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Privacy Policy

Last updated: February 17, 2026

Effective Date: February 17, 2026

This Privacy Policy explains how Comma Labs Yazılım Anonim Şirketi ("Comma Labs," "we," "us," or "our") collects, uses, and discloses information about you when you use our mobile application Nerdy (the "App") and our website located at commalabs.co and iamnerdy.ai (collectively, the "Service").

We are committed to protecting your privacy and ensuring you have a positive experience on our Service. This policy applies to all users of the Service globally.

By using our Service, you agree to the collection and use of information in accordance with this policy.

Questions? Contact us at privacy@iamnerdy.ai

1.Information We Collect

Information You Provide

  • Account Information: Name, email address, password, and profile details when you create an account.
  • Audio & Voice Data: Voice recordings you choose to capture through our Service for transcription and note generation. We request microphone access solely for this purpose, and recording is always initiated by you.
  • User Content: Notes, documents, flashcards, and other content you create or upload.
  • Payment Information: Billing details processed securely through our payment providers (Stripe, Apple Pay, Google Pay).
  • Communications: Feedback, support requests, and other communications you send to us.

Information Collected Automatically

  • Device Information: Device type, operating system, unique device identifiers, and mobile network information.
  • Usage Data: Features used, recording duration, interaction patterns, and performance metrics.
  • Log Data: IP address, browser type, access times, and pages viewed.
  • Analytics Data: Anonymized usage statistics to improve our Service.

2.How We Use Your Information

We use the information we collect to:

  • Provide, maintain, and improve our Service
  • Process your audio recordings and generate AI-powered transcriptions and notes
  • Create flashcards, summaries, and study materials
  • Process payments and manage your subscription
  • Send service-related communications and updates
  • Provide customer support and respond to inquiries
  • Analyze usage patterns to enhance user experience
  • Detect, prevent, and address technical issues or fraud
  • Comply with legal obligations

3.AI Processing & Machine Learning

Our Service uses artificial intelligence and machine learning to process your audio recordings and generate notes. Here's how we handle your data:

  • Transcription: Your audio is processed using advanced speech recognition models to generate accurate transcriptions.
  • AI Analysis: We use large language models to summarize, organize, and enhance your notes.
  • No Training on Your Data: We do NOT use your personal audio recordings or notes to train our AI models without your explicit consent.
  • Third-Party AI Services: We use third-party AI service providers, including OpenAI and Google Cloud, to process your audio and text data for transcription and analysis. Your personal data is shared with these providers solely for the purpose of delivering the Service. These providers are bound by strict data processing agreements and are prohibited from using your data for their own purposes, including AI model training.
  • Ephemeral Processing: Audio files are processed in real-time and can be deleted from our processing servers immediately after transcription upon your request.

4.Sharing Your Information

We do not sell your personal information. We may share your information in the following circumstances:

  • Service Providers: With trusted third parties who assist us in operating our Service (cloud hosting, payment processing, analytics).
  • AI Processing Partners: With AI service providers for transcription and analysis, under strict data protection terms.
  • Legal Requirements: When required by law, legal process, or to protect our rights.
  • Business Transfers: In connection with a merger, acquisition, or sale of assets.
  • With Your Consent: When you explicitly authorize us to share your information.

5.Data Security

We implement industry-standard security measures to protect your data:

  • Encryption: All data is encrypted in transit (TLS 1.3) and at rest (AES-256).
  • Access Controls: Strict access controls and authentication requirements for our systems.
  • Regular Audits: Periodic security assessments and vulnerability testing.
  • Secure Infrastructure: Our services are hosted on secure, SOC 2 compliant cloud infrastructure.

While we strive to protect your personal information, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

6.Data Retention

We retain your information for as long as your account is active or as needed to provide you services:

  • Account Data: Retained while your account is active and for 30 days after deletion request.
  • Audio Recordings: Stored according to your preferences. You can delete recordings at any time.
  • Notes & Content: Retained until you delete them or close your account.
  • Usage Analytics: Anonymized data may be retained indefinitely for service improvement.

7.International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses approved by relevant authorities
  • Data Processing Agreements with all service providers
  • Compliance with applicable data transfer regulations

8.Your Rights & Choices

Depending on your location, you may have the right to:

  • Access: Request a copy of your personal data.
  • Correction: Request correction of inaccurate data.
  • Deletion: Request deletion of your personal data.
  • Portability: Request your data in a portable format.
  • Restriction: Request restriction of processing.
  • Objection: Object to certain processing activities.
  • Withdraw Consent: Withdraw consent where processing is based on consent.
  • Delete Account: You can request the deletion of your account and all associated data directly within the App settings. Upon request, your account will be deactivated immediately, and your data will be permanently deleted from our active servers within 30 days.

To exercise these rights, contact us at privacy@iamnerdy.ai.

9.Children's Privacy

Our Service is not intended for children under 13 years of age (or the applicable age in your jurisdiction). We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at privacy@iamnerdy.ai.

10.California Privacy Rights (CCPA)

California residents have additional rights under the CCPA:

  • Right to know what personal information is collected
  • Right to know if personal information is sold or disclosed
  • Right to say no to the sale of personal information
  • Right to equal service and price
  • Right to delete personal information

We do not sell personal information. To make a verifiable consumer request, contact us at privacy@iamnerdy.ai.

11.Updates to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

Continued use of the Service after any changes to this Privacy Policy constitutes your acceptance of such changes.

12.Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us: