Privacy Policy

Introduction

Copysmith AI, Inc ("us", "we", or "our") operates the https://www.frase.io, https://next.frase.io and https://app.frase.io websites and the Frase mobile application (collectively, the "Services"). This page informs you of our policies and practices regarding the collection, use and disclosure of information which personally identifies you ("Personal Information") when you use our Services.

We will not use or share your information with anyone except as described in this privacy policy (the "Privacy Policy"). We use your Personal Information for providing and improving the Services. By using the Services, you agree to the collection and use of your Personal Information in accordance with this Privacy Policy.

Information Collection and Use; Personal Information

We may ask you to provide us, or third parties may provide us, with certain Personal Information that can be used to contact or identify you. Personal Information may include, but is not limited to, your name, postal address, email address, and employer.

We collect Personal Information for the purpose of providing the Services, identifying and communicating with you about the Services, responding to your requests/inquiries, servicing your purchase orders, improving our Services, and communicating with you about our Services, discounts, and promotions.

How Long We Keep Your Personal Information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account Information

We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, it will be anonymized and used to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

Managed Accounts

If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by your employer under our agreement with your employer as required by the administrator of your account. If your account is deactivated, your information and conversations you may have had and actions you may have taken on the Services will remain in order to allow your team members to make full use of the Services.

Marketing Information

If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. Every marketing email we send will provide you with the option to opt out of receiving future emails.

Accessing and Correcting Your Personal Information

We acknowledge individuals' rights to access their personal information. You may access, update, correct or have removed from our systems and records the Personal Information you provided to us by emailing a request to support@frase.io or contacting us by telephone or postal mail as further specified in the How to Contact Us clause of this Privacy Policy.

To protect your privacy and security, we will also take reasonable steps to verify your identity before updating or removing your information.

Information Collected Directly from You

We collect information about you when you provide it to us and automatically when you use the Services.

Log Data

We collect information that your browser sends whenever you visit our website or use our Services ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Services' functionality. These third-party service providers have their own privacy policies addressing how they use such information. This is Frase's own analytics of visits to our Services. It is separate from, and must not be confused with, a Google Analytics account that you may choose to connect to Frase, which Frase only reads and never writes to — see Google User Data.

When you access the Services by or through a mobile device, we collect certain information automatically, including the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, and your general location information as described further below.

Location Information

We use and store information about your general location. We use this information to provide features of our Services and to improve and customize our Services.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device. We use cookies to collect information in order to improve our Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The "Help" feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Services and we recommend that you leave them turned on.

Do Not Track Disclosure

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the "Preferences" or "Settings" page of your web browser.

Use of Customer Data for AI/ML Models

Frase does not use Customer Data obtained through Google APIs or any other platform to develop, improve, or train generalized AI and/or machine learning (ML) models. Any data accessed through these APIs is used solely for the purpose of providing services to you, and we ensure that no data is retained for any purpose related to training AI/ML models. Frase explicitly affirms that the data is handled in compliance with Google's policies and that no user data is used to develop generalized AI models.

For a full description of the Google data Frase accesses, how it is used, and with whom it is shared, see Google User Data below.

Information Collected from Other Sources

We will enrich your Personal Information with additional Personal Information received from publicly accessible sources. We may also receive your information from services you integrate with Frase, from other users of Frase, or from our partners.

Integrations

You may enhance the Services by enabling Frase integrations with third-party products. If you provide third-party account credentials to us, you understand some content and/or information in those accounts ("Third Party Account Information") will be transmitted into your account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy.

Further, Frase may request permission to take actions on your behalf using your third-party account credentials. For example, if you connect a content management system, Frase can publish content you have approved to that system. Frase requests only the permissions a feature needs, and each integration shows you what it is asking for before you connect it. Some integrations are read-only and cannot change anything in the connected account.

Where the third-party product is a Google service, the two paragraphs above are qualified by the Google User Data section below, which governs and states exactly what Frase can and cannot reach in each case.

Other Users of the Services

Other users of our Services may provide information about you when they use the Services. For example, we receive your email address from other Service users when they provide it in order to invite you to the Services.

Partners

We work with partners who may market, sell, or support our Services. These partners may provide us your Personal Information so that we can contact you. We also may receive your Personal Information from advertising, market research, or data enrichment partners with whom we engage to identify prospective customers.

Google User Data

How Frase accesses and uses Google user data

Frase connects to Google services only when you choose to connect them, and only for the features described here. You can connect one service without connecting the others, and you can disconnect at any time. Where you connected more than one service with the same Google account, removing that account can end those connections together.

Google Search Console. With your permission, Frase reads search performance data for the properties you select: the queries your pages appear for, their impressions, clicks, average position, and the URLs involved. Frase uses this to show you how your content is performing, to identify pages and queries worth improving, and to inform the recommendations and drafts you ask Frase to produce. Frase requests read-only access and cannot change anything in your Search Console account.

Google Analytics. With your permission, Frase reads reporting data for the Analytics properties you select, such as sessions, engagement, and page-level traffic. Frase uses this to show how your content performs alongside your search data. Frase requests read-only access and cannot change anything in your Analytics account.

Google Docs and Google Drive. When you use the Google file picker inside Frase, Frase accesses only the individual files you select in that picker. Frase uses this to bring a document into Frase to work on, and to send finished content back out to a document you choose. Frase cannot see, list, or open any other file in your Drive.

Your Google account email address. When you connect a Google service, Frase records the email address of the Google account you connected, so that you and your teammates can tell multiple connections apart.

Confirming an email address. Frase also offers Google sign-in as a way to confirm that you own an email address you are adding to your Frase account. Google returns the basic profile information for that account — your email address, name, and profile picture. Frase reads the email address, checks that it matches the address you entered, and does not store the name or the profile picture.

Frase does not request access to Gmail, your contacts, your calendar, or your Google Drive as a whole.

How Frase shares, transfers, and discloses Google user data

Frase does not sell Google user data, and does not share it for advertising. Frase transfers Google user data only in the circumstances below.

• Service providers that operate the Frase platform. Cloud hosting, storage, and database providers hold your Google user data so that Frase can show it back to you. These providers act on Frase's instructions under written agreements and may not use the data for their own purposes.
• AI model providers, when you ask Frase to generate or analyze content. Some Frase features include your connected Google data as context in the request sent to the AI provider that powers the feature. For example, when you ask Frase to improve a page, Frase may include that page's Search Console queries and performance so the result reflects how the page is actually performing. These providers process the request and return a result; they are not permitted to use your data for their own purposes, including training their models.
• People in your organization. Anyone with access to your Frase workspace can see the connected data in that workspace.
• Where you direct us to send it. For example, exporting a finished piece of content to a Google Doc you select.
• Legal requirements. Where we are required to disclose data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
• A merger, acquisition, or sale of assets. If Frase is involved in one, Google user data may transfer as part of it, and only after we obtain your explicit prior consent.

Frase does not transfer Google user data to any other third party. In particular, Google user data is never sold, and is never transferred to advertising platforms, data brokers, or information resellers.

Frase maintains a current list of the service providers that process Google user data on its behalf, and will provide that list to a customer on request.

Limited Use

Frase's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. These commitments apply both to the data Frase obtains from the Google permissions described above and to anything aggregated, anonymized, or derived from it. Specifically:

• Frase uses Google user data only to provide or improve user-facing features that are prominent in the Frase user interface.
• Frase transfers Google user data only where doing so is necessary to provide or improve those features, for security purposes, to comply with applicable law, or as part of a merger, acquisition, or sale of assets after obtaining your explicit prior consent.
• Frase does not use Google user data for advertising, including retargeting and personalized or interest-based advertising, and does not sell it.
• Frase does not use Google user data to develop, improve, or train generalized artificial intelligence or machine learning models.
• Frase does not allow humans to read Google user data, except: where you have given affirmative agreement to view specific data; where necessary for security purposes, such as investigating a bug or abuse; to comply with applicable law; or where the data, including anything derived from it, is aggregated and used for internal operations in accordance with applicable privacy and other legal requirements.

Keeping and deleting Google user data

You can disconnect any Google connection at any time from your Frase settings, and you can withdraw Frase's access from your Google Account permissions page. When you disconnect, Frase stops accessing that Google service and removes the stored credentials for that connection. Data already brought into your workspace — stored search performance history, or a document you imported — remains available to you until you or your workspace administrator deletes it, or your account is closed, except where we are required to retain it to comply with a legal obligation.

Service Providers who may Receive Your Personal Information

We may employ third-party companies and individuals (our "agents") to facilitate our Services, to provide the Services on our behalf, to perform complementary services and/or to assist us in analyzing how our Services are used. Examples may include storing data, delivering messages, processing credit card payments, analyzing data, providing marketing assistance, managing our agreements with you, supplementing the information you provide us in order to provide you with better service, and providing customer service.

We do not transfer data to non-agent third parties. These third parties have access to your Personal Information only to perform specific tasks on our behalf and are under written obligation not to disclose or use your Personal Information for any purpose other than those disclosed in this Privacy Policy.

Notwithstanding such legal and contractual obligations between us and such service providers, we remain potentially liable for any misuse of your Personal Information. We will only disclose Personal Information when we are required to do so in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Communications; Your Options

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by emailing support@frase.io.

Security of Personal Information

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

Links To Other Sites

Our Services may contain links to other web sites or online locations that are not operated or controlled by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site or location you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children's Privacy

Only persons who are age 18 or older have permission to access our Services. Our Services are not intended to be used by anyone under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from children under 13.

If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we take steps to remove that information from our servers.

For EU Users

This section applies only to Users located in the European Union.

Contact Information for the Data Controller

This paragraph pertains only to individuals for whom Frase is a "controller" within the meaning of Regulation (EU) 2016/679 of the German Parliament and of the Council of 27 April 2016 ("GDPR"):

Controller of your Personal Information:
Copysmith AI, Inc.
2127 Morris Ave,
Birmingham, AL 35203
Email: support@frase.io

Legal Bases for Processing EU Users' Personal Information

We only process your information when we have the legal basis to do so. That is, we will only process your Personal Information when:

• We need it to provide you the Services;
• You give us consent for a specific purpose; or
• It satisfies Frase's legitimate interests (which are not overridden by your data protection interests), such as for improving, marketing, and promoting the Services and protecting our legal rights;
• We need to process your data to comply with our legal obligations.

EU Users' Rights to Control Personal Information

You have control over your Personal Information. Below are the rights you have and the steps you can take to exercise them. Please note that your rights may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your employer are permitted by law or have compelling legitimate interests to keep, and it may take time for us to investigate your request.

If you believe that we are not respecting your rights with regard to your Personal Information, you may lodge a complaint with your local supervisory authority.

Right to Access

You have a right to request a copy of the Personal Information that Frase holds. To request this information, please email us at support@frase.io.

Right to Rectification

If you believe that any Personal Information that Frase holds is incorrect, you have the right to correct that information. You can change your Frase account information on the "Settings" page, and if you have any further concerns regarding the accuracy of your information, please email us at support@frase.io.

Right to Erasure, Restriction, or Objection to Processing

If you believe we do not have the right to process your information or you object to our processing for a particular purpose, or if you want us to erase your Personal Information altogether, please email us at support@frase.io.

Right to Withdraw Consent

If you gave us consent to process your Personal Information for a particular purpose, you have the right to withdraw that consent by emailing us at support@frase.io. Your withdrawal of consent does not affect the lawfulness of our processing of your Personal Information prior to the withdrawal.

Data Portability

You have the right to obtain the Personal Information that you have directly submitted to Frase in a format you can transfer to another service provider. If you want to exercise this right, please email us at support@frase.io.

Changes to This Privacy Policy

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Services after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

How to Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

Email: support@frase.io

Frase is wholly owned by Copysmith AI, Inc.
Our Address is 2127 Morris Avenue, Birmingham, AL 35203