PRIVACY POLICY

Last updated October 6, 2026

This Privacy Policy for Funi AI Inc. (“we,” “us,” or “our“), describes how and why we might access, collect, store, use, and/or share (“process“) your personal information when you use our services (“Services“), including when you:

  • Visit our website at https://lisly.ai and its subdomains, https://go.lisly.app, or any other website of ours that links to this Privacy Policy

  • Visit one of the single property websites we host for our users, at forsale.so, forrent.so, or rental.so

  • Download and use our mobile application (Lisly), or any other application of ours that links to this Privacy Policy

  • Use Lisly. Lisly is an AI agent that lets anyone create a property listing by opening their phone’s camera and walking through the property, and gives them the material to market it.

  • Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us through https://lisly.ai/contact.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by clicking the link following each key point or by using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more in Section 1.

Do we process any sensitive personal information? We do not ask for, and we do not set out to collect, the categories that count as “special” or “sensitive” in most jurisdictions — for example racial or ethnic origin, sexual orientation, or religious beliefs. Two things are worth naming plainly. If you use the optional location feature, we process your device’s precise location while you set a property’s location on the map, and precise location is treated as sensitive personal information under some US state laws. And a walkthrough video recorded inside a home can incidentally capture things we never asked for; we do not use that material for any purpose other than creating your listing and running the automated content check described in Section 6. Learn more in Section 1.

Do we collect any information from third parties? We do not buy personal information from data brokers, public databases, or marketing partners. We receive limited profile information from your social login provider (Google or Apple) when you choose to sign in with it, and we receive information about other people from our users — the email address of someone invited to an account, and the contact details someone puts on a listing. Learn more in Section 1.

How do we process your information? We process your information to provide, secure, and administer our Services, to improve how they work, to communicate with you, to prevent fraud, and to comply with law. We do not use your property content — videos, audio, photos, transcriptions, or listing text — to train AI models, and we do not sell or license it to anyone else to train theirs. See Section 6. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more in Section 2.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more in Section 4.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more in Section 10.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more in Section 12.

How do you exercise your rights? The easiest way to exercise your rights is through https://lisly.ai/contact; Sections 12, 14 and 17 give the other routes. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Read the full Privacy Policy below.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?

  2. HOW DO WE PROCESS YOUR INFORMATION?

  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

  6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

  7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

  8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

  9. HOW LONG DO WE KEEP YOUR INFORMATION?

  10. HOW DO WE KEEP YOUR INFORMATION SAFE?

  11. DO WE COLLECT INFORMATION FROM MINORS?

  12. WHAT ARE YOUR PRIVACY RIGHTS?

  13. CONTROLS FOR DO-NOT-TRACK FEATURES

  14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

  15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

  16. DO WE MAKE UPDATES TO THIS POLICY?

  17. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

  18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names

  • email addresses

  • usernames

  • passwords

  • contact preferences

  • contact or authentication data

  • profile photos

  • property videos, photos, and audio you record or upload

  • contact information you add to listings (agent or contact name, phone number, email, agent photos, brokerage or team name and logo)

Sensitive Information. We do not ask you for information in the categories that data protection laws treat as special or sensitive, and we do not use the Services to profile you on them. Two exceptions to a flat “no” are worth stating, and so is one further point about faces and voices:

  • Precise location. If you use the optional location feature, we process your device’s precise location while you set a property’s location on the map. Some US state privacy laws classify precise geolocation as sensitive personal information, so we treat it that way.

  • What a walkthrough can incidentally capture. A video recorded inside a home can show or record things that fall into sensitive categories — a religious object on a wall, mobility or medical equipment, a person’s voice or face. We do not seek this out. Our AI reads what is in your video in order to write the listing, so anything visible or audible in frame is part of what it processes, and a feature such as a ground-floor accessible bathroom may end up described in your listing, because that is what a listing describes. We do not use any of it for any purpose other than generating the listing you asked for and running the automated content check described in Section 6. Section 9 sets out what can outlast your account, including the legal-claims archive of original photos and the narrow exception for an open legal matter. If you would rather it were not recorded, remove it from view or from the recording before you upload.

  • We do not use faces or voices to identify anyone. Your video may contain a face, and it will usually contain your voice, because narrating is how the app works. We transcribe what is said and describe what is shown so that we can write your listing. We do not run facial recognition, we do not create a faceprint, voiceprint, or any other biometric template, we do not separate or identify speakers, we do not verify or authenticate who anyone is, and we do not match anyone against any database. Our AI providers process this content on our instructions and for this purpose only.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases. In-app purchases (subscriptions and credit packs) are processed by the Apple App Store or Google Play together with our subscription infrastructure provider, Adapty. We do not store your full payment card number. You may find the relevant privacy notices here: Apple, Google, and Adapty.

Social Media Login Data. We may provide you with the option to register with us using your existing Google or Apple account details. If you choose to register in this way, we will collect certain profile information about you from the login provider, as described in Section 7 below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Geolocation Information. We may request access or permission to your mobile device’s location when you use the location feature, for example to center the map while you set a property’s location. This is the only time we ask for your device’s location: we read it at the moment you open that screen, we do not track your location continuously or in the background, and the step can be skipped entirely. If you wish to change our access or permissions, you may do so in your device’s settings.

  • Photo metadata. A camera writes information into the photo file itself, and that can include where the photo was taken, the make, model, and serial number of the device that took it, and when. Every photo you upload — property photos, agent and brokerage photos, your profile picture — has that information removed on your device, before the photo reaches us, so we do not store it and it does not travel to anyone we send your photos to. The only thing kept is the orientation tag, so that a photo taken in portrait is displayed the right way up; the picture itself is unchanged. Your own copy of the file is untouched. Videos are a different case: we upload them as your camera recorded them, so a video may still carry what the camera wrote into it.

  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, microphone, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

  • Property Content. When you create a listing, we collect the videos you record or upload, the photos derived from them, and the audio captured in those videos. Our AI transcribes what is seen and said in your videos to create the listing. This content may include your voice and images of the property.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. On its own this information does not name you, but some of it — an IP address, a device identifier — can identify you when combined with other information, so we treat it as personal information. It may include your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, approximate location derived from your IP address, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

  • Approximate location. Where we or our analytics providers record a country or region, it is derived from your IP address, not from your device’s location sensors. We read your device’s precise location only through the optional location feature described above, only while that screen is open, and only if you grant the permission. A video you upload is a separate case: it can carry location information your camera wrote into the file, as the Photo metadata note above explains.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources

In Short: We collect limited data from social login providers and social media platforms, and we receive information about other people from our users. We do not buy data from public databases, data brokers, or marketing partners.

We do not buy personal information from public databases, data brokers, or marketing partners.

From social login and social media. When you sign in with a social login provider (Google or Apple), we receive profile information from that provider. If you interact with us on a social media platform using your social media account (e.g., Facebook or X), we receive personal information about you from such platforms, such as your name and email address. Any personal information that we collect from your social media account depends on that account’s privacy settings, and the platform’s own use of your information is not governed by this Privacy Policy.

From our users, about other people. Some of the information we hold is about people who are not our users and who gave it to a user rather than to us. There are three routes:

  • Account invitations. When a user invites someone to their account or shares a listing with them, we receive that person’s email address, and their name where the user provides one, in order to send the invitation and set up access.

  • Listing contact details. When a user adds contact information to a listing — an agent or contact name, phone number, email address, brokerage or team name, a photo, a logo — we store it, and we publish it on the property website if the user chooses to publish. Where the user generates a creative image in a style that shows the agent, we also send that agent photo to our AI provider, because the image is generated with that person in it (Section 6). That information often describes a colleague or a client rather than the user.

  • People in a property recording. A walkthrough video can contain the voice or image of someone other than the person filming, such as an occupant, a tenant, or a passer-by. Our Acceptable Use Policy requires the user to have permission or another legal basis before recording an identifiable person, and it is the user who decides what to record and what to publish. We process that footage to generate the listing the user asked for. We do not use it to identify anyone, and we do not use it to train AI models.

If you are one of those people. You have the same rights over your personal information as anyone else described in this Privacy Policy, and Section 12 explains how to exercise them. You can also ask us to remove content that concerns you: write to us at https://lisly.ai/contact, or use the reporting route in Section 10 of our Acceptable Use Policy, which is open to anyone affected and not only to our users. Once we have confirmed that the content concerns you, and where the law entitles you to know it, we will also tell you who published the content so you can take it up with them directly.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, secure, and administer our Services, to improve how they work, to communicate with you, to prevent fraud, and to comply with law. We process the personal information for the purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

None of the purposes below involves training AI models on your property content. We do not do that at all, as Section 6 explains. Improvement here means understanding which features are used and where they fail, fixing bugs, and deciding what to build.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

  • To manage your purchases. We may process your information to manage your subscription, your credit purchases, and the payments behind them.

  • To let you work with other people. We may process your information when you invite members to your account, share a listing with someone, or publish a property website that carries contact details.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see Section 12 below.

  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. This includes the automated content check described in Section 6.

  • To identify usage trends. We may process information about how you use our Services — which screens are opened, which features are used, where an operation fails — to understand how the Services are used so we can improve them. This uses account and usage data, not the content of your property videos, photos, or transcriptions.

  • To determine the effectiveness of our marketing campaigns. We may process your information to understand which of our campaigns bring people to the Services.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

*In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.*

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. See Section 12.

  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

  • Legitimate Interests. We may process your information when it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. Ours are: keeping the Services secure and preventing fraud and abuse; understanding how the Services are used so we can fix and improve them; telling existing users about our own products; and establishing, exercising, or defending legal claims.

  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Which basis applies to what. The table below maps what we do to the information it uses and the basis we rely on.

What we do

Information used

Legal basis

Create and run your account, authenticate you

Name, email address, password or social login identifier, account settings

Performance of a contract

Generate listings, transcriptions, photos, creative content, and property websites

Property videos, photos, audio and transcriptions, listing information, contact details you add

Performance of a contract

Place a property on the map

Precise device location, at the moment you use the location screen

Consent (device permission)

Take payment and manage your subscription and credits

Purchase and subscription records from the stores and our subscription provider

Performance of a contract

Send you service messages about your account, listings, and these documents

Name, email address, account and listing events

Performance of a contract

Send you marketing about our own products

Name, email address, marketing preferences

Legitimate interests, or consent where the law requires it. You can opt out at any time

Keep the Services secure, prevent fraud and abuse, diagnose faults

Device and log data, IP address, crash reports, usage events; for the automated content check in Section 6, the videos you record or upload and their transcription

Legitimate interests

Understand how the Services are used and improve them

Usage events, device data, approximate location from IP address

Legitimate interests

Measure which campaigns bring people to the Services

Attribution and campaign data, device identifiers

Legitimate interests, and consent where the law requires it for the technologies involved

Invite members and share listings

Email address and name of the invited person

Legitimate interests, ours and the user’s, in running a shared account

Publish a property website

The listing content and contact details the user chooses to publish

Performance of a contract with the user; legitimate interests as regards the person whose contact details appear

Answer support requests and complaints

Your message, contact details, account context

Performance of a contract, and legitimate interests

Meet legal obligations and defend legal claims

Whatever the obligation or claim requires; after account deletion, original property photos, and anything kept for an open legal matter as Section 9 describes

Legal obligation; legitimate interests in defending claims (Section 9)

You can object to any processing we base on legitimate interests. Section 12 explains how.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent. The ones that could realistically arise for a service like ours are:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

  • For investigations, and for fraud detection and prevention

  • For a business transaction, provided the conditions in the law are met

  • Where collection with consent would compromise the availability or accuracy of the information, and the collection is reasonable for investigating a breach of an agreement or a contravention of the law

  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. We have data protection terms in place with them — a data processing agreement where the provider offers one, and otherwise the provider’s published terms — which limit them to processing your personal information to provide their service to us and require them to protect it.

Like almost every company, our vendors run on infrastructure of their own, so each of them engages sub-processors — cloud hosting, storage, monitoring. That is how the internet works, and it is why the sentence “they never share your information with anyone” would be untrue. What we do instead is name them: the current list of our sub-processors, with what each one is used for, where it is located, and a link to the terms that govern it, is at https://lisly.ai/sub-processors. We update that page when we add or replace one, and you can ask us to notify you when it changes.

The categories of third parties we share personal information with are as follows:

  • AI providers. Google processes your property video, its audio, the transcription made from it, and your listing text, to transcribe the walkthrough and generate the listing. Google also does the AI work on your photos — photo edits, creative images, and creative video — so the photos you send for that work go to Google, together with the agent photo saved in the listing’s contact information where the creative image style you choose shows the agent. fal.ai is our fallback for one part of that work only: when a creative video cannot be completed by Google, the frames that video is built from go to fal.ai instead: the listing photo you picked and, in some styles, an AI-generated image made from it. Nothing else of yours reaches fal.ai — not your photo edits, not your creative images, not the agent photo, and not your walkthrough video, your recorded audio, or the transcription.

  • Cloud hosting and infrastructure. Google Cloud Platform and Firebase (including Cloud Storage, Firestore, and Cloud Functions), Amazon Web Services, and Cloudflare, which hosts and delivers the property websites.

  • Website hosting. Framer, which hosts lisly.ai and the contact form on it.

  • Maps. Google Maps Platform, which provides the map you use to place a property and the map on a published property website. In the app, loading a map sends Google the information it needs to serve it, including your IP address. On a property website the location is shown first as a still map image our own servers request from Google, so a visitor’s device reaches Google only if the visitor opens the interactive map.

  • Sign-in providers. Google and Apple, if you choose to sign in with them.

  • Payments and subscriptions. The Apple App Store, Google Play, and Adapty, our subscription infrastructure provider.

  • Messaging and support. Customer.io, which sends the emails, push notifications and in-app messages the app sends you, and receives your name, email address and in-app activity to decide which of them to send; Mailgun, which carries mail to and from our support address; our own helpdesk, which we host ourselves rather than buy as a service, so your support conversations stay on our infrastructure; and Anthropic, whose AI assistance our support team uses to triage conversations and draft replies.

  • Analytics and error tracking. Google Analytics, Google Tag Manager, Google Analytics for Firebase, Mixpanel, Airbridge, Crashlytics, Firebase Performance Monitoring, and Sentry.

  • Issue tracking. Linear, where we record bugs and product work. If you report a problem or make a request, what you told us can be written into an issue there so that we can act on it.

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • Legal reasons. We may disclose your personal information where we are required to by law, or where it is necessary to establish, exercise, or defend legal claims.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third-party analytics and error-tracking providers (Google Analytics, Google Tag Manager, Google Analytics for Firebase, Mixpanel, Airbridge, Crashlytics, and Sentry) to use these technologies on our Services to help us understand how the Services are used and where they fail. We do not currently allow third-party advertising networks to place tracking technologies on our Services.

To the extent these online tracking technologies are deemed to be a “sale” or “sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out by submitting a request as described in Section 14.

Where you can turn these off: on our websites, through the consent banner and the cookie settings link where they are shown, and through your browser controls anywhere; in the app, under Settings → Security & Privacy. Specific information about how we use these technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. We do not use Google Analytics Advertising Features. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: Yes. Lisly’s core features are powered by artificial intelligence. This section explains which AI features we offer, which providers power them, what each provider receives, and our commitment not to use any of it to train AI models.

As part of our Services, we offer products, features, or tools powered by artificial intelligence and machine learning (collectively, “AI Products”). The terms in this Privacy Policy govern your use of the AI Products within our Services.

Our AI Products

  • Video transcription. Our AI reviews the property videos you record or upload and writes down what it sees and hears, including what you say about the property.

  • Listing creation. Our AI generates your listing from your videos: descriptions, property features, photos extracted from video frames, and captions.

  • Photo editing. AI-powered photo edits (virtual staging, furniture changes, object and reflection removal, sky replacement, lighting changes, and image enhancement).

  • Creative and text content. AI-generated marketing images and videos, and text content (social media captions, emails, SMS messages, blog posts) based on your listing.

  • Automated content check. When you create a listing, an automated check looks at the videos you recorded or uploaded, and at the transcription made from them, for content our Acceptable Use Policy prohibits and for whether the video is a property walkthrough at all. A listing that fails it is not created, and prohibited content can also suspend the account automatically. Section 12 describes your right to a human review of a decision like that.

All AI-generated content can be reviewed and edited by you before you use it.

Use of AI Technologies

We provide the AI Products through third-party service providers (“AI Service Providers”): Google and fal.ai. They receive different things, and this is the part of this policy most worth reading closely:

  • Google receives the property video you record or upload, the audio in it, the transcription made from it, and your listing text. It powers transcription and listing generation. It also does the AI work on your photos — photo edits, creative images, and creative video — so the listing photos you send for that work go to Google. A creative image style that shows the agent also sends the agent photo saved in that listing’s contact information — a headshot or a full-length photo, depending on the style — because the image is generated with that person in it. That photo often shows a colleague rather than you; Section 1 explains your rights and theirs. Google states that it does not use the content we send it to train its models.

  • fal.ai is our fallback for one part of that photo work: creative video. When a creative video cannot be completed by Google — an error, a problem reaching the service, or anything else — the frames that video is built from go to fal.ai instead, and it returns the video. Those frames are the listing photo you picked and, in styles that use one, an AI-generated image made from that same photo for the other end of the video. Together with a standard text instruction we write, which names the kind of room, they are everything fal.ai receives. Photo edits and creative images do not go to fal.ai, the agent photo does not go to fal.ai, and your walkthrough video, your recorded audio, and the transcription are not sent to fal.ai.

Whichever provider a job goes to, the photos that reach it carry no camera metadata: the location, device and capture information a camera writes into a photo file is removed on your device before the photo is uploaded, as described in Section 1.

Your permission in the app. Before you start something that sends your content to these providers, such as creating a listing, editing a photo, or generating a creative, a description or other content, the app tells you who receives what and asks for your permission. Nothing goes to them until you allow it, and until you do, the app asks again each time. Your answer belongs to you and applies in every account you are part of. You can withdraw it at any time under Settings → Security & Privacy; new AI work then waits until you allow it again, and what was already created stays in your listings.

Where each provider is located, and the agreement that governs it, is set out at https://lisly.ai/sub-processors. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

We do not train AI models on your content

We do not use your property content to train or fine-tune artificial intelligence or machine-learning models, and we do not sell or license it to anyone else to train theirs. That covers your walkthrough videos, the audio in them, the transcriptions made from them, your photos, and your listing text.

The only thing we do with that content is generate the listing you asked for and run the Services for you, which includes the automated content check described above and the limited retention described in Section 9. If we ever wanted to do more, we would have to come back and ask you, separately and in plain terms, and you would be free to say no and carry on using the Services exactly as before.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party account details (your Google or Apple login). Where you choose to do this, we will receive certain profile information about you from the login provider. The profile information we receive may vary depending on the provider concerned, but will often include your name, email address, and profile picture.

We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States, and that is where your information is processed. Regardless of your location, your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we share your personal information (see Section 4).

Where our vendors are. Most of them are in the United States. Two are elsewhere: Framer, which hosts our website, is in the Netherlands; and Airbridge, which measures marketing attribution, is a Korean company whose data is stored in Japan. The sub-processors page states the location of each one.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then the countries your information reaches may not have data protection laws as comprehensive as those where you live. Where we transfer personal information out of the EEA, UK, or Switzerland, we rely on the European Commission’s Standard Contractual Clauses (and their UK and Swiss equivalents) entered into with our service providers, or on an adequacy decision where one applies. You can request a copy of the relevant safeguards by contacting us.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: While you have an account, we keep your information for as long as we need it to run the Services. After you delete your account we clear our active systems; beyond short-lived backups and records the law requires, the one thing we routinely keep is your original property photos, in an encrypted archive for two years. There is a narrow exception for an open legal matter, described below.

While you have an account. We keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax or accounting requirements). Your listings, their content, and your original photos stay with your account until you delete them or delete the account.

When you delete your account. We delete your personal information from our active systems. Three things do not disappear at that instant, and we would rather say so than let you find out:

  • Backups. Deleted data survives in routine backups for a short period until those backups roll over, and it is isolated from any further use in the meantime.

  • Records we are required to keep. Purchase and tax records are kept for the period the law requires. Records held by the app stores are the stores’ own and are governed by their policies.

  • Original property photos, for two years. This one deserves a paragraph of its own.

The two-year photo archive. After your account is deleted, we keep the original, unedited photos from your listings in an encrypted archive for two years, and then we delete them. The reason is narrow. Our editing tools change how a property looks, and if someone later claims that an edited photo misrepresented a property, the original is the evidence of what was actually there. Retention for the establishment, exercise, or defence of legal claims is a recognised basis, and two years is set by how long such a claim realistically takes to arrive: a property is listed, it sells, a buyer moves in, and only then notices something.

What the archive holds and what it does not: original photos only. Your walkthrough videos, the audio in them, and the transcriptions are deleted with the account and are not archived. They are more sensitive and they say much less about what a published photo showed. Access to the archive is restricted to the people who need it, and it is opened only against an actual claim, or where the law requires it, for example a court order or your own request for a copy of your data.

One exception, and it is a narrow one. If a legal claim involving your account, or a complaint that could lead to one, has been made or threatened before the account is deleted, or if we have set content aside because it appears to break the law or our Acceptable Use Policy, we may keep what is relevant to that matter, and only that, for as long as the matter is open or the law requires, and we delete it after that. The law allows information to be kept for the establishment, exercise, or defence of legal claims, and sometimes requires it.

Published material and links. When your account is deleted — and also when a subscription ends, as described in Section 5 of the Subscription Terms — published property websites are taken offline, and the public share links for your listings stop working. The download links for your export packages stop working as well. Copies that other people downloaded while those links were live are outside our control.

Where we no longer have a business or legal need to process personal information but cannot yet delete it, we store it securely and isolate it from any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 13 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 13 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 13, or older where the law in your jurisdiction sets a higher minimum age for consenting to online services, as Section 2 of our Terms of Service requires, and that if you are under the age of legal majority a parent or legal guardian has agreed to those Terms on your behalf. If we learn that personal information has been collected from someone under that age, we will deactivate the account and take reasonable measures to promptly delete the data from our records. If you become aware of any data we may have collected from children under age 13 or the equivalent age as specified by law in your jurisdiction, please contact us through https://lisly.ai/contact.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details in Section 17 below.

We will consider and act upon any request in accordance with applicable data protection laws. Before we hand over, change, or delete anything, we confirm that the request comes from the person the information is about, or from someone entitled to act for them, and where we have reasonable doubts we may ask for information to confirm it. Exercising these rights is free of charge, unless a request is manifestly unfounded or excessive, in which case, where the law that applies to you allows it, we may charge a reasonable fee or decline it, and we would tell you which and why. We aim to respond within one month of receiving your request. If a request is unusually complex we may need longer, in which case we will tell you within that month and explain why.

If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018.

How to contact us:

What happens after you complain

  • We will acknowledge your complaint within 30 days of receiving it.

  • We will investigate without unjustifiable or excessive delay.

  • We will keep you informed of progress and explain the outcome.

If you are not happy with our final response, you can refer your complaint to the Information Commissioner’s Office, the UK supervisory authority, at ico.org.uk/make-a-complaint.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw it at any time. How depends on what you consented to: turn off the location permission in your device settings; use the unsubscribe link in any marketing email; and turn analytics and crash reporting off in the app under Settings → Security & Privacy. You can always withdraw a consent by contacting us using the details in Section 17.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details in Section 17 below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

You can review and change the information in your account at any time in the app’s settings, and you can delete your account there too, under Settings → Security & Privacy. Deleting the account deletes every account you own; it is permanent and we cannot undo it. Deleting your account does not cancel a subscription you bought through the App Store or Google Play; cancel it there first, as Section 4 of our Subscription Terms explains.

What deleting actually does. We remove your personal information from our active systems, your published property websites go offline, and your share links stop working; the download links for your export packages stop working as well. What survives, and for how long, is set out in Section 9: routine backups until they roll over, records the law requires us to keep, and your original property photos in an encrypted archive for two years, plus the narrow exception for an open legal matter. We say this here rather than only in Section 9 because “delete” should not mean something different from what you expected when you pressed the button.

Analytics and crash reporting in the app. You can turn analytics data collection and crash reporting on and off in the app under Settings → Security & Privacy. Data collection covers our product analytics (Google Analytics for Firebase and Mixpanel) and the in-app events we send to Airbridge; crash reporting covers Crashlytics and Firebase Performance Monitoring.

One thing it does not cover, and we would rather say so. Airbridge measures which campaign or link brought you to the app. It runs the first time the app opens, before you have had a chance to change any setting, and records how the app was installed; turning data collection off later does not undo that record. After that it also receives a short list of in-app events, until you turn data collection off: signing up, signing in, signing out, finishing the tutorial, and sharing the app or a property website. We use these events to see whether the people a campaign brings in go on to use the app. They carry the sign-in method, or whether the app or a property website was shared, and nothing about your listings. We do not give Airbridge your name, email address or account identifier. No advertising identifier is collected: app tracking is off and we do not use the IDFA or the Android advertising ID. If you would rather we did not hold this data, ask us and we will delete it. Because this record is not tied to your name, email address or account, we may need information from your device to find it.

Cookies and similar technologies. Most web browsers are set to accept cookies by default; you can usually set yours to remove or reject them, which may affect some features. Our Cookie Policy explains what we use on our websites and how to change your choice.

If you have questions or comments about your privacy rights, you may contact us through https://lisly.ai/contact.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.*

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to Section 1.

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

YES

B. Personal information as defined in the California Customer Records statute

Name, contact information, education, employment, employment history, and financial information

YES

C. Protected classification characteristics under state or federal law

Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data

NO

D. Commercial information

Transaction information, purchase history, financial details, and payment information

YES

E. Biometric information

Fingerprints and voiceprints

NO

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

YES

G. Geolocation data

Device location

YES

H. Audio, electronic, sensory, or similar information

Property videos, photos, and audio recordings you create or upload when making a listing, and transcriptions derived from them

YES

I. Professional or employment-related information

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

NO

J. Education Information

Student records and directory information

NO

K. Inferences drawn from collected personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

YES

L. Sensitive personal information

Precise geolocation, when you use the optional location feature to place a property on the map

YES

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;

  • Participation in customer surveys or contests; and

  • Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - As long as the user has an account with us

  • Category B - As long as the user has an account with us

  • Category D - As long as the user has an account with us

  • Category F - As long as the user has an account with us

  • Category G - As long as the user has an account with us

  • Category H - As long as the user has an account with us, except original property photos, which are kept for two years after account deletion as described in Section 9, and anything kept for an open legal matter under the same Section

  • Category K - As long as the user has an account with us

  • Category L - Only while you use the location feature; the resulting property location is kept with the listing

Whatever the category, Section 9 describes what can outlast your account: routine backups until they roll over, records the law requires us to keep (purchase and tax records are in Category D), and anything kept for an open legal matter.

Sources of Personal Information

Section 1 describes where the personal information we hold comes from: what you give us, what is collected automatically, what a social login provider sends us, and what we receive about other people from our users.

How We Use and Share Personal Information

Section 2 describes how we use your personal information, and Section 3 maps each purpose to the information it uses.

Will your information be shared with anyone else?

We disclose personal information to our service providers under a written contract with each of them. Section 4 describes the categories, and https://lisly.ai/sub-processors names each one.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

  • Category A (identifiers)

  • Category B (personal information under the California Customer Records statute)

  • Category D (commercial information)

  • Category F (internet or other similar network activity)

  • Category G (geolocation data)

  • Category H (audio, electronic, sensory, or similar information)

  • Category K (inferences)

  • Category L (sensitive personal information — precise geolocation)

The categories of third parties to whom we disclosed that information are set out in Section 4, and each one is named individually at https://lisly.ai/sub-processors.

We do not sell your personal information, we do not share it for targeted advertising, and we do not license your property content to anyone for AI model training. See Section 6.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data

  • Right to access your personal data

  • Right to correct inaccuracies in your personal data

  • Right to request the deletion of your personal data

  • Right to obtain a copy of the personal data you previously shared with us

  • Right to non-discrimination for exercising your rights

  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

  • Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)

  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)

  • Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)

  • Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)

  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida). Lisly does not operate a voice or facial recognition feature, so we do not collect personal information in that way

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting https://lisly.ai/contact, from the app under Settings → Support → Contact Support, which opens a message to us in your email app, or by writing to the postal address in Section 17.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by submitting the appeal through https://lisly.ai/contact. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

*In Short: You may have additional rights based on the country you reside in, and this section says what we actually do about them.*

What is true everywhere. Rather than claim compliance with each country’s regime one by one, here is our position, and it applies to you wherever you live:

  • The rights below are honoured for everyone. Whatever your local law gives you, we will act on a request to access the personal information we hold about you, to correct it, to delete it, to receive a copy of what you gave us, to object to processing based on our legitimate interests, and to withdraw a consent you gave us. We do not ask which country you are in before deciding whether to answer. What we do ask is who you are: before we hand over, change, or delete anything, we confirm that the request comes from the person the information is about, or from someone entitled to act for them, and we may ask for information to do that. This applies to every request for access, correction, deletion or a copy described in this section.

  • Where your information is. In the United States, with the two exceptions named in Section 8. If your country restricts transfers abroad, that is the transfer we are describing, and it happens because that is where the Services run.

  • How to reach us. Use https://lisly.ai/contact, or write to the postal address in Section 17. We answer in English, and we aim to do it within one month. Answering is free of charge. The one exception is a request that is manifestly unfounded or excessive, for example the same request repeated without a reason: where the law that applies to you allows it, we may charge a reasonable fee for such a request or decline it, and we will tell you which and why.

  • If you are not satisfied. You can complain to the data protection authority in your country. Where we know the authority, we name it below.

We are a small company based in the United States, with no office anywhere else, so what we can offer you is the list above rather than local machinery we do not have.

Australia and New Zealand

You can ask us for access to the personal information we hold about you and for its correction, using the contact details in Section 17. Complaints go to the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner. Your information is stored and processed in the United States, and Section 4 lists the recipients.

Brazil

You can ask us to confirm whether we process your personal information, to give you access to it, to correct information that is incomplete, inaccurate or out of date, to anonymise, block or delete unnecessary or excessive information, to provide it in a portable form, to tell you who we have shared it with, and to withdraw a consent you gave. Use the contact details in Section 17. If you believe your rights have been infringed, you may complain to the Brazilian National Data Protection Authority (ANPD).

Canada

Our processing of personal information in Canada is described in the Canada part of Section 3. You can ask for access to your personal information and for its correction, and you can withdraw your consent at any time, using the contact details in Section 17. If you are not satisfied with how we have handled your personal information, you may complain to the Office of the Privacy Commissioner of Canada, or, in Quebec, to the Commission d’accès à l’information du Québec.

If you are in Quebec, you may also ask us to delete or de-index personal information about you where the law provides for it.

India

You can ask us for a summary of the personal information we process about you, ask us to correct or erase it, withdraw a consent you gave us as easily as you gave it, nominate another person to exercise your rights if you die or become incapacitated, and raise a grievance with us. Use the contact details in Section 17; a grievance reaches the same address and we treat it as a complaint rather than an ordinary request. If you are not satisfied with our response, you may complain to the Data Protection Board of India.

Middle East

United Arab Emirates, Saudi Arabia, Bahrain, Qatar, and Egypt. Each of these countries has its own data protection law, and the rights they give you are broadly the ones listed at the top of this section: to be told what we process, to access and correct it, to ask for its deletion where the law allows, to object, and to withdraw consent. We honour those requests, and you can make one using the contact details in Section 17. You may also complain to the data protection authority in your country — in Saudi Arabia, the Saudi Data & AI Authority (SDAIA); in the UAE, the competent federal or free-zone authority, including the Commissioner of Data Protection in the DIFC or the ADGM if you are in one of those zones.

Your personal information is processed in the United States. Several of these countries impose conditions on transferring personal information abroad. We do not hold a transfer instrument specific to any of them: our contractual safeguards with our vendors are the European-form clauses described in Section 8, which were made for a different regime. We are telling you that instead of implying a local safeguard exists. If you would rather your information were not processed in the United States, the Services are not able to offer you that today.

Republic of South Africa

You can ask us for access to the personal information we hold about you and for its correction, using the contact details in Section 17. If you are not satisfied with how we have handled a complaint, you can contact the regulator, The Information Regulator (South Africa), whose current contact details are published on its website.

Türkiye

If you are in Türkiye, you can ask us: whether we process your personal information; for information about that processing and its purpose; whether it is being used in line with that purpose; who we have transferred it to, in Türkiye or abroad; to correct information that is incomplete or inaccurate; and to delete or destroy it where the conditions for that are met. You can also object to a result produced against you solely by automated analysis. Use the contact details in Section 17. If your request is refused or not answered in time, you may complain to the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu).

Two things we should be straight about, because a Turkish reader is entitled to them. Your personal information is processed in the United States, and Section 4 lists who receives it. And Funi AI Inc. is a US company with no establishment or registered representative in Türkiye; we have not been assessed against Turkish data protection law, and we do not claim registration or a Turkish transfer instrument. What we do claim is the list above: those requests are honoured.

Other jurisdictions

If you are somewhere not named above, the rights at the top of this section still apply to you as a matter of how we work, whatever your local law does or does not require of us. Contact us using the details in Section 17.

16. DO WE MAKE UPDATES TO THIS POLICY?

*In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.*

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you before the changes take effect, by email or by a prominent notice in the app, and we will ask for your consent again where the law requires it. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact us through https://lisly.ai/contact or by post at:

Funi AI Inc.
320 Cobble Creek Curve, Suite 110
Newark, DE 19702
United States

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit https://lisly.ai/contact. You can also delete your account, and everything in it, in the app under Settings → Security & Privacy; Section 9 explains what deletion keeps and for how long.