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Ascent HI Mobile App Privacy Policy

Effective Date: July 14, 2026

 

This Privacy Policy explains how Ascent HI LLC (“Ascent HI,” “we,” “us,” or “our”) accesses, collects, uses, shares, stores, and protects personal data when you use the Ascent HI mobile application for Android or iOS (the “App”) and the related coaching services provided through it (the “Service”).

It also explains your privacy rights, how to request access to or deletion of your information, and how our practices relate to the Google Play Data safety disclosures and Apple App Store privacy disclosures.

The App is developed and provided by Ascent HI LLC, the developer identified in the App’s applicable store listing.

Summary: Recordings remain on your device unless you intentionally submit them for coaching. When you submit a recording, it is securely transmitted, transcribed, and analyzed to produce coaching feedback. Your submitted content may be accessible to your coach, manager, company, or other sponsoring organization. We do not sell personal data, use personal data for third-party advertising, or track users across unrelated apps or websites.

1. Scope of This Policy

This Privacy Policy applies to:

  • the Ascent HI Android and iOS mobile applications;

  • account, authentication, subscription, and technical information processed through the App;

  • audio recordings that you choose to submit;

  • transcripts, analyses, scorecards, reports, briefs, audio feedback, video feedback, and other coaching materials generated through the Service; and

  • communications relating to your App account or use of the Service.

This policy does not govern the independent privacy practices of your employer, coach, manager, consultant, trainer, or other organization sponsoring your access, except to explain how information may be made available to that organization through the Service.

2. Who Is Responsible for Your Data

The Service may be made available through a coaching organization, employer, company, coach, manager, consultant, or other sponsoring entity referred to in this policy as your “Organization.”

Depending on the processing activity:

  • Ascent HI acts as a data controller for information used to operate the App, authenticate users, manage subscriptions, secure the Service, provide support, and satisfy our own legal obligations.

  • Your Organization may act as the data controller for recordings you submit, transcripts, coaching results, evaluation history, and related workplace or coaching information.

  • Ascent HI generally acts as a processor or service provider when processing submitted coaching content on behalf of your Organization.

Your Organization determines which authorized people can access coaching content and may establish its own retention, evaluation, employment, coaching, or performance-management practices.

Questions about how your Organization uses coaching information should be directed to your Organization. Questions about Ascent HI’s privacy practices may be directed to us using the contact information in Section 17.

3. Information We Access or Collect

3.1 Account and profile information

Depending on how your account is established, we may process:

  • name;

  • email address;

  • account username or internal account ID;

  • encrypted or cryptographically protected authentication information;

  • role, coach assignment, manager assignment, or organization assignment;

  • organization portal address or organization access code;

  • account preferences;

  • subscription or entitlement status; and

  • support communications.

Your password is not stored by us in readable form. Authentication may be provided through Amazon Web Services Cognito or another secure authentication service.

3.2 Audio recordings and recording information

The App allows you to record audio using your device’s microphone.

We may process:

  • audio recordings;

  • recording names or titles;

  • recording duration and file metadata;

  • upload status; and

  • information spoken or otherwise contained in a submitted recording.

The App accesses the microphone only after you grant permission and initiate a recording feature.

Recordings ordinarily remain locally on your device until you intentionally choose to submit or upload them. Merely recording audio does not automatically send that audio to Ascent HI.

When operating in a local or guest mode that does not include submission, recordings remain on the device and are not transmitted to Ascent HI.

3.3 Submitted user content and generated coaching content

When you submit a recording, we may create or process:

  • audio files;

  • transcripts;

  • speaker labels or speaker separation;

  • conversation summaries;

  • scorecards and performance measurements;

  • coaching observations;

  • written reports;

  • presentation briefs;

  • recommended actions;

  • audio coaching feedback;

  • AI-generated coaching videos; and

  • other analysis or content requested by you or your Organization.

Recordings and transcripts may contain the personal information of other conversation participants. This may include names, voices, business information, opinions, or other information disclosed during the conversation.

3.4 Subscription and purchase information

When subscriptions or purchases are offered through an app store, the applicable platform processes payment information.

We may receive:

  • product or subscription selected;

  • subscription status;

  • trial status;

  • purchase or renewal status;

  • transaction or receipt identifier;

  • entitlement information; and

  • limited transaction records needed to validate or manage access.

We do not receive or store complete payment-card numbers from Google Play or Apple.

Subscription management may be facilitated through RevenueCat and the applicable app-store billing service.

3.5 Device, network, diagnostic, and security information

When the App communicates with our systems, we or our service providers may automatically process limited technical data such as:

  • IP address;

  • device type and operating-system version;

  • App version;

  • language or regional settings;

  • timestamps;

  • authentication and session events;

  • server request outcomes;

  • crash or diagnostic information;

  • security events;

  • upload and processing status; and

  • internal identifiers required to operate, secure, and troubleshoot the Service.

We do not use this information to build advertising profiles.

3.6 Information we do not intentionally collect

Unless a future feature clearly states otherwise, the App does not intentionally collect:

  • precise or approximate location;

  • address-book contacts;

  • call logs;

  • SMS or MMS messages;

  • health or fitness information;

  • browsing history;

  • advertising identifiers for targeted advertising;

  • biometric templates;

  • files unrelated to recordings selected or created through the App; or

  • photos or videos from your device library.

The App does not activate the microphone for hidden or unrelated background surveillance.

4. Microphone Access and Prominent Disclosure

The App requests microphone permission because recording audio is a central feature of the App.

Before or at the time permission is requested, the App will explain that microphone access is used to:

  • record audio when you intentionally start a recording;

  • save the recording on your device;

  • allow you to listen to or manage the recording; and

  • submit the recording for coaching evaluation when you choose to do so.

The microphone is not intended to be accessed for advertising, tracking, or unrelated background collection.

You may deny or revoke microphone permission through your device settings. Doing so will prevent new recordings but should not prevent access to features that do not require the microphone.

5. Your Responsibility When Recording Other People

You are responsible for using the recording feature lawfully.

Before recording or submitting a conversation, you must:

  • provide any notice required by applicable law;

  • obtain consent from all participants when legally required;

  • comply with workplace, contractual, confidentiality, and professional obligations;

  • avoid submitting information you are not authorized to disclose; and

  • follow any recording or data-handling requirements established by your Organization.

Recording-consent laws vary by location. The App does not determine whether you have obtained legally sufficient consent.

Do not record emergency communications, highly sensitive personal information, legally privileged communications, classified information, or other content that you are not authorized to process through the Service.

6. How We Use Information

We use information for the following purposes:

Providing the App and Service

  • authenticating users;

  • connecting users to their Organization;

  • saving and managing recording information;

  • receiving recordings that users intentionally submit;

  • transcribing and analyzing submitted conversations;

  • generating coaching reports, scorecards, briefs, audio, and video feedback;

  • delivering completed coaching materials;

  • displaying coaching history; and

  • providing subscription-based functionality.

Security and technical operations

  • protecting accounts and infrastructure;

  • detecting unauthorized use, fraud, abuse, or security incidents;

  • maintaining service reliability;

  • debugging errors;

  • monitoring processing status; and

  • enforcing applicable agreements.

Communications and support

  • responding to support or privacy inquiries;

  • providing processing or account notices;

  • sending password, security, or authentication messages;

  • notifying users when submitted content or coaching results are ready; and

  • communicating material policy or service changes.

Legal and compliance purposes

  • complying with applicable law;

  • responding to lawful legal process;

  • protecting the rights and safety of users and others;

  • resolving disputes;

  • maintaining records required for accounting, tax, or regulatory purposes; and

  • establishing, exercising, or defending legal claims.

We do not use personal data for third-party targeted advertising.

7. Legal Bases for Processing

Where the GDPR, UK GDPR, or similar laws apply, we rely on one or more of the following legal bases:

  • Performance of a contract: to authenticate you, provide the Service, process submitted recordings, deliver coaching results, and manage subscriptions.

  • Legitimate interests: to secure, maintain, improve, and support the Service; prevent misuse; and communicate with users.

  • Legal obligation: to comply with tax, accounting, legal-process, security, and regulatory requirements.

  • Consent: when required for a specific optional activity or permission.

  • Your Organization’s instructions and lawful basis: when we process coaching content as a processor on behalf of your Organization.

Where we rely on consent, you may withdraw it prospectively, subject to legal and contractual limitations.

8. AI and Automated Processing

When you submit a recording, the following processing may occur:

  1. The audio is securely uploaded to cloud infrastructure.

  2. A speech-to-text provider converts the audio into a transcript and may identify or separate speakers.

  3. An artificial-intelligence provider analyzes the transcript using the applicable coaching criteria or methodology.

  4. The Service creates written evaluations, metrics, scorecards, reports, briefs, or recommended actions.

  5. When selected, additional providers may generate audio or AI-avatar video feedback.

Current providers may include:

  • AssemblyAI for transcription;

  • Anthropic for language-model analysis;

  • HeyGen for AI-generated coaching video; and

  • other contracted processors needed to provide a selected feature.

These providers are authorized to process submitted content only to provide contracted services to Ascent HI, subject to their agreements with us.

We do not authorize these providers to use your recordings, transcripts, or coaching results to train their general-purpose artificial-intelligence models.

Coaching outputs are automatically generated and may contain inaccuracies. They are intended to support human coaching, review, and development. They should not be treated as the sole basis for legal, employment, medical, financial, safety-critical, or similarly consequential decisions.

Ascent HI does not itself make automated decisions that produce legal or similarly significant effects concerning users. Your Organization is responsible for how it independently uses coaching information.

9. How Information Is Shared

We may disclose information to the following categories of recipients.

Your Organization

Submitted recordings, transcripts, coaching results, account identity, and coaching activity may be available to authorized representatives of your Organization, such as:

  • coaches;

  • managers;

  • trainers;

  • administrators;

  • consultants; and

  • other authorized personnel.

Your Organization determines its authorized users and how it uses information available through the Service.

Service providers

We use contracted companies to operate the Service. Depending on the features used, these may include:

  • Amazon Web Services for hosting, storage, security, databases, and authentication;

  • AssemblyAI for transcription;

  • Anthropic for AI analysis;

  • HeyGen for AI-video generation;

  • RevenueCat for subscription and entitlement management;

  • Google Play for Android app distribution and applicable billing;

  • Apple for iOS app distribution and applicable billing;

  • Postmark for transactional email; and

  • security, monitoring, support, or infrastructure providers acting on our behalf.

Service providers receive only the information reasonably required to perform their contracted function and are subject to contractual restrictions.

For purposes of the Google Play Data safety disclosure, transmission of data to processors and service providers may constitute collection by the App even when those providers process the data solely on our behalf.

Legal, security, and safety disclosures

We may disclose information when reasonably necessary to:

  • comply with law, regulation, legal process, or enforceable governmental demand;

  • investigate fraud, misuse, or security incidents;

  • protect the rights, property, or safety of Ascent HI, users, Organizations, or the public; or

  • establish, exercise, or defend legal claims.

Business transactions

Information may be transferred in connection with a merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or similar transaction. Any recipient will remain subject to applicable privacy obligations.

10. Sale, Advertising, and Tracking

We do not:

  • sell personal data;

  • share personal data for cross-context behavioral advertising;

  • use submitted recordings or coaching content for third-party advertising;

  • use advertising SDKs to profile users across unrelated apps; or

  • use sensitive data to determine eligibility for credit, housing, insurance, employment, or similar services.

We have not sold personal information or shared it for cross-context behavioral advertising during the preceding 12 months.

11. International Data Transfers

Ascent HI and some of its service providers operate in the United States and other countries.

Production data for certain European Organizations may be hosted in the Amazon Web Services Frankfurt region. Some contracted providers may nevertheless process information in the United States or another country.

Where legally required, international transfers are supported by appropriate safeguards, which may include:

  • European Commission Standard Contractual Clauses;

  • the United Kingdom Addendum or International Data Transfer Agreement;

  • adequacy decisions;

  • applicable data-privacy frameworks; or

  • other legally recognized transfer mechanisms.

You may contact us for additional information about applicable safeguards.

12. Data Retention

We retain information only for as long as reasonably necessary for the purposes described in this policy, subject to Organization instructions and legal requirements.

Recordings that are not submitted

Recordings not submitted ordinarily remain only on your device.

They remain until you:

  • delete the recording;

  • clear the App’s storage;

  • uninstall the App, where the operating system deletes local App data; or

  • otherwise remove the local file.

Ascent HI cannot delete a local recording that was never transmitted to us.

Submitted recordings, transcripts, and coaching results

Submitted content may be retained:

  • while your account or Organization relationship is active;

  • for the retention period established by your Organization;

  • until a verified deletion request is completed;

  • as necessary to complete processing or resolve a support issue; or

  • as required for legal, security, dispute-resolution, or compliance purposes.

When your Organization acts as controller, it may require us to retain or delete submitted content according to its instructions.

Account and profile data

Account and profile information is ordinarily retained while the account remains active and is deleted or anonymized following account closure, subject to limited legal or security exceptions.

Subscription and transaction data

Subscription and transaction records may be retained as required for financial reporting, fraud prevention, tax, accounting, and legal compliance.

Logs and security information

Technical and security logs are retained for a limited period appropriate to security, troubleshooting, fraud prevention, and reliability. Logs are then deleted, aggregated, or anonymized unless longer retention is necessary for an investigation or legal obligation.

Backups

Deleted data may remain temporarily in encrypted backups until overwritten or purged through our normal backup cycle. Backup copies are isolated from ordinary production use and are not restored except for disaster recovery, security, or continuity purposes.

13. Account and Data Deletion

Deleting your account inside the App

Where account management is available, you may initiate deletion through:

Settings → Account → Delete Account

The wording or location may vary slightly by App version, but the deletion option will be reasonably discoverable within the App.

Requesting deletion outside the App

You may initiate an account and data-deletion request without reinstalling the App by visiting:

https://www.ascenthi.com/mobile-account-deletion

You may also email:

privacy@ascenthi.com

Use the subject line Mobile Account Deletion Request and send the request from the email address associated with your account when possible.

We may take reasonable steps to verify your identity and protect accounts from unauthorized deletion.

What account deletion removes

Following verification, account deletion ordinarily includes:

  • deletion of authentication credentials;

  • deletion or anonymization of the account’s active personal identifiers;

  • revocation of App access;

  • invalidation of active Ascent HI sessions where technically available;

  • deletion of preferences controlled by Ascent HI; and

  • deletion or de-identification of other account data controlled by Ascent HI, subject to the exceptions below.

Submitted coaching content controlled by an Organization

Submitted recordings, transcripts, evaluations, and historical coaching results may be controlled by your Organization rather than Ascent HI.

When that applies:

  • we will notify or route the request to the relevant Organization;

  • we will assist the Organization in responding as required by applicable law and our agreement;

  • content may be deleted, anonymized, or disassociated from your active user profile;

  • your Organization may retain certain historical content under its documented retention policy; and

  • retained information will no longer be used to provide an active personal App account to you.

Information that may be retained

We may retain limited information after a deletion request when reasonably necessary for:

  • tax or accounting requirements;

  • legal or regulatory obligations;

  • fraud or abuse prevention;

  • security investigations;

  • resolving disputes;

  • enforcing agreements;

  • documenting and honoring the deletion request; or

  • preserving information under a valid legal hold.

Where possible, retained information will be minimized, restricted from ordinary use, and deleted when the reason for retention ends.

Local recordings

Deleting your online account does not necessarily delete recordings still stored locally on your device. You must separately delete local recordings or remove the App’s local data.

Subscriptions

Deleting an Ascent HI account does not automatically cancel a subscription managed through Google Play or Apple.

For Android subscriptions, cancellation is managed through Google Play’s subscription settings.

For iOS subscriptions, cancellation is managed through Apple’s subscription settings.

Account deletion is permanent and may not be reversible.

14. Security

We use administrative, technical, and organizational safeguards designed to protect personal information.

These safeguards include, as applicable:

  • HTTPS/TLS encryption for data transmitted between the App and our systems;

  • encryption at rest on supported cloud infrastructure;

  • secure platform-provided storage for authentication tokens;

  • cryptographically protected authentication;

  • access restrictions based on job responsibilities;

  • organization-level data separation;

  • activity logging and security monitoring;

  • threat detection;

  • limited service-provider access;

  • incident-response procedures; and

  • contractual data-protection obligations for processors.

On Android, sensitive authentication material is stored using secure operating-system-supported storage where available, such as Android Keystore-backed mechanisms.

On iOS, sensitive authentication material may be stored using Apple Keychain.

No system can guarantee absolute security. If a qualifying personal-data breach occurs, we will notify affected users, Organizations, and regulators as required by applicable law.

15. Your Privacy Rights

Depending on your location and the relationship between you, Ascent HI, and your Organization, you may have the right to:

  • request access to personal data;

  • receive a copy of certain information;

  • correct inaccurate information;

  • request deletion;

  • request restriction of processing;

  • object to certain processing;

  • receive portable data;

  • withdraw consent where processing is based on consent;

  • appeal a denied privacy request where applicable;

  • use an authorized agent where permitted; and

  • file a complaint with an applicable regulator.

We will not discriminate against you for exercising an applicable privacy right.

When Ascent HI acts solely as a processor for your Organization, we may refer your request to that Organization and assist it with the response.

Requests may be submitted to privacy@ascenthi.com. We may verify your identity before fulfilling a request.

California and other U.S. state rights

Residents of California and certain other U.S. states may have rights to know, access, correct, delete, or obtain a copy of personal data and to opt out of certain sales, targeted advertising, or profiling.

Because Ascent HI does not sell personal data or share it for cross-context behavioral advertising, we do not currently provide a sale or targeted-advertising opt-out mechanism for the App.

European Economic Area and United Kingdom rights

Users in the EEA or UK may have rights under the GDPR or UK GDPR, including access, rectification, erasure, restriction, objection, portability, and the right to complain to a supervisory authority.

We ordinarily respond within the period required by applicable law. In certain circumstances, the response period may be extended as legally permitted.

16. Children

The App and Service are intended for professional and business use by adults. They are not directed to children.

We do not knowingly collect personal data directly from children under 16, or under a higher minimum age where required by local law.

Organizations and users must not create accounts for children or submit children’s personal information unless the use is specifically authorized by Ascent HI, legally permitted, and supported by all required parental or institutional consents.

If you believe a child has provided personal data through the App, contact privacy@ascenthi.com so that we can investigate and take appropriate action.

17. App-Store Privacy and Data Safety Disclosures

Google Play Data safety

The Google Play Data safety section for the App is intended to reflect the App’s actual practices, including information collected through the App and through third-party libraries or service providers.

Depending on the App features used, data categories disclosed in Google Play may include:

  • personal information, such as name and email address;

  • audio files or voice recordings;

  • other user-generated content;

  • identifiers;

  • purchase history or subscription information;

  • app interactions;

  • crash logs;

  • diagnostics; and

  • other technical information required for app functionality, security, fraud prevention, account management, analytics limited to service operations, or developer communications.

The App’s Google Play disclosure should indicate, where accurate for the released version, that:

  • data is encrypted in transit;

  • users may request account and data deletion;

  • data is not sold;

  • data is not used for third-party targeted advertising; and

  • collection may be required or optional depending on the feature.

The Google Play Data safety form is a summary. This Privacy Policy provides additional detail. If an inconsistency is discovered, we will update the policy, App behavior, or store disclosure as appropriate.

Apple App Store privacy disclosure

Depending on the features used, the Apple App Store disclosure may identify collection of:

  • contact information;

  • user content, including audio;

  • identifiers;

  • purchases;

  • diagnostics; and

  • usage information.

Such information is used for App functionality, account management, security, subscription management, support, and delivery of coaching services—not for cross-app tracking or third-party advertising.

18. Third-Party Services and Links

The App may link to websites, app-store pages, or services operated by third parties.

Third-party services process information under their own privacy policies when acting independently. This may include Google Play, Apple, or a website operated by your Organization.

We encourage you to review the privacy terms of any independently operated service you use.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect:

  • changes to the App or Service;

  • new or changed service providers;

  • security improvements;

  • legal or regulatory developments;

  • changes to app-store requirements; or

  • changes in our data practices.

The Effective Date at the top of the policy will identify the latest revision.

When required, material changes will be communicated through the App, email, the website, or another appropriate method before they become effective.

20. Contact Us

Ascent HI LLC

Privacy inquiries and privacy-rights requests:
privacy@ascenthi.com

General support:
support@ascenthi.com

Website:
https://www.ascenthi.com

Account and data-deletion requests:
https://www.ascenthi.com/mobile-account-deletion

Users in the EEA or UK may also contact the data-protection supervisory authority in their country. UK users may contact the Information Commissioner’s Office.

© 2026 Ascent HI LLC. All rights reserved.

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