Updated 24 January, 2025

This Privacy Policy describes how Nothing Technology Limited a company registered in England and Wales under company number: 12984564. Our registered office is at 21a John Street, Bedford House, London, United Kingdom, WC1N 2BF or its affiliated companies (collectively, "we", "us", or "our") collect, use, share and otherwise process your data in connection with your use of Essential Space, our Artificial Intelligence app and widget (collectively, “Essential Space” or “Services”). We are the controller and responsible for your personal data that is processed as part of your use of Essential Space.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

1. What Personal Data we collect
To provide our services, we collect, use, store and process the following types of data:
Identity and Contact Data : When you download Essential Space you will be asked to provide your Nothing account details or Google Account details in order to use the app or widget. This will be stored while your Nothing and Google Account remains active.
Audio Data: When you record content with speech, the audio is processed locally on your device using offline speech-to-text technology. For the avoidance of doubt, your audio remains on your device and is not uploaded to our servers.
Text Data: Transcriptions of your audio are sent to our servers temporarily for processing and are not retained on our servers once the Service has been provided.
Screenshots: Screenshots taken during usage are stored locally on your device and sent to our servers only during processing. They are stored on our servers only during processing and are not retained on our servers after the Service has been provided.
Time and Time Zone: The current time and time zone are collected during processing to enhance the accuracy of our Service.
Basic Information(such as your region and language): The language of your device's interface is collected to determine the appropriate output language.
Location Data: Your device's current location is collected during usage to improve analysis. Location data is used only during an active session and is not stored persistently.

Please note that we may collect special categories of data about you, if you input this information into Essential Space. For example, if you input details about your race, ethnicity, religious or philosophical beliefs, sex life, political opinions, trade union membership, information about your health and genetic and biometric data. When your Essential Space request can be generated successfully this data will be processed for the purposes of generating the summary or other output only. Once processing is complete, this special category data will be permanently deleted.

2. How We Use Your Data
We use your data to:
Process and analyze your recordings.
Provide AI-generated outputs.
Your data will not be used for advertising purposes or shared with third parties beyond what is necessary to provide the Services. This may include our service providers who help provide some of the functionality that is part of the Services.
We require all third parties to respect the security of your data and to treat it in accordance with the law. We do not allow our third-party service providers to use your data for their own purposes and only permit them to process your data for specified purposes and in accordance with our instructions.

3. Data Storage and Transfer
3.1 Retention period
Data sent to our servers is temporarily stored for processing. Once processing is complete, all data is permanently deleted. We will store your data only to the extent as necessary for the proper business needs of our company (e.g., for the purposes of providing the Services to you, except where we are complying with applicable laws or regulations.

3.2 Regional Processing:
For users in the United Kingdom (UK), all data is processed on servers located in Paris, France.
For users in the European Union (EU), all data is processed on servers located in Paris, France, in compliance with GDPR.
For users in India, all data is processed on servers located in Mumbai, India.
For users outside the EU, data is processed on servers located in Paris, France

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that adequate safeguards are in place as required under UK data protection law

4. Legal Basis for Processing
4.1 We will only use your personal data when we have a lawful basis to do so. Our lawful basis for which we use your personal data is specified as follows:

4.1.1 Consent: You have freely consented before the processing in a specific informed and unambiguous indication of what you want. If you consent, you should select the appropriate consent option at the pop up.

4.1.2 Performance of a contract: we need to process your personal data or any data that you input into Essential Space to provide the Services and therefore perform a contract with you.

4.1.3 Compliance with law: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

5. Your Data Rights
You have the following rights under data protection laws in relation to your personal data. These include:
Right to access your data: request access to and / or a copy of the personal data we process about you (commonly known as a data subject access request).
Right to correct your data: request correction of any incomplete or inaccurate data we hold about you.
Right to request to delete your data: request us to delete or remove your personal data where there is no good reason for us continuing to process it.
Right to object: object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
Right to request restriction; request that we restrict or suspect our processing of your personal data.
Data portability: request we transfer certain of personal data to you or your chosen third party in a commonly used, machine readable format.
Withdraw consent: Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we will be unable to provide the Services to you. We will advise you of this at the time you withdraw your consent.
Complaint: If you are unhappy with how we process your personal data, we ask that you contact us first using the details below so that we have the chance to put it right. However, you also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights at any time by contacting us using the contact details provided in this Privacy Policy.

6. Data Security
All information you provide to us is stored on our secure servers. We also implement robust measures to protect your personal data, including:
Encryption during data transmission.
Immediate deletion of data after processing.
Access controls to prevent unauthorized access.

We use appropriate technical and organizational measures to protect your data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your data. Please be aware and understand that we cannot ensure an absolute secure network.

7. Children's Privacy
Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children without parental consent.

8. Changes to This Privacy Policy
We keep this Privacy Policy under regular review and we may update this policy to reflect changes in our practices or regulatory requirements. Updates will be communicated via the app or widget. You may be required to read and acknowledge the changes to continue your use of Essential Space.

9. Contact Us
If you have any questions regarding this Privacy Policy or its implementation, here is how you can reach us:
Email Address: privacy@nothing.tech.

At all times, data collected by us will be treated in accordance with our official website's Privacy Policy, which can be found at https://intl.nothing.tech/pages/privacy-policy