JetSpring, LLC d/b/a Palera (“Palera,” “we,” “us,” or “our”)respects your privacy and is committed to protecting personal data. ThisPrivacy Policy explains how we collect, use, disclose, and otherwise processpersonal data in connection with our websites, applications, APIs, integrations, voice and messaging services, and related business activities.

Palera provides an enterprise conversation operations platformsupporting communications and workflows across channels such as SMS, MMS, webchat, live chat, social and messaging channels, voice, Voice AI, analytics, transcription, recording, automation, and related integrations. This Privacy Policy helps you understand what personal data we collect, how we use it, who we share it with, and what choices you have.

This Privacy Policy applies when you:

•      visit websites, landing pages, or digital propertiesthat link to this Privacy Policy;

•      sign up for a free trial, request a demo, create anaccount, or use our Services;

•      interact with us as a customer, prospect, vendor, partner, event attendee, or office visitor;

•      communicate with us by email, phone, chat, socialmedia, or otherwise; or

•      interact with content, features, or communications thatreference this Privacy Policy.

This Privacy Policy does not apply to Palera personnel or jobapplicants, or to information subject to a separate notice provided in a particular context. It also does not alter any data processing terms, data protection addenda, or other contractual commitments we make to customers in connection with our role as a data processor or service provider.

1. OUR ROLE AND SCOPE

1.1 Controller / Business Activities

Palera acts as a data controller or “business” with respect to personal data we collect and process for our own business purposes, including website administration, sales and marketing, account administration, billing, support, vendor management, security operations, event management, and legal compliance.

1.2 Processor / Service Provider Activities

When our customers use the Services to communicate with theirown end users, leads, patients, students, customers, members, employees, or other contacts, Palera generally processes relevant personal data on behalf ofand under the instructions of the customer. In that context, the customer typically determines the purposes and means of processing and Palera acts as a data processor or service provider, subject to applicable contractual terms. If you are an end user interacting with one of our customers through the Services and have questions about how your data is used, you should contact that customer directly.

1.3 Business and Commercial Context

Palera’s Services are intended primarily for use in commercial, professional, institutional, and business contexts rather than for personal, family, or household use.

1.4 Customer Responsibilities

Customers are responsible for determining whether and how they use the Services to process personal data; for providing appropriate notices totheir own end users; and for obtaining any consents or authorizations requiredby law. Customers are also responsible for configuring channel settings, retention settings, access controls, workflow rules, and integrations in a lawful manner. Customers are responsible for providing all required disclosures to their end users regarding call recording, transcription, and AI-generated communications, including two-party consent disclosures required in applicable states.

2. PERSONAL DATA WE COLLECT

The categories of personal data we collect depend on how youinteract with us and the Services, the features you use, the channels involved,and whether you are acting as an account user, website visitor, prospect, event attendee, support contact, or end user.

2.1 Information You Provide to Us

•      Contact and account information: your name,business email address, phone number, company name, title, role, mailing address, and account profile details.

•      Registration and onboarding information: credentials, user IDs, preferences, workspace information, channel configuration details, and implementation inputs.

•      Billing and transaction information: billing contact information, payment-related details, invoicing information, tax information, and transaction history. Payment card processing is handled by third-party processors rather than by Palera directly.

•      Communications and support information: the contents of messages, emails, support tickets, call recordings, meeting notes, chat transcripts, attachments, screenshots, and feedback you provide to us.

•      Sales, marketing, and events information: webinar registrations, survey responses, event attendance details, promotional preferences, or information you provide during demos, calls, or conferences.

•      Office and security information: visitor sign-ininformation, access logs, CCTV footage, or identification details where required for physical security.

•      Customer content and workspace data: conversation records, transcripts, recordings, notes, tags, dispositions, summaries, QA evaluations, routing information, campaign configuration, automation settings, and user-generated content stored in or transmitted through the Services.

•      Integration and channel configuration information: accountIDs, page IDs, channel tokens, meta data, phone numbers, messaging numbers, SIP configuration, webhook destinations, or other information required to connectexternal services to the platform.

2.2Information Collected Automatically

When you use our websites, applications, or Services, we and our service providers may automatically collect:

•      Device and browser information: IP address, browser type, operating system, device identifiers, language settings, screenresolution, and approximate geolocation inferred from IP address.

•      Usage and log information: access times, pagesviewed, features used, links clicked, referral URLs, diagnostic logs, crash data, navigation paths, session information, and interaction data.

•      Authentication and security information: login attempts, token activity, device activity, system alerts, and fraud-prevention signals.

•      Cookie and similar technology data: as described in Section 6 (Cookies and Similar Technologies).

2.3 Information From Customers, Integrations, and Third Parties

We may receive personal data from:

•      our customers and their authorized users;

•      connected services and integrations selected or enabled by customers, such as CRM platforms, ticketing systems, SSO providers, data warehouses, analytics providers, cloud telephony vendors, social and messaging platforms, and other APIs;

•      telecommunications carriers, messaging channel providers, and voice providers;

•      marketing, advertising, enrichment, lead generation, ordata verification providers;

•      publicly available sources, such as professionalprofiles or company websites; and

•      event organizers, partners, or referral sources.

2.4 Conversation and Communications Data

Because Palera is a communication and conversation operations platform, personal data processed through the Services may include:

•      phone numbers and messaging identifiers;

•      names, email addresses, or account identifiers;

•      communication content and attachments;

•      call recordings and transcripts (subject to applicable consent and two-party consent requirements);

•      AI-generated summaries, classifications, and inferences;

•      tags, notes, disposition codes, and workflow metadata;

•      timestamps, duration, delivery status, and routing events; and

•      support history, conversation history, and interaction patterns.

Depending on customer configuration and use case, this information may relate to customers’ end users, patient contacts, students, leads, members, applicants, clients, employees, or other individuals with whom a customer interacts through the Services.

2.5 Sensitive Data

We ask customers and users not to submit sensitive personal data — including payment card data, protected health information, student education records, or special category data under GDPR — unless Palera hasexpressly agreed in writing to support the relevant regulated use case and the parties have executed any necessary addenda. Please see the Agreement for details on Sensitive Data restrictions.

3. HOW WE USE PERSONAL DATA

3.1 Service Delivery and Account Administration

We use personal data to provide, maintain, administer, monitor, and improve the Services; create and manage accounts; authenticate users; enable channel connections and integrations; configure workspaces;provide customer support; facilitate onboarding and implementation; process transactions; and communicate about the Services.

3.2 Communications

We use personal data to respond to inquiries, provide technical and account support, send administrative notices, notify users ofchanges or incidents, schedule meetings, conduct customer success activities, and otherwise communicate with customers, prospects, and partners.

3.3 Product Improvement and Research

We use personal data, including usage data and de-identifiedor aggregated information, to analyze performance, troubleshoot issues, improve user experience, build or refine features, train internal teams, and support product development, analytics, and research.

3.4 Artificial Intelligence and Automation

We use artificial intelligence, machine learning, generativeAI, transcription technologies, speech technologies, and workflow automation to support certain features and internal operations. Depending on configuration, these activities may include transcription, summarization, classification, quality scoring, routing assistance, sentiment analysis, keyword extraction, suggested actions, and operational analytics.

Palera contractually prohibits its Third-Party AI Providersfrom using Customer Data to train or improve their generalized foundation models for their own benefit without Customer consent. Any use of de-identifiedor aggregated data for product improvement purposes is subject to the opt-out mechanism described in the AI + VoiceSupplemental Terms.

3.5 Security, Integrity, and Abuse Prevention

We use personal data to maintain the security, availability, and integrity of our websites, systems, and Services; detect and prevent fraud,spam, abuse, unauthorized access, and unlawful activity; enforce our terms andpolicies; conduct internal audits and investigations; and protect our rights, property, and safety and the rights, property, and safety of others.

3.6 Sales, Marketing, and Advertising

As permitted by law, we use personal data to market our products and services, send newsletters and promotional communications, managelead generation, run events and campaigns, measure campaign performance, and personalize content. You can opt out of marketing communications as described in Section 10.

3.7 Business Operations

We use personal data to administer contracts, manage vendors, perform finance and accounting functions, process invoices and payments, support internal reporting, manage audits, perform due diligence, maintain business continuity, and support day-to-day operations.

3. Legal and Compliance Purposes

We use personal data to comply with legal obligations, cooperate with law enforcement or regulatory authorities, respond to legal process, establish or defend legal claims, enforce agreements, manage corporate transactions, and meet tax, accounting, audit, and recordkeeping requirements.

4. LEGAL BASES FOR PROCESSING (EEA, UK, AND SWITZERLAND)

If you are located in the EEA, UK, or Switzerland, our legal bases for processing your personal data include:

4.1 Contractual Necessity

We process personal data where necessary to enter into orperform a contract with you or the organization you represent, including to provide the Services, create accounts, onboard customers, deliver support, process payments, and respond to requests related to contractual performance.

4.2 Legitimate Interests

We process personal data where necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms. Our legitimate interests include operating and improving our Services, securing our systems, preventing fraud, communicating with business contacts, measuring product performance, supporting customer success, and marketing our products in a business context.

4.3 Consent

We process personal data based on consent where required bylaw, such as for certain marketing communications or certain cookies and tracking technologies. You may withdraw consent at any time, although this does not affect prior lawful processing.

4.4 Compliance With Legal Obligations

We process personal data where necessary to comply with applicable laws, regulations, court orders, government requests, or other legal obligations.

5. HOW WE SHARE PERSONAL DATA

We may disclose personal data to the following categories of recipients, as appropriate:

5.1 Service Providers and Subprocessors

We share personal data with vendors and service providers that help us operate the Services or our business, such as cloud hosting providers, infrastructure providers, analytics vendors, payment processors, customer support platforms, security vendors, identity and authentication providers, AI and transcription providers, telephony and messaging vendors, email providers, and professional services firms. These parties process personal data on ourbehalf and under contractual restrictions.

5.2 Channel Partners, Carriers, and Connected Services

Where required to deliver the Services or where selected by a customer, we may disclose personal data to messaging channels, telecom carriers, voice providers, CRM systems, ticketing systems, cloud telephony providers, social media and messaging platforms, and other Connected Services. If a customer uses Meta channels, WhatsApp, voice providers, SIP carriers, or customer-owned carrier accounts, relevant communications data and metadata maybe transmitted to or from those parties as necessary to provide the service.

5.3 Affiliates and Corporate Group Entities

We may share personal data with current or future affiliates or related entities for purposes consistent with this Privacy Policy, including operations, support, security, finance, legal, and service administration.

5.4 Professional Advisors

We may share personal data with lawyers, auditors, accountants, insurers, bankers, and similar professional advisors where necessary in connection with the services they provide to us.

5.5 Authorities and Others for Legal and Security Purposes

We may disclose personal data to law enforcement, regulators, courts, private litigants, and other third parties where we believe in good faith that disclosure is necessary to comply with law, enforce our rights,protect safety or security, investigate misuse, or prevent fraud or other illegal activity.

5.6 Business Transfers

We may disclose or transfer personal data in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, including during diligence and negotiation.

5.7 AtYour Direction or With Your Consent

We may disclose personal data at your direction, through your use of integrations and settings, or with your consent.

5.8 NoSale of Personal Data; No Sharing of SMS Consent Data

Palera does not sell personal data for money. Palera does not share personal data with third parties for those third parties’ owncross-context behavioral advertising purposes. Because we do not engage in the“sale” or “sharing” of personal data as defined under the California ConsumerPrivacy Act (CCPA/CPRA), a “Do Not Sell or Share” opt-out mechanism is not required for our business at this time. We will update this section promptly ifthis practice changes.

Mobile phone numbers and SMS opt-in consent records are notsold, rented, or transferred to third parties for marketing purposes. In the event of a business transfer, Palera will provide notice and an opportunity to opt out before any such data is transferred to a successor.

6. COOKIES AND SIMILAR TECHNOLOGIES

We and our partners use cookies, pixels, local storage, SDKs, and similar technologies on our websites and certain digital properties to:

•      operate and secure the websites;

•      remember preferences and settings;

•      measure traffic, engagement, and feature performance;

•      support analytics and troubleshooting; and

•      where permitted, support advertising and remarketing.

6.1 Types of Cookies

•      Essential cookies: needed for security, authentication, or core website operation.

•      Functional cookies: that remember settings and preferences.

•      Analytics cookies: that help us understand site and product usage.

•      Advertising or marketing cookies: that support campaign measurement or remarketing where permitted.

6.2 Cookie Choices

In jurisdictions where consent is required before placing non-essential cookies, we will obtain consent via our cookie consent banner before doing so. You may manage your cookie preferences at any time through ourcookie preference center available in the footer of our website or by adjusting your browser settings. Disabling certain cookies may affect website functionality.

6.3 DoNot Track and Global Privacy Control

We currently do not respond to “Do Not Track” browser signalsbecause there is no consistent industry standard for such signals. Whererequired by applicable law, we honor Global Privacy Control (GPC) signals asopt-out instructions for sale or sharing of personal information.

7. DATA RETENTION

We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain accounts, comply with legal obligations, resolve disputes,enforce agreements, preserve evidence, complete audits, and protect security and integrity.

Retention periods vary depending on the type of data, the nature of the relationship, legal obligations, customer settings, backup practices, and the purposes for processing. When we no longer need personal data, we will delete, anonymize, aggregate, or isolate it, unless retention is required or permitted for backup, legal hold, dispute resolution, fraud prevention, security logs, or record keeping.

8. INTERNATIONAL DATA TRANSFERS

Palera is headquartered in the United States, and we mayprocess personal data in the United States and other countries where we or ourservice providers operate. Those countries may have data protection laws that differ from the laws of your jurisdiction.

Where required, we implement appropriate safeguards for international transfers, such as Standard Contractual Clauses (SCCs) issued bythe European Commission or other legally recognized transfer mechanisms. We mayalso rely on adequacy decisions where available. Customers requiring a Data Processing Addendum with incorporated SCCs or other transfer documentation may contact us at privacy@palera.ai.

9. SECURITY

We use technical, administrative, and organizational safeguards designed to protect personal data against unauthorized access,destruction, loss, alteration, misuse, or disclosure. These measures may include access controls, encryption, logging, secure development practices, vendor diligence, and incident response procedures.

No method of transmission or storage is completely secure, andwe cannot guarantee absolute security. Customers are also responsible formaintaining appropriate security in their own environments, including credential management, integration settings, access permissions, and lawful useof channels and end-user data.

10. YOUR RIGHTS AND CHOICES

10.1 General Choices

You may opt out of marketing emails by using the unsubscribe link in the message or contacting us at privacy@palera.ai. Even if you opt out of marketing, we may still send service-related or transactional communications.

10.2 Access, Update, and Deletion Requests

Depending on your relationship with us and applicable law, youmay be able to request access to, correction of, deletion of, or portability of your personal data; object to certain processing; restrict certain processing; or withdraw consent. We may need to verify your identity before honoring arequest. To submit a request, contact privacy@palera.ai.

10.3 EndUsers of Our Customers

If your personal data is processed through the Services onbehalf of one of our customers, we may direct your request to that customer, because that customer is generally responsible for determining how that data is processed.

10.4 EEA, UK, and Switzerland Rights

Individuals in the EEA, UK, and Switzerland may have rights ofaccess, rectification, erasure, restriction, objection, portability, and withdrawal of consent under applicable data protection laws, and may lodge acomplaint with a supervisory authority. Requests may be submitted to privacy@palera.ai. We will respond within the timeframes required by applicable law.

10.5 California Rights

If you are a California resident, you may have rights under the CCPA/CPRA, including the right to know, access, delete, and correct personal information we have collected about you, and the right to non-discrimination for exercising these rights.

As stated in Section 5.8, Palera does not sell or share personal information for cross-context behavioral advertising. Accordingly, a“Do Not Sell or Share My Personal Information” opt-out is not applicable to our current data practices. We will update this section promptly if this changes.

To exercise your rights to know, access, delete, or correct your personal information, please contact us at privacy@palera.ai. We will verify your identity and respond within the timeframes required by applicable law. California residents may use an authorized agent to submit requests, subject to verification requirements.

10.6 AIModel Improvement Opt-Out

If Customer wishes to opt out of de-identified use of data formodel improvement purposes, Customer may do so through the account settings toggle (where available) or by submitting a written request toprivacy@palera.ai. Palera will process opt-out requests within thirty (30) days. See the AI + Voice Supplemental Terms for full details.

11. CHILDREN’S PRIVACY

Our websites and Services are not directed to children underthe age of 13, and we do not knowingly collect personal data directly fromchildren under 13 for our own marketing or website purposes. If we become awarethat we have collected such data in violation of applicable law, we will take appropriate steps to delete it.

Because customers may use the Services in contexts such as education or healthcare where interactions may involve minors, customer-controlled use of the Services may involve information about minors where permitted by applicable law and customer contract. In such cases, the customer is responsible for obtaining all necessary notices, consents, anda uthorizations and for operating in compliance with applicable children’s privacy laws, including COPPA and FERPA. Customers using the Services in an educational context involving student records should contact legal@palera.ai regarding a FERPA addendum.

12. THIRD-PARTY WEBSITES AND SERVICES

Our websites and Services may contain links to third-party websites, products, or services, and we may offer integrations with third-party platforms. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy notices before providing any personal data.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect legal, technical, or business developments. When we make material changes, wewill revise the effective date and provide notice as required by applicable law, such as by posting a notice on our website or sending an email to account holders. Your continued use of the applicable websites or Services after an updated Privacy Policy becomes effective means the updated policy applies going forward, subject to applicable law.

14. CONTACT US

If you have questions, requests, or concerns about this Privacy Policy or our privacy practices, please contact us at:

JetSpring, LLC d/b/a Palera

1221  Brickell Avenue, Suite 900

Miami,  FL 33131

Privacy  inquiries: privacy@palera.ai

General:  hello@palera.ai

Telephone:  (786) 862-6112

Legal  notices: support@palera.ai

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