Privacy Policy

Last Updated: June 17, 2026

This Privacy Policy explains how Conflead (“Conflead,” “App,” “Service,” “we,” “us,” or “our”) collects, uses, stores, and protects personal data when you use Conflead as a standalone mobile user. We are committed to processing personal data responsibly, securely, and transparently, in compliance with Regulation (EU) 2016/679 (GDPR), the UK GDPR where applicable, and other applicable data protection laws. By using the App, you acknowledge that your personal data will be processed as described here. This Privacy Policy should be read together with our Terms of Use.

1. Who We Are

Conflead is operated by Geniusee LLC registered under the laws of Ukraine, registration number 41464540, registered address: Yaroslavs’kyi Ln, 4, Kyiv, Ukraine, 04071. For standalone users, we act as data controller within the meaning of Article 4(7) GDPR.

Data Protection Contact: c.conflead@geniusee.com

2. Scope of This Privacy Policy

This Privacy Policy applies to users of the Conflead mobile application. It governs our processing of personal data when you create or use a standalone account, use available features, add or generate data, use AI-assisted functionality, or contact us for support.

3. Personal Data We May Collect

Account and profile data: email address, name, gender, profile picture, preferred language or languages, account settings, account status, login and session details, and other profile or account details needed to create, secure, personalise, and operate your account.

Authentication provider data: if you sign in via Apple, Google, or Microsoft, we receive only the data necessary to authenticate you, including provider ID, email, gender, name, profile picture, and authentication tokens. We do not receive your password.

User Content and lead data: conference and event information; lead and contact details such as names, emails, phone numbers, job titles, company names, LinkedIn links, websites, country, and region; meeting information and summaries; voice recordings or transcriptions; AI-generated content; follow-up emails and sequences; calendar data; export files; and related metadata. If you add data about third parties, you are responsible for ensuring you have all required rights, notices, and lawful bases to do so.

AI-related data: data you provide or create in the App to generate AI outputs, including account data, lead data, meeting information, summaries, and transcriptions. You must not submit sensitive personal data, special category data under Article 9 GDPR, or data you are not authorised to process through AI features.

Email and communication data: recipient information, subject lines, email content, send date and time, email sequence data, email status, connected email account information, and related metadata where you use email functionality.

Purchase and subscription data: purchased plan, subscription and payment status, transaction identifier, renewal and cancellation status, and payment confirmation. Full payment card details are handled by Apple App Store, Google Play, or Stripe; we do not store them.

Device, technical, and usage data: device model, operating system and app version, IP address, approximate location from IP, app events, feature usage, crash reports, error logs, and security events.

Support and contact data: name, email, message content, and communication history when you contact us.

Aggregated or anonymised data: we may derive aggregated or anonymised information for analytics and product improvement. If such data could re-identify you, we treat it as personal data.

4. Special Categories of Personal Data

We do not intentionally collect special category data within the meaning of Article 9 GDPR, such as health data, biometric data, racial or ethnic origin, political opinions, religious beliefs, or sexual orientation. You must not upload or process such data through the Service unless you hold all required explicit consents and legal safeguards under applicable law.

5. Data Minimisation

We collect and process only personal data that is reasonably necessary for the purposes described in this Privacy Policy.

6. Lawful Bases for Processing

Where applicable law requires a lawful basis for processing, we rely on:

  • Performance of a contract (Art. 6(1)(b) GDPR): to provide the Service, manage your account, and process payments.
  • Legitimate interests (Art. 6(1)(f) GDPR): to maintain security, prevent fraud, improve the Service using aggregated data, and provide support. We have assessed that these interests are not overridden by your fundamental rights.
  • Legal obligation (Art. 6(1)(c) GDPR): to comply with applicable tax, financial, and regulatory requirements and respond to lawful authority requests.
  • Consent (Art. 6(1)(a) GDPR): for non-essential cookies and optional marketing communications where required by law. Consent may be withdrawn at any time without affecting prior lawful processing.

7. How We Use Personal Data

We use your personal data for the following purposes:

  • Service Delivery: to create and manage your account; to execute test sessions you request; to generate and display video recordings, logs, and reports.
  • Billing and Payments: to process subscription payments, issue invoices, and manage billing disputes.
  • Customer Support: to respond to inquiries, troubleshoot issues, and provide technical assistance.
  • Security and Fraud Prevention: to detect, investigate, and prevent fraudulent transactions, unauthorized access, and abuse of the Service.
  • Service Improvement: to analyze aggregated, anonymized usage patterns to improve the Service's functionality, performance, and reliability. We do not use your session-specific data for this purpose.
  • Legal Compliance: to comply with applicable law, respond to lawful requests, and enforce our Terms.
  • Communications: to send you service-related notifications such as billing receipts or downtime alerts and, with your consent, marketing updates about new features.
  • To execute the test cases you request.
  • To provide you with video evidence and reports of the test runs.

No Model Training: We do not use your proprietary test data, screenshots, or code snippets to train or improve the underlying BrowserUse or third-party AI models.

8. Data About Other People

The Service may permit you to add, store, or otherwise process data relating to third parties, including without limitation leads, contacts, meeting participants, email recipients, or any other individuals whose information you input into or process through the Service.

You bear sole and complete responsibility for ensuring that you possess all necessary rights, permissions, notices, consents, or other lawful basis required to use such data through the Service.

The Company acts solely as a technical intermediary and processes such third-party data only to the extent necessary to provide the Service and the specific functionality you elect to use. The Company does not verify, validate, or assume any responsibility for the lawfulness, accuracy, completeness, or basis upon which you obtained such information.

You agree to be solely responsible, at your own expense, for resolving any claims, disputes, or demands brought by third parties arising from or related to the processing of their data through the Service, and you agree to indemnify and hold the Company harmless from any losses, damages, or liabilities arising from your breach of this provision.

  • input such data into the Service;
  • store such data;
  • process such data in any manner;
  • send emails based on or to such data;
  • synchronize such data with other systems or platforms;
  • export such data; or
  • otherwise use such data through any functionality of the Service.

The Company acts solely as a technical intermediary and processes such third-party data only to the extent necessary to provide the Service and the specific functionality you elect to use. The Company does not verify, validate, or assume any responsibility for the lawfulness, accuracy, completeness, or basis upon which you obtained such information.

You agree to be solely responsible, at your own expense, for resolving any claims, disputes, or demands brought by third parties arising from or related to the processing of their data through the Service, and you agree to indemnify and hold the Company harmless from any losses, damages, or liabilities arising from your breach of this provision.

9. AI Processing

Where you use AI-assisted features, information you provide is processed to generate outputs such as summaries, extracted data, talking points, or follow-up emails. We may use third-party AI providers to support AI features; such providers process data only as necessary to generate the requested output and do not retain User Content beyond the active processing request or use it to train their models. AI outputs may be inaccurate or incomplete. You are responsible for reviewing all AI-generated content before using or sending it.

10. Email Features

If you connect an email account or use email functionality within the Service, we process the data needed to create, schedule, send, stop, or track emails.

You are responsible for ensuring you have the right to contact recipients and that your communications comply with applicable laws, including privacy, electronic communications, marketing, and anti-spam laws such as the ePrivacy Directive 2002/58/EC and GDPR.

We do not guarantee email delivery, inbox placement, replies, conversions, or other business results.

11. Third-Party Services and Disclosures

We do not sell your personal data. We share personal data with third-party service providers only as necessary to operate the Service, under written agreements requiring them to process data only on our instructions and maintain appropriate security.

Providers include:

  • cloud hosting and infrastructure providers;
  • authentication providers (Apple, Google, Microsoft);
  • payment providers (App Store, Google Play, Stripe);
  • AI, transcription, and automation providers;
  • email and calendar providers;
  • analytics and diagnostics providers;
  • security and fraud prevention providers;
  • legal, accounting, and compliance advisers;
  • competent authorities, regulators, or courts where required by law;
  • successors in a merger, acquisition, or sale of assets, subject to confidentiality obligations.

12. International Data Transfers

Your data may be processed in countries outside the European Economic Area, including the country where you are located.

Where such transfers occur, we apply appropriate safeguards required by applicable law, such as Standard Contractual Clauses adopted by the European Commission, adequacy decisions, or other legally recognised transfer mechanisms.

Details on the safeguards applied to a specific transfer are available upon request.

13. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure in accordance with Article 32 GDPR. These measures may include access controls, confidentiality obligations, encryption in transit (TLS 1.2 or higher), monitoring, and incident response procedures.

No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with Article 34 GDPR.

You are responsible for keeping your device, account credentials, email account, authentication methods, and connected third-party accounts secure.

14. Data Retention

We retain personal data only for as long as necessary for the purposes described here or as required by applicable law:

  • Account and profile data: duration of your account plus 3 years after closure.
  • Lead data, meeting content, AI outputs, voice recordings: duration of your account; deleted within 30 days of account deletion except where required by law.
  • Billing records: 7 years from transaction date, as required by financial and tax law.
  • Support communications: 2 years from resolution.
  • Security and usage logs: 90 days; anonymised aggregates may be retained indefinitely.

If you delete your account, we will delete or anonymise personal data where required, subject to backup retention, fraud prevention, security logs, legal obligations, billing records, and dispute records. Data that has been sent, exported, synced, emailed, or stored in third-party services may need to be deleted separately through those services.

15. Account Deletion

Where required by applicable app store rules or law, the App provides a mechanism to initiate account deletion. Deleting your account may remove or disable access to your personal workspace and associated data, subject to applicable law and the retention rules described above. Some data may remain in backups or logs for a limited period before permanent deletion.

16. Your Privacy Rights

Depending on your location and applicable law, you may have rights regarding your personal data. If you are located in the EEA or UK, you have the right under the GDPR and UK GDPR to:

  • be informed about how your personal data is processed (Arts. 13–14 GDPR);
  • request access to your personal data (Art. 15 GDPR);
  • request correction of inaccurate or incomplete personal data (Art. 16 GDPR);
  • request deletion of personal data, where the legal basis for processing no longer applies (Art. 17 GDPR);
  • request restriction of certain processing (Art. 18 GDPR);
  • receive your data in a portable format, where processing is based on contract or consent and carried out by automated means (Art. 20 GDPR);
  • object to processing based on legitimate interests, including direct marketing, at any time (Art. 21 GDPR);
  • not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR);
  • withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal;
  • lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).

To exercise your rights, contact us using the details in the Contact section. We may need to verify your identity before responding to your request. We will respond within 30 days of receipt, which may be extended by a further 60 days for complex requests, in which case we will notify you of the extension and the reasons for the delay. Some rights may be limited by applicable law, security requirements, legal obligations, fraud prevention, or the rights of others.

17. Service and Marketing Communications

We may send you service-related communications, including account messages, security notices, purchase confirmations, product updates, technical notices, and support messages, as necessary for the provision of the Service.

Where permitted by law and, where required, with your prior consent, we may send marketing communications about Conflead. You may opt out of marketing communications at any time using the unsubscribe option provided or by contacting us. You may still receive non-marketing service communications even if you opt out of marketing messages.

18. Cookies and Similar Technologies

Where Conflead uses websites, landing pages, analytics tools, or web-based services, we use only strictly necessary cookies without consent. For non-essential cookies, we obtain your prior consent in accordance with Article 5(3) of Directive 2002/58/EC (ePrivacy Directive) and provide cookie management options. More information may be provided in a Cookie Policy or cookie notice where applicable.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide at least 14 days' prior notice through the App, by email, on our website, or by another reasonable method, and update the Last Updated date.

Your continued use of the Service after the updated Privacy Policy becomes effective constitutes your acceptance of the updated Privacy Policy.

20. Contact

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

Company: Conflead

Data Protection Contact: c.conflead@geniusee.com

Address: Yaroslavs’kyi Ln, 4, Kyiv, Ukraine, 04071

We aim to respond to all privacy-related inquiries within 72 hours.