Introduction

Welcome to Commenter.ai.

Commenter AI LTD ("Commenter.ai", "Company", "we", "our", or "us") operates https://commenter.ai and provides the Commenter.ai website, software, applications, browser extensions, integrations, AI features, analytics, and related services (together, the "Service").

This Privacy Policy explains how we collect, use, store, protect, share, and otherwise process information when you access or use the Service.

By creating an account, accessing the Service, connecting your LinkedIn account, connecting any other supported account, enabling tracking, or otherwise using Commenter.ai, you agree to this Privacy Policy and our Terms of Service.

If you do not agree with this Privacy Policy, you must not access or use the Service.

1. Definitions

For this Privacy Policy:

"Service" means the Commenter.ai website, platform, software, applications, browser extensions, integrations, AI features, analytics, account features, and any related products or services we provide.

"User", "you", or "your" means any person or entity that accesses or uses the Service.

"Account" means your registered Commenter.ai account.

"Connected Account" means any third-party account, including LinkedIn, email, or another supported service, that you connect to Commenter.ai or authorize Commenter.ai to process.

"Connected Account Data" means data collected, processed, stored, displayed, analyzed, transmitted, or generated from a Connected Account.

"Personal Data" means information that identifies, relates to, describes, or could reasonably be linked to an identified or identifiable person.

"Usage Data" means data collected automatically when you access or use the Service.

"Content" means information, text, comments, drafts, posts, messages, conversations, profile data, notes, labels, templates, uploads, settings, prompts, AI inputs, AI outputs, or other material submitted, created, imported, connected, displayed, processed, analyzed, or generated through the Service.

"Service Provider" means a third-party company, vendor, contractor, or processor that helps us provide, operate, secure, support, maintain, analyze, or improve the Service.

"Data Controller" means the entity that determines the purposes and means of processing Personal Data. For the purposes of this Privacy Policy, Commenter AI LTD is the Data Controller of your Personal Data, unless otherwise stated.

"Data Processor" means an entity that processes Personal Data on behalf of the Data Controller.

2. Information We Collect

We collect different types of information to provide, operate, secure, support, maintain, personalize, analyze, and improve the Service.

The information we collect depends on how you use the Service, which features you enable, and which accounts you connect.

3. Account Information

When you create an Account or use the Service, we may collect information such as:

1. name
2. email address
3. password or authentication-related information
4. billing information
5. subscription status
6. account settings
7. preferences
8. support messages
9. device and browser information
10. login information
11. authentication tokens or session-related information
12. any other information you choose to provide

We use this information to create and manage your Account, provide the Service, process payments, provide support, send important notices, prevent abuse, protect security, and communicate with you.

4. Connected Account Data

If you connect LinkedIn, email, or another supported account, we may collect, process, store, analyze, transmit, and display data from that Connected Account.

This may include:

1. LinkedIn messages and conversations
2. conversation metadata
3. comments, replies, posts, and other content activity
4. profile, contact, and connection-related information
5. timestamps, activity status, interaction history, and engagement history
6. labels, notes, settings, preferences, and actions you create inside the Service
7. AI prompts, AI inputs, AI outputs, summaries, classifications, suggestions, and other generated outputs
8. prioritization data, reason codes, state changes, and workflow data
9. technical identifiers such as user IDs, conversation IDs, message IDs, and provider IDs
10. other activity data needed to display, organize, prioritize, personalize, secure, debug, support, maintain, or improve your workflow

We process this information so the Service can function properly, including to:

1. show relevant conversations
2. help you manage LinkedIn activity
3. help prioritize conversations or activity
4. personalize your experience
5. generate comments, replies, summaries, classifications, labels, or suggestions where applicable
6. provide analytics and reporting
7. improve product reliability
8. provide customer support
9. debug technical issues
10. protect the Service from abuse, fraud, unauthorized access, or security issues
11. comply with legal obligations
12. enforce our Terms of Service

By connecting a Connected Account, you authorize us to access, collect, process, store, analyze, transmit, and display the relevant Connected Account Data needed to provide the Service.

5. LinkedIn Data

If you connect LinkedIn to Commenter.ai, we may process LinkedIn-related data, including:

1. private messages and conversations
2. conversation metadata
3. profile and contact information
4. posts, comments, replies, and engagement activity
5. timestamps and interaction history
6. connection-related information
7. content you create, view, save, classify, label, or process through the Service
8. AI-generated outputs related to LinkedIn activity
9. activity used for prioritization, organization, analytics, support, debugging, security, or workflow assistance

We use LinkedIn data to provide the features you enable, including conversation organization, prioritization, AI-powered assistance, comment generation, reply suggestions, workflow support, analytics, product improvement, debugging, security, and support.

When you connect LinkedIn, we may show you additional consent or permission language explaining what data is processed and why. You can disconnect LinkedIn or manage available tracking settings inside your Account settings.

Commenter.ai is not owned by, endorsed by, sponsored by, supported by, or affiliated with LinkedIn unless expressly stated. LinkedIn is a trademark of LinkedIn Corporation or its affiliates. Your use of LinkedIn remains subject to LinkedIn's own terms, policies, and restrictions.

6. Optional Email and Additional Account Data

Some users may choose to provide an email address or connect additional supported accounts so the Service can track, organize, or display additional activity relevant to their workflow.

If you provide an email address or connect an additional account for tracking, we may collect, process, store, analyze, transmit, and display relevant activity data from that account or email address to provide the Service.

You can manage or disable supported tracking settings inside your Account settings. Disabling tracking may limit or prevent certain features from working properly.

7. AI Processing and AI Providers

The Service may use artificial intelligence systems and third-party AI providers, including OpenAI or similar providers, to provide AI-powered features.

AI processing may include:

1. LinkedIn messages and conversation history
2. comments, replies, posts, and other content
3. prompts and instructions
4. profile or contact context
5. labels, notes, settings, and user actions
6. metadata and workflow data
7. AI inputs and AI outputs

AI-powered features may include:

1. comment generation
2. reply suggestions
3. conversation summaries
4. prioritization
5. classification
6. labeling
7. recommendations
8. analytics
9. workflow assistance
10. other product functionality

We share relevant data with AI providers where necessary to provide, operate, support, maintain, secure, debug, or improve the Service.

You are responsible for reviewing and approving any AI-generated output before using, publishing, sending, or relying on it.

AI-generated outputs may be inaccurate, incomplete, offensive, inappropriate, misleading, or unsuitable for your specific use case.

8. Product Analytics, Logs, Monitoring, and Error Tracking

We may collect and process product analytics, logs, monitoring data, error reports, and usage data to operate, secure, debug, support, maintain, and improve the Service.

This may include:

1. actions taken inside Commenter.ai
2. feature usage
3. connected account status
4. timestamps
5. technical events
6. error events
7. system performance
8. device or browser information
9. usage patterns
10. request metadata
11. user IDs, conversation IDs, message IDs, or similar technical identifiers
12. AI request status
13. model usage
14. token counts
15. error codes
16. latency data
17. prioritization state, reason codes, and workflow state changes
18. other technical data needed to operate, debug, secure, support, maintain, or improve the Service

Some logs, monitoring tools, or error-tracking tools may process Content or Connected Account Data where necessary to diagnose errors, investigate issues, maintain security, prevent abuse, provide support, or improve the Service.

We may use third-party providers for analytics, logging, monitoring, and error tracking.

We apply safeguards designed to limit unnecessary exposure of private message content. However, limited processing of message content or related data may occur where necessary for debugging, monitoring, security, support, maintenance, product improvement, or error investigation.

Private Connected Account messages are not sold to analytics, logging, monitoring, or error-tracking providers.

9. Cookies and Similar Technologies

We may use cookies and similar tracking technologies, such as pixels, beacons, tags, and scripts, to operate the Service, remember preferences, improve functionality, analyze usage, and support security.

Cookies may include:

1. session cookies, used to operate the Service
2. preference cookies, used to remember settings and preferences
3. security cookies, used for authentication and security
4. analytics cookies, used to understand how the Service is used
5. advertising or marketing cookies, where applicable

You can instruct your browser to refuse cookies or notify you when cookies are being sent. However, some parts of the Service may not work properly without cookies.

10. Usage Data

When you access or use the Service, we may collect Usage Data automatically.

Usage Data may include:

1. IP address
2. browser type and version
3. device type
4. operating system
5. pages visited
6. time and date of visit
7. time spent on pages
8. referring pages
9. unique device identifiers
10. diagnostic data
11. crash data
12. feature usage
13. approximate location derived from IP address

We use Usage Data to operate, secure, analyze, debug, support, maintain, and improve the Service.

11. Payment and Billing Data

If you purchase a paid subscription or service, we may collect billing-related information such as:

1. name
2. email address
3. billing address
4. subscription plan
5. payment status
6. invoice history
7. transaction identifiers

Payment information may be processed by third-party payment processors. We do not store full credit card numbers unless expressly stated.

Payment processors handle payment information according to their own terms and privacy policies.

12. Support and Communication Data

If you contact us for support, send feedback, report a problem, or communicate with us, we may collect:

1. your name
2. your email address
3. your message
4. attachments or screenshots you provide
5. support history
6. Account information
7. technical information needed to investigate the issue
8. relevant Connected Account Data where necessary to resolve your request

We use this information to respond to you, investigate issues, provide support, improve the Service, and maintain security.

13. How We Use Data

We use data to:

1. provide, operate, and maintain the Service
2. create and manage Accounts
3. connect and process LinkedIn or other Connected Accounts
4. display and organize conversations, comments, posts, and related activity
5. provide AI-powered features
6. generate comments, replies, summaries, suggestions, classifications, labels, or workflow assistance
7. prioritize or organize activity
8. personalize the user experience
9. process payments and manage subscriptions
10. provide customer support
11. send service-related communications
12. send marketing communications where permitted
13. analyze usage and improve the Service
14. debug errors and investigate technical issues
15. monitor system performance
16. protect against abuse, fraud, unauthorized access, and security risks
17. comply with legal obligations
18. enforce our Terms of Service
19. fulfill any other purpose disclosed when you provide the information
20. process data with your consent where required

14. Legal Bases for Processing

If you are located in the European Economic Area, United Kingdom, or another jurisdiction requiring a legal basis for processing, we process Personal Data under one or more of the following legal bases:

1. Contract: to provide the Service you requested, manage your Account, process subscriptions, and perform our Terms of Service.
2. Consent: where you connect accounts, enable tracking, receive marketing communications, or use features that require consent.
3. Legitimate interests: to operate, secure, debug, support, maintain, analyze, and improve the Service, prevent abuse, and understand product performance, where those interests are not overridden by your rights.
4. Legal obligation: where processing is necessary to comply with applicable law, legal requests, tax obligations, accounting obligations, or regulatory requirements.
5. Vital or public interests: where applicable law recognizes these bases, although we do not normally rely on them.

You may withdraw consent where we rely on consent. Withdrawing consent may limit or prevent certain features from working.

15. How We Share Data

We may share data with:

1. Service Providers that help us provide, operate, secure, support, maintain, and improve the Service
2. AI providers
3. hosting and infrastructure providers
4. database and cloud storage providers
5. analytics providers
6. logging, monitoring, and error-tracking providers
7. customer support providers
8. email and communication providers
9. payment processors
10. security providers
11. professional advisors, such as lawyers, accountants, or auditors
12. affiliates, subsidiaries, or business partners where necessary for business operations
13. authorities, regulators, courts, or law enforcement where required by law
14. another company in connection with a merger, acquisition, financing, restructuring, bankruptcy, or sale of assets

Service Providers may access Personal Data, Content, or Connected Account Data only where necessary to perform services for us, subject to their agreements with us, their service terms, and applicable law.

We do not sell your private messages.

We do not sell your private LinkedIn conversations.

We do not make your private LinkedIn messages or private Connected Account Data available to other users.

We do not share your Personal Data with third parties for their independent marketing purposes.

16. Third-Party Service Providers

We may use third-party Service Providers to help provide, operate, secure, analyze, support, maintain, and improve the Service.

These providers may include:

1. infrastructure providers
2. hosting providers
3. database providers
4. payment processors
5. AI providers
6. analytics providers
7. logging providers
8. monitoring providers
9. error-tracking providers
10. email providers
11. customer support providers
12. security providers
13. other technical service providers

These providers may process Account data, Content, Connected Account Data, technical data, usage data, payment data, or other information where necessary to provide their services to us.

We do not authorize third-party Service Providers to use your private messages for their own independent purposes, except as permitted by their agreements with us, their service terms, or applicable law.

17. Security of Data

We take the security of your data seriously.

Private messages and Connected Account Data are encrypted before storage using technical security measures such as AES-256-GCM. However, some message content may be decrypted and processed when required for the Service to function, including for AI-powered features, prioritization, support, debugging, security, system maintenance, product improvement, legal compliance, and abuse prevention.

Private message content is not exposed through standard admin dashboards during normal use. However, limited access may be possible by authorized technical personnel, Service Providers, or third-party processors where necessary to operate, secure, debug, support, maintain, or improve the Service, comply with legal obligations, investigate abuse, prevent fraud, or provide AI-powered functionality.

We use commercially reasonable technical and organizational measures designed to protect Personal Data, Content, and Connected Account Data.

However, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security.

18. Retention of Data

We retain Personal Data, Content, Connected Account Data, Usage Data, logs, analytics data, and other information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods may depend on:

1. the type of data
2. the feature used
3. whether your Account remains active
4. legal, tax, accounting, or regulatory requirements
5. security needs
6. dispute resolution needs
7. fraud or abuse prevention
8. backup and disaster recovery practices
9. product operation and support needs

If you disconnect a Connected Account or disable tracking, we may stop collecting new data from that Connected Account, but previously collected data may remain stored for a period of time unless you request deletion and deletion is legally and technically available.

Some data may remain in backups, logs, security records, audit records, or archived systems for a limited period, even after deletion from active systems.

19. Data Deletion

You may request deletion of eligible Personal Data by contacting us at support@commenter.ai.

You may also be able to manage or delete certain data through your Account settings.

When we receive a deletion request, we may need to verify your identity before processing the request.

We may retain certain information where necessary to:

1. comply with legal obligations
2. resolve disputes
3. enforce agreements
4. prevent fraud or abuse
5. maintain security
6. complete transactions
7. comply with tax, accounting, or regulatory requirements
8. preserve backup integrity for a limited period
9. maintain audit, legal, or security records

Deleting data or disconnecting a Connected Account may cause certain features to stop working or lose historical context.

20. Managing Tracking and Connected Accounts

You may manage available tracking settings inside your Account settings.

Depending on the features enabled in your Account, you may be able to:

1. disconnect LinkedIn
2. disconnect email
3. disable supported tracking settings
4. remove connected accounts
5. request deletion of eligible Account data

If you disable tracking or disconnect an account, the Service may no longer be able to provide certain features, including conversation prioritization, activity history, comment assistance, analytics, support, debugging, or other connected account features.

Disabling tracking does not affect processing that occurred before tracking was disabled.

21. International Data Transfers

Your information may be transferred to and processed in countries other than the country where you are located.

These countries may have data protection laws that differ from those in your jurisdiction.

Where required by law, we use appropriate safeguards for international transfers, such as contractual protections, data processing agreements, or other lawful transfer mechanisms.

By using the Service, you understand that your information may be transferred to and processed outside your country of residence.

22. Your GDPR and EEA/UK Data Protection Rights

If you are located in the European Economic Area, United Kingdom, or another jurisdiction with similar rights, you may have the right to:

1. access the Personal Data we hold about you
2. request correction of inaccurate Personal Data
3. request deletion of Personal Data
4. request restriction of processing
5. object to processing
6. request data portability
7. withdraw consent where processing is based on consent
8. lodge a complaint with a data protection authority

To exercise these rights, contact us at support@commenter.ai.

We may ask you to verify your identity before responding.

Some rights may be limited where data is necessary for the Service, legal compliance, security, fraud prevention, dispute resolution, contract performance, or legitimate business purposes.

23. California Privacy Rights

If you are a California resident, you may have rights under California privacy laws, including the right to know, access, delete, correct, and opt out of certain sharing or sale of Personal Data.

We do not sell your private messages.

We do not sell your private LinkedIn conversations.

We do not sell your Personal Data for monetary consideration.

Some transfers of data may be considered a "sale" or "sharing" under California law, depending on the context. If applicable, you may request to opt out by contacting support@commenter.ai.

To exercise your California privacy rights, contact us at support@commenter.ai.

We will not discriminate against you for exercising your privacy rights, although some features may not work if you delete or restrict data needed to provide the Service.

24. Do Not Track

Some browsers offer a "Do Not Track" signal.

Because there is no consistent industry standard for responding to Do Not Track signals, we may not respond to them in all cases.

You can manage cookies and tracking preferences through your browser settings and, where available, through our Service settings.

25. Children's Privacy

The Service is not intended for individuals under the age of eighteen (18).

We do not knowingly collect Personal Data from individuals under 18.

If you believe that a person under 18 has provided us with Personal Data, contact us at support@commenter.ai, and we will take appropriate steps to delete the information where required.

26. Marketing Communications

We may use your email address or contact information to send newsletters, product updates, offers, or other marketing communications where permitted by law.

You may opt out of marketing emails by clicking the unsubscribe link or contacting support@commenter.ai.

You may still receive service-related communications, such as billing notices, security alerts, account notices, support messages, and legal updates.

27. Business Transfers

If Commenter AI LTD is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, your information may be transferred as part of that transaction.

We will make reasonable efforts to ensure that the recipient handles your information in a manner consistent with this Privacy Policy or provides notice where required by law.

28. Legal Disclosure

We may disclose information if we believe in good faith that disclosure is necessary to:

1. comply with a legal obligation
2. respond to lawful requests by public authorities
3. protect and defend our rights or property
4. prevent or investigate possible wrongdoing
5. protect the safety of users, the public, or others
6. protect against legal liability
7. enforce our Terms of Service
8. investigate fraud, abuse, or security issues

29. Links to Other Websites

The Service may contain links to websites or services not operated by us.

If you click a third-party link, you will be directed to that third party's website or service.

We are not responsible for the content, privacy policies, terms, or practices of third-party websites or services.

You should review the privacy policy of every website or service you visit.

30. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we will make reasonable efforts to notify users, such as by posting the updated Privacy Policy on our website, sending an email, or showing an in-product notice.

Changes become effective when posted or on the effective date stated in the updated Privacy Policy.

Your continued use of the Service after changes become effective means you accept the updated Privacy Policy.

If you do not agree to the updated Privacy Policy, you must stop using the Service.

31. Contact Us

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

Commenter AI LTD

Email: support@commenter.ai

Website: https://commenter.ai