DTEN Action Card Privacy Policy

Effective date: 29 October 2026 · Version 2.6

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This Privacy Policy explains how DTEN, Inc. handles personal information when you use the DTEN app for iPhone and Android, the DTEN Action Card device, and the DTEN cloud services that work with them (together, the “Service”).

Feature availability varies by platform, app version and region. The standard iPhone App Store release currently does not offer Zoom integration. The Zoom provisions below apply only when that integration is available in your version and you choose to connect it.

You can read this policy in the app and at actioncard.dten.com/legal/privacy-policy.

Privacy at a glance

This summary helps you find the key points. It is not a substitute for the full policy.

1. Scope

This policy covers the DTEN app, DTEN Action Card, and DTEN’s cloud services for recordings, transcripts, summaries, action items and related features.

We offer the Service in the United States, the European Economic Area (EEA), the United Kingdom, Switzerland and Japan.

This policy does not cover services run by other companies that you choose to connect, such as Zoom, Google Calendar or Salesforce. Their own privacy policies apply to what they do with your information. This policy explains what DTEN and the app send to them and receive from them.

Purchases of Action Card hardware are covered by separate terms of sale. Use of the Service is also governed by our Terms of Use.

2. Who we are

The Service is provided by DTEN, Inc., 2099 Gateway Pl, Suite 400, San Jose, CA 95110, United States (“DTEN”, “we”, “us”). DTEN, Inc. is the controller of the personal information described in this policy, except where Section 2A says otherwise.

2A. If you use the Service for an organization

If your organization has an agreement with DTEN under which we process personal information on its behalf, your organization is the controller of the recordings and content you create for it, and DTEN processes them as its processor under that agreement. In that case, your organization’s privacy notice applies to that content, and requests about it should be sent to your organization; we will help it respond. DTEN remains the controller of your account information, diagnostic and security information, and of any other processing described in this policy that we carry out for our own purposes.

3. What we collect

3.1 Information you give us

3.2 Recordings and what is created from them

Recordings can include anything said during a conversation, including confidential or sensitive information about you and other people. We do not look for sensitive information in recordings. We process it only as part of providing the features described in this policy.

3.3 Device and diagnostic information

We do not use advertising identifiers, and the app does not include advertising software.

Android permissions. On Android, the app asks for the Nearby devices permission to find and connect to Action Card over Bluetooth. On older Android versions, Android requires location permission for Bluetooth scanning. We do not collect or store your location.

3.4 Information from services you connect

3.5 Information about other people

Using the Service means handling information about people other than you:

Section 13 explains what this means for people who are recorded.

4. How recordings move

What this means for you. The DTEN app is not a permanent archive of original audio. The app does not offer sharing or exporting its original recording audio. Once that audio has been removed from the app and DTEN’s cloud, the DTEN app cannot restore it or transcribe it again. Where available, you can regenerate a summary from the retained transcript; that does not restore or reprocess the original audio. App cleanup does not erase an original file you imported from outside the app or a copy you previously saved elsewhere.

Short recordings. If Skip short recordings is enabled in Settings > General, eligible recordings shorter than 10 seconds are discarded rather than uploaded. This setting is on by default. Turning it off later does not recover audio already discarded. This rule does not retroactively erase a recording already accepted by an upload destination.

Pending or disabled uploads. If you have not given permission, or an upload is interrupted or fails, temporary audio may remain on the phone pending your decision, a retry or deletion. Choosing Not now is not an instruction to delete existing audio. You can remove remaining local recordings using the controls in Section 11.

Optional Zoom path. Where Zoom integration is available, you must connect your Zoom account and enable Cloud & AI before new audio is submitted. Your phone sends audio and recording information, such as its title, times, length and size, directly to Zoom and requests processing by Zoom AI Companion. The app downloads the resulting notes. DTEN’s servers manage the OAuth connection; this does not mean the audio is relayed through DTEN’s cloud or that DTEN sends its own transcripts to Zoom.

When you first connect Zoom, new recordings are set to go to Zoom only. You can change destinations in Settings where that control is available. Recordings set to Zoom only are not uploaded to DTEN for its transcription and summarization. Connection information, recording status events and diagnostic information are separate and are handled as described in Section 3. The app does not provide a general-purpose feature for sending your historical recordings to Zoom, and audio already removed from the app cannot be uploaded again from that deleted copy.

5. Your Cloud & AI permission

You choose whether to enable Cloud & AI. You can decline without agreeing to upload meeting audio. In this policy, phone-only mode means that new meeting recordings are not uploaded while Cloud & AI is off; it does not mean that account services, notifications or separately permitted diagnostics never use a network connection.

Cloud storage and AI processing go together. We do not offer a separate DTEN audio-storage-only service: uploading a recording to DTEN starts processing it for the AI features described here.

Asking first. Before meeting audio is uploaded, the app shows a Cloud & AI permission screen. It identifies Google Gemini and OpenAI, explains the information shared with them and why, and links to this policy. Select Agree and continue to enable the disclosed processing, or Not now to decline. Creating an account, accepting our Terms of Use, allowing Bluetooth or microphone access, or starting a recording does not by itself give this permission. Zoom additionally requires your explicit connection authorization where available.

We record your permission choice, when you made it and the version of the notice you saw. Permission is associated with your account; another person’s decision on the same phone is not permission for your account.

Earlier app versions. If you have not already made a choice under the applicable permission notice, the app asks you and pauses uploads until you choose. Previously uploaded recordings and results are not deleted by that prompt; you can delete them using Section 11.

Turning it on later. Go to Settings > General > Cloud & AI. Enabling it permits eligible pending recordings to upload according to their selected destinations and your short-recording setting. It does not restore deleted audio or change every recording to a different destination.

Turning it off. Go to Settings > General > Cloud & AI and turn it off. From that point:

Requests and data already submitted to an AI provider cannot be recalled. Zoom may continue processing audio already accepted by Zoom. Turning off Cloud & AI does not delete previous results, end a connected service’s authorization, or automatically remove copies already held by providers. To end a Zoom connection, also disconnect it in Settings; manage recordings already in Zoom using Zoom’s controls.

Existing results remain available until you delete them or your account. We retain them to provide the Service you signed up for, not to initiate new AI processing after you withdraw permission.

Separate choices. Cloud & AI does not replace the separate permission for Voice ID or the diagnostics choices in Section 3.3. Turning Cloud & AI off does not turn off account, security, notification or diagnostic processing described elsewhere in this policy. Diagnostic uploads and crash reporting remain subject to their own applicable permissions.

When we ask again. If we add a new AI provider, a new use of your content or a new kind of data, we ask for permission again before that change applies to you.

6. How we use information

We use personal information to:

DTEN does not use your recordings or content created from them to train general-purpose AI models (see Section 8), and we do not use your content for advertising.

Legal bases (EEA, UK and Switzerland)

Objecting. Where we rely on legitimate interests, you can object by emailing help.actioncard@dten.com. We will stop unless we have compelling legitimate grounds, which we will explain to you. You can also turn off automatic upload of diagnostic logs yourself in Settings (Section 3.3).

6A. Internal quality evaluation

To check and improve the quality of our features — for example, whether transcripts, summaries and action items are accurate — authorized DTEN staff run internal tests and evaluations. In these evaluations we may run recordings, transcripts and results through our features again, and we may send them to our AI providers (Google and OpenAI) under the same terms described in Section 7, for example to compare results. Evaluations are not model training, and the results are used only to improve how our features work.

We carry out these evaluations using recordings made by DTEN staff and test accounts. We do not use recordings or content from customer accounts for evaluation.

7. Who receives your information

We share personal information only as described in this section, as required by law, or as described below the table.

Our service providers. Amazon Web Services, Google (Gemini API and Firebase Crashlytics), OpenAI, Twilio SendGrid, Apple (push notifications on iPhone) and Google (Firebase Cloud Messaging, for push notifications on Android) process personal information on our behalf. Our contracts require them to use it only to provide their services to us and to protect it. When we share personal information with third parties to provide the Service, we require protection that is the same as, or equivalent to, the protection described in this policy and applicable privacy requirements. Services you connect, such as Zoom, Google Calendar and Salesforce, are provided under your own (or your organization’s) account with those companies. When you ask the app or us to read from or send information to them, they handle it under their own terms and privacy policies.

Amazon Web Services also stores your Voice ID data, profile photo, feedback, diagnostic logs and connected-service credentials for us. Diagnostic uploads can include the account and content fields described in Section 3.3. The Gemini API is provided by Google LLC. If you have turned on “Let AI learn about me”, OpenAI also receives the transcripts of your recordings with speaker labels, titles and tags (see Section 10).

Your phone’s calendar and reminders. If you add action items to the calendar or reminders app on your phone (for example, Apple Calendar or Reminders on iPhone), the app writes them on your phone. DTEN does not receive your phone’s calendar or reminders data.

Other disclosures. We may also disclose information:

DTEN staff. Authorized DTEN staff may access account information, diagnostic logs or content when this is needed to provide support you request, investigate a problem or misuse, or comply with the law.

8. Model training

9. Voice ID and speaker recognition

What it is. Voice ID lets the Service recognize which parts of a recording are spoken by you, so it can pick out the action items that are yours. To do this we create a voiceprint: a numerical representation of the characteristics of your voice. A voiceprint is a biometric identifier under the laws of several U.S. states, such as Illinois, Texas, Washington and Colorado; it is biometric data, a special category of personal data, in the EEA, the UK and Switzerland; and it is a personal identification code under Japanese law. We handle all Voice ID data as biometric data.

Your choice and consent. Voice ID is optional. It requires Cloud & AI and asks for your consent on its own screen, which tells you what we collect, why, how long we keep it and who stores it for us. We collect Voice ID data only after you agree on that screen, and we keep a record of your consent (the date and the version of the screen). Accepting our Terms of Use is not consent to Voice ID. If you skip it, recording, transcription and summaries still work. You can withdraw your consent at any time by deleting Voice ID.

What we collect.

What we use it for. Only to work out which parts of your recordings are spoken by you. We do not use Voice ID data to identify anyone else, for advertising, or to train general-purpose AI models.

Who stores and processes it. Voice ID data is stored in DTEN’s cloud on Amazon Web Services in the United States, which hosts it for us as our service provider under a contract that limits its use to that purpose. Matching runs only on DTEN’s own servers. The Voice ID enrollment samples and stored voiceprint are not sent to Google, OpenAI or Zoom. Ordinary meeting audio may still contain your voice and may be sent to Gemini or, if you choose that destination, Zoom as described in Sections 4 and 7. We do not disclose Voice ID data to anyone else unless you ask us to, or the law, a valid warrant or a subpoena requires it.

No sale. We do not sell, lease, trade or otherwise profit from Voice ID data.

Only your voiceprint. We create a voiceprint only for you. We do not create or keep voiceprints for other people.

How recordings are analyzed. To work out which parts of a recording are spoken by you, our servers separate the speakers in each recording and compare each speaker’s voice with your voiceprint. This means that the voices of other people in your recordings are analyzed by an automated comparison while the recording is processed. The voice measurements used for this comparison are not saved. What we do save, with the recording:

We use the comparison only to label which parts of a recording are yours, not to identify anyone else. These results are deleted with the recording (see Section 11).

Retention and destruction. This is our public policy for keeping and destroying Voice ID data. We permanently destroy your voice samples and voiceprint, including all stored versions of those files, at the earliest of these times:

Copies in our backups are overwritten within 35 days. After deletion we keep only a record, with no voice data, that you set up and deleted Voice ID (such as the dates and the number of samples), to show that we followed your choice. It is deleted when you delete your account.

Security. We store, transmit and protect Voice ID data using the reasonable standard of care in our industry, and at least as protectively as we protect other confidential information.

10. About Me

What it is. About Me is optional information about you that helps the AI understand your meetings — for example, which action items belong to you and how people refer to you. You do not have to use it: recording, transcription and summaries work without it. It is not only what you write: if you allow AI to learn about you, we also learn things about you from your meetings. It has two parts:

How it is used. When we extract action items, we send your About Me text, display name and other names to OpenAI as context (and to Google’s Gemini API when it is used as a backup), and we use them to correct who an action item belongs to. If you turn on “Let AI learn about me”, we send the transcripts of your recordings, with speaker labels, titles and tags, to OpenAI to create and update entries. Entries are updated daily and rebuilt every 14 days.

What it is not.

Your controls. In Settings > About me you can:

About Me requires Cloud & AI. After you turn off Cloud & AI, we do not start any new AI processing of your data, so About Me is no longer used and “Let AI learn about me” no longer learns. When you delete a recording, we remove it as a source of your learned entries, and entries that came only from that recording are deleted. Deleting your account deletes About Me.

11. Retention and deletion

We keep personal information until you delete it or your account, unless a shorter period or an exception below applies. Some information is deleted automatically: temporary app audio after the selected upload destinations accept it; recording audio in DTEN’s cloud once AI processing is complete; Voice ID after 24 months without use; and, once we introduce paid plans, content in accounts on the Free plan, as described below.

Request deletion of your DTEN app account and data

You can ask DTEN, Inc. to delete your DTEN app account and its associated data using the options below. You do not need to install, reinstall or sign in to the app to make an email request.

Verification and timing. We may need to verify that you own the account before deleting it. For email requests, we respond within one month; if a request is complex and needs more time, we will explain why and any extension, as described in Section 12. Sending an email does not immediately disable your account. After verification and once we initiate deletion, you are signed out and cannot sign in. Deletion of the account’s cloud content usually completes within minutes and, in any case, within 30 days after deletion is initiated, subject to the retention periods and exceptions below. The same cloud deletion process applies when you confirm deletion in the app.

What we delete. We delete your account profile and sign-in credentials, any remaining cloud recording audio, transcripts, summaries, action items, Ask AI conversations and other AI results, Voice ID, About Me, speaker information, project notes, feedback, settings and permission records, including stored file versions. We remove the Google Calendar, Salesforce and Zoom connection credentials held by DTEN, where connected, and release your Action Card’s account pairing. The limited records described below are retained separately.

What may remain and for how long. Backups are overwritten within 35 days; service logs are kept for 30 days; diagnostic logs for 90 days after upload; and crash reports for 90 days under the retention settings described below. To demonstrate that we completed your request, a limited deletion record is kept for 3 years. An internal account number and the account’s creation and deletion dates, with no other information about you, remain for technical reasons; no fixed deletion period is set for this technical record. Information subject to a legal hold may be kept longer as explained below. See retention details and deletion limits for the data involved and the separate schedules that apply to AI providers.

Devices and other services. An email request does not remotely erase files on your phone, Action Card, personal backups or other devices. Content already sent to Zoom, Salesforce or another recipient, and information in another user’s account, is handled as described below. To revoke access you granted to connected services, use those services’ account settings. You can request deletion of your DTEN app account without first clearing your devices or disconnecting those services.

How long we keep each type of information

Free and Pro plans

We plan to introduce a Free plan and a paid Pro plan (see Section 5 of our Terms of Use). Once these plans are available, the following applies. If you have Pro — whether it was included with Action Card or you paid for it — and it ends, your account moves to the Free plan. The recordings and results already in your account in DTEN’s cloud are then kept for another 30 days. If you do not upgrade within those 30 days, they are deleted. After that, new recordings and results in an account on the Free plan are also kept for 30 days. These future plan limits do not change the temporary-audio cleanup rules on your phone described in Section 4.

What each action does

Deleting a recording in the DTEN app does not delete a copy that was already sent to Zoom.

What we keep after you delete your account

What deleting your account does not reach

12. Your choices and rights

Controls in the app

What you must provide

To create an account we need your email address, a password and your name; without them we cannot provide the Service. Everything else is optional: you can use phone-only mode, and you can choose not to set up Voice ID, About Me or any connection. If you do not turn on Cloud & AI, we cannot provide transcripts, summaries or other AI features.

Automated decisions

We do not make decisions about you based solely on automated processing that produce legal effects or similarly significantly affect you. AI-generated results, such as suggested action items, are suggestions for you to review.

Your rights

Depending on where you live, you may have the right to:

To request deletion of your DTEN app account and its associated data without using the app, follow the account deletion instructions. To make another privacy request, email help.actioncard@dten.com. We may need to confirm your identity first. We respond within one month. If a request is complex, we may extend this by up to two more months and will tell you why.

United States

Residents of California and other U.S. states with privacy laws may have the right to know what personal information we collect, use and disclose; to access, correct and delete it; and to opt out of the sale or sharing of personal information and of certain profiling. You can use an authorized agent, and you can appeal if we decline your request by replying to our decision. We will not treat you differently for using these rights.

Japan

If you are in Japan, the Act on the Protection of Personal Information (APPI) applies to how we handle your personal information.

13. If you were recorded, or are named, in someone else's DTEN app account

Users of the DTEN app record meetings and conversations. If you took part in one, or were invited to a calendar event connected by a user, DTEN may hold information about you in that user’s account:

Where it comes from and why. We received this information from the user, who decides what to record and upload. We use it only to provide the Service to that user — for example, to create a transcript and summary of the meeting. For DTEN cloud AI features, Google (Gemini API) processes meeting audio and related content, and OpenAI processes transcripts and related text; DTEN stores the applicable information on Amazon Web Services in the United States (Sections 7 and 14). In the EEA, the UK and Switzerland, we rely on legitimate interests (Article 6(1)(f) GDPR) for this. We do not use your information to train general-purpose AI models, to profile you, or for advertising.

How long. Until the user deletes the recording or their account, or until we delete the recording at your request (see below), and within the periods in Section 11.

We do not actually know who you are. We do not verify the identity of anyone who speaks in a recording, and we do not create a voiceprint for you. A name attached to a speaker may have been added by the user, suggested from the user’s calendar, or taken from what was said in the transcript, and any of these can be wrong. For this reason we cannot search recordings by your name or voice alone.

We do not contact you directly. We usually cannot contact people who appear in recordings, and doing so would reveal the user’s meetings. We make this notice publicly available instead, and our Terms require users to tell people when they record and to obtain any consent the law requires.

Your rights. You can ask us for access to, correction or deletion of your information, or object to our processing of it. To help us find it, please tell us your name and email address and, if you can, the date of the meeting and who organized or recorded it. Where appropriate we will inform the user. If you object, we will stop processing your information unless we have compelling legitimate grounds, which we will explain to you. You can also complain to a data protection authority (Section 12). Contact: help.actioncard@dten.com.

Unlawful recordings. If you believe you were recorded unlawfully, tell us at the same address. We may restrict or remove the recording and take action under our Terms of Use.

14. Where we process your information

DTEN, Inc. is based in the United States and provides the Service from there. We store your information on Amazon Web Services in the United States (us-east-1 region). Google (Gemini API, Firebase Crashlytics and, on Android, Firebase Cloud Messaging) and OpenAI process it in the United States, and may process or temporarily store it in other countries where they or their service providers have facilities. Where Zoom integration is available and you connect it, DTEN manages the OAuth connection on its servers and your phone sends selected recordings directly to Zoom. Zoom processes them in the locations described in its privacy policy.

If you are in the EEA, the UK or Switzerland, this means your information is processed outside your country, including in the United States, whose laws may not give the same level of protection. We apply the protections described in this policy wherever your information is processed. Where personal information is transferred to us or by us from the EEA, the UK or Switzerland — for example, when an organization uses the Service for its staff — we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, with the UK Addendum and the Swiss amendments. Our contracts with our service providers require them to process personal information only for us and to protect it. You can ask for a copy of the relevant safeguards by emailing help.actioncard@dten.com.

15. Security

We use technical and organizational measures intended to protect personal information against unauthorized access, loss and misuse, and we limit access to people who need it to run the Service. No system is completely secure, and we cannot guarantee the security of information.

If a security incident affects your personal information, we will notify you and the authorities as required by law.

16. Children

The Service is for people 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has created an account, email us and we will delete it.

17. Changes to this policy

We will post any changes on this page and update the effective date. For material changes, we will notify you in the app or by email before they take effect. If a change adds a new AI provider, a new use of your content or a new kind of data, we will ask for your permission again before it applies to you.

18. Contact us

DTEN, Inc.
 2099 Gateway Pl, Suite 400
 San Jose, CA 95110
 United States
Support: help.dten.com