Privacy Policy

PRIVACY POLICY

Last updated October 07, 2026

This Privacy Notice for Upwage 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://askkeo.ai or any website of ours that links to this Privacy Notice

Use Keo. An AI assistant for teams that works inside Slack, with a web console at askkeo.ai. Keo answers questions using the workspace data and third-party tools an organization connects to it, creates documents and reports that can be shared within the workspace, and runs scheduled tasks on request.

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

Questions or concerns? Reading this Privacy Notice 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 at support@askkeo.ai.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our 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 about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. 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 about how we process your information.

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 about when and with whom we share your personal information.

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 about how we keep your information safe.

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 about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. 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? Review the Privacy Notice in full.

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 PERSONAL 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. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

8. HOW LONG DO WE KEEP YOUR INFORMATION?

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

10. DO WE COLLECT INFORMATION FROM MINORS?

11. WHAT ARE YOUR PRIVACY RIGHTS?

12. CONTROLS FOR DO-NOT-TRACK FEATURES

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

14. SCOPE AND COVERED SERVICES

15. CUSTOMER DATA AND THE ROLE OF UPWAGE

16. THIRD-PARTY WORKSPACE INTEGRATIONS AND USE OF PLATFORM DATA

17. INFORMATION ABOUT INDIVIDUALS WHO DO NOT USE KEO

18. ARTIFICIAL INTELLIGENCE PROCESSING AND HUMAN REVIEW

19. SECURITY MEASURES

20. ANALYTICS ONLY, NO ADVERTISING TRACKING

21. DO WE MAKE UPDATES TO THIS NOTICE?

22. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

23. 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

job titles

usernames

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

Payments are processed by Stripe through a hosted checkout page. Card numbers and security codes are entered directly with Stripe and are never received or stored by Upwage Inc. We receive only billing contact details and transaction metadata such as the amount, the date, and the last four digits of the payment card.

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. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, 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. You can find out more about this in our Cookie Notice: https://askkeo.ai/cookie-policy.

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, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

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

2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

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. (Retention period: 30 days after account termination)

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. (Retention period: 30 days after account termination)

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. (Retention period: 24 months)

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. (Retention period: 30 days after account termination)

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. (Retention period: 7 years, to meet tax and accounting obligations)

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services. (Retention period: 24 months)

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. (Retention period: 12 months)

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them. (Retention period: 24 months)

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

Authenticate users and workspaces. To verify user and workspace identity through Slack OAuth and to maintain the integrations a workspace connects.

Generate AI responses and outputs. To process requests using AI systems and produce answers, documents, reports and other outputs at the user's direction.

Maintain conversation context and memory. To retain conversation history and durable facts so Keo can provide continuity across sessions and channels.

Execute scheduled tasks and automations. To run the recurring checks and scheduled tasks that users configure.

To maintain the reliability and performance of the Service. We monitor errors, diagnose issues, and measure performance across Keo's infrastructure.

To improve Keo using aggregated or de-identified data. We analyze usage patterns and quality signals using data that cannot reasonably identify an individual.

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. Learn more about withdrawing your consent.

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 we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

Analyze how our Services are used so we can improve them to engage and retain users

Diagnose problems and/or prevent fraudulent activities

Understand how our users use our products and services so we can improve user experience

keep the Service available, stable and responsive for all users.

improve the accuracy, quality and usefulness of the Service without processing identifiable personal information.

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.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the "data controller" under European data protection laws of the personal information described in this Privacy Notice, since we determine the means and/or purposes of the data processing we perform. This Privacy Notice does not apply to the personal information we process as a "data processor" on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the "data controller" responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.

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, including, for example:

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

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next of kin

If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

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

If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

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 may 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 contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

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

AI Service Providers

Anthropic and OpenAI

Allow Users to Connect to Their Third-Party Accounts

Google account and Github account

Functionality and Infrastructure Optimization

Termly.io

Invoice and Billing

Stripe

Web and Mobile Analytics

Posthog

Website Performance Monitoring

PostHog

Core platform integration (OAuth, messaging, and app functionality)

Slack

Secrets and credential management

Doppler

AI model routing and inference

OpenRouter

Issue tracking integration

Linear

Meeting transcript integration

Fireflies

Data warehouse integration

ClickHouse

Feature flag and experimentation integration

GrowthBook

Content and transcript retrieval

Supadata

Cloud hosting, compute, database, object storage, and AI gateway

Cloudflare

Application logging, monitoring and error tracking

New Relic

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.

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 parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements or to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://askkeo.ai/cookie-policy.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including Anthropic, OpenAI and OpenRouter. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

AI automation

AI bots

AI document generation

AI insights

AI research

AI search

Natural language processing

Text analysis

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

How to Opt Out

We believe in giving you the power to decide how your data is used. To opt out, you can:

Remove Keo from a Slack channel to stop Keo from accessing that channel

Revoke an individual connector to stop Keo from accessing that service

Remove the Keo app from your Slack workspace to stop all new collection

Ask a workspace administrator to remove or deactivate your account to end Keo's access to your data

7. 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. Regardless of your location, please be aware that 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 may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), including facilities in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses are available here: https://askkeo.ai/dpa. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). If you are located in the EU or UK, see section "HOW DO WE PROCESS YOUR INFORMATION?" for our retention periods by purpose.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. 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.

10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 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 18 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 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at support@askkeo.ai.

11. 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 provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

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:

Online: https://app.termly.io/dsar/f0a5c94d-c40e-43bc-b9a1-ba6fa1daf27f

Email: support@askkeo.ai

Post: See "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

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.

Website: ico.org.uk/make-a-complaint
Helpline: 0303 123 1113
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

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 your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

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.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://askkeo.ai/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at support@askkeo.ai.

12. 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 Notice.

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.

Global Privacy Control: We recognize and honor Global Privacy Control (GPC) signals. If you use a browser or extension that supports GPC, we will treat this as a valid request to opt out of the sale or sharing of your personal information for targeted advertising purposes under applicable state privacy laws, including the California Consumer Privacy Act (CCPA). When we detect a GPC signal from your browser, we will automatically apply your opt-out preference without requiring you to take any additional action. For more information about GPC and how to enable it, visit globalprivacycontrol.org.

13. 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 the section "WHAT INFORMATION DO WE COLLECT?"

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	NO
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
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	YES
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		NO

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 - For as long as the user has an account with us, and deleted within 30 days after the account is terminated

Category B - For as long as the user has an account with us, and deleted within 30 days after the account is terminated

Category D - 7 years, to meet tax and accounting obligations

Category F - For as long as the user has an account with us, and deleted within 30 days after the account is terminated

Category I - For as long as the user has an account with us, and deleted within 30 days after the account is terminated

Category K - For as long as the user has an account with us, and deleted within 30 days after the account is terminated. Keo builds a workspace knowledge graph of derived facts to answer questions accurately and maintain context. These are operational inferences used to serve the workspace's own requests. Keo does not build marketing profiles, segment audiences, or make automated decisions about individuals.

Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"How We Use and Share Personal Information
Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

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 as defined in the California Customer Records law

Category D. Commercial information

Category F. Internet or other electronic network activity information

Category I. Professional or employment-related information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

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)

How to Exercise Your Rights
To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at support@askkeo.ai, by visiting https://app.termly.io/dsar/f0a5c94d-c40e-43bc-b9a1-ba6fa1daf27f, or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

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 emailing us at support@askkeo.ai. 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.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

14. SCOPE AND COVERED SERVICES
This Privacy Notice applies to the Keo application, the website at https://askkeo.ai and any of its subdomains, and all related services we provide under the Keo name. All references to we, us, and our in this Privacy Notice include Keo and Upwage Inc. Keo is a workplace assistant that operates alongside third-party collaboration tools that your organization chooses to connect, and it may create, store, and share documents, pages, and other artifacts at your direction. Other products and services operated by Upwage Inc. are governed by the Upwage Privacy Notice available at https://upwage.com. Where a written agreement between Upwage Inc. and your organization addresses the processing of personal information, that agreement governs to the extent it conflicts with this Notice.

15. CUSTOMER DATA AND THE ROLE OF UPWAGE
Keo is provided to organizations. When your organization enrolls in Keo and connects its workspace tools, your organization decides how Keo is used and what content Keo may access. In relation to content Keo accesses from your organization's connected tools, including messages, files, and documents, and in relation to the outputs Keo generates from that content, we act as a processor. We process that content only on your organization's documented instructions and in accordance with the agreement between us. Your organization acts as the controller of that content. In relation to information we collect to operate the Keo service itself, including account registration details, authentication data, billing information, support communications, and product usage and diagnostic data, we act as a controller, and this Privacy Notice describes our own processing. If you use Keo through your organization and you wish to access, correct, or delete content held in your organization's workspace, we may require that the request come from an administrator or account owner of that workspace, or we may direct you to your organization's administrator. We will notify your organization of any request we receive relating to content they control and will assist them in responding. Requests relating to information for which we are the controller are handled directly by us as described in this Notice.

16. THIRD-PARTY WORKSPACE INTEGRATIONS AND USE OF PLATFORM DATA
Keo works by connecting to third-party platforms that you or your organization authorize, which may include Slack, Google Workspace, and similar collaboration tools. We access data from these platforms only after authorization is granted through the platform's own consent screen, and only within the permission scopes granted at that time. We request the narrowest scopes required for the features you use.

Keo's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

We do not use data obtained through Slack APIs, Google APIs, or any other connected platform API to develop, improve, or train generalized or general-purpose artificial intelligence or machine learning models. We do not sell data obtained through connected platform APIs, we do not share it for cross-context behavioral advertising, and we do not use it for advertising or advertising measurement.

You can revoke Keo's access at any time from the platform where you granted it, for example through Slack App Management or your Google Account permissions page. Revoking access stops further collection immediately. Revocation does not by itself delete data we have already stored. To request deletion of previously stored data, see the sections of this Notice covering your privacy rights and data retention.

Google user data

When you connect your Google account to Keo, you choose the permissions on Google's consent screen. Keo requests the following scopes and uses each one only for the purpose stated here.

Google Drive (drive.readonly, drive, drive.file): to search and read files you can see in order to answer your questions, and to create or edit files when you ask.

Google Calendar (calendar.readonly, calendar.events): to read your events in order to answer questions about your schedule and, when proactive features are on for you, to prepare the weekly preview Keo shows you; and to create, change, answer or cancel an event when you ask.

Gmail (gmail.readonly, gmail.send): to search and read your own mail in order to answer your questions, and to send email as you only after you approve that send on an approval card; nothing is sent on standing permission.

Account email (openid, userinfo.email): to show which Google account is connected.

How Google user data is used and shared. Google user data is used only to provide Keo's features to you: to answer your requests, to carry out the actions you ask for and, when proactive features are turned on for your workspace and you have not opted out, to prepare the previews and suggestions Keo shows you, for which Keo may read the sources above on a schedule. To produce these, the relevant content is processed on our behalf by the service providers named in this Notice, our AI model providers and our monitoring provider; we send a no-training instruction wherever the route accepts one, and our monitoring provider is opted out of using the data for its own purposes, including training. We do not sell Google user data, we do not use it for advertising, and we do not share it with anyone else. Google Workspace APIs are not used to develop, improve, or train non-personalized artificial intelligence or machine learning models.

How Google user data is stored and deleted. Keo stores the OAuth tokens that Google issues, encrypted at rest, for as long as your connection is active. Content Keo reads through your connection stays inside your workspace's own environment, apart from the monitoring records of the request. Three kinds of copy exist, each bounded: what you ask Keo to keep, such as a document, page or note it created for you, the previews and summaries Keo prepared for you, and the files in your private workspace area, which stay while you use them (an unused workspace's files expire with their backup after about 90 days); the record of your most recent conversations, which Keo keeps for its own context, capped at 2,000 turns; and everything else Keo holds to do its work, from a task's working copies to the notes proactive features keep about what changed in your week, which Keo trims as it works: most of it within days of being read, the rest when the feature that used it next runs, or when you ask us to delete it. Monitoring records expire after a configured 30 days and are deleted within 60 days, because the store drops them in monthly parts, and the platform's recovery copies expire after 30 days. One exception: prompt logs our gateway collected before 7 October 2026 do not expire on their own and stay stored until we finish deleting them, so the 60-day limit does not apply to them. Files your organization's administrator shares with Keo's own Drive account and selects for the workspace knowledge base are indexed through that account, not through your personal connection, and are readable by the members your organization admits. When you disconnect Google in Keo, Keo deletes the stored tokens, and all use of them ends within a minute. Disconnecting in Keo does not revoke Keo's authorization at Google, so to end access at once, revoke Keo from your Google Account permissions page, which invalidates every token Google issued to Keo for you. You can ask us to delete any of the data above at support@askkeo.ai.

17. INFORMATION ABOUT INDIVIDUALS WHO DO NOT USE KEO
Keo processes content from your organization's connected workspace tools, and that content may describe or refer to people who have never created a Keo account and have never interacted with Keo directly. This can include colleagues, customers, candidates, vendors, and other third parties named or discussed in messages and documents. We process this information solely to perform the task your organization has asked Keo to perform, and we act as a processor in doing so. We do not build standing profiles of individuals from this content. We do not use it to enrich records about them. We do not combine it with information obtained from other organizations. We do not use it for advertising or marketing. Because we receive this information from your organization rather than from the individual, your organization is responsible for providing any notice required under applicable law, including Article 14 of the GDPR, and for having a lawful basis for including that information in the content Keo accesses. If you believe your personal information appears in a Keo workspace and you wish to exercise your rights, you may contact us using the details in this Notice. We will identify the organization concerned, notify them, and assist them in responding, and where we are permitted to act directly we will do so.

18. ARTIFICIAL INTELLIGENCE PROCESSING AND HUMAN REVIEW
Keo uses large language models to interpret requests, generate text and documents, and carry out tasks. Model requests are routed through an AI gateway to the third-party model providers listed in "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" Personal information processed by our AI Products is handled in line with this Privacy Notice and the published terms of those providers. We use providers whose published terms for business use state that content submitted through their services is not used to train their models, and we configure our model routing to exclude providers that permit such use. We do not use your organization's content to train our own general-purpose models. Keo produces drafts, summaries, recommendations, and other outputs that are reviewed and acted on by people. Keo does not make decisions that produce legal effects concerning an individual, or that similarly significantly affect an individual, without human involvement. If an output affects you and you would like a person to review it, contact us using the details in this Notice and we will arrange human review. Model outputs may be inaccurate or incomplete. Keo output should not be relied on as the sole basis for a decision about a person.

19. SECURITY MEASURES
We protect information using technical and organizational measures appropriate to the risk, including the following. Data is encrypted in transit using TLS. Data at rest is encrypted, and credentials for connected platforms are encrypted with AES-256-GCM before storage. Each customer organization's working data is held in an isolated compute and storage context, so that one organization's data is not accessible from another organization's session. Access to production systems is limited to authorized personnel on a least-privilege basis, requires multi-factor authentication, and is reviewed periodically. Administrative actions are logged. We maintain separate development, staging, and production environments, and changes reach production only after review and successful automated checks. Backups are encrypted, access-controlled, and retained on a defined rotation, after which they expire automatically. We maintain an incident response process and will notify affected customers and, where required, supervisory authorities within the timeframes applicable law requires. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

20. ANALYTICS ONLY, NO ADVERTISING TRACKING
Keo uses cookies and similar technologies only to operate the Services, keep accounts secure, and understand how the Services are used through our analytics provider, PostHog. This includes session replay, which records how users interact with the Keo web console so we can find and fix problems. We do not use advertising cookies. We do not allow third parties to use tracking technologies on our Services to serve or tailor advertisements, and we do not sell or share personal information for targeted or cross-context behavioral advertising. Any general statements about advertising in the section "DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?" do not apply to Keo.

21. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

22. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at support@askkeo.ai, or contact us by post at:

Upwage Inc.

Data Protection Officer

8693 Coldwater Dr

Powell, OH 43065

United States

If you are a resident in the European Economic Area, we are the "data controller" of your personal information. We have appointed Euverify Limited to be our representative in the EEA. You can contact them directly regarding our processing of your information, by email at gdpr@euverify.com, or by post to:

Unit 3D, North Point House

North Point Business Park, New Mallow Road

Cork, County Cork T23 AT2P

Ireland

If you are a resident in the United Kingdom, we are the "data controller" of your personal information. We have appointed Euverify Ltd to be our representative in the UK. You can contact them directly regarding our processing of your information, by email at gdpr@euverify.com, or by post to:

3rd Floor, 86–90 Paul Street

London EC2A 4NE

England

23. 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 fill out and submit a data subject access request.