Privacy Policy

As a Controller. We act as the data controller when you visit our websites, create an account, communicate with us, interact with our marketing materials, or take part in our Intempt Collective (see Section 2B).

As a Processor. We act as a data processor when our customers use the Intempt platform to collect and process personal data about their own end users. In that capacity, our processing is governed by the Data Processing Addendum, not this Privacy Policy. If you are an end user of one of our customers, we recommend that you review that customer's privacy policy.

As a Controller (limited). We may also act as a controller for limited purposes such as platform security, fraud prevention, and product analytics.

1.1 Information You Provide. When you create an account, contact us, or purchase our services, we may collect your name, email address, phone number, company name, job title, billing information, and the content of your communications with us.

1.2 Customer Data. Our customers submit data to the platform through SDKs, APIs, and integrations. The types of data collected depend on how each customer configures the Services.

1.3 Information Collected Automatically. When you visit our websites, use our web applications, or use our mobile applications, we may automatically collect your IP address, browser type and version, device information (including device model, operating system version, and unique device identifiers), mobile advertising identifiers, push notification tokens, app version, referring URL, pages and screens viewed, session duration, and usage data. On mobile devices, we may also collect information about your network connection type and mobile carrier. On our websites we also use Microsoft Clarity to record session replays and build heatmaps, which captures your mouse movement, clicks, scrolls and interactions with pages. Clarity is listed in our Cookie Policy and on our Subprocessors page. You can prevent it by blocking third-party scripts or cookies in your browser. When you sign up, sign in, use our free tools, download a skill or submit a recipe, we use Cloudflare Turnstile to check that the request comes from a person and not an automated bot. Turnstile processes information about your browser and device for this check, as described in the Cloudflare Turnstile Privacy Addendum. We collect this information using cookies and similar technologies on the web, and through standard mobile operating system mechanisms on mobile devices, as described in our Cookie Policy.

1.4 Information from Third Parties. We may receive personal information about you from our service providers, business partners, and third-party data providers.

2.1 General Purposes. We use personal information to provide and improve the Services, communicate with you, process transactions, enforce our agreements, ensure security, and send marketing communications (from which you may opt out at any time).

2.2 Meeting Recording. Where a customer enables recording features, recordings are processed as Customer Data. The customer is responsible for obtaining all necessary consents.

2.3 AI Processing. We use AI and machine learning models to deliver platform capabilities including predictions, segmentation, and recommendations. This processing occurs within logically isolated, per-customer environments. Customer Data used for AI processing is never shared with or used to benefit other customers. Certain AI features route requests through third-party AI APIs (OpenAI, Anthropic and Google Gemini) — those providers process data on Intempt's behalf only and, consistent with their commercial API terms, restrict the use of Customer Data for model training purposes.

2.4 Legal Bases. We process personal information on the following legal bases: performance of a contract, legitimate interests, consent, and compliance with legal obligations.

Intempt integrates with Google Workspace to provide specific account features: automatically sending scheduled outreach messages through Journeys and pausing that automation the moment a reply is received, generating draft email replies for a user's manual review, applying inbox organization labels, creating and checking calendar events for meeting scheduling, and resolving meeting attendees' names from the user's saved Google contacts, Google's automatically-saved "Other contacts," and the organization directory.

Google user data obtained through these integrations is used solely to provide and improve the specific features described above. It is never used for marketing or advertising purposes, never sold, and never used to train or improve any general-purpose or foundation AI/ML model.

Some of these features are powered by third-party AI providers. Where Intempt sends Google user data to such a provider — for example, to generate a suggested email reply — it is sent to Anthropic (Claude), OpenAI (GPT), or Google (Gemini), each acting as a processor on Intempt's behalf under its enterprise or standard API terms. Under those terms, data submitted through the API is not used to train the provider's models. Intempt does not use consumer-tier AI services to process Google user data.

Intempt's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

2B.1 Our role. Intempt is the controller of personal data processed for the Intempt Collective, both for creators (people who earn from referrals or recipe royalties) and for the people who sign up through a creator's link. The Data Processing Addendum does not apply to this processing.

2B.2 What we collect from creators. Your name, email address and creator handle; the payout method you choose (Intempt credits, PayPal, Wise or Revolut) and the contact email for that method; your tax form status (form type, status and the date it was received), not the form itself, which our finance team collects separately; a record of each acceptance of the Intempt Collective Terms (the terms version, a fingerprint of the text you accepted, the checkbox wording, the time, your IP address and browser user agent); your referral commissions, recipe royalties, holds, adjustments and payout history; and the emails we send you about payouts and terms changes. We do not collect or store bank account numbers.

2B.3 What we record about referred people. If you arrive through a creator's link and accept marketing cookies, we store the creator's handle in the intempt_ref cookie, and any launch code shared with the link in the intempt_offer cookie, both described in our Cookie Policy. When you sign up we record which creator referred you, and later which subscription charges earned that creator a commission. If you run a recipe another customer authored, we record the credits consumed so its author can be paid a royalty. Creators see their own balances and payouts, not your account details.

2B.4 Why we use it. To perform the Intempt Collective Terms (attributing referrals, calculating and paying commissions and royalties), to meet our legal and tax obligations (including year-end tax reporting), and for our legitimate interest in preventing fraud, such as checking whether a creator and a referred account share a payment card or email domain.

2B.5 Who we share it with. Stripe, which processes the subscription charges commissions are calculated on, and the payout provider you choose (PayPal, Wise or Revolut), which receives your payout contact email and the amount. We also share it with tax authorities where the law requires.

2B.6 How long we keep it. Acceptance records are kept for the life of your Intempt account plus seven (7) years. Earnings, payout history and tax form status are kept for as long as you take part in the program and then for seven (7) years after your last payout, for legal and tax purposes. Referral attribution records are kept for the same period as the earnings they produced. The intempt_ref cookie expires after ninety (90) days.

4.1 Transfers. Our primary hosting infrastructure is located in the United States. We rely on the Standard Contractual Clauses for transfers of personal data from the European Economic Area, the United Kingdom, and Switzerland to the United States.

4.2 EU Representative. Pursuant to Article 27 of the GDPR, Intempt Technologies LLC has appointed MB Intempt Technologies, Odminių g. 11-4, Vilnius, LT-01122, Lithuania as its EU Representative. EU data subjects and supervisory authorities may contact the EU Representative at privacy@intempt.com.

5.1 Security. We implement commercially reasonable administrative, technical, and organizational safeguards to protect personal information. Additional details are available at https://intempt.trustshare.com/.

5.2 Retention. Customer Data is held for the period our customer chooses, up to a maximum of thirty-nine (39) months, after which it is deleted unless required by law. Events and identified events carry separate retention windows, so they may be held for different periods. Following termination, Customer Data is retained for thirty (30) days and then deleted. Intempt takes daily backups of Customer Data, retains each for seven (7) days and then deletes it as part of Intempt's standard data lifecycle procedures. Backups are not edited to remove individual records; a deletion request is completed within the period set out in the DPA, and any backup copy expires within the backup window. Intempt also maintains data redundancy and infrastructure resilience controls; where infrastructure-level copies exist, they are encrypted and isolated from active processing. Where Intempt acts as a data controller, we retain personal data as follows: account information — duration of account plus one (1) year; support records — three (3) years from interaction; website analytics — thirteen (13) months rolling; marketing data — one (1) year from last interaction or until opt-out; billing records — seven (7) years for tax compliance. Data may be retained longer where required by law.

5.3 Deleted Projects. A deleted or reset project remains recoverable for thirty (30) days, after which it is permanently deleted and cannot be restored.

5.4 Incident Response. In the event of a confirmed security incident, we will notify affected parties within seventy-two (72) hours of confirmation.

7.1 Your Choices. You may opt out of marketing communications at any time, manage your cookie preferences through our cookie banner, and exercise your rights to access, correct, delete, or port your personal data by contacting us at privacy@intempt.com. Data portability rights apply to personal data you have directly provided to Intempt where we act as a data controller, such as account and billing information. Individual account holders may also request portability of their own account data by contacting hey@intempt.com.

7.2 Customer Data. If you are an end user of one of our customers and wish to exercise your data protection rights, please contact the relevant customer directly, as they are the data controller.

7.3 Right to Restrict Processing. You have the right to request that we restrict the processing of your personal data where: (a) you contest the accuracy of the data; (b) the processing is unlawful and you oppose deletion; (c) we no longer need the data but you require it for legal claims; or (d) you have objected to processing pending verification of our legitimate grounds.

7.4 Right to Object. You have the right to object to the processing of your personal data based on our legitimate interests under GDPR Article 6(1)(f). Upon receiving your objection, we will cease processing unless we demonstrate compelling legitimate grounds that override your interests. You may object at any time by contacting privacy@intempt.com.

7.5 Right to Lodge a Complaint. If you are located in the EEA, the UK, or Switzerland, you have the right to lodge a complaint with your local data protection supervisory authority if you believe our processing of your personal data violates applicable law. A list of EU supervisory authorities is available at edpb.europa.eu.

7.6 Automated Decision-Making. We use automated processing, including AI-powered scoring and segmentation, to deliver platform features. You have the right not to be subject to a decision based solely on automated processing that produces legal effects or similarly significant effects on you. Where such processing occurs, you may request human review by contacting privacy@intempt.com.

This section is written for individuals (consumers) who interact directly with Intempt's products or websites — not for business customers.

What data we collect about you: When you use our website or create an account, we collect your name, email address, and information about how you use our services. If you use our mobile app, we also collect device information and app usage data.

How we use your data: We use your data to provide our services, communicate with you, improve our products, and send you marketing messages (which you can opt out of at any time).

How long we keep it: We keep your account information for as long as your account is active, plus one year after you close it. We keep billing records for seven years for legal and tax purposes.

Your rights: You have the right to see what data we hold about you, correct it if it is wrong, delete it, and object to how we use it. To exercise any of these rights, contact us at privacy@intempt.com.

How to contact us: privacy@intempt.com — we aim to respond within thirty (30) days.

If you are an EU consumer, you have a statutory right to withdraw from any subscription within fourteen (14) days of entering into it. To exercise this right, contact hey@intempt.com. Upon valid withdrawal, we will refund all payments made within fourteen (14) days using your original payment method. See Section 4.5 of the Customer Terms of Service for full details.

If you are a California resident, you have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA).

8.1 Categories of Personal Information Collected. We collect the following categories: identifiers (name, email, phone, IP address); commercial information (billing records, purchase history); internet or electronic network activity (browsing history, interactions with our website and services); geolocation data (derived from IP address); professional or employment information (job title, company name); and inferences drawn from the above to create a profile.

8.2 Sources. We collect personal information directly from you, automatically through your use of our services, and from third-party data providers and business partners.

8.3 Business Purposes. We use personal information to provide and improve our services, process transactions, communicate with you, ensure security, and for marketing (from which you may opt out).

8.4 Third-Party Sharing. We share personal information with our service providers (listed at intempt.com/subprocessors) for business purposes. We do not sell or share your personal information for cross-context behavioral advertising as defined by the CCPA/CPRA.

8.5 Your Rights. You have the right to: know what personal information we collect, use, disclose, and sell; delete your personal information; correct inaccurate personal information; opt out of the sale or sharing of your personal information; and limit the use of sensitive personal information. We will not discriminate against you for exercising your rights.

8.6 How to Exercise. Contact hey@intempt.com with "California Privacy Request" in the subject line. We will verify your identity before processing the request. We respond within forty-five (45) days, with one extension of forty-five (45) days if needed.

8.7 Minors. We do not sell the personal information of consumers under sixteen (16) years of age.

8.8 Other U.S. States. Residents of Virginia, Colorado, Connecticut, Utah, Oregon, Montana, and other states with comprehensive privacy laws may have similar rights. To exercise any applicable rights, contact hey@intempt.com.

If you use the Intempt mobile application (available through the Apple App Store and other app stores), the following additional information applies:

9.1 Data We Collect. In addition to the information described in Section 1, we may collect device identifiers, push notification tokens, mobile operating system version, app version, crash logs, and performance data.

9.2 Device Permissions. The app may request access to your device's camera, microphone, contacts, calendar, or notifications. You can manage these permissions at any time through your device settings. Denying certain permissions may limit the functionality of the app.

9.3 Push Notifications. If you opt in to push notifications, we will send notifications to your device using Apple Push Notification Service (APNs) or Google Firebase Cloud Messaging (FCM). You can disable push notifications at any time through your device settings.

9.4 App Store Privacy. Information about the categories of data we collect through the mobile application is also disclosed through the App Store's privacy nutrition labels, which are maintained in our App Store listing.

9.5 No Payments Through App Stores. We do not process payments through Apple In-App Purchase, Google Play Billing, or any other App Store billing mechanism. All subscription payments are processed directly by Intempt through Stripe.