Privacy policy

Flexspeak, Inc. ("Flexspeak," "we," "us," or "our") is committed to protecting the privacy and security of personal data. This Privacy Policy explains how we collect, use, protect, and retain personal data when you use our websites, applications, and services (collectively, the "Services").

1. Scope of This Policy

This Privacy Policy applies to all Flexspeak Services.

Some Services, including Flexspeak Studio, are provided to schools, school districts, and other educational institutions under institutional agreements. When Services are used in an educational or school-managed context, Flexspeak processes student data solely on behalf of and under the direction of the contracting institution, and the student-specific provisions described in this policy apply.

Where Services are used directly by individuals or families, including AAC users who access Flexspeak outside of a school setting, Flexspeak acts as a service provider directly to the user, subject to applicable law.

Depending on how you use the Services, different data practices apply:

• School-managed Student Data is processed under institutional agreements and the education-specific provisions in Section 5.

• AAC end-user accounts, meaning individuals or families using Flexspeak for assistive communication outside a professional or school-managed context, are not subject to sales lead scoring, marketing qualification, or CRM-based sales outreach described in Sections 3 and 4.

• Professional Users, including educators, clinicians, administrators, and other professionals using Flexspeak for instructional, clinical, or administrative purposes, may be subject to additional processing for product improvement, account management, and commercial relationship management as described in this Policy.

If there is any conflict between the general provisions of this Privacy Policy and provisions governing school-managed educational use, the education-specific provisions control with respect to Student Data.

2. Definitions

Student Data

"Student Data" means personal data and user-generated content associated with students using Flexspeak in a school-managed or institution-licensed context, including data protected under FERPA.

Professional Users

"Professional Users" means educators, clinicians, administrators, or other professionals using Flexspeak for instructional, clinical, or administrative purposes.

Lead Scoring

"Lead scoring" means a process used to better understand professional or institutional interest in Flexspeak's offerings and to help prioritize sales, onboarding, customer success, and support outreach.

Lead scoring is used only for commercial relationship management involving Professional Users and eligible marketing contacts. It is not used to evaluate students, AAC end-users, educational performance, communication ability, clinical progress, or eligibility for Services.

Marketing Qualification Data

"Marketing qualification data" means information used to understand whether a professional contact, educator account, or institutional prospect may be interested in or likely to benefit from Flexspeak's professional or institutional offerings.

Marketing qualification data may include contact information, professional role, organization or institution, referral source, website engagement, communication preferences, product interest, and engagement with Flexspeak's professional offerings.

3. Information We Collect

3.1 Information You Provide

Depending on how the Services are used, we may process:

• Account and contact information

• User profile details

• User-generated content, such as communication boards, symbols, text, audio, or other content created or uploaded through the Services

• Accessibility and configuration settings

• Progress or usage data to support communication, educational, or therapeutic use

For Professional Users and educator accounts, we may also collect:

• Professional role or discipline, such as speech-language pathologist, teacher, occupational therapist, administrator, or other professional role

• Referral or "how did you hear about us" information

• Work or institutional email address, where provided

• Information submitted through marketing, interest, demo, or contact-sales forms

We do not collect professional role, referral source, or marketing qualification data for the purpose of sales lead scoring from Communicator (student or AAC end-user) accounts.

3.2 Automatically Collected Information

We automatically collect certain technical and operational information necessary to run, secure, and improve the Services, including:

• Device, browser, and application performance data

• Authentication, security, and audit logs

• Session and feature usage necessary to operate core functionality

For Professional Users, we may also collect information about how you interact with our Services, such as feature usage, account activity, engagement with product features, and activity related to professional or institutional offerings.

We use this information to operate and improve the Services, enhance reliability, support account management, and improve onboarding and customer success.

3.3 Voice Data and Voice Cloning

If you use voice cloning, we collect short voice recordings and use them to create a digital voice model. Voice recordings and voice models are biometric information that can identify a person.

We collect voice data only with the written in-app consent of the speaker or their parent or legal guardian. We use it solely to provide the cloned voice for assistive communication. We do not sell voice data, use it for advertising or marketing, or use it to train AI models.

Recordings are transmitted to our voice provider (ElevenLabs) to build the voice model and are not stored by Flexspeak. The voice model is stored by ElevenLabs and is permanently destroyed when you delete the voice in the app or when you delete your account.

You may delete a cloned voice at any time in the app, or by contacting us as described in Section 14.

Marketing Engagement

If you receive marketing communications from Flexspeak, submit your email through our website, request information, book a demo, or otherwise interact with Flexspeak's professional offerings, we may collect information about your engagement with those communications or offerings.

This may include whether you opened or clicked an email, submitted a form, requested a demo, viewed information about pricing or plans, or otherwise expressed interest in Flexspeak's professional or institutional offerings.

What We Do Not Do for AAC End-Users or Student Data

We do not use automatically collected information from AAC end-user accounts or Student Data for:

• Sales lead scoring

• Marketing qualification

• CRM-based sales outreach

• Advertising

• Targeted marketing

Analytics for Student Data, where permitted, remain limited to operational functionality, performance, and reliability in aggregated or de-identified form, as described in Section 5.

4. How We Use Personal Data

We use personal data to:

• Provide, operate, and support the Services

• Maintain system security and reliability

• Respond to support requests and communications

• Meet legal and regulatory obligations

• Improve product functionality and user experience

• Understand how Professional Users engage with Flexspeak's professional offerings

• Manage commercial relationships with educators, clinicians, administrators, institutions, and other Professional Users, where permitted

Product Analytics

Flexspeak uses analytics tools to understand how the Services are used and to improve functionality.

Analytics may be used to understand:

• System performance

• Feature usage trends

• Product reliability

• User experience

• Errors, bugs, and technical issues

• Adoption of professional or institutional features

Where appropriate, analytics data may be processed in an aggregated or de-identified manner.

Analytics involving Student Data, where permitted, are limited to operational functionality, performance, and reliability and are not used for advertising, marketing, commercial sales qualification, or targeted sales analytics.

Marketing and Customer Relationship Management

For Professional Users and individuals who interact with Flexspeak's professional offerings, such as by subscribing to updates, requesting information, submitting an interest form, booking a demo, or creating an educator account, we may use contact information and engagement data to:

• Send product updates and marketing communications

• Respond to inquiries and support requests

• Manage customer relationships

• Improve onboarding and customer success

• Better understand interest in Flexspeak's professional offerings

• Prioritize sales, success, and onboarding outreach for professional or institutional offerings

This processing applies only to Professional Users and eligible marketing contacts.

It does not apply to Student Data or AAC end-user accounts.

Lead Scoring

Flexspeak may use information about how Professional Users and marketing contacts interact with our website, communications, and Services to better understand interest in our professional offerings and to prioritize sales, onboarding, support, and customer success efforts.

Lead scoring:

• Applies only to Professional Users and eligible marketing contacts

• Is used solely for commercial relationship management, onboarding, support, sales, and customer success

• Is never used to evaluate students, AAC end-users, educational performance, communication ability, clinical progress, or eligibility for Services

• Does not use Student Data or school-managed educational records

• Does not use AAC end-user account data

We do not sell personal data used for lead scoring.

We do not use Student Data or AAC end-user data for lead scoring.

5. Educational Use and Student Data

When Flexspeak is used in a school-managed or institution-licensed context:

• Student Data is processed solely to provide educational and assistive communication services

• Flexspeak does not use Student Data for advertising, marketing, or commercial purposes

• Flexspeak does not sell Student Data

• Student Data is not used to train or improve products or services for students

• Student Data is not used for non-educational research, profiling, or targeted analytics

Any analytics involving Student Data are limited to operational functionality, performance, and reliability, and are conducted only in an aggregated or de-identified form.

Flexspeak acts as a data processor with respect to Student Data and processes such data only in accordance with institutional instructions and applicable law, including FERPA.

AAC End-User Accounts

When individuals or families use Flexspeak as AAC end-users outside a school-managed or professional administrative context, Flexspeak does not use their personal data for:

• Advertising

• Sales lead scoring

• Marketing qualification

• CRM-based sales outreach

• Targeted marketing

Professional Users in Schools

Educators, clinicians, and administrators using Flexspeak in professional capacities may be subject to the marketing, CRM, and lead scoring practices described in Section 4.

Those practices relate to the professional's business relationship with Flexspeak and are separate from the processing of Student Data on behalf of a school.

No Change to Student Protections

The following continues to apply to Student Data in school-managed contexts:

• Student Data is processed solely to provide educational and assistive communication services

• Flexspeak does not use Student Data for advertising, marketing, or commercial sales qualification

• Flexspeak does not sell Student Data

• Student Data is not used to train or improve products or services for students

• Student Data is not used for non-educational research, profiling, or targeted sales analytics

6. Minors

Flexspeak's Services may be used by minors who require AAC or educational supports.

When Services are used through a school or educational institution, the institution controls account creation and data use.

When Services are used directly by families or individuals, parents or guardians are responsible for account management and consent, in accordance with applicable law.

7. Sharing of Personal Data

We share personal data only as necessary to provide, operate, secure, and improve the Services.

We may share personal data with trusted third-party service providers that assist us with:

• Cloud hosting and infrastructure

• Authentication and security

• Product analytics

• Email delivery and communications

• Customer relationship management

• Marketing automation for eligible professional and institutional contacts

• Customer support

• AI services operating under contractual privacy protections

These providers process personal data only on our behalf and under contractual obligations designed to protect it.

Student Data and AAC end-user account data are not shared with CRM or marketing providers for sales lead scoring.

All service providers are subject to written agreements requiring data protection obligations consistent with this Privacy Policy.

Flexspeak does not sell Student Data.

8. Data Retention and Deletion

Student Data is retained only for as long as necessary to provide educational services or to support the user's use of the Services.

Upon request from a school or institution, or upon termination of an institutional agreement, Student Data will be securely deleted or de-identified, subject to legal obligations and limited backup retention periods required for disaster recovery.

Data associated with non-educational use is retained in accordance with operational needs, user preferences, and legal requirements.

Marketing Qualification and CRM Data

Marketing qualification data, lead scoring information, and related customer relationship records for Professional Users and marketing contacts are retained for as long as needed to manage commercial relationships, comply with law, and resolve disputes, unless a shorter period is required by applicable law or your request.

When you delete your account or request deletion, we will delete or de-identify marketing qualification data associated with your account within a reasonable period, subject to backup retention and legal holds.

Marketing contacts without a Flexspeak account may retain engagement history until they unsubscribe or request deletion, subject to legal obligations and legitimate business needs.

9. Access, Review, and Deletion Requests

For school-managed use, requests to access, review, correct, or delete Student Data must be submitted through the school or contracting institution.

For direct users, requests may be submitted directly to Flexspeak, subject to verification and applicable law.

For Professional Users and direct account holders, you may request access to, correction of, or deletion of marketing qualification and CRM-related data associated with your educator or professional account by contacting Flexspeak as described in Section 14, subject to verification and applicable law.

10. Data Security and Encryption

Flexspeak maintains administrative, technical, and physical safeguards consistent with industry standards.

• Data is encrypted in transit using TLS

• Data is encrypted at rest using AES-256

• Sensitive credentials are encrypted at the application level

• Flexspeak's backend infrastructure provider, Supabase, is SOC 2 Type II compliant

Access to personal data is restricted to authorized personnel based on role and necessity.

11. Use of Artificial Intelligence (AI)

Flexspeak may use AI features to provide the Services.

When AI features process user data:

• Data is processed through a zero data retention workflow

• Data is not logged, stored, or retained by AI providers

• Data is not used to train or improve AI models

Flexspeak maintains contractual agreements with AI providers to ensure compliance with applicable privacy and student data protection laws.

Voice cloning is an exception to the zero-retention workflow above: when you create a cloned voice, the resulting voice model is stored by our voice provider (ElevenLabs) so it can speak for you, and is retained until you delete the voice or your account. Your source recordings are not retained by Flexspeak as described in Section 3.3.

12. Legal Compliance

Flexspeak complies with applicable federal, state, and local laws, including FERPA, COPPA, IDEA, and relevant student privacy regulations.

Where required by applicable law, Flexspeak processes Professional User and marketing contact data for commercial relationship management and lead scoring based on legitimate interests in operating and growing our professional and institutional business, balanced against your rights, and/or your consent where required, for example, for certain marketing communications.

You may object to or opt out of marketing communications as described in those communications or by contacting us.

13. Changes to This Policy

We may update this Privacy Policy periodically.

Material changes will be communicated through our Services or other other appropriate means.

14. Contact Information

For questions or privacy-related requests, contact:

Flexspeak, Inc.

Email: support@flexspeak.com

Address: 14561 Wakefield St, Westminster, CA 92683

Attn: Data Protection Officer

Website: https://www.flexspeak.com