described
in Section 8.

No trial checks. This version makes no trial-extension policy
request. The trial_policy_checks_enabled setting, if present in
config.toml, has no effect. A trial-policy-refresh.json file saved
by an earlier version may remain in the application-data directory;
this version does not read or write it, and you can delete it.

Acceptance records. The Software separately stores local records of
the EULA version and content hash you accepted, the acceptance time,
the Software version, the type of acceptance event, and any
cloud-processing consent. EULA acceptance evidence is kept in an
append-only local ledger: accepting a later agreement updates the
current acceptance fields while preserving earlier exact acceptance
records in the same file. These records are used to identify the
current legal notice and consent state. They are not sent to
Lanreal.

3.10 Imported audio, app/site routing, and text delivery
--------------------------------------------------------

When you import audio, the Software reads and decodes each file in
place, transcribes it on your device, and stores the resulting entry
under the same history settings as a microphone dictation. The
selected path is used only while the import is active; its base
filename may be shown in the active progress interface but is not
written to diagnostics. The Software does not modify, delete, or
make a plaintext path-based copy of your source file. If cloud AI
cleanup is enabled, the resulting transcript may be sent to the
provider you selected under Section 6. The imported audio itself is
not uploaded.

Foreground and browser information is read only when a configured
app or site rule, manual route, Pin Mode, or destination-delivery
operation can use it. App routing uses local process identity. A
configured browser site rule may cause the Software to read only the
normalized active host from a supported browser's address bar; it
does not collect the full URL through this route. Pin Mode keeps the
selected window handle and process identifier in bounded process
memory for activation. No foreground or host probe is performed when
routing cannot affect the current operation. These transient values
are not written to diagnostics or sent to Lanreal. The app paths and
host rules you choose to save remain in your local settings.

When you choose a site-routing rule, the Software may read matching
favicon data from the local Chrome, Edge, or Firefox favicon
database to display the rule. It first uses a read-only database
connection. If the browser has locked that database, it may create
an attributable copy in the operating-system temporary directory.
The Software closes the copy and makes up to three ordinary deletion
attempts after use. At startup and before creating another owned
copy, it also tries to remove only attributable Whisperstream copies
older than 24 hours. A copy can remain longer after a crash or
repeated deletion failure; the Software does not broadly delete
older unattributable browser-database copies. It does not send the
database, host, or favicon to Lanreal or a network favicon service.

Whisperstream delivers finished text to the focused or pinned
destination application using a clipboard paste or simulated
keystrokes. The destination application then receives and controls
that text under its own privacy and retention practices. Lockdown
Mode does not prevent this user-directed delivery.

3.11 Agent Speak and coding-agent interactions
----------------------------------------------

Agent Speak provides optional, default-off connections to Claude
Code and Codex. When enabled, Whisperstream's local plugins forward
supported response text, permission context, short replies,
session-scoped identifiers, and a sanitized session name to the
Software's loopback-only backend so the local HUD can display,
speak, or answer them. Claude Code also supports structured
questions and options; Codex does not provide that question flow.
Enabling one provider does not enable the other. When response
display is disabled, the raw response is not sent to the HUD,
although local speech or reply routing may still use it. Interaction
content is not automatically sent to Lanreal.

The Software keeps active Agent Speak content in bounded process
memory and does not write hook payloads, content-derived
fingerprints, paths, session identifiers, or interaction content to
diagnostic logs or support exports. Questions expire after
approximately 15 seconds if they are not answered. Delivered
decisions are discarded, and retained reply drafts expire after
approximately 120 seconds and are subject to count and size limits.
Optional managed terminal sessions (started with whisperstream
claude or whisperstream codex) can retain the selected session's
response and a reply draft while that session remains registered.
Completion acknowledgement, disconnecting the applicable provider,
Lockdown Mode, or shutdown clears the applicable active state and
bounded caches. The coding agent's own files and terminal session
are separate and may remain.

To resolve an active display name, Whisperstream may reduce a
working directory immediately to its base name or read a limited
tail of an eligible local coding-agent transcript file. A project
base name can itself be sensitive; it remains bounded active display
state and is not logged or exported. Local discovery and
managed-session capability files contain connection details,
including a per-run token, while the feature is enabled. They are
not content archives. Processes running as your Windows user may
read them; this is not isolation from other same-user processes.

A reply you dictate through Agent Speak passes through
Whisperstream's ordinary local dictation pipeline. If "Save
transcripts" is on, that reply is stored as an agent_reply history
entry with the same encrypted content and retention controls as
other saved dictations. Other coding-agent interaction content is
not written to transcript history. Whisperstream does not
automatically send these local records or interaction content to
Lanreal.

Agent Speak does not control how Claude Code or Codex sends prompts
or receives responses from Anthropic, OpenAI, or another provider
you configured in that coding agent. That provider interaction
occurs outside Whisperstream and is governed by your coding-agent
and provider terms. While Lockdown Mode is on, Whisperstream
disables Agent Speak, clears its active state, and does not accept
new coding-agent events, but it does not close Claude Code or Codex
or change their own network behavior.

3.12 Feature requests on Featurebase
------------------------------------

If you choose "Request a feature on Featurebase," the Software opens
Lanreal's external feedback board in your browser. Whisperstream
does not automatically send transcript content or other application
data to the board. Information you choose to submit there may
include a feature request, messages, attachments, contact or account
identifiers, votes, and standard service-usage data. Lanreal uses
submissions to evaluate, respond to, and plan product improvements.
Do not include dictation content, sensitive personal information, or
GDPR Article 9 special-category data. If Lanreal becomes aware that
a submission contains such information, Lanreal will delete or
restrict it as reasonably practicable, subject to any legal
retention obligation. Featurebase's role is described in Section 5.

3.13 Correspondence, refunds, and privacy requests
--------------------------------------------------

If you contact Lanreal, for example at support@whisperstream.io, we
receive the contact details, message, and any attachments you choose
to send, including any diagnostic archive you choose to attach.
Refund handling can also involve the relevant purchase, payment, and
refund status from you or Polar. Lanreal has chosen to issue
voluntary goodwill refunds of Pro purchases at its discretion (EULA
Section 8). If a goodwill refund cannot be made through Polar, we
may use the email address from your purchase record to contact you,
and the payment details you choose to give us to pay it another way.
If you tell us you do not want a refund, we keep a record of that
choice. We use this information to address your request, handle
refunds, perform surviving obligations, and resolve related claims.
Do not send API keys, passwords, or unnecessary sensitive content.
Local diagnostic exports are not automatically uploaded or sent to
AI tools.

We use Gmail and Resend for email, and OpenAI Codex and Anthropic
Claude to help review correspondence and prepare replies. This can
make the messages and attachments supplied for that purpose
available to those providers. Their processing, retention, and
model-improvement practices depend on the applicable account terms
and settings. This support workflow is separate from the Software's
optional cloud post-processing feature and its provider consent.
Contact support@whisperstream.io about our handling of
correspondence.

4. WHY WE PROCESS YOUR INFORMATION
==================================

This section explains, for each category of information described in
Section 3, the purpose for which Lanreal processes that information
and the corresponding lawful basis under GDPR Article 6. A lawful
basis for processing does not itself establish an
international-transfer mechanism; see Section 7.

- Update-check data. The purpose of the update checks is to let the
  Software determine whether a newer release in this version line is
  available, and to verify the integrity and authenticity of any
  installer before it is installed. As described in Section 3.2, the
  update server sees your IP address as part of the underlying
  network connection. The lawful basis for this incidental
  processing of your IP address is GDPR Article 6(1)(f), Lanreal's
  legitimate interest in delivering signed, authenticated software
  updates to protect the security and integrity of the Software.
- Model-download connection information. For public Hugging Face and
  GitHub downloads described in Sections 3.3, 3.7, and 3.8, the
  Software contacts the file host directly when a required or
  selected model is missing. Those hosts collect connection
  information from your device and determine their own purposes and
  legal bases under their policies. Lanreal supplies the download
  tool and selects verified model files; it does not engage these
  hosts to process customer records on its behalf. To the extent
  Lanreal's choice of these sources requires an Article 6 basis, it
  is Article 6(1)(f), Lanreal's legitimate interest in providing the
  speech-recognition model the Software requires and the optional
  models you ask the Software to enable. Installed local models do
  not require recurring model-host communication for inference.
- Curated cloud-model list. The purpose is to show an up-to-date
  list of supported models when you configure optional cloud
  cleanup. The lawful basis for the incidental processing of your IP
  address by Cloudflare is Article 6(1)(f), Lanreal's legitimate
  interest in keeping that list accurate without an application
  update.
- Local product data and state. The local information described in
  Sections 3.4 and 3.9 to 3.11 is processed by the Software to
  provide the features you request, choose the wording of the
  open-source edition notice from an earlier version's record, route
  dictation, and preserve legal acceptance records. Lanreal does not
  receive this information through the Software. To the extent an
  Article 6 basis is required for Lanreal's determination of these
  local purposes, the basis is Article 6(1)(b) for feature and
  license performance and Article 6(1)(f) for accurate notices and
  legal record-keeping. If you choose to send logs to Lanreal as
  part of a bug report, the lawful basis for Lanreal's subsequent
  processing is Article 6(1)(f), our legitimate interest in
  diagnosing and fixing the issue you have reported, balanced
  against your interests and your expectations as the person who
  initiated the bug report.
- Transcribed text transmitted under the optional cloud
  post-processing feature. If you enable the optional feature
  described in Section 6 and select a cloud provider, the purpose of
  transmitting your transcribed text to that provider is to perform
  the post-processing that you have requested (for example, grammar
  or style correction). The lawful basis under GDPR Article 6 is
  Article 6(1)(a), your explicit consent, which you give by enabling
  the feature in the Software's settings, selecting a provider, and
  supplying a credential for that provider. This consent basis
  covers all data transmitted to the provider as part of the
  post-processing request, including the transcribed text, your API
  credential, any instruction prompt you have configured, and the IP
  address visible to the provider as a standard byproduct of the
  HTTPS connection. You may withdraw your consent at any time by
  disabling the feature as described in Section 6.5, which stops all
  further transmission of transcribed text to the provider. Note
  that Lanreal is not the recipient of the transcribed text in this
  processing; the recipient is the provider you selected, and your
  contractual relationship is directly with that provider.
- Feedback, earlier ratings, and earlier written testimonial
  submissions (Section 3.5). Lanreal processes private feedback, the
  email address you enter, application versions, and ratings
  collected by earlier versions to operate its feedback database,
  respond to feedback, and improve the Software. The lawful basis is
  GDPR Article 6(1)(a), consent expressed through the affirmative
  act of sending feedback (or, for earlier versions, selecting a
  star) after receiving the disclosures in this Privacy Policy. You
  may withdraw that consent and request deletion under Section 10.
  For testimonial and display-name records collected through earlier
  versions, the same basis applies to the original voluntary
  submission. Any separate consent to public display may be
  withdrawn independently.
- Feature requests (Section 3.12). Lanreal processes information you
  submit on the Featurebase board to evaluate and respond to
  feedback and plan product improvements. The lawful basis is
  Article 6(1)(f), Lanreal's legitimate interest in operating and
  improving the Software. You may use Whisperstream without visiting
  or submitting to the board. Lanreal does not intentionally process
  Article 9 special-category data for this purpose; incidental
  special-category content is handled as described in Section 3.12
  rather than treated as ordinary feature-request data.
- Correspondence, refunds, and privacy requests (Section 3.13).
  Lanreal processes the information you send, and related purchase
  and refund records, including the purchase email and any payment
  details used for a refund that cannot be made through Polar, under
  Article 6(1)(f), its legitimate interest in addressing your
  request, handling refunds (including voluntary goodwill refunds),
  and resolving related claims; under Article 6(1)(b) where
  necessary to perform the applicable agreement, including the
  30-day refund in EULA Section 8; and under Article 6(1)(c) where
  necessary to meet GDPR Articles 12 to 22 for rights requests or to
  keep required financial records.
- License records from earlier versions (Section 3.1). Records that
  earlier versions sent to Polar, and that Polar may still hold on
  Lanreal's behalf, are retained only as necessary to perform the
  applicable license terms, including the 30-day refund, under
  Article 6(1)(b), to meet a legal obligation under Article 6(1)(c),
  or, under Article 6(1)(f), to handle goodwill refunds and to
  establish, exercise, or defend claims. This version initiates no
  licensing requests.

Obligation to provide personal data. This version of the Software
does not require a license key, hostname submission, purchase, or
activation. Downloading a missing model necessarily exposes ordinary
connection information to the serving hosts. You are not under any
statutory or contractual obligation to provide the personal data
described in this Privacy Policy. If you choose not to enable the
optional cloud post-processing feature described in Section 6, or if
you withdraw your consent by disabling it, the Software continues to
function normally for all core features (on-device transcription,
text injection, local configuration). The only consequence is that
the cloud-based post-processing functionality is unavailable.
Sending feedback (Section 3.5) or contacting Lanreal (Section 3.13)
is voluntary. If you withhold information reasonably needed to
understand a request or identify the relevant transaction, we may be
unable to complete that support or refund request.

Except for the optional cloud post-processing feature described in
Section 6 and the voluntary feedback, rating, and
testimonial-display choices described in Sections 3.5 and 4, Lanreal
does not rely on your consent (GDPR Article 6(1)(a)) as the lawful
basis for processing described in this Privacy Policy. Lanreal does
not engage in automated decision-making that produces legal or
similarly significant effects within the meaning of GDPR Article 22.

5. WHO WE SHARE IT WITH (SERVICE PROVIDERS AND OTHER RECIPIENTS)
================================================================

Whisperstream relies on the following third-party service providers
and other recipients across its default and user-initiated
application flows. Some act as processors on Lanreal's behalf;
others determine their own purposes for limited connection data as
identified below. The numbered list is exhaustive for those
application flows. If you enable the optional cloud post-processing
feature described in Section 6, you establish a direct contractual
relationship with the cloud provider you select, and that provider
is not a Lanreal service provider or recipient within the meaning of
this Section 5. Changes to this list are communicated via version
bumps to this Privacy Policy (see Section 14), and are also
published in advance via the public provider page and RSS feed
described in Section 14. In accordance with Principle 4.1.3 of the
Personal Information Protection and Electronic Documents Act,
Lanreal uses contractual and other means to ensure that each listed
recipient acting as a processor on Lanreal's behalf provides a
comparable level of protection for personal information transferred
for processing. Lanreal remains accountable for the protection of
personal information transferred to third-party processors. Lanreal
does not use or disclose personal information for purposes other
than those described in this Privacy Policy, unless required by law.

1. Polar Software Inc. (Delaware, USA) -- Merchant of Record for
   historical purchases and refunds, and holder of license
   activation records created by earlier versions. This version of
   the Software does not contact Polar. Earlier versions sent Polar
   your license key, the Whisperstream organization identifier, your
   device hostname, and your operating system family (Section 3.1).
   For those activation records, Polar acts as a data processor on
   Lanreal's behalf within the meaning of GDPR Article 28. For the
   separate checkout, payment, and refund data that Polar collects
   or processes directly with you (email address, payment
   information), Polar acts as an independent data controller.
   Polar's processing is governed by Polar's privacy policy at
   https://polar.sh/legal/privacy. Polar's Data Processing Addendum
   (at https://polar.sh/legal/data-processing-addendum), which forms
   part of the Polar Master Services Terms, designates Polar as the
   processor and incorporates the European Commission's Standard
   Contractual Clauses (Controller-to-Processor, Module 2) and the
   UK International Data Transfer Addendum as the mechanisms for
   transfers of personal information from the European Economic Area
   and the United Kingdom to the United States.

2. Cloudflare, Inc. (Delaware, USA) -- software updates and the
   curated cloud-model list. The Software's update endpoint is
   hosted on Cloudflare infrastructure at releases.whisperstream.io,
   and the cloud-model list at models.whisperstream.io. This version
   does not download model files from Cloudflare. Cloudflare
   receives only the standard HTTP headers automatically sent by the
   underlying HTTP library, including your IP address, and the
   requested URL. Cloudflare's processing is governed by
   Cloudflare's privacy policy at
   https://www.cloudflare.com/privacypolicy/. Cloudflare's GDPR
   transfer mechanism is the European Commission's Standard
   Contractual Clauses combined with EU-U.S. Data Privacy Framework
   certification.

3. Supabase, Inc. (Delaware, USA) -- feedback and reviews database.
   If you send feedback as described in Section 3.5, Supabase hosts
   the relational database tables (reviews and feedback) that store
   your submission and ratings or testimonials collected by earlier
   versions. Supabase receives the submitted fields (feedback text
   and the email address you entered, together with the
   Whisperstream application version; for earlier versions, also the
   rating, testimonial, display name, and "feature on website"
   consent flag) together with the standard HTTP headers
   automatically sent by the underlying HTTP library (including your
   IP address). Supabase's processing is governed by Supabase's
   privacy policy at https://supabase.com/privacy. Lanreal has
   executed Supabase's Data Processing Addendum (published at
   https://supabase.com/legal/dpa); the Standard Contractual Clauses
   (Controller-to-Processor, Module 2) incorporated into that
   Addendum are the transfer mechanism for personal information sent
   from the European Economic Area, the United Kingdom, and
   Switzerland to Supabase in the United States.

4. CORDNET OU (d/b/a Featurebase) (Estonia) -- external
   feature-request board. If you choose the control described in
   Section 3.12 and submit information on the board, Featurebase
   processes feedback, messages, attachments, end-user identifiers,
   and workspace usage on Lanreal's behalf. Lanreal is the
   controller for this Customer Personal Data and Featurebase is the
   processor. Featurebase separately acts as an independent
   controller for its own account, billing, security,
   fraud-prevention, and service data. Its Data Processing Agreement
   is incorporated into its customer terms and is available through
   Featurebase's help centre at https://help.featurebase.app. Its
   privacy policy is at
   https://help.featurebase.app/en/articles/4744036-privacy-policy.
   Featurebase states that Customer Personal Data is primarily
   hosted in the European Economic Area and uses Standard
   Contractual Clauses, a UK Addendum, and a Swiss Addendum where an
   onward transfer requires them.

5. Hugging Face, Inc. (United States) -- public model delivery
   described in Sections 3.3, 3.7, and 3.8, including the speech
   recognition, Voice Model, and Gemma downloads and the Kokoro
   archive published in a Hugging Face repository operated by
   Lanreal. Hugging Face and its delivery infrastructure receive the
   connection data described in those Sections. Hugging Face
   determines its own purposes for operating, securing, and
   maintaining its services and acts as an independent controller
   for those uses. Its privacy policy is at
   https://huggingface.co/privacy. The Software requests files
   directly from the upstream host as described in Section 3.3.
   International processing and host-controlled retention are
   described in Sections 7 and 8.

6. GitHub (United States / Netherlands) -- backup delivery of speech
   models described in Section 3.3. GitHub receives the model
   connection data described in Section 3.3. Its privacy statement
   describes independently controlled service usage data and is
   available at https://github.com/site/privacy. International
   processing and host-controlled retention are described in
   Sections 7 and 8. GitHub is not engaged as Lanreal's processor
   for public model-download connection records.

Correspondence services. Correspondence under Section 3.13 uses
Gmail (Google) and Resend for email, and OpenAI Codex and Anthropic
Claude for assistance reviewing messages and preparing replies.
Those services can receive the contact details, messages, and
attachments supplied for that purpose. Their policies are at
https://policies.google.com/privacy,
https://resend.com/legal/privacy-policy,
https://openai.com/policies/privacy-policy/, and
https://www.anthropic.com/legal/privacy. Applicable account terms
and settings govern their processing, including any
model-improvement use. Lanreal remains responsible for its handling
of correspondence. These services are separate from the providers
you may select under Section 6.

Refund payment services. If a refund cannot be made through Polar
(Section 3.13), Lanreal may send it through Wise Payments Canada
Inc., a money-transfer service, and Lanreal's bank. Wise receives
your name, the amount and the payment details you give for that
payment, and processes them under its own privacy notice and legal
obligations, including identity and anti-money-laundering checks.
Wise's privacy notices are at
https://wise.com/gb/legal/privacy-notices.

Other than the recipients listed above, the correspondence services,
the refund payment services, and the legally permitted disclosures
in Sections 12b and 12c, Lanreal does not share personal information
with any other recipients. In particular, Lanreal does not disclose
personal information to advertisers, data brokers, or social media
platforms, and Lanreal does not use third-party analytics, crash
reporting, or error-reporting services (see Section 9 for the full
enumeration of what the Software does not do).

6. OPTIONAL CLOUD POST-PROCESSING (BRING YOUR OWN KEY)
======================================================

The Software includes an optional AI cleanup feature that can route
transcribed text through a Large Language Model for post-processing
(for example, filler-word removal, spoken-correction handling,
punctuation and number normalization, style adjustment, or custom
formatting). This feature is disabled by default in every new
installation. When it is disabled, the Software does not transmit
transcribed text to any party, consistent with the default-state
promise made in Section 9.

When you enable AI cleanup, it can run on a Large Language Model
hosted on your own device, in which case your transcribed text is
processed locally and does not leave your device. Alternatively,
under Bring Your Own Key, you may configure the feature to route
your transcribed text to a third-party cloud provider that you
select, using a credential that you supply. This Section 6 describes
that optional cloud path: the providers you may select, what is
transmitted, and your relationship with the provider. The on-device
option involves no transmission of transcribed text and is covered
by the default-state promises in Sections 3.4 and 9.

6.1 Supported providers
-----------------------

If you enable the optional post-processing feature, you may
configure the Software to route transcribed text to any one of the
following providers. Lanreal does not host, operate, resell, or
receive revenue from any of these providers. Your contractual
relationship is directly with the provider whose credentials you
supply.

1. OpenAI, L.L.C. (Delaware, USA) -- a cloud-based Large Language
   Model provider. Users outside North America may contract with a
   different OpenAI regional entity (for example, OpenAI Ireland
   Limited for users in the European Economic Area). See OpenAI's
   privacy policy at https://openai.com/policies/privacy-policy/ and
   OpenAI's terms of use at
   https://openai.com/policies/terms-of-use/ for information on how
   OpenAI handles content submitted to its API.

2. Anthropic, PBC (Delaware, USA) -- a cloud-based Large Language
   Model provider. Users outside North America may contract with a
   different Anthropic regional entity (for example, Anthropic
   Ireland Limited for users in the European Economic Area). See
   Anthropic's privacy policy at
   https://www.anthropic.com/legal/privacy and Anthropic's
   Commercial Terms of Service at
   https://www.anthropic.com/legal/commercial-terms for information
   on how Anthropic handles content submitted to its API.

3. Google LLC (Delaware, USA), via the Google Gemini API -- a
   cloud-based Large Language Model provider. The specific Google
   legal entity that contracts with you for Gemini API access
   depends on your location and your Google Cloud billing
   arrangement, and is determined by Google at
   https://cloud.google.com/terms/google-entity. For most individual
   users the contracting entity will be Google LLC (Delaware, USA).
   Canadian users contracting for paid Gemini API access may
   contract with Google Canada Corporation. See
   https://ai.google.dev/gemini-api/terms for the
   Gemini-API-specific additional terms and
   https://policies.google.com/privacy for Google's general privacy
   policy.

4. A self-specified endpoint (Ollama-compatible or other
   OpenAI-compatible endpoint) -- a Large Language Model server that
   you point the Software at by supplying its URL, together with a
   credential where the endpoint requires one. This covers both an
   Ollama server speaking the Ollama HTTP API and any other endpoint
   speaking the OpenAI-compatible chat API. If the endpoint is a
   process running on your own device (for example, an Ollama
   process at http://localhost:11434), transcribed text does not
   leave your device at all. If you configure the Software to
   connect to a non-local endpoint (for example, a self-hosted
   server on another machine, or an endpoint on a private network),
   transcribed text is transmitted to the URL you specify. The
   operator of that endpoint, which may be you or another party, is
   responsible for its own data handling, and Lanreal has no
   visibility into or control over that endpoint.

6.2 What is transmitted
-----------------------

When the optional post-processing feature is enabled, for each
eligible transcript the Software transmits to the provider you
selected:

- The transcribed text produced by the speech recognition model, as
  an input to the post-processing request. Transcripts of three
  words or fewer are excluded from this transmission and remain
  local to your device.
- The API key or credential that you supplied for the selected
  provider, as an Authorization or equivalent request header, so
  that the provider can authenticate you and apply the usage limits
  of your account.
- Any instruction prompt that you have configured in the Software
  (for example, a system prompt describing the post-processing style
  you want), as part of the request payload.
- Standard HTTP headers automatically attached by the Software's
  HTTP library, including your IP address as it is seen by the
  provider.

The Software does not transmit, as part of any optional
post-processing request, any of the following: your audio recording,
your license key, the Whisperstream organization identifier, your
device hostname, your operating system family, your local diagnostic
logs, your in-memory frontend log ring buffer, your usage
statistics, your configuration file, or any other category of
information listed in Section 3.4 as staying on your device. These
remain on your device regardless of whether the optional
post-processing feature is enabled.

In addition to the per-transcript transmissions described above,
while the feature is enabled and a credential is present the
Software periodically sends a short connectivity probe to the
provider you selected to verify that the credential is valid and the
provider is reachable, so that the Software can display an accurate
connection status in its settings interface. The probe transmits the
same API credential, the same standard HTTP headers including your
IP address, and a short fixed test prompt authored by Lanreal; it
does not transmit any of your transcribed text, any prompt you have
configured, or any other user content. The probe is covered by the
same consent you give when you first enable the feature under
Section 6.5, and the Software will not send a probe to any provider
for which that consent has not been recorded.

6.3 Provider response handling
------------------------------

After the provider processes your request, it returns the
post-processed text to the Software as the response body. That
response is then handled locally by the Software under the same
rules as any other transcribed text: it is typed into the focused
window and, if you keep the local transcript history enabled, stored
encrypted on your own device as described in Section 3.4. Lanreal
does not receive or retain a copy, and the Software does not
transmit the provider's response to any other recipient.

6.4 Your credentials
--------------------

The API key or credential you supply for any of the providers listed
in Section 6.1 is stored locally on your device within your Windows
user profile, under %LOCALAPPDATA%\Whisperstream\. The key is
encrypted at rest using the Windows Data Protection API
(specifically, the CryptProtectData function), which derives the
encryption key from your Windows user account credentials. As a
consequence, the encrypted credential can only be decrypted by the
same Windows user on the same device on which it was stored. A
different Windows user logged into the same device, and any user on
a different device, cannot decrypt the stored credential.

The stored credential is transmitted only to the provider you
selected, only over HTTPS with certificate verification enabled, and
only as a request header on the post-processing requests described
in Section 6.2. The Software does not transmit the credential to
Lanreal, to any service provider or recipient listed in Section 5,
or to any recipient other than the provider you selected. Lanreal
does not receive, store, or have any ability to recover your
credential.

6.5 How to enable, disable, and delete
--------------------------------------

- Enabling. The optional post-processing feature is disabled by
  default in every new installation. To enable it, you must
  explicitly select a provider and supply a valid credential for
  that provider through the Software's settings interface. Before
  the feature begins transmitting transcribed text, the Software
  will display a blocking consent dialog that identifies the
  provider you selected, describes what data will leave your device,
  links to this Privacy Policy and to the provider's own privacy
  policy, and requires an affirmative click to continue. The
  Software will not begin transmitting transcribed text to any
  provider until you have completed all of those steps and confirmed
  the blocking consent dialog.
- Disabling. To disable the feature, toggle it off in the same
  settings interface. After you disable it, the Software will not
  transmit any further transcribed text to any provider, and will
  resume the default behaviour described in Sections 3.4 and 9 of
  this Privacy Policy.
- Deleting your credential. To delete a stored credential, use the
  "remove key" control in the same settings interface. This removes
  the encrypted credential from your Windows user profile in its
  entirety.
- Lockdown Mode override. While Lockdown Mode (Section 3.6) is on,
  all of the cloud providers and self-specified endpoints listed in
  Section 6.1 are disabled and AI cleanup is forced to the on-device
  model, so no transcribed text leaves your device regardless of any
  provider you may have configured.

6.6 Relationship to Section 5 (service providers and other recipients)
----------------------------------------------------------------------

The four providers listed in Section 6.1 are not Lanreal
sub-processors, resellers, or agents within the meaning of Section
5. This classification rests on four facts about how the optional
cloud post-processing feature operates:

1. You determine the purposes and means of processing. You select
   the provider, you supply the credential, you configure the
   instruction prompt, and you trigger each transmission by enabling
   the feature and completing the consent gate described in Section
   6.5. Lanreal's code is the transport; it does not select the
   destination, does not determine the purpose of the
   post-processing, and does not act on behalf of Lanreal in
   performing the transmission.

2. Lanreal does not hold the transcribed text. The transcript is
   generated on your device by the local speech-recognition model,
   transmitted directly from your device to the provider you
   selected, and is not routed through, copied to, or received by
   any Lanreal server. Lanreal has no possession, custody, or
   control of the transcript at any point.

3. Lanreal has no contract with the provider. Your credential is
   issued to you by the provider under the provider's own terms of
   service and privacy policy. Your contractual relationship is
   directly with the provider. Lanreal is not a party to that
   agreement, has no contract with the provider concerning the
   processing of your data, and does not assume any obligation owed
   to you by the provider.

4. Lanreal receives no consideration from the provider. Lanreal
   receives no revenue, referral fees, usage-based payments, or
   other valuable consideration from any of the four providers
   listed in Section 6.1, and Lanreal pays none of them.

Because of these facts, for the optional cloud post-processing
feature: (a) the provider is not processing personal data on
Lanreal's behalf within the meaning of Article 4(8) of the GDPR and
is therefore not a Lanreal processor under Article 28; (b) Lanreal
does not transfer personal information to the provider "for
processing" within the meaning of Clause 4.1.3 of Schedule 1 to
Canadian federal privacy law, and accountability for the provider's
handling of the transcript does not attach to Lanreal; (c) the
transmission is not a "sale" under Cal. Civ. Code Section
1798.140(ad)(1) (Lanreal receives no consideration), not a "share"
under Section 1798.140(ah) (the transmission is not for
cross-context behavioural advertising), and not a disclosure to a
service provider under Section 1798.140(ag) (no contract, no
on-behalf-of relationship). To the extent the transmission could be
characterised as a disclosure at all, it is a user-directed
disclosure within the carve-outs at Cal. Civ. Code Sections
1798.140(ad)(2)(A) and 1798.140(ah)(2)(A).

By enabling the feature and supplying a credential, you represent
that you have read and agreed to the selected provider's terms of
service and privacy policy, and that you have the legal right to
submit the content you are submitting for post-processing.

7. INTERNATIONAL DATA TRANSFERS
===============================

Because Lanreal is incorporated in Canada and the service providers
and other recipients listed in Section 5 operate outside Canada,
personal information forwarded through the Software may be
transferred across international borders. This section summarizes
the transfer mechanism or other transfer posture for each processor
and other recipient under Chapter V of the GDPR. It distinguishes
direct public-host connections from information Lanreal processes or
discloses for its own purposes.

- Direct public-model downloads. The Software requests model files
  directly from the upstream host when a required or selected model
  is missing. Hugging Face and GitHub collect the connection records
  described in Section 3.3 for their own service purposes. Lanreal
  does not engage them to process customer records on its behalf.
  Their delivery infrastructure can process those records in the
  United States and other countries. Their policies linked in
  Section 5 describe international processing, applicable
  safeguards, and ways to contact them.
- Hugging Face, Inc. (United States). Hugging Face identifies a
  French establishment and international infrastructure in its
  privacy information; that does not mean every download remains in
  the European Economic Area. Review https://huggingface.co/privacy
  for its independently controlled processing and rights routes.
- GitHub (United States / Netherlands). Public release downloads
  follow GitHub's privacy statement at
  https://github.com/site/privacy. GitHub describes international
  safeguards, including participation in the EU-U.S. Data Privacy
  Framework, its UK Extension, and the Swiss-U.S. Data Privacy
  Framework for covered data. Those safeguards apply within their
  stated scope; they do not describe every recipient or all
  processing by Lanreal.
- Polar Software Inc. (United States). Polar is incorporated in
  Delaware, USA. Polar's Data Processing Addendum (at
  https://polar.sh/legal/data-processing-addendum), which forms part
  of the Polar Master Services Terms and applies automatically,
  incorporates the European Commission's Standard Contractual
  Clauses (Controller-to-Processor, Module 2) and the UK
  International Data Transfer Addendum as the mechanisms for
  transfers of personal information from the European Economic Area
  and the United Kingdom to Polar in the United States. Lanreal
  relies on these Standard Contractual Clauses for the
  license-activation and validation records that earlier versions
  sent to Polar, described in Section 3.1.
- Cloudflare, Inc. (United States). Cloudflare is incorporated in
  Delaware, USA. Cloudflare's published privacy policy and Trust Hub
  cite both the European Commission's Standard Contractual Clauses
  and EU-U.S. Data Privacy Framework certification as the mechanisms
  for transfers of personal information from the European Economic
  Area, the United Kingdom, and Switzerland to Cloudflare in the
  United States. Lanreal relies on Cloudflare's combined Standard
  Contractual Clauses and Data Privacy Framework certification for
  the update checks and update downloads in Section 3.2 and the
  curated cloud-model list in Section 3.8.
- Supabase, Inc. (United States). Supabase is incorporated in
  Delaware, USA, and hosts the feedback and reviews database
  described in Section 3.5. Lanreal has executed Supabase's Data
  Processing Addendum (published at https://supabase.com/legal/dpa),
  which incorporates the European Commission's Standard Contractual
  Clauses (Controller-to-Processor, Module 2) and the UK
  International Data Transfer Addendum as the mechanisms for
  transfers of personal information from the European Economic Area,
  the United Kingdom, and Switzerland to Supabase in the United
  States.
- CORDNET OU (Featurebase) (Estonia). Featurebase primarily hosts
  Customer Personal Data in the European Economic Area. Its Data
  Processing Agreement incorporates the European Commission's
  Standard Contractual Clauses, the UK Addendum, and the Swiss
  Addendum for any transfer to a location that lacks an applicable
  adequacy decision.
- Email and support assistance. Google, Resend, OpenAI, and
  Anthropic can process correspondence and supplied attachments in
  the United States and other countries under the applicable account
  terms, settings, and privacy policies linked in Section 5. Their
  service disclosures describe processing locations and available
  safeguards. Lanreal remains responsible for applicable transfer
  duties for its handling of that information.
- Refund payment services. A refund paid outside Polar (Section
  3.13) goes through Wise Payments Canada Inc. and Lanreal's bank,
  which can process the payment details in the countries needed to
  complete that payment. Where GDPR Chapter V applies and no other
  safeguard is available, the transfer is necessary to make the
  payment you asked to receive and gave your details for (Article
  49(1)(b)), and Lanreal does not make it without that request.

Transfers to Canada. The European Commission has recognized Canada
as providing an adequate level of data protection (Commission
Decision 2002/2/EC). Transfers of personal information from the
European Economic Area to Lanreal in Canada are therefore covered by
this adequacy decision.

If you are located in the European Economic Area, the United
Kingdom, or Switzerland and wish to receive further information
about these transfer mechanisms, including copies of the relevant
Standard Contractual Clauses where available, please contact Lanreal
at support@whisperstream.io.

Foreign law enforcement access. Because personal information may be
transferred to service providers or other recipients in the United
States for processing (as described in Section 5), that information
may be accessible to the courts, law enforcement agencies, and
national security authorities of the United States under the laws of
that jurisdiction.

Optional cloud post-processing (Section 6). If you enable the
optional cloud post-processing feature described in Section 6 and
select a cloud provider other than a local Ollama-compatible
endpoint, transcribed text is transmitted to the provider's
infrastructure, which is typically located in the United States.
Three of the four providers listed in Section 6.1 (OpenAI,
Anthropic, Google) are U.S.-incorporated entities whose processing
infrastructure generally sits in the United States, and your
contract for Gemini API access through Google may involve a Canadian
or European Google entity depending on your location. Lanreal does
not control the routing, the storage locations, or the onward
transfer decisions those providers make once the data leaves your
device, and Lanreal does not implement Standard Contractual Clauses
or any other Chapter V transfer mechanism on your behalf for that
transmission, because Lanreal is not the contracting party. Your
contractual protection for any such cross-border transfer is
governed by the privacy policy and terms of service of the provider
you selected, and Lanreal encourages you to review both documents
before enabling the feature.

8. HOW LONG WE KEEP IT (RETENTION)
==================================

Lanreal's retention strategy is hybrid. For information that the
Software controls directly, we state concrete retention behaviour
because the data flow is narrow enough to do so honestly. For
information that a third-party service provider or recipient
controls, we describe the retention category and point you to that
party's own policy, because Lanreal cannot enforce a specific
retention period on a third party's infrastructure.

Retention for information the Software controls directly:

- Audio recordings: not retained by Lanreal, and never transmitted
  off your device. Microphone audio is held in random-access memory
  while each capture is transcribed. If you keep audio saving
  enabled in the local transcript history (on by default, and
  separately disableable), a copy of the recording is also stored,
  encrypted, on your own device, and is removed on the same schedule
  as the rest of your history (see "Local transcript history"
  below).
- Transcribed text: not retained by Lanreal. The output of the
  speech recognition model is typed into the focused window. If you
  keep the local transcript history enabled (on by default), the
  transcribed text is also stored, encrypted, on your own device and
  removed on the schedule you set (see "Local transcript history"
  below). If you have enabled the optional cloud post-processing
  feature described in Section 6 and the transcript is longer than
  three words, the text is transmitted to the provider you selected
  for the duration of the post-processing request; Lanreal does not
  retain a copy, and the provider's retention of your submitted
  content is governed by the provider's own terms of service and
  privacy policy (see the links in Section 6.1).
- Local transcript history (your transcribed text, encrypted
  waveform peaks, and, optionally, your audio): retained on your own
  device only, encrypted at rest (AES-256-GCM with the data key
  sealed by the Windows Data Protection API), and never transmitted
  to Lanreal. You control how long it is kept: a retention window of
  1, 7, or 30 days, or forever, with 7 days as the default, removes
  older entries, and you may delete any individual entry or clear
  the entire history at any time. Retention and orphan-audio cleanup
  run at startup, after live and imported saves, after a retention
  change, and after a successful Lockdown unlock. Cleanup that
  requires the history key is deferred while the history is locked
  and retried after unlock. Deletion uses ordinary SQLite deletion
  and file unlinking, not secure disk overwrite. A failed file
  deletion may be retried by a later cleanup; database free pages or
  journals, filesystem remnants, backups, shadow copies, and
  exported copies remain outside the Software's deletion control. If
  the history cannot be decrypted on your current Windows account
  (for example, after a profile reset or a move to a different
  device), it is not readable and no new entries are written to it.
- Local diagnostic logs: the active file and up to three 2 MiB
  backups are retained locally by size-based rotation in ordinary
  use, voluntary Lockdown, and administrator-managed Lockdown. The
  supplemental Lockdown diagnostic file retains at most 256 events
  and 128 KiB. These files are never transmitted automatically. You
  may delete the local log directory at any time.
- Lockdown access log (Section 3.4): while Lockdown Mode is
  effective, the active content-free file and up to five 2 MiB
  backups are retained locally by size-based rotation. The Software
  does not assign it a time-based purge period. It is never
  transmitted or included in the support archive. You may delete it
  with the local log directory.
- Frontend diagnostic buffers: each application window keeps at most
  500 entries, 2 KiB per entry, and 128 KiB total in memory; the
  backend keeps at most 128 KiB of re-sanitized frontend entries
  across windows. Ring eviction or process/window exit releases that
  state. Lockdown transitions do not clear the rings.
- Local usage statistics and configuration: retained locally on your
  device until you uninstall the Software or delete the
  %LOCALAPPDATA%\Whisperstream\ directory.
- Earlier license records and legal-acceptance state (Section 3.9):
  retained in the current user's Windows registry and application
  data until you remove those records. Uninstalling does not
  necessarily remove them. This version does not write or delete an
  earlier version's license and trial record. The HMAC detects
  modification; it is not encryption. Exact EULA acceptance events
  remain in the append-only local ledger so accepting updated terms
  does not erase prior evidence. The cached cloud-models.json list,
  any update-opt-out.json record, and any trial-policy-refresh.json
  file left by an earlier version remain in the application-data
  directory until you remove them; the update opt-out stops applying
  after thirty days.
- Agent Speak interaction content (Section 3.11): active responses,
  questions, permissions, session display state, and reply drafts
  remain in bounded process memory. They are discarded on the
  applicable delivery, acknowledgement, approximately 15-second
  question expiry, approximately 120-second retained-draft expiry,
  feature disablement, Lockdown Mode, or shutdown. Interaction
  content and content-derived fingerprints are not written to
  diagnostics or support exports. A reply you dictate through Agent
  Speak follows your ordinary encrypted transcript-history retention
  setting when that setting is enabled.
- Credentials you supply for the optional cloud post-processing
  feature (Section 6): retained locally on your device,
  DPAPI-encrypted, inside your Windows user profile, until you
  remove the credential through the Software's settings interface
  (see Section 6.5) or until you uninstall the Software and delete
  the %LOCALAPPDATA%\Whisperstream\ directory. Lanreal does not
  retain, store, or have any visibility into this credential.
- Diagnostic archives and logs: the support ZIP is assembled in
  backend memory and streamed to your selected download destination,
  with no app-managed ZIP retention. The ZIP may contain recent
  sanitized backend and frontend diagnostics, bounded system
  information, and supplemental closed-schema Lockdown events. It
  excludes the separate Lockdown access log, transcript history,
  audio, imported source files, and Agent Speak stores. Your
  downloaded copy remains under your control. The Software never
  uploads the ZIP automatically; Lanreal receives it only if you
  separately choose to send it. Logs you voluntarily send to Lanreal
  with a bug report are retained only for the duration of the
  support interaction and deleted or anonymized once the issue is
  resolved. The DPAPI-encrypted credential you supply for the
  optional cloud post-processing feature (Section 6.4) is not part
  of the bug-report log export, so it is not inadvertently
  transmitted when you submit a bug report.
- Feedback and earlier reviews you voluntarily submitted (Section
  3.5): stored by Supabase on Lanreal's behalf (see Sections 3.5, 5,
  and 7). Lanreal retains submitted reviews and feedback
  indefinitely for the business purposes described in Section 4
  (improving the Software and, where you consented, publicly
  displaying testimonials on the Whisperstream website) until you
  request deletion by contacting Lanreal at support@whisperstream.io
  as described in Section 10. On receipt of a valid deletion
  request, Lanreal will delete the corresponding row from the
  reviews or feedback database within the response timeline
  described in Section 10.

Retention for information third-party providers and recipients
control:

- Polar activation-slot data from earlier versions (your license
  key, the Whisperstream organization identifier, your hostname, and
  your OS family): this version does not use, validate, or
  deactivate those slots. Polar retains them on Lanreal's behalf as
  governed by Polar's privacy policy at
  https://polar.sh/legal/privacy and its Data Processing Addendum.
  Lanreal remains responsible for appropriate retention and deletion
  instructions for records processed on its behalf and will request
  deletion of records no longer needed to fulfil earlier
  obligations, resolve requests, or meet a lawful retention
  requirement. Polar separately retains purchase and refund records
  it controls as Merchant of Record under its own policy.
- Cloudflare access logs: standard content delivery edge access logs
  for update and cloud-model-list requests, including requests made
  by earlier versions, as governed by Cloudflare's privacy policy at
  https://www.cloudflare.com/privacypolicy/.
- Hugging Face public-download connection logs: Hugging Face
  controls retention under https://huggingface.co/privacy. The
  Software does not control or delete those host-held records, and
  Lanreal promises no fixed public-download log period.
- GitHub connection data: GitHub controls retention of backup
  model-download connection data under its privacy statement linked
  in Section 5; the Software does not control or delete those
  host-held logs.
- Correspondence (Section 3.13): Lanreal retains correspondence and
  request-handling records for as long as necessary to address the
  request and document any remaining refund, rights, or claim
  obligation, taking account of applicable limitation periods and
  legal retention requirements, and then deletes or anonymizes them.
  Resolving a request does not itself mean all related records or
  provider backups are immediately deleted. The email and support
  assistance services named in Section 5 can retain supplied
  information under their applicable account terms, settings, and
  privacy policies.
- Featurebase feature-request data: retained according to the board
  configuration and Featurebase's retention schedule until Lanreal
  or the submitting user deletes it, subject to legal-record and
  backup periods described in Featurebase's Privacy Policy and DPA.
  You may request deletion from Lanreal at support@whisperstream.io.

Retention by optional cloud post-processing providers (Section 6).
If you have enabled the optional cloud post-processing feature and
selected a cloud provider, your transcribed text and any instruction
prompt you have configured are submitted to that provider as part of
each eligible request. How long the provider retains that submitted
content, whether it is used to train the provider's models, and
whether it is logged for abuse detection are governed entirely by
the provider's own terms of service and privacy policy, which vary
by provider and by account tier (for example, some providers offer a
"zero-data-retention" enterprise tier that differs from their
default consumer retention). Lanreal has no visibility into and no
control over retention decisions at the provider, and Lanreal does
not make representations about them. Please review the provider's
published policies (see the links in Section 6.1) before enabling
the feature.

9. WHAT WE DON'T DO
===================

This section enumerates categories of information that the Software
never collects, never transmits, and never retains. It is intended
as an explicit companion to Section 3, so that you can see not just
what the Software does, but also what it does not do.

- No audio recordings leave your device. Microphone audio is
  processed by the speech recognition model on your CPU and is never
  uploaded to any server for any reason. If you keep audio saving
  enabled in the local transcript history (Section 3.4), a copy of
  the recording is stored encrypted on your own device only; it
  still never leaves your device.
- By default, no transcribed text leaves your device. In the default
  configuration of the Software, the output of the speech
  recognition model is typed into the focused window, and the
  Software does not upload transcriptions to any server. The
  transcribed text may be stored in the local, encrypted transcript
  history on your own device (Section 3.4), which never leaves your
  device. If you explicitly enable the optional cloud
  post-processing feature described in Section 6 and supply a
  credential for a cloud provider, transcribed text longer than
  three words is transmitted only to the specific third-party
  provider you selected, only over HTTPS, and only for the duration
  of each post-processing request. No transcribed text is
  transmitted to Lanreal or to the service providers listed in
  Section 5 as part of Whisperstream's transcription or
  cloud-cleanup pipeline. Text you deliberately submit to a
  destination application, Claude Code or Codex, a feedback form, or
  Featurebase is controlled by that destination.
- No microphone input, typing, keystrokes, or clipboard contents are
  transmitted. The Software does not intercept or transmit your
  keyboard or clipboard activity.
- No telemetry, no analytics, error reporting, crash reporting, no
  usage tracking. The Software does not integrate Sentry, PostHog,
  Mixpanel, Google Analytics, Plausible, or any comparable service.
  No automatic event streams, per-action tracking, or behavioural
  profiling are sent to any server. Operational data leaves your
  device only through the flows explicitly described in Section 3:
  update checks and required model downloads. This version makes no
  license validation request and no trial-extension policy request.
  The user-initiated outbound flows are voluntarily sending feedback
  (Section 3.5), opening and submitting to Featurebase (Section
  3.12), selecting an optional speech, local AI, or Voice Model
  (Sections 3.3, 3.7, and 3.8), opening the Enhancement page, which
  can request the cloud-model list (Section 3.8), opening the
  website's download page in your browser (Section 3.2), and, if you
  explicitly enable it, optional cloud post-processing (Section 6).
  Communication with the local backend uses only the loopback
  interface and does not leave your device. There is no "opt out"
  for telemetry because there is no telemetry to opt out of; the
  user-initiated flows are controlled by you each time you use them.
  The content-free local access log described in Section 3.4 is
  likewise stored only on your device and is never transmitted.
- No advertising identifiers. The Software does not collect,
  generate, or transmit any advertising identifier (such as IDFA,
  AAID, or similar).
- No local network scanning. The Software does not scan your local
  network, enumerate devices on it, or probe for other services.
- No persistent loopback-accessible endpoints beyond the local
  backend process. The local backend process binds exclusively to
  the loopback interface (127.0.0.1) so that no other device on your
  network can reach it, and it exposes no outbound telemetry.
- No sale of personal information. Lanreal does not sell or rent
  personal information. See Section 13 for the CCPA-specific
  disclosure on sale and sharing.
- No profiling or automated decision-making. The Software does not
  profile you, score you, rank you, or make any automated decision
  that produces legal or similarly significant effects within the
  meaning of GDPR Article 22.
- No cookies or tracking technologies. The Software does not use
  cookies, web beacons, pixel tags, local storage tokens, browser
  fingerprinting, or any other tracking technology to identify you,
  track your behaviour, or build a profile about you. The local
  communication between the Software's frontend and backend
  processes (over the loopback interface) does not use persistent
  cookies or session identifiers.

10. YOUR RIGHTS
===============

Depending on where you live, you may have one or more of the rights
listed in this section. Lanreal extends all of these rights to every
Whisperstream user, regardless of jurisdiction, so that you do not
have to prove residency in order to exercise a right.

Rights summary. The most commonly exercised rights, with the
statutory basis for each, are:

- Right to know what personal information Lanreal holds about you
  and how we use it (GDPR Article 15 / CCPA Section 1798.110 /
  Canadian federal privacy law Principle 4.9).
- Right to delete or erase personal information Lanreal holds about
  you (GDPR Article 17 / CCPA Section 1798.105). This includes
  deletion of any review or feedback you have submitted under
  Section 3.5.
- Right to correct inaccurate personal information (GDPR Article 16
  / CCPA Section 1798.106 / Canadian federal privacy law Principle
  4.9.5).
- Right to data portability in a structured, commonly-used,
  machine-readable format (GDPR Article 20).
- Right to withdraw consent for the optional cloud post-processing
  feature (Section 6) and for feedback and earlier review
  submissions (Section 3.5), which are the two pieces of processing
  described in this Privacy Policy that rely on your consent as the
  GDPR Article 6 lawful basis (GDPR Article 7(3)).
- Right to complain to a privacy regulator (GDPR Article 77, CCPA,
  Canadian federal privacy law; see Section 15 for the supervisory
  authorities).

To exercise any of these rights, email Lanreal's Privacy Officer at
support@whisperstream.io. There is no charge, no account required,
and no in-app rights-request form. Lanreal will respond within 30
days under Canadian federal privacy law and the GDPR and within 45
calendar days under the CCPA, with the extensions described in the
timelines at the end of this Section 10.

Rights under the European Union General Data Protection Regulation
(GDPR Articles 15 to 22):

- Right of access (Article 15): you may ask Lanreal to confirm
  whether we process personal information about you and, if so, to
  provide a copy of that information.
- Right to rectification (Article 16): you may ask Lanreal to
  correct any inaccurate personal information we hold about you.
- Right to erasure (Article 17): you may ask Lanreal to delete
  personal information we hold about you, subject to the statutory
  exceptions in Article 17(3).
- Right to restriction of processing (Article 18): you may ask
  Lanreal to restrict the processing of your personal information in
  the circumstances set out in Article 18(1).
- Right to data portability (Article 20): you may ask Lanreal to
  provide your personal information in a structured, commonly used,
  machine-readable format where the processing is based on consent
  under Article 6(1)(a) or contract under Article 6(1)(b) and is
  carried out by automated means.
- Right to object (Article 21): you may object at any time, on
  grounds relating to your particular situation, to processing of
  your personal information that is based on Article 6(1)(f) (our
  legitimate interests). If you believe that any processing by
  Lanreal that is based on Article 6(1)(f) affects you, you may
  object on grounds relating to your particular situation, and
  Lanreal will cease the processing unless we demonstrate compelling
  legitimate grounds that override your interests, rights, and
  freedoms.
- Rights in relation to automated decision-making (Article 22): not
  applicable. Lanreal does not engage in automated decision-making
  that produces legal or similarly significant effects within the
  meaning of Article 22.
- Right to withdraw consent (Article 7(3)): applies to the optional
  cloud post-processing feature described in Section 6 and to the
  feedback and earlier review submissions described in Section 3.5.
  These are the two pieces of processing described in this Privacy
  Policy that rely on your consent as the GDPR Article 6 lawful
  basis. For the cloud post-processing feature, you may withdraw
  your consent at any time by disabling the feature through the
  Software's settings interface as described in Section 6.5, which
  stops all further transmission of transcribed text to the
  provider. For reviews and feedback, you may withdraw your consent
  and request deletion of your previously submitted content by
  emailing Lanreal at support@whisperstream.io; where you checked
  the "feature my review on the website" consent flag in an earlier
  version, that separate consent may be withdrawn the same way.
  Withdrawal of consent does not affect the lawfulness of processing
  already performed under your consent before withdrawal. The other
  processing described in this Privacy Policy does not rely on
  consent, so the Article 7(3) right to withdraw does not apply to
  any processing outside Sections 3.5 and 6.

Rights under the California Consumer Privacy Act (CCPA):

- Right to know what categories of personal information we have
  collected about you, the sources from which we collected it, the
  business or commercial purposes for collecting it, and the
  categories of third parties with whom we shared it.
- Right to delete personal information we collected from you,
  subject to the statutory exceptions in Cal. Civ. Code Section
  1798.105(d).
- Right to correct inaccurate personal information we maintain about
  you.
- Right to limit use of sensitive personal information: Lanreal does
  not request or use sensitive personal information for a purpose
  that triggers this right. A voluntary Featurebase submission could
  nevertheless contain sensitive personal information despite the
  instruction in Section 3.12; Lanreal handles such incidental
  content as described there.
- Right to opt out of the sale or sharing of personal information:
  not applicable. Lanreal does not sell or share personal
  information for cross-context behavioural advertising, as
  described in Section 13 below. The disclosure that this right is
  not applicable is nonetheless provided.
- Right to non-discrimination for exercising any CCPA right. Lanreal
  will not deny you the Software, charge you a different price, or
  provide a different level of quality because you exercised a right
  under the CCPA.

Rights under Canadian federal privacy law:

- Right of access to personal information Lanreal holds about you.
- Right to correction of inaccurate personal information.
- Right to challenge compliance with this Privacy Policy and with
  Canadian federal privacy law generally. Challenges are directed to
  the Privacy Officer in the first instance (see Section 15).

How to exercise your rights. To exercise any of the rights above,
email Lanreal's Privacy Officer at support@whisperstream.io with a
description of your request and enough information for us to verify
your identity and locate your personal information (typically the
email address you used for a purchase, feedback, or correspondence,
if any). Lanreal does not operate an in-app rights-request button in
this version of the Software; the email channel above is the
designated rights mechanism.

Verification. Because Lanreal does not maintain a user account
database, identity verification for most requests will consist of
confirming that the email you use to contact us matches a purchase,
feedback, or correspondence record we can locate, or otherwise
confirming enough details about your use of the Software that we can
associate your request with specific personal information we hold.

Unresolved challenges. If you challenge the accuracy of personal
information Lanreal holds and the challenge cannot be resolved to
your satisfaction, Lanreal will record the substance of the
unresolved challenge alongside the information in question.

Response timeline. Lanreal will acknowledge your request within a
reasonable period and will respond substantively within 30 days of
receipt. Lanreal will respond to access and correction requests at
no cost to you. Under GDPR Article 12(3), Lanreal may extend this
period by up to an additional 60 days where necessary, taking into
account the complexity and the number of requests; if we need to do
so, we will inform you of the extension and the reasons for it
within the original 30-day window.

CCPA response timeline. For requests submitted by California
residents under the CCPA, Lanreal will respond within 45 calendar
days. Lanreal may extend this period by an additional 45 calendar
days (for a total of 90 calendar days) where reasonably necessary,
and will inform you of any extension within the original 45-day
window.

If Lanreal does not take action. If Lanreal decides not to take
action on your request, we will inform you within 30 days of receipt
of the reasons for not taking action and of your right to lodge a
complaint with a supervisory authority and to seek a judicial
remedy.

Authorized agents. California residents may use an authorized agent
to submit a rights request on their behalf. If you do so, we may
require the agent to provide written authorization from you and to
verify their own identity.

11. CHILDREN'S PRIVACY
======================

The Software is not directed to children. Lanreal does not knowingly
collect personal information from children under the age of 13 in
the United States (consistent with the Children's Online Privacy
Protection Act, or COPPA), or from children under the age of 16 in
the European Economic Area (consistent with GDPR Article 8). If you
are a parent or guardian and you believe your child has provided
personal information to Lanreal through the Software, please contact
us at support@whisperstream.io and we will take reasonable steps to
delete that information. The Software does not implement age
verification because it does not require account creation, does not
collect age or date-of-birth information, and is not directed to
children.

12. SECURITY SAFEGUARDS
=======================

Lanreal implements security safeguards proportional to the
sensitivity of the personal information the Software processes.
Because the data flow described in Section 3 is narrow by design
(ordinary connection data for update, model, policy, and list
requests, and only the content you choose to submit), the attack
surface is correspondingly narrow. In particular:

- Lanreal does not maintain a user account database for the Software
  in the conventional sense: the Software does not require user
  registration, does not issue Lanreal-hosted credentials, and does
  not track individual user accounts. The only Lanreal-hosted
  database containing personal information is the reviews and
  feedback database described in Section 3.5, which is populated
  only by content that you have voluntarily submitted.
- All network communications described in Section 3 travel over
  HTTPS with the certificate-verification behaviour of the
  underlying HTTP library. The Software does not disable certificate
  verification.
- Update manifests and installers are cryptographically signed using
  minisign and verified locally on your device before installation.
  Model files are verified against pinned checksums before
  installation.
- The local backend process binds exclusively to 127.0.0.1 on a
  fixed port, so that no other device on your network can reach it.
- Local configuration, logs, and usage statistics are stored under
  your Windows user profile with the access controls your operating
  system provides.
- The local transcript history described in Section 3.4 separately
  encrypts the raw transcript, enhanced transcript, waveform peaks,
  and, if enabled, audio using AES-256-GCM. The AES data key is
  itself sealed using the Windows Data Protection API, bound to your
  Windows user account on the specific device, so the history can be
  decrypted only by the same Windows user on the same device.
  Lightweight index metadata needed for lookup and playback remains
  unencrypted. Existing plaintext waveform peaks from an older
  database schema are transactionally migrated to separately
  authenticated ciphertext when the data key is available; if the
  history is locked, migration is deferred and retried after unlock.
  The replacement of a legacy database value uses ordinary SQLite
  updating and is not represented as secure erasure of storage
  remnants.
- When Lockdown Mode (Section 3.6) is on, the Software adds a
  password layer to the transcript history. A key derived from a
  password you choose (using the scrypt key-derivation function) and
  a separate key derived from a one-time recovery code each wrap the
  transcript encryption key using AES-256-GCM, on top of the at-rest
  encryption and Windows Data Protection API sealing described
  above. The transcript history locks automatically after an idle
  period you set, and repeated failed unlock attempts trigger
  escalating delays. Lanreal never receives your password or your
  recovery code.
- For the optional cloud post-processing feature described in
  Section 6, credentials (API keys) that you supply are encrypted at
  rest using the Windows Data Protection API (specifically, the
  CryptProtectData function), which binds the encrypted value to
  your Windows user account on the specific device where the
  credential is stored. A different Windows user on the same device
  cannot decrypt the stored credential, and neither can any user on
  a different device. The encrypted credential is stored under
  %LOCALAPPDATA%\Whisperstream\ with the access controls your
  operating system provides, and is not part of the bug-report log
  export described in Section 8, so it is not inadvertently
  transmitted when you submit a bug report to Lanreal.
- When the optional cloud post-processing feature is enabled, each
  request to the provider you selected travels over HTTPS with
  certificate verification enabled. Your credential is transmitted
  only as a request header on those requests, and only to the
  provider you selected. The Software does not transmit the
  credential to Lanreal, to any service provider or recipient listed
  in Section 5, or to any other recipient.

No security program can guarantee absolute protection against all
threats. If you become aware of a security issue affecting the
Software, please contact Lanreal at support@whisperstream.io.

12A. DATA BREACH NOTIFICATION
=============================

In the event of a breach of security safeguards involving personal
information under Lanreal's control that creates a real risk of
significant harm to you, Lanreal will:

(a) report the breach to the Office of the Privacy Commissioner of
Canada in accordance with section 10.1 of the Personal Information
Protection and Electronic Documents Act and the associated Breach of
Security Safeguards Regulations (SOR/2018-64);

(b) notify you of the breach as soon as feasible after determining
that the breach has occurred, by email if we have your email address
on file through a purchase, feedback submission, or correspondence,
or by prominent notice on the Whisperstream website at
https://whisperstream.io if we do not have a direct means of
contacting you;

(c) where required by the General Data Protection Regulation
(Articles 33 and 34), notify the relevant European supervisory
authority within 72 hours of becoming aware of the breach, and
notify you without undue delay where the breach is likely to result
in a high risk to your rights and freedoms; and

(d) where required by the California Consumer Privacy Act or other
applicable law, provide notice in accordance with the requirements
of that law.

Lanreal maintains a record of all breaches of security safeguards
involving personal information under its control, as required by
section 10.1(3) of the Personal Information Protection and
Electronic Documents Act and the Breach of Security Safeguards
Regulations (SOR/2018-64). This record is retained for at least 24
months and is available to the Office of the Privacy Commissioner of
Canada upon request.

12B. BUSINESS TRANSFERS
=======================

If Lanreal Technologies Inc. is involved in a merger, acquisition,
reorganization, sale of assets, or bankruptcy, personal information
we hold may be transferred as part of that transaction. If such a
transfer occurs, the acquiring entity's use of your personal
information will remain subject to the commitments made in this
Privacy Policy. We will notify you of any such transfer and of any
changes to the applicable privacy terms by updating this Privacy
Policy (see Section 14) and, where feasible, by notice on the
Whisperstream website. Where required by applicable law, we will
obtain your consent before transferring your personal information to
the acquiring entity.

12C. LAW ENFORCEMENT AND GOVERNMENT REQUESTS
============================================

Lanreal may disclose personal information to law enforcement,
regulatory authorities, courts, or other governmental bodies where
we are legally required to do so (for example, in response to a
valid subpoena, warrant, or court order), or where we reasonably
believe disclosure is necessary to comply with applicable law or to
protect the safety of any person. Lanreal will attempt to notify you
of any such disclosure before it occurs, unless notification is
prohibited by law or court order. Lanreal does not voluntarily
provide personal information to any government surveillance
programme.

12D. SURVIVAL
=============

Sections 8 (How Long We Keep It), 10 (Your Rights), 11 (Children's
Privacy), 12 (Security Safeguards), 12a (Data Breach Notification),
12b (Business Transfers), 12c (Law Enforcement and Government
Requests), 13 (CCPA Notice for California Residents), 14 (Changes to
This Policy), 15 (How to File a Complaint), and 16 (Contact Us) of
this Privacy Policy, and any obligations arising from a data breach
that occurred before termination, survive the termination of your
license or the uninstallation of the Software for as long as Lanreal
retains any personal information about you.

13. CCPA NOTICE FOR CALIFORNIA RESIDENTS
========================================

This section supplements the rest of this Privacy Policy for
California residents whose personal information is collected by
Lanreal through the Software, and is provided in accordance with the
California Consumer Privacy Act of 2018, as amended by the
California Privacy Rights Act (the "CCPA").

Categories of personal information collected. In the preceding
twelve months, Lanreal has collected the following categories of
personal information from or about California residents through the
Software, as those categories are defined by Cal. Civ. Code Section
1798.140(v). Items marked "earlier versions" describe processing by
earlier versions of the Software during that period that this
version no longer performs.

- A. Identifiers (such as real name, alias, postal address, unique
  personal identifier, online identifier, IP address, email address,
  account name, or similar identifiers): IP address, visible to
  Cloudflare during update checks, update downloads, and cloud-model
  list requests, and, through earlier versions, trial-extension
  policy checks; to Hugging Face and GitHub during model downloads
  (Hugging Face and GitHub receive it as independent recipients, as
  described in Section 5); and to Supabase as an automatic byproduct
  of the HTTPS connection during feedback submission; the email
  address you enter when you send feedback (Section 3.5); and,
  through earlier versions, the device hostname and license key
  forwarded to Polar for license activation (Section 3.1), the IP
  address visible to Polar during license validation, the customer
  email received from Polar and sent with a rating, and the display
  name supplied with an earlier testimonial. If you submit a feature
  request under Section 3.12, Featurebase may also receive the name,
  email, username, IP address, or other account identifier you
  provide or that its board ordinarily processes. If you contact
  Lanreal (Section 3.13), Lanreal receives the contact details you
  send.
- B. Personal information categories listed in Cal. Civ. Code
  Section 1798.80(e) (such as name, signature, social security
  number, physical characteristics, address, telephone number,
  passport number, or similar): display name if supplied with an
  earlier testimonial (Section 3.5), and a name or similar
  information if you voluntarily provide it to Featurebase (Section
  3.12) or in correspondence (Section 3.13). Other information in
  this statutory category is not requested, but could appear in a
  voluntary freeform submission or message.
- C. Characteristics of protected classifications under California
  or federal law (such as race, religion, sexual orientation, gender
  identity, marital status, medical condition, or similar): Not
  requested. A voluntary Featurebase submission or message could
  contain this information despite the instructions in Sections 3.12
  and 3.13.
- D. Commercial information (such as records of personal property,
  products or services purchased, obtained, or considered, or other
  purchasing histories): Purchase processing was handled separately
  by Polar at checkout and is not transmitted by the Software.
  Refund handling under Section 3.13 can involve purchase and refund
  records. Feedback is opinion content, not a purchase history. A
  voluntary Featurebase submission could nevertheless contain
  commercial information if you choose to include it.
- E. Biometric information: None. Voice audio is processed by the
  on-device speech recognition model solely for the purpose of text
  transcription, not for the purpose of identifying you. The audio
  is processed in volatile memory for each push-to-talk capture and,
  if you enable audio saving in the local transcript history
  (Section 3.4), is also stored only on your own device, encrypted
  at rest. It is never transmitted to Lanreal, and is never used to
  create a voiceprint, template, or other biometric identifier.
- F. Internet or other electronic network activity information (such
  as browsing history, search history, or interactions with a
  website, application, or advertisement): None beyond the network
  flows described in Section 3 (update checks, required or
  user-selected model downloads, the cloud-model list, feedback
  submissions described in Section 3.5, an optional Featurebase
  submission under Section 3.12, and, through earlier versions,
  license activation and validation and trial-extension policy
  checks). If you enable the optional cloud post-processing feature
  described in Section 6, additional network activity (the
  transmission of transcribed text to the provider you selected)
  also falls within this category; see Section 6 for details.
- G. Geolocation data: None.
- H. Audio, electronic, visual, thermal, olfactory, or similar
  information: Feature-request messages and attachments, and
  messages and attachments you send to Lanreal, are electronic
  information disclosed when you choose to submit them. Do not
  attach audio, dictation content, or sensitive files. Voice data
  handled by Whisperstream remains on your device as described in
  category E above.
- I. Professional or employment-related information: Not requested.
  A voluntary Featurebase submission or message could contain this
  information.
- J. Education information: Not requested. A voluntary Featurebase
  submission or message could contain this information.
- K. Inferences drawn from any of the above to create a profile
  reflecting preferences, characteristics, psychological trends,
  predispositions, behaviour, attitudes, intelligence, abilities, or
  aptitudes: None.
- L. Sensitive personal information as defined by Cal. Civ. Code
  Section 1798.140(ae): Not requested. A voluntary Featurebase
  submission or message could contain this information despite the
  instructions in Sections 3.12 and 3.13; incidental content is
  handled as described there.

Local transcript history is not collected by Lanreal. The searchable
transcript history described in Section 3.4 (your saved transcribed
text and, if you enable it, your audio), the content-free local
access log described in Section 3.4, are created and kept entirely
on your own device, encrypted at rest where noted, and are never
transmitted to Lanreal. Because Lanreal never receives them, they
are not "collected," "sold," or "shared" by Lanreal within the
meaning of the CCPA, and they do not add a new category of personal
information to the list above. You retain full control of this
on-device information and can delete its database records and
associated files at any time (see Sections 3.4 and 8).

Sources of personal information. The IP address is an automatic
byproduct of the HTTPS connections described above. The email
address and feedback text are collected directly from you when you
send feedback. Correspondence is collected directly from you, and
related purchase and refund status may come from you or Polar.
Through earlier versions, the device hostname was supplied by your
own computer at license activation, the license key was issued to
you by Polar Software Inc. upon purchase, and the customer email
used with a rating was received from Polar. Featurebase
feature-request data is collected directly from the text,
attachments, account details, messages, and votes you choose to
provide on the external board; Featurebase also receives ordinary
connection and service-usage data from your visit to that board.

Business or commercial purposes for collecting personal information.
The IP address is not separately collected by Lanreal for a business
purpose; it is an automatic byproduct of the HTTPS connection
visible to the applicable recipient. Feedback, and ratings and
testimonials collected by earlier versions, are collected for the
business purposes of improving the Software, responding to user
feedback, and (where you checked the "feature my review on the
website" consent flag in an earlier version) publicly displaying
testimonials for marketing purposes. Correspondence is collected to
respond to your request, to handle refunds, and to perform other
surviving obligations. Through earlier versions, the device hostname
was collected to label license-activation slots and the license key
to activate, validate, and deactivate a Pro license. Featurebase
submissions are collected to evaluate and respond to feature
requests, administer the feedback board, and plan product
improvements.

Retention periods. The retention periods for each category of
personal information listed above are described in Section 8 of this
Privacy Policy. In summary: Category A data (device hostname,
license key, IP address) forwarded to Polar by earlier versions is
retained by Polar as described in Section 8. Feedback and reviews
you voluntarily submit under Section 3.5 are retained by Lanreal on
Supabase until you request deletion. Correspondence is retained as
described in Section 8. All other categories listed as 'None' above
are either not collected or are retained only on your local device
under your control. Featurebase feature-request data is retained
under the board configuration and Featurebase retention schedule
described in Section 8, until Lanreal or you delete it where the
board permits.

Categories of third parties with whom we share personal information.
Polar Software Inc., Cloudflare Inc., Supabase Inc., and CORDNET OU
(Featurebase), for the purposes described in Section 5, and the
correspondence services named in Section 5 for the correspondence
you send, and the refund payment services described in Section 5 for
a refund paid outside Polar. Hugging Face and GitHub receive
connection data directly from your device as independent recipients
when the Software downloads a model. The feedback fields (email,
feedback text, and, for earlier versions, rating, display name,
testimonial, and feature-on-website consent flag) are shared only
with Supabase when you voluntarily submit them. Information you
choose to submit on the Featurebase board, together with ordinary
board connection and service-usage data, is disclosed to Featurebase
for feedback-board operation and product planning.

Categories of personal information disclosed for a business purpose.
In the preceding twelve months, Lanreal has disclosed the following
categories of personal information to the following categories of
third parties for business purposes: Identifiers (IP address) to
Cloudflare Inc. for update checks and update delivery, the
cloud-model list, and, through earlier versions, trial-extension
policy checks and model downloads; through earlier versions,
Identifiers (device hostname, license key, IP address) to Polar
Software Inc. for license activation and validation; for users who
voluntarily submit feedback or a review, Identifiers (email, IP
address), Personal information in Section 1798.80(e) (display name,
for earlier testimonials), and electronic network activity
information (the submission itself) to Supabase Inc. for the
feedback and reviews database; Identifiers and electronic
information you send in correspondence to the correspondence
services named in Section 5; Identifiers and payment details to a
refund payment service for any refund paid outside Polar; and
Identifiers, electronic information, and ordinary network-activity
information to Featurebase for the external feature-request board.
If a user voluntarily includes them in a Featurebase message,
correspondence, or attachment despite the instructions in Sections
3.12 and 3.13, these disclosures may also include personal
information under Section 1798.80(e), characteristics of protected
classifications, commercial information, professional or
employment-related information, education information, or sensitive
personal information. Lanreal does not disclose any other category
of personal information to third parties for a business purpose.

Sale or sharing of personal information ("Do Not Sell or Share My
Personal Information"). Lanreal does not sell your personal
information to third parties in exchange for money or other valuable
consideration, and Lanreal does not share your personal information
for cross-context behavioural advertising. The transfer of feedback
content and email to Supabase, and of license data that earlier
versions sent to Polar, are disclosures to service providers for the
business purposes described above, not a "sale" or "sharing" within
the meaning of Cal. Civ. Code Sections 1798.140(ad) or 1798.140(ah).
Lanreal has not sold or shared personal information about California
residents in the preceding twelve months and does not intend to do
so. Because there is no sale or sharing, there is no "Do Not Sell or
Share My Personal Information" link; this Privacy Policy, which
discloses that the right is not applicable to Lanreal's practices,
serves as the required disclosure under Cal. Civ. Code Section
1798.135.

Use of sensitive personal information. Lanreal does not request or
use sensitive personal information for a purpose that triggers the
CCPA right to limit. A voluntary Featurebase submission or message
could contain sensitive personal information despite the
instructions in Sections 3.12 and 3.13; incidental content is
handled as described there.

How to submit CCPA requests. California residents may submit a
right-to-know, right-to-delete, right-to-correct, or
non-discrimination request by emailing support@whisperstream.io. As
a business that operates exclusively online and has a direct
relationship with its customers through the Software, Lanreal uses
email as its designated CCPA request method under Cal. Civ. Code
Section 1798.130(a)(1)(A).

14. CHANGES TO THIS POLICY
==========================

Lanreal may revise this Privacy Policy from time to time. When we
revise it, we will change the version number, effective date, or
last updated date at the top of this document. The version number of
this Privacy Policy is an identifier only and may differ from the
version of the Software it is bundled with. Whether a change is
material is determined by whether it changes how Lanreal collects,
uses, shares, or retains personal information, not by how the
version number changes.

How you learn about changes. The current version of this Privacy
Policy is the version bundled with the installer for the Software
version you have installed. New installs always receive whichever
version ships in the installer at the time of download. Existing
users receive the updated Privacy Policy with the updated installer.
If an updated End User License Agreement changes rights or
obligations, the installed release blocks content processing until
the user reviews the complete updated agreement and affirmatively
accepts it; closing, deferring, installing, or continued use does
not record acceptance. The most recent published Privacy Policy for
this edition is also available at
https://whisperstream.io/privacy/private. The privacy policy of the
open-source edition is a separate document and is not an update to
this Privacy Policy.

Service-provider and recipient changes. If Lanreal adds, removes, or
replaces a party listed in Section 5, or materially changes that
party's role or purpose, the change will be reflected in a new
version of this Privacy Policy. Lanreal also publishes a public
provider list at https://whisperstream.io/subprocessors and a
companion RSS feed at
https://whisperstream.io/subprocessors/feed.xml, both of which
mirror Section 5 and the human-readable changelog Lanreal maintains
for provider additions, removals, replacements, and material
updates. Except for changes required for security, legal, or
fraud-prevention reasons, Lanreal commits to publishing each
prospective provider change to that page and feed at least thirty
(30) days before it takes effect, so that you have a meaningful
opportunity to exercise the right to object to processing under
Article 21 of the General Data Protection Regulation, or the
equivalent right of withdrawal of consent and accountability-based
recourse under Canadian federal privacy law and the Personal
Information Protection and Electronic Documents Act, before the
change becomes operative. The page and feed are the canonical
advance-notice channel; Section 5 of this Privacy Policy remains the
authoritative source of truth for the current list.

15. HOW TO FILE A COMPLAINT
===========================

If you believe that Lanreal has processed your personal information
in a way that is inconsistent with this Privacy Policy or with
applicable privacy law, please contact Lanreal first at
support@whisperstream.io so that we have the opportunity to address
your concern. Lanreal's Privacy Officer will investigate your
complaint and respond within the timeline described in Section 10.
Lanreal commits to investigating all privacy complaints received
and, if a complaint is found justified, taking appropriate measures
including amending policies and practices where necessary.

If you are not satisfied with Lanreal's response, you may also have
the right to lodge a complaint with a supervisory authority:

- European Economic Area, the United Kingdom, and Switzerland: you
  have the right under GDPR Article 77 to lodge a complaint with the
  data protection supervisory authority of the Member State of your
  habitual residence, place of work, or the place of the alleged
  infringement.
- California: you may contact the California Privacy Protection
  Agency or the California Attorney General's Office for information
  about your rights under the CCPA.
- Canada (federal): you may file a complaint with the Office of the
  Privacy Commissioner of Canada (the 'OPC') at
  https://www.priv.gc.ca/en/report-a-concern/, toll-free
  1-800-282-1376. The OPC has the authority to investigate your
  complaint under section 11 of the Personal Information Protection
  and Electronic Documents Act, issue a Report of Findings, and make
  formal recommendations. If the matter remains unresolved after the
  OPC's investigation, section 14 of the Act grants you the right to
  apply to the Federal Court of Canada for a hearing.
- Canada (provincial): if you are a resident of Quebec, British
  Columbia, or Alberta, your provincial regulator may have parallel
  jurisdiction. You may contact Quebec's Commission d'acces a
  l'information at https://www.cai.gouv.qc.ca, the Office of the
  Information and Privacy Commissioner for British Columbia at
  https://www.oipc.bc.ca, or the Office of the Information and
  Privacy Commissioner of Alberta at https://www.oipc.ab.ca.

Nothing in this section limits any other right or remedy available
to you under applicable law.

16. CONTACT US
==============

Questions, requests, and complaints about this Privacy Policy and
about Lanreal's handling of personal information should be directed
to Lanreal's Privacy Officer:

Privacy Officer Lanreal Technologies Inc. 18 King Street East, Suite
1400 Toronto, Ontario M5C 1C4 Canada

Email: support@whisperstream.io

Lanreal Technologies Inc. is the data controller for the personal
information described in this Privacy Policy. The Privacy Officer is
the designated contact for Canadian federal privacy law, for GDPR
Articles 13 and 14, and for CCPA consumer requests.

Accessibility. This Privacy Policy is available in Markdown format
bundled with the Software, in plain text format inside the
installer, and in HTML format at
https://whisperstream.io/privacy/private. If you need this Privacy
Policy in an alternative format to accommodate a disability, please
contact us at support@whisperstream.io.

Copyright (c) Lanreal Technologies Inc. All rights reserved.