Bespoke Privacy Policy

Bespoke Studios Inc. ("Bespoke," "we," "us," or "our") provides voice-driven coaching, performance analytics, and gamification tools for restaurant and hospitality professionals. This Privacy Policy describes what information we obtain, how we use and share it, and the rights you have.

If you have questions, contact us at support@bespokecast.ai.

1. Scope and Definitions

This policy applies to all Bespoke products and properties, which we collectively call the "Services":

• The Bespoke mobile application used by servers and other frontline staff (the "App")
• The Bespoke web dashboard used by restaurant managers and operators (the "Manager Dashboard")
• The Bespoke administrative web application used by Bespoke personnel
• The marketing website at bespokecast.ai (the "Website")

"You" means the natural person using the Services. "Employer" means the restaurant or hospitality operator that authorizes your use of the Services as part of its program.

2. Information We Obtain

We obtain the following categories of information.

Account Information. When you create an account, we collect your first name, last name, and phone number. For web-app users, we also collect an email address.

Audio Recordings. When you use the App during a shift, the App records audio captured by a Bluetooth lavalier microphone positioned near your mouth. These recordings are intended to capture your speech (the server side of server-customer interactions) for coaching and performance analysis.

Device and Technical Information. We collect IP address, approximate location (city, country, and continent), device manufacturer, device model, device name, locale, operating system name and version, and timezone.

Cookies. On bespokecast.ai we use session authentication cookies to keep you logged in. These are necessary cookies under GDPR-style frameworks and are not used for advertising or cross-site tracking.

Usage Analytics. We collect product analytics through PostHog, including which screens you visit, which features you use, and how long sessions last. We use this data to improve the Services.

3. How We Use the Information We Obtain

We use the information described above for the following purposes:

• To create and secure your account, authenticate you, and prevent fraud
• To provide the core functionality of the Services, including transcription, performance analytics, and coaching feedback
• To generate aggregated and individual performance metrics for you and your Employer
• To improve the Services, including by training and evaluating our models in a manner consistent with this policy
• To communicate with you about the Services, including service notices and material policy changes
• To comply with legal obligations and enforce our agreements

4. Audio Recordings

When you use the App during a shift, Bespoke records audio captured by a Bluetooth lavalier microphone worn by the server. We recommend that Employers post in-store signage indicating that audio recording is in progress, comparable to standard CCTV signage. Servers may turn the device off at any time, may revoke consent on a going-forward basis, and may request deletion of their recordings consistent with Section 9 of this policy. Bespoke retains digital in-app consent records for each participating server as a system of record.

5. Third-Party Service Providers and Processors

We engage the following third parties to process information on our behalf:

• Deepgram transcribes audio recordings to text.
• Anthropic (Claude) analyzes transcripts to produce coaching and performance insights.
• PostHog provides product usage analytics.

Each processor is contractually bound to data protection commitments substantially equivalent to those in this policy and is permitted to use the data only to provide the contracted service to Bespoke.

We may engage additional third-party processors as the Services evolve. We will update this policy if material changes occur to our processor list.

6. Information Sharing with Restaurant Employers

If you use the App as part of an Employer's program, your Employer may receive performance analytics, coaching metrics, transcripts, summaries, and aggregated insights derived from your use of the Services. The exact data shared is determined by the Employer's program configuration with Bespoke.

You retain the rights described in Section 9 with respect to your own personal data regardless of any Employer access. Decisions about employment, compensation, scheduling, or discipline are made by your Employer, not by Bespoke.

7. Information We Disclose

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

We disclose information only in these circumstances:

• Service Providers and Processors. As described in Section 5.
• Your Employer. As described in Section 6.
• Legal Compliance. Where required by law, subpoena, court order, or regulatory request, or where necessary to enforce our agreements or protect rights, safety, or property.
• Business Transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to commercially reasonable confidentiality commitments.

8. Data Retention

We retain personal information for as long as necessary for the purposes outlined in this policy and as required by applicable law. You may request deletion of your personal information at any time, subject to legal and Employer-mandated retention requirements. We may retain aggregated and de-identified data for model improvement, benchmarking, and research; this data is not reasonably linkable to you.

9. Your Rights

Subject to applicable law (including the California Consumer Privacy Act as amended by the California Privacy Rights Act), you have the following rights:

• Right to Know. You may request the categories of personal information we have collected, the sources from which we obtained it, the purposes for which we use it, and the categories of third parties with which we share it.
• Right to Delete. You may request deletion of your personal information, subject to legal and Employer-mandated retention requirements.
• Right to Correct. You may request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing. We do not sell personal information and we do not share it for cross-context behavioral advertising. No opt-out is required.
• Right to Limit Use of Sensitive Personal Information. We do not use sensitive personal information beyond purposes permitted by applicable law.
• Right to Non-Discrimination. We will not discriminate against you for exercising your rights.

You may submit a request, including through an authorized agent, by emailing support@bespokecast.ai. We will respond within the timeframes required by applicable law.

10. Biometric Information

We do not perform voice biometric identification or speaker recognition. We process audio recordings for content analysis (what was said), not to create biometric voice prints.

11. Data Security

We implement administrative, technical, and physical safeguards designed to protect your information. No system is perfectly secure, and we cannot guarantee absolute security.

12. Breach Notification

If we discover a data breach affecting your personal information, we will notify you as required by applicable state and federal law.

13. Children's Information

The Services are not directed to children under thirteen (13). We do not knowingly collect personal information from children under thirteen. If you believe a child has provided us personal information, please contact us at support@bespokecast.ai and we will delete it.

14. Changes to This Policy

We may update this policy from time to time. We will provide reasonable advance notice of material changes consistent with applicable law, through in-app notification or email.

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