Privacy Policy

At Granola, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. Remember that your use of Granola’s Services is at all times subject to our Platform Terms of Service (the “Terms”), which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms.  Before we get into the details, below are a few key points we’d like you to know:

• We do not and do not allow third parties such as OpenAI or Anthropic to use your Personal Data to train AI models.
• We only use De-Identified Data to train AI models, which you can opt-out of within your Granola account settings.  
• We store your Personal Data in Amazon Web Services (“AWS”) servers located in the U.S. All Personal Data is encrypted at rest and in transit using AWS’s encrypted database system. Additionally, we implement a variety of security measures including firewalls, virtual private cloud (VPC) setups, and anti-virus/malware protection to help protect your Personal Data.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Granola website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

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What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

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Personal Data

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Categories of Personal Data We Collect

This chart details the categories of Personal Data that we may collect and may have collected over the past 12 months. You can find a description of the Categories of Third Parties here.

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties With Whom We Share this Personal Data
Profile or Contact Data	- First and last name - Email	- Service Providers - Parties You Authorize, Access or Authenticate
Payment Data	- Payment card type - Last 4 digits of payment card - Billing address, phone number, and email	- Service Providers (specifically our payment processing partner, currently Stripe, Inc.)
Device/IP Data	- IP address - IP-address-based location information - Device ID - Type of device/operating system/browser used to access the Services - Other applications that utilize the microphone function	- Service Providers - Parties You Authorize, Access or Authenticate
Web Analytics	- Web page interactions - Referring webpage/source through which you accessed the Services	- Service Providers - Parties You Authorize, Access or Authenticate
Social Network Data	- Social media profiles	- Service Providers - Parties You Authorize, Access or Authenticate
Professional or Employment-Related Data	- Job title and role - Employer - Professional website	- Service Providers - Parties You Authorize, Access or Authenticate
Recordings and Transcriptions	- Recordings and transcriptions of communications captured through our Services	- Service Providers - Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide	- Identifying information in emails, letters, texts, or other communication you send us - Images or screenshots you upload to the Services - Calendar data, including but not limited to meeting invitations, body text, and sender and recipients - Meeting data, including but not limited to attendees, audio, and transcriptions - Any other identifying information you authorize Granola to access or elect to share with Granola	- Service Providers - Parties You Authorize, Access or Authenticate

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Categories of Sources of Personal Data

We may collect Personal Data about you from the following categories of sources: You When you provide such information directly to us:

• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically:

• Through Cookies (defined in the “Cookies” section below).
• If you use a location-enabled browser, we may receive information about your location.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Third Parties Vendors:

• We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
• We may use vendors to obtain information regarding business leads. 

Third Party Accounts:

• If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

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Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

• Providing, Customizing and Improving the Services
  • Creating and managing your account or other user profiles.
  • Processing orders or other transactions; billing.
  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Services.
  • Improving the Services, including testing, research, internal analytics and product development. For clarity, we do not and do not allow third parties such as OpenAI and Anthropic to use your Personal Data to train AI models. For more information on model training, please see the De-Identified Data section. 
  • Personalizing the Services, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
• Marketing the Services
  • Marketing and selling the Services.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Granola or the Services.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.

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Other Permitted Purposes for Processing Personal Data

Additionally, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Granola or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

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De-Identified Data 

We may create de-identified, anonymized data (“De-Identified Data”) from the Personal Data we collect so that it does not identify you. We may use such De-Identified Data for our lawful business purposes, including to analyze, build and improve the Services (including to train AI models that support our Services) and promote our business. You can opt-out from our use of your De-identified Data to train AI models within your Granola account settings. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

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How We May Disclose Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties listed in this section. 

• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They may include:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.
  • Audio transcription providers and processors.
  • Analytics providers that help analyze use of our Services. 
  • Payment processors.
    • Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment.
    • Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.
• Parties You Authorize, Access or Authenticate
  • Organizations through which you access our Services (such as your employer).
  • Third parties you access through the Services.
  • Social media services.
  • Other users.

Additionally, if you are using our Services as an authorized user of an enterprise customer, you can find our list of Granola’s Subprocessors here. Legal Obligations We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under the “Other Permitted Purposes for Processing Personal Data” paragraph above.  Business Transfers All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

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Cookies

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies can also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings in your browser settings. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit allaboutcookies.org or ico.org.uk/for-the-public/online/cookies if you are located in the European Union.

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Data Storage and Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. We store your Personal Data in Amazon Web Services (“AWS”) servers located in the U.S. All Personal Data is encrypted at rest and in transit using AWS’s encrypted database system. Additionally, we implement a variety of security measures including firewalls, virtual private cloud (VPC) setups, and anti-virus/malware protection to help protect your Personal Data. You can also help protect your Personal Data by appropriately limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

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Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider factors such as our purposes for collecting and the sensitivity of such data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. For example:

• Recordings of communications using our Services are captured only for the purposes of providing you a transcription. We do not retain or store such recordings once the transcription is created. 
• We retain your profile information, credentials, and User Data for as long as you have an account with us.
• We retain your payment data for as long as we need to process your purchase or subscription.
• We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

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Personal Data of Children

As noted in our Terms, we do not knowingly collect or solicit Personal Data from children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@granola.so.

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State Law Privacy Rights

California Resident Rights Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; however, we do not knowingly make any such disclosures.  Nevada Resident Rights If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties; however, we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

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European Union, United Kingdom, and Swiss Data Subject Rights

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below. For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Granola will be the controller of your Personal Data processed in connection with the Services. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@granola.so. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data. Personal Data Use and Processing Grounds The Our Commercial or Business Purposes for Collecting Personal Data section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms  with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
  • Profile or Contact Data
  • Payment Data
  • Professional or Employment-Related Data
  • Recording and Transcripts 
  • Other Identifying Information that You Voluntarily Choose to Provide
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
  • Profile or Contact Data
  • Payment Data
  • Device/IP Data
  • Web Analytics
  • Professional or Employment-Related Data
  • Recordings and Transcripts
  • Other Identifying Information that You Voluntarily Choose to Provide
  • We may also de-identify or anonymize Personal Data to further our legitimate interests. 
    • Examples of these legitimate interests include (as described in more detail above):
      • Providing, customizing and improving the Services.
      • Marketing the Services.
      • Corresponding with you.
      • Meeting legal requirements and enforcing legal terms.
      • Completing corporate transactions.
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Data Subject Rights You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@granola.so with the subject line: “GDPR Request: [nature of request]”. Your request must include enough information for us to verify your identity, relationship with Granola, and the nature of your request. In some circumstances, we may not be able to fully comply with your request, such as if we are unable to verify your identity, your request it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. Lastly, please note that where we process your Personal Data as a data processor on behalf of another organization (such as an enterprise customer), you may need to submit your request directly to that organization.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please note that due to the nature of our Services, transcripts cannot be modified after creation. However, you can modify summaries of transcripts.
• Erasure: 
  • Deleting Your Granola Account: To delete your account, open your Granola app, click on Granola on the top left on your screen —> Settings —> Profile and at the bottom —> Delete Account.
  • Deleting a Meeting: You can delete any meeting summary from your dashboard by going to your meeting list on the Granola app and clicking on the 3 dots on the right of a meeting. 
  • Deleting Other Account-Related Information: You can delete certain other account-related information by opening your Granola app, clicking Granola on the top left of the screen —> Settings —> Profile.
  • For any other question or requests to delete your Personal Data, please email privacy@granola.so. 
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Granola’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here.

Transfers of Personal Data Our Services are hosted and operated in the U.S. through Granola and its Service Providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using our Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Granola in the U.S. and will be hosted on U.S. servers, and you authorize Granola to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses. 

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Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: Granola, Inc. 
privacy@granola.so
1151 Walker Road, Suite 417, Dover, Delaware 19904 _If you are located in the UK, you may use the following information to contact us: _ Granola Labs Ltd
Arquen House, 4-6 Spicer Street, St. Albans AL3 4PQ
privacy@granola.so