Privacy Policy

Spoken Empathy Systems, Inc., a Delaware corporation, d.b.a. Felix (“Felix,” “we,” “us,” or “our”), provides a hosted cloud service and operator-led executive-assistant and related business-support services. This Privacy Policy explains how we collect, use, disclose, and otherwise process Personal Information when you visit https://felix.so/(the “Site”), communicate with us, or use our Services. “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual, and includes “personal data” under applicable privacy laws.

This Privacy Policy (“Privacy Policy”) should be read with the Felix Core Terms available at https://felix.so/terms(the “Core Terms”). Capitalized terms not defined in this Privacy Policy have the meanings given in the Core Terms.

1. Scope and Felix’s Role

When Felix Acts As a Controller (business)

This Privacy Policy applies when Felix determines why and how Personal Information is processed, meaning it is a “business” under certain U.S. state privacy laws or a “controller” under European privacy laws. This includes Personal Information processed for the purposes described in Section 3.

When Felix Acts As a Processor (service provider)

When Felix processes Personal Information included in Customer Data on the customer’s behalf, Felix acts as a processor or service provider. The customer acts as a controller, and Felix follows the customer’s documented instructions. That processing is governed by the customer’s agreement with Felix, including the Felix Data Processing Agreement, not this Privacy Policy.

2. Personal Information We Collect

Depending on how you interact with Felix, we may collect the following categories of Personal Information:

• Contact, account, and professional information: Information you or your organization provide when creating a Felix account, accessing our customer portal, or requesting the Services, such as name, business email address, employer organization, title or role, profile image, account identifiers, login and authentication details. If you use a third-party sign-in provider, such as Google, we receive the account information that the provider makes available to us under your settings and its terms.
• Payment and billing information: Subscription and purchase information, billing email and address, transaction identifiers, and related records. Our Payment Processor receives and processes full payment-card or bank account details, but Felix does not store full payment-card numbers.
• Communications and relationship information: Information you provide when you contact sales or support, request information, participate in an event or survey, submit feedback, or otherwise communicate with Felix. This may include the content and metadata of communications, preferences, and records of our relationship with you.
• Site, device, and network information: IP address, approximate location derived from IP address, browser and device type, operating system, language, referring URL, pages viewed, links clicked, time and date of access, session information, cookie identifiers, and similar technical information collected when you use the Site or the Services.
• Service administration, security, and Usage Data: Information used to administer, measure, support, and secure the Services, including Active Time, task categories, feature use, configuration and status information, system and audit logs, performance metrics, diagnostic data, and records of suspected fraud, abuse, or security events.

We obtain Personal Information from:

• you, including through the Site, account setup, support, sales, events, and other communications;
• your employer or customer organization who invites you to the Services;
• identity and sign-in providers, Payment Processors, and other vendors that support Felix’s own business operations; and
• your browser, device, and the cookies and similar technologies described in Section 4.

Sensitive Data. The Services are not designed for Sensitive Data, as defined in the Core Terms. This includes protected health information; full payment-card or financial-account data; government identification numbers; information regulated under COPPA, GLBA, or similar sector-specific laws; special-category personal data; genetic, neural, or identifying biometric data; precise geolocation; and other information subject to heightened legal safeguards. Felix does not intentionally collect Sensitive Data, and we ask you not to provide Sensitive Data to Felix.

3. How and Why We Use Personal Information

We use Personal Information for the following purposes and legal bases, as applicable:

Where we rely on your consent, you may withdraw it at any time without affecting processing that occurred before withdrawal. We may also use Personal Information for another purpose that is compatible with the purpose for which it was collected, or as otherwise disclosed to you and permitted by law.

Felix may use Interaction Data to operate, secure, evaluate, train, and improve the Services and internal systems only after aggregating or irreversibly de-identifying it so that it cannot reasonably be linked to a customer, user, or other identifiable person. Felix will not attempt to re-identify that information or disclose Customer Confidential Information through a model, dataset, benchmark, or publication. Felix may process identifiable Usage Data for billing and to operate, secure, support, analyze, and improve the Services, but will not disclose identifiable Usage Data externally except as described in this Privacy Policy, the Agreement, or as required by law. Once Interaction Data or Usage Data has been aggregated or irreversibly de-identified in accordance with the Core Terms so that it cannot reasonably be linked to a customer, user, or other identifiable person, Felix may retain and use that information as described in the Core Terms, and it is no longer Personal Information for purposes of this Privacy Policy.

4. Cookies and Similar Technologies

We and our vendors may use cookies, pixels, local storage, and similar technologies to operate the Site and provide the Services, remember preferences, keep users signed in, understand performance and use, improve functionality, and, if enabled, support marketing. Cookies may be session cookies, which expire when you close your browser, or persistent cookies, which remain for a stated period or until deleted. We use the following categories of cookies and similar technologies:

• Strictly necessary: support security, authentication, network management, and core functions. Where permitted by law, these do not require consent.
• Performance and analytics: help us understand traffic, interactions, reliability, and performance. Where required, we use them only with consent.
• Advertising: if used, support campaign measurement, personalization, or targeted advertising. Where required, we use them only with consent and offer applicable opt-outs.

When you first visit the Site, our consent-management platform provides information about the cookies and similar technologies we use and, where required, asks for your consent before nonessential technologies are activated. You can review or change your choices at any time through the cookie settings available on the Site and can also adjust browser settings. Blocking some technologies may affect the functionality of the Site or Services. Withdrawal of consent does not affect processing that occurred before withdrawal.

The up-to-date list of the specific cookies we use is set out in the declaration below, which is maintained automatically through our consent-management platform:

5. How We Disclose Personal Information

We may disclose Personal Information to the following categories of recipients:

• Service providers that provide hosting, authentication, security, analytics, payment processing, communications, customer support, marketing, professional, or other business services;
• Associates and authorized Felix personnel subject to confidentiality, privacy, and security obligations; provided that Customer Data and Customer Confidential Information are accessible by default only to the assigned Associate; other Felix personnel may access that information only for the limited purposes and subject to the safeguards stated in the Agreement;
• Affiliates, professional advisers, auditors, insurers, and financing sources;
• Government authorities, regulators, courts, law enforcement, or other parties when disclosure is required or permitted by law or reasonably necessary to protect rights, safety, and security;
• An actual or potential buyer, investor, successor, or other participant in a merger, financing, reorganization, sale of assets, acquisition, insolvency, or similar corporate transaction; and
• Other recipients at your direction, with your consent, or as otherwise disclosed when the information is collected.

6. Third-Party Services and Links

A customer may connect or direct Felix to use Third-Party Services. The customer’s and individual’s use of those services is governed by the relevant provider’s terms and privacy practices. The Site and Services may also contain external links. Felix is not responsible for the privacy practices of third parties acting for their own purposes, and we encourage you to review their privacy notices.

7. International Data Transfers

Felix is based in the United States, and its primary hosting and processing facilities are in the United States. Personal Information may be transferred to, stored in, or accessed from the United States and other countries where Felix, its personnel, Associates, or service providers operate. Those countries may have privacy laws that differ from the laws where you live.

Where European Economic Area, United Kingdom, or Swiss law requires safeguards for controller-to-provider transfers, Felix uses appropriate transfer mechanisms, which may include an adequacy decision, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, and Swiss adaptations, as applicable. You may contact us for information about applicable safeguards at support@felix.so.

8. How Long We Retain Personal Information

Felix retains Personal Information only for as long as reasonably necessary for the purposes described in this Privacy Policy. Retention period depends on the nature, amount, and sensitivity of the information; the purposes and legal requirements for processing; the potential risk of harm; and whether the purpose can be achieved by other means.

• Account and customer-relationship information is generally retained while the account or business relationship is active and for an appropriate period afterward for legal, security, and recordkeeping needs.
• Billing, payment, tax, and transaction records are retained for periods required by financial, tax, and other applicable laws.
• Marketing contact information is retained until you opt out or we determine that it is no longer needed, subject to retaining a suppression record so we can honor the opt-out.
• Cookie and similar-technology information is retained according to the duration disclosed in the cookie preference tool or cookie notice.
• Security, audit, and diagnostic logs are retained for periods reasonably necessary to protect the Services, investigate incidents, and meet legal and contractual obligations.

When Personal Information is no longer needed, we delete or de-identify it. If immediate deletion is not feasible, such as for backup archives, we isolate the information from further use until deletion is possible, except as required by law.

9. Security

Felix maintains commercially reasonable administrative, technical, and organizational safeguards designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Depending on the system and risk, these measures include least-privilege and role-based access, multi-factor authentication where supported, encryption in transit and encryption at rest where Felix stores Personal Information, confidentiality obligations, logging and monitoring, vendor diligence, and incident-response procedures.

No security measure can eliminate all risk. You are responsible for protecting your account credentials and for notifying Felix promptly if you suspect unauthorized access to your account.

10. Your Privacy Rights

Privacy rights vary by jurisdiction and may be subject to exceptions. Felix will not discriminate against you for exercising an applicable privacy right.

10.1 U.S. residents

Depending on your state of residence and subject to applicable law, you may have the right to:

• confirm whether Felix processes your Personal Information and access or obtain a copy of it;
• learn the categories of Personal Information collected, the categories of sources, the business or commercial purposes for processing, and the categories of recipients;
• request that we correct inaccurate Personal Information;
• request that we delete your Personal Information, subject to statutory exemptions (e.g., security, fraud prevention, compliance, recordkeeping);
• receive certain Personal Information in a portable format;
• where applicable, opt out of sale, sharing, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects;
• limit certain uses or disclosures of sensitive Personal Information, where applicable; and
• appeal a decision concerning your request.

Felix does not currently engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Felix does not sell Personal Information for money and does not knowingly sell or share the Personal Information of individuals under 16. If nonessential advertising or analytics technologies used by Felix constitute sale, sharing, or targeted advertising under applicable law, you may opt out through the Site’s cookie preference tool or by contacting Felix as described in Section 10.3.

10.2 EEA, UK, and Swiss residents

If you are a resident of the European Economic Area, United Kingdom, or Switzerland, you may have the right to:

• request access to and a copy of your Personal Information;
• request that we correct inaccurate Personal Information;
• request that we delete your Personal Information, subject to statutory exemptions (e.g., security, fraud prevention, compliance, recordkeeping);
• object to or restrict processing based on legitimate interests and direct marketing;
• receive your personal information from us in a structured, commonly used and machine-readable format in order to transmit the personal information to another controller;
• withdraw consent if we rely on your consent as our legal basis for processing your Personal Information without affecting prior processing;
• lodge a complaint with the data protection authority in the country where you live or work or where you believe an infringement occurred;
• not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, subject to applicable exceptions. Felix does not conduct such decision-making.

10.3 How to exercise your rights

To exercise a right, email support@felix.so or write to the address in Section 13. Describe your request and your relationship with Felix. We may verify your identity and authority before responding. If you use an authorized agent, we may require proof of authorization and may ask you to verify your identity directly, as permitted by law. We will respond within the period required by applicable law. If we deny a request, you may appeal by replying to our decision or emailing the same address.

11. Children

The Site and Services are intended for business users and are not directed to individuals under 18. Felix does not knowingly collect Personal Information directly from individuals under 18. If you believe that a person under 18 provided Personal Information directly to Felix, please contact us so we can take appropriate action.

12. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in law, technology, the Services, or our privacy practices. We will post the updated version on the Site and change the “Last updated” date. If required by law, we will provide additional notice or obtain consent before a material change applies. We encourage you to review this Privacy Policy periodically.

13. Contact

Questions, complaints, and privacy requests may be directed to: