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Privacy Policy

Your privacy is important to us

Effective Date: February 20, 2026

Last Updated: February 20, 2026

Version: 2.0

SumGeniusAI LLC ("Company", "we", "our", or "us") values your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://sumgenius.ai (the "Site") or use any services or features we provide (collectively, the "Services").

By accessing or using our Services, you agree to the terms of this Privacy Policy. If you do not agree, please do not access the Site.

1. Information We Collect

a. Personal Information You Provide to Us:

  • Name, email address, phone number, company name
  • Billing and payment information
  • Project or service inquiry details
  • Any other data you voluntarily submit through contact forms or service requests

b. Information We Automatically Collect:

  • IP address and browser type - Collected for security monitoring, rate limiting, fraud prevention, and abuse protection
  • Device type, operating system, and geographic location
  • Pages visited, referring website, and usage patterns (via cookies and tracking tools like Google Analytics and Microsoft Clarity)
  • Session recordings and interaction data - Mouse movements, clicks, scrolling behavior, and page interactions captured via Microsoft Clarity (with automatic masking of sensitive fields)

Security & Fraud Prevention Logging:

We log IP addresses for security monitoring, rate limiting, and fraud prevention. See §5 (Data Security) for full details on what is logged, how long it is retained, and how IP addresses are anonymized.

c. Information from Third Parties:

We may receive information from third-party sources including partners, service providers, and publicly available databases.

2. How We Use Your Information

We use your information to:

  • Provide and improve our Services
  • Respond to inquiries or support requests
  • Personalize user experience
  • Send marketing and promotional materials (if you opt in)
  • Process payments and manage subscriptions
  • Comply with legal obligations or enforce our terms

3. Sharing Your Information

We do not sell your personal information. We may share your data with:

  • Service providers (e.g., hosting, analytics, payment processors, real-time messaging via Pusher)
  • Contractors or business partners under confidentiality obligations
  • Legal or governmental authorities as required by law
  • In case of a business transfer (e.g., merger or acquisition)

4. Cookies & Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience. We now provide a cookie consent banner that allows you to control which types of cookies you accept. You can also manage cookie settings through your browser.

Types of Cookies We Use:

Essential Cookies (Always Active)

These cookies are necessary for the website to function properly and cannot be disabled.

  • PHPSESSID - Session cookie for maintaining login state (expires when browser closes)

Functional Cookies (Optional)

These cookies remember your preferences and enhance your experience.

  • sumgenius_cookie_consent - Your cookie consent preferences (persistent)

Analytics Cookies (Optional)

These cookies help us understand how visitors use our website (includes session recordings and heatmaps).

  • Google Analytics (_ga, _gid, _gat) - Website traffic analytics and user behavior tracking
  • Microsoft Clarity (_clck, _clsk) - Session recordings, heatmaps, and user interaction analytics

Marketing Cookies (Optional)

These cookies track the effectiveness of our marketing campaigns. Currently not implemented.

Managing Your Cookie Preferences

You can manage your cookie preferences at any time by:

  • Using our cookie consent banner that appears on your first visit
  • Clicking the "Cookie Settings" button in the consent banner
  • Clearing your browser's cookies and localStorage
  • Adjusting your browser settings to block or delete cookies

Note: Disabling essential cookies may prevent you from using certain features of our website, such as the customer portal.

Session Recording & Heatmap Analytics

We use Microsoft Clarity to understand how visitors interact with our website through session recordings and heatmap analytics. This helps us identify usability issues, improve user experience, and optimize our website design.

What Microsoft Clarity Collects:

Clarity captures session recordings (mouse movements, clicks, scrolling), heatmaps, and behavior insights (rage clicks, dead clicks, JavaScript errors). It also collects technical data including browser type, device type, screen resolution, and navigation paths. IP addresses are automatically anonymized by Microsoft. Two cookies are set: _clck (persistent, 1 year — stores a unique user ID) and _clsk (session, 1 day — groups page views into a single recording).

Third-Party Data Processing:

Microsoft Clarity processes session data in accordance with the Microsoft Privacy Statement. Microsoft does not sell personal data collected through Clarity or use it for advertising purposes. Session recordings are stored on Microsoft's secure servers and are accessible only to authorized SumGeniusAI personnel.

Privacy Protections for Session Recordings:

Automatic Data Masking:

  • ✓ Password fields are always masked (shown as ••••••)
  • ✓ Email addresses are automatically masked
  • ✓ Credit card numbers and payment information are masked
  • ✓ Phone numbers are masked
  • ✓ IP addresses are anonymized by Microsoft
  • ✓ Text masking mode: "Balanced" - masks user-entered data while showing site content

How to Opt-Out of Session Recordings:

You can disable Microsoft Clarity session recordings and heatmaps by:

  • Rejecting or disabling "Analytics" cookies in our cookie consent banner
  • Enabling Global Privacy Control (GPC) in your browser (automatically blocks all analytics)
  • Using browser privacy extensions like Privacy Badger or uBlock Origin to block third-party analytics
  • Adjusting your browser settings to block third-party cookies

Data Retention for Session Recordings:

  • Session Recordings: Stored by Microsoft Clarity for up to 30 days, then automatically deleted
  • Heatmap Data: Aggregated anonymized data retained indefinitely for performance analysis
  • Analytics Reports: Summary statistics retained to track improvements over time

Legal Basis (GDPR): Article 6(1)(f) - Legitimate interests in improving website usability and user experience. You can object to this processing by disabling Analytics cookies.

5. Data Security

We implement industry-standard security measures to protect your data, including SSL encryption, firewalls, and regular vulnerability scanning. However, no method of transmission over the internet is 100% secure.

Security Monitoring & Audit Logging

To maintain the security and integrity of our services, we implement comprehensive security logging:

  • Access Logging: All authentication attempts, including successful logins and failed attempts, are logged with timestamps and IP addresses
  • CSRF Protection Logging: Failed CSRF token validations are logged to detect and prevent cross-site request forgery attacks
  • Rate Limiting: Request patterns are monitored to identify and block abusive traffic or potential DDoS attacks
  • Webhook Security: All webhook requests are verified using cryptographic signatures, with verification failures logged for security analysis
  • Data Access Auditing: Sensitive data operations (conversations deletion, consent changes, etc.) are logged with full audit trails

Security logs are stored securely with restricted access. IP addresses in logs are automatically anonymized by masking the last two octets. Log files are automatically rotated when they exceed 10MB to prevent indefinite storage growth.

Data Protection Measures

  • Encryption at Rest: OAuth tokens and sensitive credentials are encrypted using AES-256-CBC encryption before storage
  • Encryption in Transit: All data transmission uses TLS/SSL encryption
  • Access Controls: Role-based access control (RBAC) ensures only authorized personnel can access sensitive data
  • Transaction Safety: Database operations use transactions with automatic rollback on errors to maintain data integrity
  • Input Validation: All user inputs are validated and sanitized to prevent SQL injection, XSS, and other injection attacks

6. Your Rights

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

  • Access, correct, or delete your personal information
  • Opt out of data processing or marketing communications
  • Request data portability
  • File a complaint with a data protection authority

For these requests, please contact us at info@sumgenius.ai.

7. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information.

Your California Rights:

  • Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collect information, our business purposes for collecting information, and the categories of third parties with whom we share information.
  • Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.
  • Right to Opt-Out: You have the right to opt-out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising.
  • Right to Correct: You have the right to request correction of inaccurate personal information.
  • Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information to purposes necessary to perform our services.
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights.

Global Privacy Control (GPC):

We honor Global Privacy Control (GPC) signals. If your browser sends a GPC signal, we will automatically opt you out of the "sale" or "sharing" of your personal information and limit the use of sensitive personal information.

Do Not Sell or Share My Personal Information:

We do not "sell" personal information as defined by the CCPA. We may share certain information with third-party service providers and analytics partners to provide and improve our services. You can opt-out of this sharing by:

  • Enabling Global Privacy Control (GPC) in your browser
  • Adjusting your cookie preferences in our cookie consent banner
  • Contacting us at info@sumgenius.ai

Categories of Personal Information We Collect:

We collect the following categories of personal information as described in the CCPA:

  • Identifiers (name, email, IP address)
  • Commercial information (purchase history, service usage)
  • Internet or network activity (browsing behavior, interactions with our services)
  • Geolocation data (approximate location based on IP address)
  • Professional or employment-related information (if voluntarily provided)
  • Inferences drawn from the above to create user profiles

Business Purposes for Collection:

We collect personal information for the following business purposes:

  • Providing and improving our AI services
  • Customer support and communication
  • Fraud prevention and security
  • Analytics and service optimization
  • Marketing communications (with consent)
  • Legal compliance

Third Parties We Share With:

We may share personal information with:

  • Service providers (hosting, analytics, AI processing)
  • Payment processors (Stripe)
  • Communication platforms (Twilio, Meta, Pusher)
  • Analytics providers (Google Analytics, Microsoft Clarity)

Exercising Your California Rights:

To exercise your California privacy rights, please contact us at:

We will verify your identity before processing your request and respond within 45 days.

Authorized Agent:

You may designate an authorized agent to make requests on your behalf. We will require written proof of the agent's authority before processing the request.

8. Data Retention

We retain your information only as long as necessary for business purposes or legal compliance. Data may be anonymized for research or analytical purposes.

9. Children's Privacy

Our Services are not intended for individuals under 13 (or 16 in the EU). We do not knowingly collect data from children.

10. Third-Party Links

Our Site may contain links to third-party websites. We are not responsible for their privacy practices or content. Please review their policies individually.

11. VibeCheck AI Chrome Extension

If you use our VibeCheck AI Chrome Extension, the following additional terms apply:

a. Data Collection and Processing:

  • Message Analysis: Text you analyze is sent to our servers for AI processing but is NEVER stored, logged, or saved. Analysis happens in real-time and data is immediately discarded after processing.
  • AI Processing: We use OpenAI's API to analyze text tone and sentiment. OpenAI processes the text temporarily and does not store or use your data for training. The analysis is performed in real-time and results are not retained.
  • Usage Tracking: We track the number of daily checks per user account to enforce free tier limits (10 checks/day for free users).
  • Authentication: Your login credentials create a secure token stored locally in your browser. Passwords are hashed using industry-standard bcrypt encryption.
  • Platform Detection: The extension detects which website you're on (Gmail, LinkedIn, Twitter, etc.) to provide context-appropriate analysis. URLs are not stored.
  • Data Retention: Usage statistics are retained for 90 days. Account information is retained until you delete your account.

b. Extension Permissions:

  • activeTab: To detect text input fields on the current tab
  • storage: To save your authentication token and track daily usage locally
  • scripting: To inject the VibeCheck analysis interface into web pages
  • clipboardRead: To enable the Ctrl+Shift+V (Cmd+Shift+V on Mac) keyboard shortcut for analyzing copied text
  • host_permissions: To communicate securely with sumgenius.ai servers for AI analysis

c. Data Security for VibeCheck:

  • All communication uses HTTPS encryption
  • No message content is ever stored in our databases
  • Authentication tokens expire after 30 days of inactivity
  • You can delete your account at any time, which removes all associated data

d. Premium Subscriptions:

If you upgrade to VibeCheck Pro, payment processing is handled by Stripe. We store only your subscription status and customer ID, never your payment details.

e. Your VibeCheck Rights:

  • Request deletion of your VibeCheck account and all associated data immediately
  • Export all your personal data in machine-readable JSON format
  • Access your account information and usage statistics anytime
  • Correct or update your personal information through the dashboard
  • Cancel your subscription at any time via Stripe's customer portal
  • Opt out of any future features that may collect additional data
  • Disable the extension at any time through Chrome's extension manager
  • Contact us at info@sumgenius.ai for any privacy concerns

VibeCheck Privacy Commitment: We built VibeCheck with privacy as a core principle. Your messages are your business - we just help you communicate better without compromising your privacy.

12. AI Voice Services & SMS Consent Collection

Voice AI Infrastructure Services

SumGeniusAI provides AI voice agent infrastructure to businesses using ElevenLabs conversational AI technology. When you interact with an AI agent using our phone numbers:

  • AI Disclosure: You are interacting with an AI assistant, not a human. This is disclosed at the beginning of each call.
  • Your call may be recorded for quality assurance and service improvement
  • Call recordings and conversation data may be shared with ElevenLabs and their third-party large language model (LLM) providers to deliver the service, improve products, and comply with applicable law
  • Information you provide during calls is collected to fulfill service requests
  • Voice recordings and data are retained for up to 90 days unless legally required longer
  • You may request deletion of your recordings and associated data at any time

SMS Consent Collection Process

Our AI agents collect explicit verbal consent before sending any text messages:

  • Agents ask: "May I send you a text message with this information? Standard message and data rates may apply."
  • Your verbal response (yes/no) is captured and recorded in our consent management system
  • SMS messages are only sent if you explicitly agree
  • Each consent interaction is logged with timestamp and conversation reference

Types of SMS Messages

After obtaining consent, you may receive:

  • Appointment confirmations and reminders
  • Service details and follow-up information
  • Booking confirmations
  • Time-sensitive notifications related to your inquiry

SMS Opt-Out Process

  • Text STOP to any message to immediately unsubscribe from all SMS communications
  • Text HELP for assistance
  • Opt-out requests are processed immediately and permanently
  • Re-subscription requires new explicit consent

SMS Service Providers

SMS messages are delivered through Twilio, a trusted telecommunications provider. Twilio processes messages in accordance with their Privacy Policy and industry compliance standards.

SMS Data Privacy Commitment

A2P 10DLC Compliance - We guarantee that:

  • No mobile information will be shared with third parties or affiliates for marketing or promotional purposes
  • ✓ Mobile information is only shared with service providers (Twilio) to support message delivery
  • Text messaging opt-in data and consent will NOT be shared with any third parties
  • ✓ Consent records are securely stored with full audit trails for a minimum of 5 years
  • ✓ No SMS will be sent without your explicit verbal consent
  • ✓ You maintain complete control over your communication preferences

13. ChatGenius - Meta Messenger Integration

Overview

SumGeniusAI's ChatGenius platform enables businesses to manage automated AI-powered conversations with their customers through Facebook Messenger and Instagram Direct Messages. This section explains how we handle data when businesses use ChatGenius to communicate with their customers on Meta's platforms.

Who We Serve

Data Controller: The business (our client) that uses ChatGenius is the Data Controller for their end users' data.

Data Processor: SumGeniusAI acts as a Data Processor, processing conversation data on behalf of the business.

Data Subjects: End users who message businesses through Facebook Messenger or Instagram DM.

Data We Collect Through ChatGenius

When end users message a business using ChatGenius, we collect:

  • Message Content: All messages sent and received in conversations
  • Profile Information: Name, profile picture, and public profile data from Meta platforms
  • Platform Metadata: Message timestamps, conversation status, platform type (Facebook/Instagram), and unique platform user IDs
  • Appointment Data: Booking details, scheduled times, and appointment status if applicable
  • Conversation Context: Historical conversation data to maintain context across multiple interactions

How We Use ChatGenius Data

We process ChatGenius conversation data for two distinct purposes:

1. Service Delivery (Required - Covered by TOS)

  • Providing AI-powered conversation responses to end users
  • Maintaining conversation context and memory across interactions
  • Managing appointment bookings and scheduling
  • Generating conversation analytics for business clients
  • Delivering customer support and service features

Legal Basis: GDPR Article 6(1)(b) - Performance of contract with our business clients to provide messaging services.

2. AI Training & Model Improvement (Optional - Requires Explicit Consent)

  • Using anonymized conversation data to improve AI response quality
  • Training custom AI models for better industry-specific responses
  • Developing new features and capabilities

Legal Basis: GDPR Article 6(1)(a) - Explicit consent from business clients (Data Controllers).

Consent Mechanism: Business clients can opt in or opt out of AI training data usage at any time through their ChatGenius portal settings. This consent is separate from our Terms of Service and can be withdrawn freely without affecting service delivery.

Third-Party AI Processing

We use OpenAI as our AI service provider for ChatGenius conversations:

  • Message data is sent to OpenAI's API for generating AI responses
  • OpenAI processes data in accordance with their Privacy Policy and Business Terms
  • Per OpenAI's API terms, data sent via API is not used for training their models unless explicitly opted in
  • When a business client enables ChatGenius webhook forwarding or another integration, selected conversation fields are shared with the client-designated endpoint to deliver that integration
  • Clients are responsible for ensuring their downstream systems handle data lawfully and securely under applicable privacy laws

Outbound Webhook Forwarding

Business clients may configure an HTTPS endpoint to receive real-time conversation events from ChatGenius. This is an optional feature that requires explicit setup and a governance attestation before it can be enabled.

Events and Data Forwarded:

Two event types may be forwarded: message.received (new incoming DM) and message.reel_shared (Instagram reel shared to DM). Each forwarded event contains:

  • Platform user ID of the end user
  • Platform username (only if client chose the "full" payload profile)
  • Raw message text
  • Attachment metadata: type and media ID (plus attachment URLs and titles if "full" profile)
  • Internal conversation ID and event timestamp

Payload Profiles:

Clients choose between two payload profiles at setup: Full (includes username and attachment URLs) or Minimal (platform user ID and message text only, no username or attachment URLs). This choice is recorded as part of the governance attestation.

Governance Attestation:

Before enabling webhook forwarding, clients must complete a governance attestation confirming the purpose of data forwarding and the identity of the receiving system. This attestation is logged with a timestamp and the email address of the attesting user.

External Reply Mode:

Clients may optionally enable External Reply Mode, which allows their external system to send replies back to end users through ChatGenius using a dedicated API key. When enabled, the external system responds on the business's behalf. The client bears full responsibility for the content and compliance of those replies.

Security and Transmission:

  • All forwarded payloads are signed with HMAC for authenticity verification
  • Endpoints must use HTTPS; private and reserved IP ranges are blocked
  • API keys used for External Reply Mode are encrypted at rest
  • SumGeniusAI retains a delivery log (status, HTTP response code, timestamps) for troubleshooting — not the full payload

Downstream Data Responsibility:

Once data reaches the client's endpoint, the client becomes the Data Controller for that data and is solely responsible for handling it in compliance with GDPR, CCPA, and all other applicable data protection laws.

Content Studio

Content Studio is an optional feature that enables clients to schedule and publish posts to Facebook and Instagram on their behalf.

Data We Process for Content Studio:

  • Content Data: Post captions, hashtags, scheduling metadata, and content templates created by the client
  • Media Files: Images and videos uploaded by the client, stored on our servers for the lifetime of the account
  • Publishing Credentials: Encrypted OAuth tokens used to publish to the client's connected Facebook Pages and Instagram accounts
  • Performance Analytics: Post reach, impressions, engagement, and other metrics pulled from Meta's Graph API after publication

Additional Meta Permissions:

Content Studio requires the following Meta permissions beyond standard ChatGenius access: pages_manage_posts, instagram_content_publish, instagram_manage_contents, and instagram_business_manage_insights. SumGeniusAI holds these permissions through Meta App Review. Clients grant our app access to their Facebook Pages and Instagram accounts during the OAuth connection flow.

Data Retention:

  • Media Files: Retained for the lifetime of the client account; deleted upon account closure or client request
  • Post Analytics: Retained indefinitely for trend analysis; clients may request deletion by contacting info@sumgenius.ai

Legal Basis (GDPR): Article 6(1)(b) — performance of contract to deliver the Content Studio service.

Data Retention & Deletion

Retention Period:

  • Active Conversations: Retained indefinitely to maintain service quality and conversation continuity
  • Resolved Conversations: Automatically deleted after 90 days from last activity
  • AI Training Data: If consent is granted, anonymized data may be retained longer for model training purposes

Deletion Process:

  • Business clients can delete conversations immediately through their portal's conversation management page
  • Deletion is permanent and includes all messages, appointments, conversation context, and related data
  • AI analytics metrics are anonymized (personal information removed) rather than deleted to preserve performance insights
  • End users can request deletion by contacting the business directly or emailing us at info@sumgenius.ai

Data Rights for ChatGenius Users

End users messaging businesses through ChatGenius have the following rights:

  • Right to Access: Business clients can export conversation data as CSV through the ChatGenius portal; end users can request their data from the business or SumGeniusAI
  • Right to Deletion (GDPR Article 17): Request immediate deletion of all conversation data and related information
  • Right to Rectification: Request correction of inaccurate personal data
  • Right to Object: Object to data processing for AI training purposes (this does not affect service delivery)
  • Right to Data Portability: Receive personal data in machine-readable format (CSV export available)
  • Right to Withdraw Consent: Business clients can withdraw AI training consent at any time without service impact

Privacy & Security Commitment

We guarantee that:

  • ✓ Conversation data is encrypted in transit (TLS/SSL) and at rest
  • ✓ Access controls ensure only authorized personnel can view data
  • ✓ AI training is 100% optional and requires separate explicit consent
  • ✓ Personal information is removed before any data is used for training
  • ✓ Meta Platform Policies are strictly followed for all messaging interactions
  • ✓ GDPR compliance is maintained for all EU data subjects
  • ✓ Automated 90-day retention policy protects against indefinite data storage
  • ✓ Business clients maintain full control over their conversation data

Compliance Standards

  • GDPR Compliance: Articles 5 (data minimization), 6 (lawful basis), 13/14 (transparency), 17 (right to erasure), 25 (data protection by design)
  • Meta Platform Policies: Full compliance with Facebook Platform Terms, Instagram Platform Policy, and Messenger Platform Policy
  • Data Processing Agreement: Available upon request for business clients requiring formal DPA documentation

Contact for ChatGenius Data Requests

For data access, deletion, or privacy concerns related to ChatGenius conversations:

14. Law Enforcement & Legal Requests

If we receive legal requests for user data from public authorities, we follow strict procedures to protect user privacy:

Our Legal Request Handling Process:

  • Legality Review: All legal requests are reviewed by our legal team to verify authenticity, proper authorization, and compliance with applicable law
  • Right to Challenge: We reserve the right to challenge requests that appear unlawful, overly broad, or improperly issued through appropriate legal channels
  • Data Minimization: We disclose only the minimum information legally required to comply with valid requests, not entire datasets
  • Documentation & Transparency: All legal requests, our responses, legal reasoning, and involved parties are documented in secure audit logs

User Notification: Where legally permitted, we will notify affected users before disclosing their information, giving them an opportunity to seek legal protection. However, we may be prohibited from providing notice in certain cases (e.g., national security letters).

Transparency Reporting: We are committed to transparency about government requests for user data and may publish aggregate statistics about such requests when legally permitted.

15. Free Tools (SiteGenius & Roast My Website)

SumGeniusAI offers two free web analysis tools that do not require account registration or login.

SiteGenius

Analyzes a submitted URL for Google PageSpeed scores, SEO, security headers, accessibility, mobile performance, and AI search readiness.

Roast My Website

Provides an AI-generated critique of a submitted URL's design, copywriting, and conversion potential.

Data We Collect When You Use Free Tools:

  • Submitted URL: The URL you enter is sent to our servers to perform the analysis. URLs may be retained for service improvement purposes.
  • IP Address: Collected for rate limiting (5 analyses per hour per IP). Not stored beyond the rate-limit window.
  • Analysis Results: Results generated by our AI are stored server-side.

What We Do Not Collect:

  • No name, email address, or account is required
  • No personal data is collected beyond your IP address for rate limiting
  • Standard analytics cookies described in §4 apply

Usage Limits:

Usage is limited to 5 analyses per hour per IP address to prevent abuse. Submitted URLs are used solely to perform the requested analysis and are not used for any other purpose.

16. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be reflected on this page with a revised "Last Updated" date. Your continued use of the Site after changes indicates your acceptance.

17. Contact Us

SumGeniusAI LLC

Email: info@sumgenius.ai

Website: https://sumgenius.ai

Location: Las Vegas, Nevada