Voicicle – Privacy Policy
In summary: Voicicle processes audio to provide transcription and summary features. If you enable Cloud Sync, the original audio file, transcript, summary and associated information are encrypted before leaving your device and are stored in Amazon S3 using AWS Regions located in the United Kingdom. Cloud Sync requires an active subscription and a signed-in account. You can turn Cloud Sync off, delete individual recordings, delete all cloud content, or delete your account, subject to limited lawful retention described below.
1. Data Controller
The controller of your personal data for the purposes of this Privacy Policy is:
KEW Consulting Partnership Limited
Company Number: 10547959
VAT Number: GB267366373
Bridge Innovation Centre, Pembrokeshire Science & Technology, Cleddau Bridge, Pembroke Dock, SA72 6UN, United Kingdom
Website: www.kewconsulting.co.uk
Email: enquiries@kewconsulting.co.uk
Voicicle is operated by KEW Consulting Partnership Limited. References in this Privacy Policy to "Voicicle", "we", "us" or "our" mean KEW Consulting Partnership Limited.
2. Introduction
Voicicle provides services that process voice inputs and related user content to produce transcripts, summaries and other AI-assisted outputs and functionality.
We are committed to protecting personal data and processing it in accordance with applicable data protection law, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.
This Privacy Policy explains what personal data we process, why we process it, when information may be stored or shared, how long we retain it, and the rights available to you.
3. Data We Process
3.1 Audio and Voice Inputs
When you use Voicicle, you may create or submit an audio recording for processing by the Service. Voicicle processes that audio to provide the functionality you request, including transcription and summary generation.
To generate a transcript, the audio file is uploaded to storage controlled by us and made available to our transcription provider, ElevenLabs, by means of a time-limited access link. Upon completion of the transcription, we delete that copy of the audio file from our transcription storage and instruct ElevenLabs to delete the transcript from its systems.
Audio processed for transcription is therefore not retained by us following completion of that processing. Where Cloud Sync is enabled, a separate encrypted copy of the recording is retained as part of your cloud backup, as described in Section 3.3.
3.2 Transcripts, Summaries and Other Outputs
Voicicle may generate transcripts, summaries, action points, structured information or other outputs from your audio and other inputs. Summaries and related AI-assisted outputs are generated using Amazon Bedrock.
Where Cloud Sync is enabled, the transcript and summary associated with an eligible recording are stored with the audio file so that the backed-up recording and its related information can later be accessed, synchronised or restored through the Service.
We do not use your audio recordings, transcripts or summaries to train general-purpose AI models operated by Voicicle unless we separately tell you about that processing and have an appropriate lawful basis to do so.
3.3 Optional Cloud Sync
Voicicle provides an optional Cloud Sync feature. Cloud Sync is not enabled unless you choose to activate it within the Service, and requires both an active subscription and a signed-in, non-anonymous account. Cloud Sync is not available where the Service is used without an account.
When Cloud Sync is enabled, Voicicle may store the following information for recordings covered by the feature:
- the original audio file;
- the transcript generated from that audio;
- the summary generated from that audio;
- the waveform generated from that audio;
- the speaker names you have assigned in respect of that recording; and
- associated technical metadata reasonably necessary to identify, organise, synchronise, restore and manage the backed-up content, including titles, descriptions, tags and timestamps.
Enabling Cloud Sync causes recordings already stored on your device to be uploaded, in addition to recordings created subsequently. The Service notifies you of this before the first upload commences.
Backup data is stored using Amazon Web Services ("AWS"), including Amazon Simple Storage Service ("Amazon S3"), using AWS Regions located in the United Kingdom.
By default, Cloud Sync uploads content only when your device is connected to Wi-Fi. You may permit uploads over mobile data through the relevant settings in the Voicicle application.
We use backed-up information to provide the backup, restoration, synchronisation and related functionality that you have requested and, where reasonably necessary, to maintain service integrity, security and availability.
You can disable Cloud Sync through the relevant settings in the Voicicle application. Disabling Cloud Sync stops new eligible recordings from being automatically backed up. Disabling the feature does not by itself delete content that was already backed up; deletion is a separate action, described in Section 3.4, so that disabling synchronisation cannot inadvertently destroy your only remaining copy of a recording.
3.4 Deletion Controls
Voicicle provides three distinct in-application deletion controls.
(a) Deleting an individual recording. Deleting a recording removes it from your device and, where Cloud Sync is enabled, from your cloud backup. Deleted recordings are first placed in Recently Deleted, from which they may be restored, and are permanently deleted after 30 days.
(b) Delete from the cloud. This function initiates deletion of all content stored in your cloud backup and disables Cloud Sync. Recordings held on your devices are not affected and remain available to you.
(c) Delete account. This function initiates deletion of your cloud backup, your account and the account, contact and profile information we hold in connection with it. Deletion of an account is permanent and cannot be reversed. Content held locally on your devices is not affected and remains under your control until you remove it.
Once content has been deleted, it may no longer be available for restoration through Voicicle. Deleting content or an account does not cancel a subscription purchased through the App Store or Google Play; subscriptions must be cancelled through the relevant platform.
We may retain limited information where retention is required or reasonably necessary for legal or regulatory compliance, tax or accounting obligations, security, fraud prevention, investigation of serious misuse, establishing or defending legal claims, or enforcing a suspension or permanent ban under our Terms & Conditions.
Any information retained for those purposes will be limited to what is reasonably necessary. We will not retain ordinary copies of your backed-up audio, transcripts or summaries solely for the purpose of maintaining a permanent ban, unless particular content must be preserved for a legal, regulatory, security or evidential reason.
Where infrastructure necessarily maintains temporary technical copies, logs or disaster-recovery data that cannot be removed immediately, those copies may remain for a limited period until they are overwritten, expire or are deleted through the applicable technical lifecycle. They will not be restored to ordinary use except where reasonably necessary for security, legal or disaster-recovery purposes.
3.5 Speaker Labelling
The transcription process separates a recording into the contributions of different speakers within that recording. You may replace the default speaker designations with names of your choosing. Those names are stored in association with that recording, and the Service additionally retains a short list of names you have recently entered in order to offer them for reuse.
Speaker separation operates within an individual recording only. Voicicle does not create, derive or store a voiceprint, voice template or other biometric identifier, and is not capable of recognising an individual's voice across separate recordings. Speaker names are text you have entered and are not linked to any biometric characteristic.
3.6 Account, Contact and Subscription Data
When you create or use a Voicicle account, we may process information including:
- your name and email address;
- authentication and account identifiers, including the identity provider you used to sign in;
- account preferences and settings;
- subscription and billing information, where applicable; and
- communications you send to us.
Where you sign in using Apple's "Hide My Email" facility, we process the private relay address provided by Apple rather than your underlying email address.
3.7 Technical, Security and Usage Data
We may process technical information relating to use of the Service, including IP address, browser and device information, operating system, timestamps, authentication events, application activity, error and diagnostic information, feature usage, security events and information concerning suspected misuse of the Service.
We use this information to operate, protect, troubleshoot and improve the Service and to detect fraud, abuse, attempted sabotage, unauthorised access and other security threats.
The Voicicle application does not incorporate advertising or third-party analytics technologies.
4. Purposes and Lawful Bases for Processing
We process personal data only where we have an appropriate lawful basis. Depending on the processing activity, our lawful bases may include:
Performance of a contract: where processing is necessary to create and manage your account, process audio, generate requested outputs, provide subscription functionality or provide features you have chosen to use, including the operation of Cloud Sync once you have enabled it.
Legitimate interests: where reasonably necessary for our legitimate interests in operating, securing, maintaining and improving Voicicle; preventing fraud and abuse; investigating attempted sabotage, cyberattacks or unauthorised access; enforcing our Terms & Conditions; protecting users; and establishing or defending legal claims, provided those interests are not overridden by your rights and interests.
Consent: where we specifically ask for permission for optional processing for which consent is the appropriate lawful basis. This includes your decision to enable Cloud Sync, and non-essential analytics cookies on our website where applicable. Where processing relies on consent, you may withdraw that consent at any time, as described in Section 5.
Legal obligation: where processing is necessary for us to comply with an applicable legal obligation.
Your choice to enable an optional feature does not give Voicicle permission to use your information for unrelated purposes.
5. Cloud Sync Choice and Withdrawal
Cloud Sync is optional. You do not have to enable it in order to use Voicicle functionality that does not depend on cloud backup.
When you enable Cloud Sync, the audio file, transcript, summary, waveform, speaker names and associated metadata for eligible recordings will be encrypted and uploaded to Voicicle's cloud backup infrastructure, including recordings created before the feature was enabled.
You may withdraw at any time. Withdrawal operates in two stages, which the Service presents separately and which we describe here so that the distinction is unambiguous:
- Turning Cloud Sync off stops further uploads. Content already stored in your cloud backup is retained and remains available for restoration.
- Deleting your cloud content, by means of the controls described in Section 3.4, removes that stored content.
This separation is deliberate: it ensures that disabling synchronisation cannot, by itself, destroy a backup you may still need. If your intention is that we should no longer hold your content at all, you must use one of the deletion controls in addition to turning the feature off, and we will act on that request accordingly.
6. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing the Service and meeting legal, security, accounting and dispute-resolution requirements.
| Category | Retention period | |---|---| | Audio uploaded for transcription | Deleted upon completion of the transcription | | Transcript held by our transcription provider | Deleted upon delivery to us | | Backed-up audio, transcripts, summaries and associated content | Until deleted by you, until deletion following account closure, or in accordance with Section 6.1 | | Recordings placed in Recently Deleted | 30 days, after which they are permanently deleted | | Records indicating that a recording has been deleted | Up to 90 days, so that other devices linked to your account do not restore deleted content | | Account and contact information | While the account remains active, and for an appropriate period afterwards where reasonably necessary for legal, accounting, security or dispute-resolution purposes | | Billing and tax records | As required by applicable tax and accounting law | | Security and enforcement records | Limited information may be retained where reasonably necessary to investigate serious misuse, protect Voicicle and its users, prevent circumvention of security measures or a permanent ban, comply with law, or establish or defend legal claims |
6.1 Retention Following Expiry of a Subscription
Cloud Sync requires an active subscription. Where a subscription lapses and is not renewed, recordings held on your devices are unaffected and remain available to you. The corresponding cloud backup is retained for a further 90 days, after which it is permanently deleted.
Before any such deletion takes place we will send you two email notifications, ordinarily at approximately 60 days and approximately 85 days following expiry of the subscription, and will allow a further period of not less than seven days after the second notification. Renewing your subscription at any point before deletion occurs preserves the backup in full.
Cloud backups deleted under this Section cannot be recovered.
7. Service Providers and Data Sharing
We do not sell your personal data, audio recordings, transcripts or summaries.
We may disclose or make personal data available where reasonably necessary to service providers that help us operate Voicicle, including:
- Amazon Web Services, including Amazon S3 for Cloud Sync storage, AWS Key Management Service for encryption key management, Amazon Bedrock for summary generation, and Amazon Simple Email Service for service notifications;
- ElevenLabs, for transcription and speaker separation;
- Google LLC (Firebase), for authentication and account security;
- Apple Inc., Google LLC and Meta Platforms, Inc., where you choose to sign in using an identity provided by them;
- Apple Inc. and Google LLC, in respect of subscription purchase and billing;
- professional advisers such as solicitors, accountants and insurers; and
- regulators, courts, law-enforcement agencies or other authorities where required or permitted by law.
Where third parties process personal data on our behalf, we require appropriate contractual, data-protection and security arrangements, including terms meeting the requirements of Article 28 UK GDPR.
8. Location of Backup Data and International Transfers
Voicicle configures its Cloud Sync storage to use AWS Regions located in the United Kingdom.
The geographic location in which content is stored is not necessarily the same as every location from which a service provider may process, support or access information. Other technology providers used to provide Voicicle features may also process information in other countries.
Where processing results in an international transfer of personal data that is subject to UK data-protection transfer requirements, we will use an appropriate lawful transfer mechanism or safeguard where required. Depending on the circumstances, this may include applicable adequacy regulations, recognised contractual safeguards, the UK International Data Transfer Agreement, the UK Addendum to approved Standard Contractual Clauses, the UK Extension to the EU–US Data Privacy Framework, or another lawful mechanism. We assess the risks associated with such transfers and keep those assessments under review.
9. Security
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, destruction, alteration, disclosure or unauthorised access. Depending on the relevant system, these measures may include access controls, authentication controls, secure communications, encryption, logging, monitoring, backup controls and restricted administrative access.
9.1 Encryption of Backup Content
Content synchronised through Cloud Sync is encrypted on your device using the AES-256-GCM algorithm before transmission, is transmitted over encrypted connections, and remains encrypted at rest.
9.2 Key Management and Access
Encryption keys for Cloud Sync content are generated and managed by us using AWS Key Management Service. Keys are managed on our side, rather than held solely on your device, so that you can restore your content after signing in on a new or replacement device; were a key held solely on a single device, loss of that device would render your backup permanently unrecoverable.
Voicicle does not provide end-to-end encryption and we do not describe it as such.
Access to content stored through Cloud Sync is restricted to personnel who require it in order to operate, maintain or troubleshoot the Service, or to investigate suspected serious misuse. Such access is subject to access controls and is logged.
We may disclose content where required to do so by a warrant, court order or other legally valid and binding demand. We assess the validity and scope of any such demand and will challenge demands that we consider to be invalid or excessive.
9.3 Personal Data Breaches
Where a personal data breach occurs which is likely to result in a risk to the rights and freedoms of individuals, we will notify the Information Commissioner's Office without undue delay and, where feasible, within 72 hours. Where a breach is likely to result in a high risk to you, we will inform you directly.
No internet-connected service or storage system can be guaranteed to be completely secure. You should maintain appropriate security over your devices and account credentials.
10. Cookies and Analytics
Our website may use essential storage required for its operation. We may also offer optional analytics cookies or similar technologies, including Google Analytics deployed through Google Tag Manager, to help us understand how people discover and use Voicicle.
Where consent is required for non-essential analytics, those technologies will be used only in accordance with the choice presented to you through our cookie controls. You can decline optional analytics and continue using the website with essential storage only.
11. Third-Party Voices, Recordings and Personal Data
If you submit audio, content or other information concerning another person, you are responsible for ensuring that you have the lawful authority, rights, permissions and, where required, consents necessary to submit that information for processing through Voicicle.
This responsibility applies particularly where recordings contain confidential information or the voices or personal data of children, pupils, employees, family members or other third parties.
You must comply with applicable privacy, recording, confidentiality, safeguarding, intellectual-property and data-protection laws. You must not use Voicicle to make unlawful recordings, violate another person's privacy, impersonate another individual deceptively, or process another person's information unlawfully.
Where you use Voicicle for purposes connected with your employment, profession or business, rather than for purely personal or household purposes, you may yourself be a controller in respect of the personal data of the individuals you record, with your own obligations under applicable data protection law. Those obligations rest with you and cannot be discharged by us on your behalf.
12. Abuse Prevention and Account Enforcement
We may process account, usage, technical and security information where reasonably necessary to identify, prevent, investigate or respond to breaches of our Terms & Conditions, attempted sabotage, cyberattacks, unauthorised system access, malicious activity, fraud or other serious misuse.
Where an account has been suspended or permanently terminated for serious misuse, we may retain limited identifiers, security records and enforcement information for a reasonable period where necessary to prevent circumvention of the restriction, protect the Service or its users, establish or defend legal claims, or comply with legal obligations.
13. Your Data Protection Rights
Subject to applicable conditions and exemptions, you may have rights including the right to:
- request access to personal data we hold about you;
- request correction of inaccurate or incomplete information;
- request deletion of personal data;
- request restriction of processing;
- object to certain processing;
- request data portability where applicable; and
- withdraw consent where processing is based on consent.
Voicicle also provides the in-application deletion controls described in Section 3.4, allowing you to delete individual recordings, your cloud backup, or your account.
To exercise your data-protection rights or ask a question, contact enquiries@kewconsulting.co.uk. We may need to verify your identity before responding to certain requests. We will respond within one month of receipt of a valid request, which period may be extended where a request is complex or where a number of requests have been received.
You also have the right to complain to the UK Information Commissioner's Office ("ICO"). We encourage you to contact us first so that we have an opportunity to address your concern.
14. Age Restriction
The Service is intended for use only by individuals aged 18 years or over. This restriction reflects both our own requirements and the terms on which our transcription provider makes its services available.
You must not use the Service, or create or maintain an account, if you are under 18 years of age, and you must not create or maintain an account on behalf of a person under that age. Where we become aware that an account is held by a person under 18, we will close that account and delete the associated data.
15. Changes to this Privacy Policy
We may update this Privacy Policy periodically to reflect changes to Voicicle, our processing activities, technology, suppliers or applicable law.
Where a change is material, we will take reasonable steps to bring it to users' attention through the Service, website, email or another appropriate communication method before the change takes effect. We will not apply a materially expanded use of personal data already collected without first bringing that change to your attention and, where required, obtaining your consent. The date shown at the beginning of this Privacy Policy indicates when it was last updated.
16. Contact
Questions concerning this Privacy Policy or Voicicle's handling of personal data may be sent to:
KEW Consulting Partnership Limited
Bridge Innovation Centre
Pembrokeshire Science & Technology
Cleddau Bridge
Pembroke Dock
SA72 6UN
United Kingdom
Email: enquiries@kewconsulting.co.uk