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We are accountable for ensuring that Personal Information we receive and subsequently transfer to third parties adheres to the DPF Principles.","source_url":"https://www.sembly.ai/policy/privacy-policy.pdf","deep_link":"https://www.sembly.ai/policy/privacy-policy.pdf#:~:text=without%20obtaining%20your%20subsequent,the%20DPF%20Principles.%20","structural_citation":"Privacy Policy, p. 9","citation_basis":"page","char_start":21422,"char_end":22872}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"If a third party, acting as an agent, processes this information inconsistently with the DPF Principles, we are responsible unless we demonstrate that the cause of the damage was not our fault. We will provide an individual opt-out choice, or opt-in for sensitive data that is not part of meeting or audio recording content, before we share your data with third parties other than our agents, or before we use it for ...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"If a third party, acting as an agent, processes this information inconsistently with the DPF Principles, we are responsible unless we demonstrate that the cause of the damage was not our fault. We will provide an individual opt-out choice, or opt-in for sensitive data that is not part of meeting or audio recording content, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to support@sembly.ai. 9.4. Security. Sembly AI implements appropriate and necessary measures, considering the 10 processing risks and the sensitivity of Personal Information, to safeguard Personal Information against unauthorized access, disclosure, alteration, destruction, loss, or misuse. 9.5. Access and Choice. If Sembly AI plans to apply your Personal Information to new purposes significantly different from initial collection or consent, or to share it with a new subprocessor, we will give you a chance to decline such use/disclosure for non-sensitive data or consent for sensitive data. You can access, rectify, or request deletion of your Personal Information if it's wrong or misused according to the DPF Principles, by contacting us as directed below. We may restrict information access based on DPF Principles. 9.6. Recourse, Enforcement and Liability.","source_url":"https://www.sembly.ai/policy/privacy-policy.pdf","deep_link":"https://www.sembly.ai/policy/privacy-policy.pdf#:~:text=If%20a%20third%20party%2C,Enforcement%20and%20Liability.%20","structural_citation":"Privacy Policy, p. 9","citation_basis":"page","char_start":22872,"char_end":24344}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"security or authentication measures without proper authorization; or (c) accessing or using the Service or any portion thereof without authorization, in violation of these Terms of Service or in violation of applicable law. Violations of system or network security may result in civil or criminal liability. Sembly AI will investigate occurrences that may involve such violations and may involve, and cooperate with, ...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"subprocessors_data_sharing","quote":"security or authentication measures without proper authorization; or (c) accessing or using the Service or any portion thereof without authorization, in violation of these Terms of Service or in violation of applicable law. Violations of system or network security may result in civil or criminal liability. Sembly AI will investigate occurrences that may involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting users who are involved in such violations. You agree not to use any device, software or routine to interfere or attempt to interfere with the proper working of this Service or any activity being conducted on this Service. In the event access to the Service or a portion thereof is limited requiring a user ID and password (“Protected Areas”), you agree to access Protected Areas using only your user ID and password as provided to you by Sembly AI. You agree to protect the confidentiality of your user ID and password, and not to share or disclose your user ID or password to any third party. You agree that you are fully responsible for all activity occurring under your user ID. Your access to the Service may be suspended or revoked by Sembly AI at any time with or without cause. 4821-6362-6685.1 3. Indemnification You agree to defend, indemnify, and hold Sembly AI harmless from and against all third-party claims, damages, and expenses (including reasonable attorneys’ fees) against or incurred by Sembly AI arising out of your breach of these Terms of Service or violation of applicable law, your use or access of the Service, or access by anyone accessing the Service using your user ID and password.","source_url":"https://www.sembly.ai/policy/tos.pdf","deep_link":"https://www.sembly.ai/policy/tos.pdf#:~:text=security%20or%20authentication%20measures,user%20ID%20and%20password.","structural_citation":"Terms of Service, p. 1","citation_basis":"page","char_start":1737,"char_end":3407}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"disclosure through no fault of Sembly AI; (iii) was known to Sembly AI prior to disclosure by the disclosing Party; or (iv) was rightfully acquired by Sembly AI after disclosure by you from a third party who was lawfully in possession of the information and was under no legal duty to you to maintain the confidentiality of the information Sembly AI’s Data Use Rights. You grant to Sembly AI a royalty-free, irrevocab...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"confidentiality","quote":"disclosure through no fault of Sembly AI; (iii) was known to Sembly AI prior to disclosure by the disclosing Party; or (iv) was rightfully acquired by Sembly AI after disclosure by you from a third party who was lawfully in possession of the information and was under no legal duty to you to maintain the confidentiality of the information Sembly AI’s Data Use Rights. You grant to Sembly AI a royalty-free, irrevocable, transferable right and license to use the Recordings, Transcripts, and Reports (a) to provide the Service to you and","source_url":"https://www.sembly.ai/policy/tos.pdf","deep_link":"https://www.sembly.ai/policy/tos.pdf#:~:text=disclosure%20through%20no%20fault,Service%20to%20you%20and","structural_citation":"Terms of Service, p. 3","citation_basis":"page","char_start":7228,"char_end":7765}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"product improvement, artificial intelligence (AI) development and training, verification of security and data integrity, identification of industry trends and developments and data analytics. Sembly AI shall have the right to use and disclose aggregated and de-identified data underlying and contained in Recordings, Transcripts, and Reports (“De-Identified Data Analytics”) for its business purposes, including the d...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"training_use","quote":"product improvement, artificial intelligence (AI) development and training, verification of security and data integrity, identification of industry trends and developments and data analytics. Sembly AI shall have the right to use and disclose aggregated and de-identified data underlying and contained in Recordings, Transcripts, and Reports (“De-Identified Data Analytics”) for its business purposes, including the development and licensing of data analytics products and reports for its customers generally, provided that such products and reports do not disclose to a third party any personal information, personally identifying information or your confidential information. Sembly AI may copy, modify, adapt, publish, translate, create derivative works from and/or sell and/or distribute De-Identified Data Analytics into any form, medium or technology. For customers located in the European Union, Sembly AI now offers the option to store meeting- related content (including recordings, transcripts, and reports) within EU-based data centers. This ensures data residency and alignment with the GDPR and other applicable EU data protection laws. Data from EU users will remain within the EEA unless explicitly authorized by the customer or required by law. Please note, some user data may still be processed and transferred, but not stored in US-based data centers. 4821-6362-6685.3 7. Support and Additional Services Sembly AI shall provide the standard user support services as set posted on the Sembly AI website (www.sembly.ai) at the time such support services are provided.","source_url":"https://www.sembly.ai/policy/tos.pdf","deep_link":"https://www.sembly.ai/policy/tos.pdf#:~:text=product%20improvement%2C%20artificial%20intelligence,services%20are%20provided.%20","structural_citation":"Terms of Service, p. 3","citation_basis":"page","char_start":7859,"char_end":9443}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"This includes information that we collect directly from you or through automated collection technologies. We DO NOT use audio, video, or text data from Enterprise Plan customers for model training. Other plans can manage this with opt-out setting. Any PII shared with us is used ONLY to provide service features such as account registration and access to service, not for any other purpose. We NEVER share content out...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"training_use","quote":"This includes information that we collect directly from you or through automated collection technologies. We DO NOT use audio, video, or text data from Enterprise Plan customers for model training. Other plans can manage this with opt-out setting. Any PII shared with us is used ONLY to provide service features such as account registration and access to service, not for any other purpose. We NEVER share content outside of our organization other than with specified subprocessors. Details about subprocessors are available here: https://go.sembly.ai/subprocessors We do not and can not control the actions of other users of the Service and your participants in Online Meetings. Therefore, although we use reasonable and appropriate data security measures in connection with the Service, you are responsible for the conduct of all users and participants of your Online Meetings. Cookies. We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Service through your computer or mobile device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser.","source_url":"https://www.sembly.ai/policy/privacy-policy.pdf","deep_link":"https://www.sembly.ai/policy/privacy-policy.pdf#:~:text=This%20includes%20information%20that,system%20or%20browser.%20","structural_citation":"Privacy Policy, p. 2","citation_basis":"page","char_start":4700,"char_end":6157}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"We use subprocessors as part of our technology platform. All our subprocessors are vetted for security certification, General Data Protection Regulation (GDPR) compliance, data retention, and follow-on use of data and ensuring that your data is protected to the highest standards. Communications between Sembly AI and subprocessors' APIs are always encrypted. Details about used services are available in our third-pa...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"data_retention","quote":"We use subprocessors as part of our technology platform. All our subprocessors are vetted for security certification, General Data Protection Regulation (GDPR) compliance, data retention, and follow-on use of data and ensuring that your data is protected to the highest standards. Communications between Sembly AI and subprocessors' APIs are always encrypted. Details about used services are available in our third-party providers page. We only share data that is required to deliver our services. This is in line with our commitment to respecting your privacy and ensuring the highest level of data protection. By using our products, you agree to have some of your data shared with the subprocessors as detailed in this policy and adjoining documents.","source_url":"https://www.sembly.ai/policy/privacy-policy.pdf","deep_link":"https://www.sembly.ai/policy/privacy-policy.pdf#:~:text=We%20use%20subprocessors%20as,policy%20and%20adjoining%20documents.","structural_citation":"Privacy Policy, p. 4","citation_basis":"page","char_start":10138,"char_end":10890}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"business and our Service (e.g., data storage, data processing, payment processing, etc.). To a buyer or other successor in the event of a merger, divestiture, restructuring, We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We may disclose your Personal Data to a few third parties, including:","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"business and our Service (e.g., data storage, data processing, payment processing, etc.). To a buyer or other successor in the event of a merger, divestiture, restructuring, We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We may disclose your Personal Data to a few third parties, including:","source_url":"https://www.sembly.ai/policy/privacy-policy.pdf","deep_link":"https://www.sembly.ai/policy/privacy-policy.pdf#:~:text=business%20and%20our%20Service,few%20third%20parties%2C%20including%3A","structural_citation":"Privacy Policy, p. 5","citation_basis":"page","char_start":12365,"char_end":12735}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"without obtaining your subsequent consent. We take reasonable steps to limit the collection and usage of Personal Information to that which is relevant for the purposes for which it was collected, and to ensure that such Personal Information is reliable, accurate, complete and current. Individuals are encouraged to keep their Personal Information with Sembly Ai up to date and may contact Sembly AI as indicated bel...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"data_retention","quote":"without obtaining your subsequent consent. We take reasonable steps to limit the collection and usage of Personal Information to that which is relevant for the purposes for which it was collected, and to ensure that such Personal Information is reliable, accurate, complete and current. Individuals are encouraged to keep their Personal Information with Sembly Ai up to date and may contact Sembly AI as indicated below or in the Policy to request that their Personal Information be updated or corrected. We will adhere to the DPF Principles for as long as we retain the Personal Information collected under DPF Principles. When providing our Services as a data processor, we process and retain Personal Information as necessary to provide our Services as permitted in our agreements, or as required or permitted under applicable law. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 10.3. Accountability for Onward Transfer of Personal Information. Sembly AI may transfer Personal Information as outlined in our Policy regarding subprocessors. In our role as a data processor for our services, we disclose Personal Information in line with our customer agreements. We are accountable for ensuring that Personal Information we receive and subsequently transfer to third parties adheres to the DPF Principles.","source_url":"https://www.sembly.ai/policy/privacy-policy.pdf","deep_link":"https://www.sembly.ai/policy/privacy-policy.pdf#:~:text=without%20obtaining%20your%20subsequent,the%20DPF%20Principles.%20","structural_citation":"Privacy Policy, p. 9","citation_basis":"page","char_start":22446,"char_end":23897}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"If a third party, acting as an agent, processes this information inconsistently with the DPF Principles, we are responsible unless we demonstrate that the cause of the damage was not our fault. We will provide an individual opt-out choice, or opt-in for sensitive data that is not part of meeting or audio recording content, before we share your data with third parties other than our agents, or before we use it for ...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"If a third party, acting as an agent, processes this information inconsistently with the DPF Principles, we are responsible unless we demonstrate that the cause of the damage was not our fault. We will provide an individual opt-out choice, or opt-in for sensitive data that is not part of meeting or audio recording content, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to support@sembly.ai. 10.4. Security. Sembly AI implements appropriate and necessary measures, considering the processing risks and the sensitivity of Personal Information, to safeguard Personal Information against unauthorized access, disclosure, alteration, destruction, loss, or misuse. 10.5. Access and Choice. If Sembly AI plans to apply your Personal Information to new purposes significantly different from initial collection or consent, or to share it with a new subprocessor, we will give you a chance to decline such use/disclosure for non-sensitive data or consent for sensitive data. You can access, rectify, or request deletion of your Personal Information if it's wrong or misused according to the DPF Principles, by contacting us as directed below. We may restrict information access based on DPF Principles. 10.6. Recourse, Enforcement and Liability.","source_url":"https://www.sembly.ai/policy/privacy-policy.pdf","deep_link":"https://www.sembly.ai/policy/privacy-policy.pdf#:~:text=If%20a%20third%20party%2C,Enforcement%20and%20Liability.%20","structural_citation":"Privacy Policy, p. 10","citation_basis":"page","char_start":23897,"char_end":25369}},{"pattern_key":"tier_condition","pattern_family":"tier_conditionality","risk_rating":"medium","confidence":"medium","stance_key":"tier_condition","stance_value":"rights_or_controls_vary_by_tier","evidence":"Need Enterprise?","reason":"The clause changes rights, controls, or obligations by plan or tier.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"tier_differences","quote":"Need Enterprise?","source_url":"https://www.sembly.ai/pricing/","deep_link":"https://www.sembly.ai/pricing/#:~:text=%20Need%20Enterprise%3F","structural_citation":"“Automation access controls”","citation_basis":"heading_path","char_start":5187,"char_end":5204}},{"pattern_key":"tier_condition","pattern_family":"tier_conditionality","risk_rating":"medium","confidence":"low","stance_key":"tier_condition","stance_value":"rights_or_controls_vary_by_tier","evidence":"We DO NOT use audio, video, or text data from Enterprise Plan customers for model training. Other plans can manage this with opt-out settings.","reason":"The clause changes rights, controls, or obligations by plan or tier.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"tier_differences","quote":"We DO NOT use audio, video, or text data from Enterprise Plan customers for model training. Other plans can manage this with opt-out settings.","source_url":"https://www.sembly.ai/pricing/","deep_link":"https://www.sembly.ai/pricing/#:~:text=We%20DO%20NOT%20use,this%20with%20opt-out%20settings.","structural_citation":"“We DO NOT use audio, video, or text data from Enterprise Plan customers for model training. Other plans can manage this with opt-out settings. Any PII shared with us is used ONLY to provide service features such as account registration and access to service, not for any other purpose. We NEVER share content outside of our organization other than with specified subprocessors.”","citation_basis":"heading_path","char_start":14116,"char_end":14258}},{"pattern_key":"tier_condition","pattern_family":"tier_conditionality","risk_rating":"medium","confidence":"medium","stance_key":"tier_condition","stance_value":"rights_or_controls_vary_by_tier","evidence":"Need Enterprise?","reason":"The clause changes rights, controls, or obligations by plan or tier.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"tier_differences","quote":"Need Enterprise?","source_url":"https://www.sembly.ai/pricing/","deep_link":"https://www.sembly.ai/pricing/#:~:text=%20Need%20Enterprise%3F","structural_citation":"“Automation access controls”","citation_basis":"heading_path","char_start":5215,"char_end":5232}},{"pattern_key":"training_permitted","pattern_family":"training_use","risk_rating":"high","confidence":"medium","stance_key":"model_training","stance_value":"training_permitted","evidence":"To use the Service, you must register as a user of the Service (“Registered User”) through our online registration process. You (and the Organization if you are using the Service and agreeing to these Terms of Service for an Organization) are solely responsible for all other Registered Users using or accessing the Service through your (or the Organization’s, as applicable) account. You are responsible for all acti...","reason":"The clause permits using submitted content for training, development, or model/service improvement.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"training_use","quote":"To use the Service, you must register as a user of the Service (“Registered User”) through our online registration process. You (and the Organization if you are using the Service and agreeing to these Terms of Service for an Organization) are solely responsible for all other Registered Users using or accessing the Service through your (or the Organization’s, as applicable) account. You are responsible for all activity occurring under any of your account(s) and you shall abide by all applicable local, state, federal, and foreign laws, treaties, and regulations in connection with your use of the Service, including those related to audio and video recording, data privacy (such as the General Data Protection Regulation for EU users), international communications, and the transmission and storage of technical or personal data. Sembly AI now provides an EU data storage option for EU-based customers in accordance with applicable data protection laws. Without limiting the foregoing, you acknowledge and agree that (a) the Service will record the contents of Online Meetings and other communications, (b) several laws prohibit, limit or regulate the recording of audio and/or video communications without the consent of all participants, and (c) you shall be solely responsible for ensuring that you and all of your Registered Users provide and obtain the consent of all meeting participants. In this regard, Customer shall, and shall train and cause all Registered Users to, announce to all participants in any Online Meeting that such meeting or communication is being recorded by the Service.","source_url":"https://www.sembly.ai/policy/tos.pdf","deep_link":"https://www.sembly.ai/policy/tos.pdf#:~:text=To%20use%20the%20Service%2C,recorded%20by%20the%20Service.","structural_citation":"Terms of Service › “4\\. 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