This Privacy Policy describes how AdamX Inc. (doing business as “AdamX”) (“AdamX”, “we”, “us”, or “our”) collects, uses, discloses, and protects personal information when you visit our websites, use our products and services—including Top Rep, Top Journey, Role Play, and Champions—or interact with us (collectively, the “Services”).

By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree, do not use the Services.

1. Scope

This Policy applies to personal information we process as a controller when we determine the purposes and means of processing (e.g., website visitors, marketing, account administration). When we process Customer Data on behalf of our business customers through the Services, we act as a processor/service provider and our processing is governed by our agreement with that customer (e.g., a Data Processing Addendum). Customers are responsible for providing any required notices to, and obtaining any necessary consents from, individuals whose information is submitted to the Services.

2. Information We Collect

• Information you provide: account and profile details (name, email, role, company), authentication credentials, billing and payment information, communications with us, support requests, feedback.
• Customer Data: meeting recordings, transcripts, chat logs, call metadata, CRM records, content, documents, and other data you or your organization connect or upload to the Services.
• Automatically collected information: device and usage information (IP address, browser type, device identifiers, pages viewed, referring/exit pages, timestamps), log data, performance and diagnostic data, and approximate location derived from IP.
• Cookies and similar technologies: cookies, pixels, local storage, and SDKs used for authentication, preferences, analytics, and to improve and secure the Services. You can control cookies via your browser settings; some features may not function without required cookies.
• Third-party sources: data from service providers and integration partners (e.g., Gong, Zoom, Salesforce, HubSpot, LinkedIn), analytics providers, and publicly available sources.
• Derived data and AI outputs: embeddings, scores, classifications, summaries, and other outputs generated by AI/ML processing of Customer Data.

3. How We Use Information

We use personal information to:

• Provide, operate, maintain, and secure the Services
• Process and analyze Customer Data to generate insights and outputs requested by customers
• Improve and develop the Services. For clarity, we do not use Customer Data to train, fine-tune, or improve any AI models.
• Communicate with you about the Services, including service updates, security alerts, and support
• Conduct analytics, quality assurance, and research
• Personalize experiences and content
• Market and promote the Services consistent with your preferences and applicable law (you can opt out of marketing communications at any time)
• Comply with legal obligations, enforce our agreements, and prevent harm

4. Legal Bases (EEA/UK/Switzerland)

Where required, we process personal information under the following legal bases: (a) performance of a contract (to provide the Services); (b) legitimate interests (e.g., to secure and improve the Services, prevent fraud, and market to business contacts); (c) consent (e.g., certain cookies/marketing); and (d) compliance with legal obligations.

5. Sharing and Disclosure

We share personal information with:

• Service providers and subprocessors who process data on our behalf to operate, secure, and support the Services (e.g., cloud hosting, data storage, analytics, email, customer support). We require them to protect personal information and use it only as instructed.
• Integration partners and third-party services you choose to connect (e.g., Gong, Zoom, Salesforce, HubSpot). Their use of information is governed by their policies.
• Professional advisors (lawyers, auditors), and in connection with business transactions (mergers, acquisitions, financing, or sale of assets) subject to confidentiality.
• Authorities and other parties when required by law or to protect rights, safety, and security, or to enforce our agreements.We do not sell personal information as defined by applicable law. We do not share personal information for cross-context behavioral advertising without your consent.

6. International Data Transfers

We are headquartered in the United States and currently store and process personal information in the United States. If we expand to other regions in the future, we will use appropriate safeguards (e.g., Standard Contractual Clauses) to protect personal information transferred internationally.

7. Data Retention

We retain personal information for no longer than necessary. By default, Customer Data such as recordings, transcripts, and derived outputs are retained for 30 days. We will delete earlier upon request and will process deletion requests within 30 days, unless a longer period is required by law.

8. Security

We implement technical and organizational measures designed to protect personal information, including encryption in transit and at rest, access controls, and secure development practices. We maintain a SOC 2–aligned security program. No security measures are perfect; you use the Services at your own risk. Please notify us promptly of any suspected security incidents. For more information, visit our [Trust Center](https://trust.adamx.ai).

9. Your Rights and Choices

Depending on your location, you may have rights to access, correct, update, delete, restrict, or object to processing of your personal information, and to data portability. You also may have the right to withdraw consent where processing is based on consent.

To exercise rights, contact us at [email protected]. We may need to verify your identity and, if applicable, work with your organization (the controller) to fulfill your request. You may also manage certain preferences in your account settings.

Marketing communications: You can opt out of marketing emails by using the unsubscribe link in our messages or contacting us. You will still receive transactional or service-related communications.

Cookies: Most browsers allow you to control cookies. Required cookies are necessary for the Services to function. Optional analytics/marketing cookies can be managed through browser or in-product controls where available.

10. State/Regional Disclosures

• California/US state privacy laws (e.g., CCPA/CPRA, CPA, VCDPA): We act as a “service provider”/”processor” when processing Customer Data for business customers. We do not “sell” or “share” personal information. You may have rights to know, access, correct, delete, and opt out of certain processing. Submit requests at [email protected].
• EEA/UK/Switzerland: You may lodge a complaint with your local supervisory authority. If we rely on consent, you may withdraw it at any time.

11. Children’s Privacy

The Services are not directed to children under 16, and we do not knowingly collect personal information from children under 16. If you believe we have collected such information, contact us to request deletion.

12. AI/ML Processing Transparency

The Services use AI/ML models to analyze recordings, transcripts, and related data to generate insights (e.g., call scores, sentiment, summaries, and content). Outputs may be probabilistic and may contain errors. Customers should review outputs before relying on them. We apply access controls and safeguards appropriate to the sensitivity of processed data.

13. Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy with a new Effective Date and indicate material changes where appropriate. Your continued use of the Services after an update constitutes acceptance of the revised Policy.

14. Contact Us

If you have questions or requests regarding this Policy or our privacy practices, contact us at [email protected] or write to: AdamX Inc., Attn: Privacy, 1702 Meridian Avenue, Suite L-150, San Jose, CA 95125. For support inquiries, contact [email protected].

Controller: AdamX Inc.