Privacy Notice

Introduction

Tetramo, Inc. (“Tetramo,” “Glassly,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Notice explains how we collect, use, disclose, and protect your personal information when you use:

• The Glassly app for iOS and Android devices
• Glassly artificial intelligence features and services (including live captions, live translation, the proactive agent, and smart notes)
• Glassly running on supported third-party smart glasses
• Our websites at glassly.ai and related domains (collectively, the “Services”)

This Privacy Notice applies to consumers and users of our products worldwide. If you are located in specific jurisdictions, additional rights and protections may apply as described in Section 15 (Jurisdiction-Specific Provisions).

By using our Services, you acknowledge that you have read and understood this Privacy Notice.

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Table of Contents

1. Information We Collect

We collect information in the following categories:

1.1 Information You Provide

• Account Information: Email address, username, password, and profile preferences when you create a Glassly account
• Purchase Information: Billing address, payment method details (processed by our payment processors), and subscription history
• Communications: Messages, feedback, support requests, and other communications you send to us
• User Content: Notes, transcriptions, and other content you create using the Services

1.2 Information Collected Automatically

• Device Information: Device identifiers, hardware model, operating system version, connected glasses model and firmware version, battery status, and connectivity status
• Usage Data: App interactions, feature usage, session duration, and navigation patterns
• Log Data: IP addresses, access times, browser type, referring URLs, and error logs
• Location Data: General location based on IP address; precise GPS location only when you grant permission through the Glassly app

1.3 Sensor Data from Connected Smart Glasses

The smart glasses you use with Glassly contain sensors (such as microphones, and on some models cameras and motion sensors) that can collect data only when you activate a feature that requires them. By default, no sensor data is collected or transmitted.

• Audio Data: Voice commands, speech captured for live captions and translation, and microphone input for AI interactions
• Camera Data: Photos, video, or live video captured through the glasses camera, on models that include one, when you activate a feature that uses it
• Motion Data: Inertial measurement unit (IMU) data including accelerometer and gyroscope readings, on models that include these sensors

2. Website, Purchases, and Subscriptions

When you visit our website or purchase a Glassly subscription, we collect and use your personal information as described in this Privacy Notice.

Depending on how you interact with our website and Services, we may collect:

• Contact details, such as your name, email address, billing address, and phone number
• Order and transaction information, such as subscriptions purchased, order history, and payment confirmation details
• Payment information, such as your payment card details and billing address, which is collected and processed by our payment processors and app store providers (we do not store full payment card numbers)
• Account information, if you create an account, and customer support information, such as messages and inquiries you send to us
• Usage and device information related to your visits to our website, such as device identifiers, browser type, IP address, and interactions with our website

We use this information to operate and improve our website and Services, process your purchases and subscriptions, communicate with you about your purchases and account, and for marketing and advertising purposes as described in this Privacy Notice.

If you subscribe through the Apple App Store or Google Play, your payment is processed by Apple or Google under their respective terms and privacy policies, and we do not receive your full payment details.

Our e-commerce providers and payment processors may process your personal information in the United States and other countries. We require these providers to protect your information in accordance with applicable law.

3. Cookies and Tracking

When you visit our websites, use our online Services, open or click on emails we send you, or interact with our content or advertisements, we and our third-party partners automatically collect certain information using cookies, pixels, and similar technologies (“Cookies”).

The information collected through Cookies may include identifiers (such as your IP address, device ID, and cookie ID), device and browser information, location information, date and time of visit, and information about your activities or interactions with our websites, emails, and online advertisements.

We use these technologies for several purposes, including to:

• Operate, secure, and improve our websites and online Services (for example, to remember your preferences and keep you signed in)
• Run analytics and measure how users access and use our websites and communications, so we can understand usage, improve our Services, and develop new features
• Provide, measure, and improve marketing and advertising, including to show you Glassly ads on other websites and apps and to understand whether those ads were effective

We may also allow certain third parties (such as analytics and advertising providers) to set Cookies on our websites or in our Services. These third parties may use Cookies to collect information about your activities on our websites and across different websites and apps over time for advertising and analytics purposes.

Your Choices: Most browsers automatically accept Cookies by default. You can choose to set your browser to remove or reject Cookies, or to prompt you before accepting a Cookie. Please note that blocking Cookies may affect your experience using our websites.

Our websites also recognize the Global Privacy Control (GPC) signal. When we detect a valid GPC signal from your browser, we will treat it as a request to opt out of the “sale” or “sharing” of your personal information for targeted advertising purposes under applicable state privacy laws.

In addition to using browser settings, Cookie preferences, and GPC, you may contact us at privacy@tetramo.com if you have questions about how we use Cookies.

4. Sensor Data and Device Permissions

4.1 Permission-Based Access

Glassly employs a permission-based model for sensor access. Sensor permissions are managed through the Glassly app and can be reviewed or revoked at any time.

4.2 Data Transmission Architecture

When sensor data is activated:

• Data is captured by your smart glasses
• Transmitted to your paired smartphone via Bluetooth Low Energy (BLE)
• From your phone, data may be transmitted to cloud infrastructure via encrypted connections (HTTPS, encrypted UDP, or WebSocket)
• Cloud infrastructure routes data to the Glassly services you are using

4.3 Local vs. Cloud Processing

• AI queries and complex processing (such as live captions, translation, and the proactive agent) require transmission to cloud-based AI services
• Notes and transcripts can be saved based on your settings and deleted through the Glassly app

4.4 Data Minimization

We apply data minimization principles in accordance with GDPR Article 5(1)(c):

• Sensor data is collected only when necessary for the specific feature you activate
• We do not collect sensor data in the background without your active initiation
• You can revoke sensor permissions at any time through the Glassly app

5. Use of Artificial Intelligence

5.1 AI Transparency Notice

You are interacting with an AI system. Glassly provides AI-powered features that process your voice, images, and text using artificial intelligence. This section explains how AI features work and how your data is processed.

5.2 AI Features and Capabilities

Glassly provides the following AI-powered features:

• Live captioning and transcription
• Real-time translation
• Proactive agent (contextual reminders, directions, and answers)
• Smart notes, note-taking, and summarization

5.3 Third-Party AI Providers

To provide AI features, we send the data described below to the following third-party providers. Nothing is sent until you turn on a feature that needs it.

Soniox

• Used for: Speech-to-text for live captions, translation, the assistant, and recording transcription
• Data processed: Microphone audio from your phone or glasses, streamed while the feature is active
• Location: Data may be processed in the United States
• Policies: Subject to Soniox's Terms of Service and Privacy Policy

Anthropic (Claude)

• Used for: The AI assistant, summarization, and answering questions, including web searches the assistant runs on your behalf
• Data processed: Transcripts, your requests, and the conversation context the assistant needs to respond
• Location: Data may be processed in the United States
• Policies: Subject to Anthropic's Commercial Terms and Privacy Policy

OpenAI

• Used for: The AI assistant, text processing, and summarization, as an alternative to Anthropic
• Data processed: Transcripts, your requests, and conversation context
• Location: Data may be processed in the United States
• Policies: Subject to OpenAI's Terms of Use and Privacy Policy

Google (Gemini)

• Used for: The AI assistant, visual understanding, and web searches the assistant runs on your behalf, as an alternative to Anthropic
• Data processed: Transcripts, your requests, conversation context, and images when you use a camera feature
• Location: Data may be processed in the United States and other countries
• Policies: Subject to Google's AI Terms of Service and Privacy Policy

ElevenLabs

• Used for: Text-to-speech for spoken replies
• Data processed: The text to be spoken, which may include assistant responses derived from your conversation
• Location: Data may be processed in the United States
• Policies: Subject to ElevenLabs' Terms of Service and Privacy Policy

Which of Anthropic, OpenAI, or Google handles a given request depends on our current configuration; Anthropic is the default. Only one of them receives any given request.

Using Your Own API Keys

You can enter your own API keys for these providers in the Glassly app (Settings › API Keys) and turn off Glassly Cloud. In that mode the app sends audio and text directly from your phone to the provider under your own account, and our contractual protections below do not apply; the provider's own terms govern that data.

Contractual Protections

We maintain data processing agreements with our AI providers that include:

• Restrictions on use of your data for training their general AI models
• Data security requirements
• Confidentiality obligations
• Data deletion upon request

Speech-to-Text Processing

When you use voice features, audio is sent to Soniox solely to generate transcripts or related outputs for the feature you requested. Glassly does not retain raw audio from these voice features beyond what is needed to provide the feature, and transcripts are stored only where a feature you use (such as smart notes) saves them for you.

5.4 AI Training and Your Data

We do not use your personal data to train Glassly's AI models without your explicit consent.

Third-Party AI Training: Our contractual arrangements with our AI providers prohibit them from using your personal data processed through the Services to train their general AI models.

5.5 Automated Decision-Making

We do not use AI to make decisions that produce legal effects or similarly significantly affect you without human involvement. AI outputs (captions, translations, suggestions) are informational only and do not constitute decisions about you.

If we implement automated decision-making in the future, we will update this Privacy Notice and, where required by law, obtain your explicit consent and provide you with the right to human review.

5.6 AI Content Labeling

In compliance with applicable AI transparency regulations, including the EU AI Act:

• Explicit Labels: AI-generated content (captions, translations, summaries, AI responses) is identified as AI-generated within the user interface
• Implicit Labels: Where AI-generated content can be downloaded or exported, metadata labels are embedded in accordance with applicable technical standards
• Chatbot Disclosure: When interacting with Glassly's conversational AI features, you are notified that you are interacting with an AI system

5.7 AI Limitations and Accuracy

Important Disclosures:

• No Guarantee of Accuracy: AI outputs may contain errors, inaccuracies, omissions, hallucinations, or biased content
• Not Professional Advice: AI outputs do not constitute medical, legal, financial, safety, or other professional advice
• User Responsibility: You are responsible for reviewing and verifying AI outputs before relying on them
• Accessibility Limitations: Live captions and translations are provided for convenience and may not meet accessibility standards or be suitable for official purposes
• Language Limitations: AI performance may vary across languages and dialects
• Evolving Technology: AI capabilities and limitations may change as underlying models are updated

5.8 Smart Notes

The Glassly smart notes feature saves:

• Raw transcriptions of conversations (speech-to-text)
• AI-generated summaries

Smart notes stores content as described above. This data is stored securely and can be deleted through the Glassly app settings.

6. How We Use Your Information

We use your personal information for the following purposes:

6.1 Providing and Improving Services

• Operate, maintain, and improve the Services
• Process transactions and fulfill subscriptions
• Provide customer support
• Enable AI-powered features as described in Section 5
• Route data between your devices and our services
• Develop new features and services

6.2 Personalization

• Remember your preferences and settings
• Provide contextual AI responses based on information you provide during a session
• Customize feature recommendations

6.3 Safety and Security

• Detect and prevent fraud, abuse, and security incidents
• Enforce our Terms of Service
• Protect the rights and safety of users and third parties
• Comply with legal obligations

6.4 Communications

• Send service-related notifications (transactional)
• Respond to your inquiries
• Send marketing communications (with your consent where required)

6.5 Analytics and Research

• Analyze usage patterns to improve Services
• Conduct research and development
• Generate aggregated, de-identified statistics

7. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data on the following legal bases under GDPR:

Special Categories of Data

We do not intentionally collect special categories of personal data (Article 9) such as health data, biometric data for identification, or data revealing racial or ethnic origin. However:

• Camera data may incidentally capture images of individuals. We do not use facial recognition for identification purposes.
• Voice data is used for speech recognition, not biometric identification.
• If you voluntarily provide sensitive information in AI queries (e.g., health questions), processing is based on your explicit consent (Article 9(2)(a)).

Legitimate Interests Assessment: Where we rely on legitimate interests, we have conducted balancing tests to ensure our interests do not override your fundamental rights and freedoms.

8. How We Share Your Information

We share personal information only as described in this Privacy Notice:

8.1 Service Providers (Processors)

We share information with service providers who process data on our behalf under written data processing agreements:

Service providers are contractually obligated to:

• Process data only on our documented instructions
• Ensure confidentiality
• Implement appropriate security measures
• Assist with data subject rights requests
• Delete or return data upon termination
• Submit to audits

8.2 Platform Infrastructure

Glassly may transmit data through Glassly platform infrastructure to deliver the Services, as described in Section 4.2.

8.3 Business Transfers

In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the successor entity. We will provide notice before your information becomes subject to a different privacy policy.

8.4 Legal Requirements

We may disclose information when required by law or in response to valid legal process, including:

• Court orders and subpoenas
• Government or regulatory agency requests
• To protect our rights, property, or safety, or that of our users or the public

Where legally permitted, we will notify you of such requests.

8.5 With Your Consent

We may share information for other purposes with your explicit consent.

8.6 Sale of Personal Information

We do not sell your personal information for money. However, like many companies, we use cookies, pixels, SDKs, and similar technologies on our websites and apps for advertising purposes, which may be considered “selling” or “sharing” personal information under certain state privacy laws (such as the CCPA/CPRA).

You can learn more about these technologies and how to control them, including how to opt out of sale/sharing, in Section 3 (Cookies and Tracking) above.

9. Third-Party Platforms and Services

9.1 Smart Glasses Manufacturers

Your smart glasses hardware is made by a third-party manufacturer (for example, Even Realities, Vuzix, Inmo, NIMO, or Mentra). Software and services provided by your glasses manufacturer are governed by that manufacturer's own terms and privacy policy. Glassly does not control how manufacturers process data collected by their own software.

9.2 Third-Party Integrations

The Services may integrate with third-party services. These third parties are independent controllers, and your use of them is subject to their respective terms and privacy policies.

9.3 Links to Third-Party Sites

Our website and Services may contain links to third-party websites. We are not responsible for their privacy practices.

10. Data Retention

We retain personal information only as long as necessary for the purposes described in this Privacy Notice, or as required by law. Our retention periods are based on:

• The nature of the data
• The purpose of processing
• Legal retention requirements
• Your instructions (e.g., account deletion requests)

Data Deletion

Upon account deletion or expiration of retention periods, we will:

• Delete personal data from active systems within 30 days
• Remove data from backups within 90 days
• Retain only data required by law or for legitimate legal claims

11. Data Security

We implement appropriate technical and organizational measures to protect your personal information in accordance with GDPR Article 32:

Technical Measures

• Encryption of data in transit (TLS 1.3, encrypted UDP)
• Encryption of data at rest (AES-256)
• Secure BLE pairing between glasses and phone
• Access controls and authentication requirements
• Regular security testing and vulnerability assessments
• Intrusion detection and monitoring

Organizational Measures

• Data protection policies and procedures
• Employee training on data protection
• Vendor security assessments
• Incident response procedures
• Regular security audits

Security Research: We welcome responsible disclosure from security researchers at security@tetramo.com.

No Absolute Guarantee: No method of transmission or storage is 100% secure. While we implement industry-standard protections, we cannot guarantee absolute security.

Breach Notification: In the event of a personal data breach likely to result in risk to your rights, we will notify the relevant supervisory authority within 72 hours and notify affected individuals where required by law.

12. International Data Transfers

Tetramo, Inc. is a company incorporated in Delaware, United States. Your personal information will be transferred to and processed in the United States and other countries where our service providers operate.

12.1 Transfer Mechanisms

For transfers from the EEA, UK, or Switzerland to countries without an adequacy decision, we implement:

• Standard Contractual Clauses (SCCs): We use European Commission-approved SCCs (Module 1: Controller-to-Controller; Module 2: Controller-to-Processor) with all relevant recipients
• Supplementary Measures: Where necessary based on transfer impact assessments, we implement additional technical and organizational measures
• Data Processing Agreements: All processors are bound by written agreements meeting GDPR Article 28 requirements

12.2 Transfer Impact Assessments

We have conducted transfer impact assessments for transfers to the United States, considering:

• The legal framework in the destination country
• The nature of data transferred
• Supplementary measures implemented
• Practical experience with government access requests

Copies of our SCCs and transfer impact assessments are available upon request.

12.3 Your Rights Regarding Transfers

You have the right to:

• Obtain information about international transfers
• Request a copy of safeguards in place
• Withdraw consent for transfers (where consent is the legal basis)
• Lodge a complaint with a supervisory authority

13. Children's Privacy

The Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

Ages 13–16 (EEA): Under GDPR Article 8, children under 16 in the EEA require parental consent for information society services. If you are between 13 and 16 in the EEA, you may use the Services only with parental consent.

Ages 13–18 (General): If you are between 13 and 18 (or the age of majority in your jurisdiction), you may use the Services only with parental or legal guardian consent.

Parental Controls: Parents or guardians may:

• Review information collected from their child
• Request deletion of their child's information
• Refuse further collection

If we learn that we have collected personal information from a child without appropriate consent, we will delete that information promptly. Contact us at privacy@tetramo.com if you believe we have collected information from a child.

14. Your Privacy Rights

14.1 Rights Available to All Users

Regardless of location, you may:

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information (subject to legal retention requirements)
• Withdraw Consent: Withdraw consent for processing based on consent
• Opt-Out of Marketing: Unsubscribe from marketing communications

14.2 How to Exercise Your Rights

To exercise your rights:

• Self-Service: Access account settings in the Glassly app for many requests
• Email: Contact privacy@tetramo.com
• Mail: Tetramo, Inc., 2810 N Church St PMB 205013, Wilmington, Delaware 19802-4447, USA

Identity Verification: We will verify your identity before processing requests to protect against unauthorized access. Verification may require:

• Confirmation from your registered email address
• Account authentication
• Additional identifying information for sensitive requests

Response Time: We will respond within 30 days (or sooner if required by applicable law). If we need additional time, we will notify you.

No Fee: We do not charge for exercising your rights, except for manifestly unfounded or excessive requests.

14.3 Authorized Agents

You may authorize an agent to submit requests on your behalf. Agents must provide:

• Signed authorization from you
• Proof of agent's identity

We may contact you directly to verify.

15. Jurisdiction-Specific Provisions

15.1 European Economic Area, United Kingdom, and Switzerland (GDPR)

If you are located in the EEA, UK, or Switzerland:

Data Controller

Tetramo, Inc.
2810 N Church St PMB 205013, Wilmington, Delaware 19802-4447, USA
Email: privacy@tetramo.com

Additional Rights

• Right to Object (Article 21): You may object to processing based on legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds.
• Right to Restrict Processing (Article 18): You may request restriction while we verify accuracy or assess an objection.
• Right to Data Portability (Article 20): You may receive your data in a structured, machine-readable format.
• Right to Lodge a Complaint: You may file a complaint with your local data protection authority. A list of EEA authorities is available at edpb.europa.eu.

EU AI Act Transparency (Regulation 2024/1689)

In compliance with EU AI Act Article 50, we provide the following transparency information:

• AI System Interaction: When you use Glassly AI features, you are interacting with an AI system
• AI-Generated Content: Captions, translations, summaries, and other outputs are generated by AI and may not be accurate
• Emotion Recognition: We do not use emotion recognition AI systems
• Biometric Categorization: We do not use biometric categorization AI systems
• Deep Fakes: We do not generate synthetic content designed to appear authentic (deep fakes)
• Risk Classification: Our AI features are not classified as high-risk AI systems under EU AI Act Annex III

15.2 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Categories of Personal Information Collected (Past 12 Months)

• Sources: Directly from you, automatically from devices, from service providers.
• Purposes: As described in Section 6.
• Disclosure: To service providers and third parties as described in Section 8.

Your California Rights

• Right to Know: Request disclosure of PI collected, sources, purposes, and third parties
• Right to Delete: Request deletion of your PI
• Right to Correct: Request correction of inaccurate PI
• Right to Opt-Out of Sale/Sharing: You have the right to direct us not to “sell” or “share” your personal information, including for cross-context behavioral advertising. To opt out, use the Global Privacy Control (GPC) signal or contact us.
• Right to Limit Sensitive PI: You control sensitive PI collection through device permissions
• Non-Discrimination: We will not discriminate against you for exercising rights

To Exercise Rights: Email privacy@tetramo.com.

Authorized Agent: You may designate an authorized agent with written permission.

Verification: We will verify your identity using information associated with your account.

Shine the Light: California Civil Code § 1798.83 permits California residents to request information about disclosure of PI to third parties for direct marketing. Contact privacy@tetramo.com.

15.3 Other U.S. States

We comply with applicable state privacy laws, including those in Colorado, Connecticut, Virginia, Utah, and other states that have enacted comprehensive privacy legislation. Residents of these states may have rights similar to those described for California residents.

15.4 Other Jurisdictions

We comply with applicable privacy laws in all jurisdictions where we operate. If you have questions about your rights under local law, please contact privacy@tetramo.com.

16. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes:

• Minor Changes: Posted on our website with updated “Last Updated” date
• Material Changes: We will notify you by email and/or in-app notification at least 30 days before changes take effect (or as required by applicable law)

Material changes include:

• New categories of personal data collected
• New purposes for processing
• New categories of recipients
• Changes to your rights
• Changes to international transfer mechanisms

Your continued use of the Services after changes become effective constitutes acceptance of the updated Privacy Notice. If you do not agree with changes, you should stop using the Services.

17. Contact Us

Data Protection Inquiries

Tetramo, Inc.
Email: privacy@tetramo.com
Address: 2810 N Church St PMB 205013, Wilmington, Delaware 19802-4447, USA
Website: https://glassly.ai/privacy

Security Concerns

Email: security@tetramo.com

Customer Support (Non-Privacy)

Email: hello@tetramo.com

Supervisory Authority Complaints

If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection authority:

• EEA: edpb.europa.eu/about-edpb/about-edpb/members_en
• UK: Information Commissioner's Office (ico.org.uk)
• California: California Attorney General (oag.ca.gov)

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Appendix: AI System Information

In accordance with EU AI Act transparency requirements, we provide the following technical information about our AI systems:

• AI Providers: Soniox (speech-to-text), Anthropic (Claude), OpenAI, Google (Gemini), and ElevenLabs (text-to-speech)
• Intended Purpose: AI features are designed to assist users with information, transcription, translation, and visual understanding tasks. They are not designed for safety-critical applications, medical diagnosis, or emergency response.

Known Limitations

• AI outputs may contain factual errors or hallucinations
• Performance varies across languages, accents, and contexts
• AI cannot provide professional medical, legal, or financial advice
• Real-time features may have latency or accuracy variations

Human Oversight: All AI outputs are presented to users for their review and decision-making. No automated decisions are made without human involvement.

Contact for AI-Related Concerns:
Email: privacy@tetramo.com

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