APEK CORPORATION

GLOBAL PRIVACY & DATA PROTECTION POLICY

Version: 2.0

Effective Date: January 1, 2025

Last Updated: January 1, 2025

Applies To: APEK.ai, Voice2Me.ai, CallMe247.ai, Service247.ai and related APIs.

1. Introduction

APEK Corporation ("APEK", "we", "us") values your trust. As a provider of AI-driven voice orchestration, we recognize that we process highly sensitive human interactions. We believe privacy is not merely a compliance requirement, but a fundamental right.

This Global Privacy Policy describes how we collect, use, store, and protect personal data across our websites, APIs, and AI Voice Services (collectively, the "Services").

2. Scope & Applicability

This policy applies to data collected from:

• Visitors: Individuals visiting our marketing websites.

• Customers: Enterprise clients, developers, and subscribers using our platform.

• End Users: Individuals interacting with our AI Voice Agents (e.g., callers speaking to a Voice2Me bot).

Role Definition (GDPR/VCDPA):

• Data Controller: When APEK collects data for its own business (e.g., billing your credit card, marketing to you), APEK is the Controller.

• Data Processor: When APEK processes call audio and generates AI responses on behalf of our Enterprise Customers, APEK acts strictly as a Data Processor. The Enterprise Customer is the Data Controller and determines how that data is used.

3. The Data We Collect

We categorize data into three distinct "Buckets" to ensure clarity regarding retention and usage.

Bucket A: Account & Business Data (Retained)

• Identity: Name, email address, phone number, company role, and login credentials.

• Financial: Payment method details (processed via PCI-compliant vendors like Stripe).

• Telemetry: IP address, browser type, device identifiers, and API latency logs.

Bucket B: Voice & AI Interaction Data (Ephemeral / Configurable)

• Audio Payloads: Raw voice recordings of calls or web sessions.

• Transcripts: Speech-to-Text (STT) conversions of the audio.

• AI Context: System prompts, user queries, and LLM-generated responses.

• Processing Rule: By default, APEK utilizes a "Headless" architecture. Audio Payloads are processed in volatile memory (RAM) and discarded immediately after the session ends, unless the Customer explicitly enables "Logging" for Quality Assurance.

Bucket C: Biometric Data (Strictly Controlled)

• Default: APEK does not collect, store, or analyze "Voiceprints" (Biometric Identification) by default.

• Exception: If a Customer explicitly enables "Voice Authentication" features, we process biometric vectors strictly for the purpose of identity verification. We never use this data for surveillance or cross-client tracking.

4. How We Use Your Data

We process data only for specific, lawful purposes:

Purpose Lawful Basis (GDPR/UK/VCDPA)

Service Delivery (Routing calls, Contractual synthesizing speech) Necessity

Security & Fraud Prevention Legitimate Interest (Detecting botnets/abuse)

Platform Optimization (Analyzing Legitimate Interest latency/errors)

AI Model Training (Only with Explicit Consent explicit Opt-In)

Billing & Compliance (Invoicing, Legal Obligation Tax)

5. AI Trust & The "No-Training" Guarantee

To ensure trust in our AI orchestration:

1. No Default Training: APEK does not use Customer Interaction Data (Voice/Text) to train, fine-tune, or improve our foundation models or third-party LLMs (e.g., OpenAI) by default.

2. Data Isolation: Customer sessions are logically isolated. Data from "Company A" is never accessible to the AI model of "Company B."

3. Transparency: Our AI Agents are configured to disclose their non-human identity upon request, complying with the EU AI Act.

6. Data Sharing & Subprocessors

We do not sell your personal data. We share data only with vetted third-party service providers ("Subprocessors") essential to delivering the Service.

• Cloud Infrastructure: AWS, Google Cloud, Azure (Hosting, Compute, & Storage).

• AI Inference & Transcription: OpenAI, Anthropic, Deepgram, Cartesia, Groq.

  • Control: All AI vendors are bound by Zero-Retention agreements, ensuring they do not store our API data for their own model training.

• Telephony & Transport: Twilio, Telnyx, LiveKit.

• Database & Auth: Supabase.

• Billing: Stripe.

7. Cookies & Tracking Technologies

We use cookies to secure our website and analyze performance.

• Essential Cookies: Required for login and security (cannot be disabled).

• Analytics Cookies: Help us understand how you use our site. You may opt-out of these via your browser settings.

• Do Not Track (DNT): We honor "Do Not Track" signals from web browsers.

8. Retention & Disposal

We enforce a strict "Data Minimization" strategy:

• Voice/AI Content:

  • Default (Logging Disabled): 0 Days (Real-time processing only).

  • Logging Enabled: Retained for 30 days, then securely purged via Cryptographic Erasure.

• Metadata/Logs: Retained for 90 days for security auditing and performance monitoring.

• Account Data: Retained for the duration of the contract + 7 years (for tax, legal, and audit compliance).

9. International Transfers

APEK is headquartered in the United States.

• EEA/UK/Swiss Users: When we transfer data from the EEA/UK to the US, we rely on the EU-US Data Privacy Framework (DPF) principles or Standard Contractual Clauses (SCCs) to ensure your rights are protected.

10. Your Privacy Rights

Depending on your location (Virginia, California, EU, etc.), you have specific rights:

• Right to Access: Request a copy of the data we hold about you.

• Right to Erasure ("Right to be Forgotten"): Request deletion of your data.

• Right to Correction: Fix inaccurate data.

• Right to Opt-Out: Stop your data from being used for targeted advertising or profiling.

• Right to Appeal (VCDPA): If we deny your request, you have the right to appeal our decision.

To exercise these rights: Email our Data Protection Officer (DPO) at security@apek.ai. We respond to all valid requests within 30 days.

11. Security Measures

We implement "Defense-in-Depth" security controls aligned with ISO 27001 and SOC 2, including:

• Encryption: TLS 1.3 for data-in-transit; AES-256 for data-at-rest.

• Access Control: Strict Role-Based Access (RBAC) and Multi-Factor Authentication (MFA) for internal staff.

• Vulnerability Management: Continuous automated scanning of our infrastructure.

12. Children's Privacy

Our Services are Business-to-Business (B2B) tools intended for adults. We do not knowingly solicit or collect data from children under 18.

Incidental Collection Defense: We acknowledge that voice agents may inadvertently interact with minors (e.g., a child answering a parent's phone). In such cases, our Zero-Persistence Architecture ensures that any incidental audio or transcript data collected from a minor is processed in volatile memory and discarded immediately upon session completion. We do not retain, analyze, or use such data for model training.

13. Updates to This Policy

We may update this policy to reflect changes in law (e.g., EU AI Act updates) or our technology. Material changes will be notified via email to account holders or a prominent banner on our website.

14. Contact Us

If you have questions about this policy or our AI safety practices, please contact us:

Email: security@apek.ai

Address: APEK Corporation, Attn: Privacy Team, 5161 Gagne Ct, Fairfax, VA 22030 USA.

This policy serves as our Notice at Collection under the CCPA/CPRA and VCDPA.

APEK CORPORATION MASTER TERMS OF SERVICE

Last Updated: January 1, 2025 Effective Date: January 1, 2025

1. NOTICE OF AUTOMATED INTERACTION (NON-HUMAN STATUS)

YOU ARE INTERACTING WITH AN ARTIFICIAL INTELLIGENCE SYSTEM.

The voice agents, chatbots, and conversational interfaces provided by APEK Corporation ("Voice2Me") are automated systems powered by Large Language Models (LLMs) and Neural Text-to-Speech technology. They do not possess human consciousness, feelings, or independent judgment.

• EU AI Act / FCC Notice: For the purposes of global transparency regulations, this system is classified as an "AI System intended to interact with natural persons."

2. ACCURACY & "HALLUCINATIONS"

Generative AI is probabilistic, meaning it predicts the next likely word in a sentence based on patterns. It does not "know" facts in the human sense.

• Warning: The Service may occasionally produce incorrect, misleading, or factually erroneous information (commonly known as "Hallucinations").

• Verification: Users should never rely solely on the Service for critical decision-making. Always verify facts, dates, and specific details with independent human sources.

3. NO PROFESSIONAL ADVICE

This Service is provided for informational and operational purposes only.

• Not Medical Advice: The AI cannot diagnose conditions, prescribe medication, or provide triage. In a medical emergency, call 911 immediately.

• Not Legal/Financial Advice: The AI is not a lawyer or financial advisor. Any information regarding laws, contracts, or investments is generated generically and may not apply to your specific jurisdiction or situation.

4. VOICE RECORDING & BIOMETRICS

• Call Recording Laws: By using this Service, you acknowledge that your voice audio is being processed to generate text transcripts. You are solely responsible for complying with all applicable "Two-Party Consent" or wiretapping laws in your jurisdiction regarding the recording of conversations.

• Biometrics: Unless you have explicitly enrolled in a "Voice Authentication" feature, APEK does not collect, store, or analyze your unique biometric voiceprint for identification purposes.

5. PROHIBITED SAFETY RISKS

You agree NOT to use this Service for:

• Emergency Services: Do not use Voice2Me agents to route 911/112 calls or critical life-safety alerts. The system is not architected for "Five Nines" (99.999%) carrier-grade reliability.

• Impersonation: You may not use the Service to clone the voice of another person to deceive, defraud, or harass others ("Deepfakes").

• High-Stakes Decision Making: You should not use the AI as the sole arbiter for decisions affecting a person's legal status, employment eligibility, or creditworthiness.

6. CONTENT PROVENANCE

Where technically feasible, APEK embeds Content Credentials (C2PA) or imperceptible audio watermarks into generated media. This allows platforms and regulators to cryptographically verify that the audio was generated by AI, preventing the spread of disinformation.

7. REPORTING ISSUES

If you encounter an AI agent that violates these safety guidelines (e.g., generating hate speech or refusing to disclose it is an AI), please report the session ID immediately to security@apek.ai.

APEK CORPORATION MASTER TERMS OF SERVICE

Version: 2.0 Effective Date: January 1, 2025 Last Updated: January 1, 2025

1. AGREEMENT OVERVIEW

These Master Terms of Service ("Terms") constitute a binding contract between APEK Corporation (d/b/a Voice2Me.ai) ("APEK," "we," "us") and the entity or individual accepting these Terms ("Customer," "You").

By creating an account, accessing our API, or using our AI Voice Services, you agree to these Terms. If you are entering into this agreement on behalf of a company, you represent that you have the legal authority to bind that entity.

2. THE SERVICE

2.1. Scope: APEK provides an AI orchestration platform ("Voice2Me") that enables real-time, conversational voice agents via API and web interfaces.

2.2. Nature of AI: You acknowledge that the Service utilizes Large Language Models (LLMs) and Generative Voice AI. These systems are probabilistic. Outputs may occasionally be inaccurate, factually incorrect ("Hallucinations"), or socially inappropriate.

2.3. Beta Features: Services labeled "Beta," "Preview," or "Experimental" are provided "AS-IS" without warranties of any kind and may be discontinued at any time.

2.4. Third-Party Dependencies: The Service integrates with third-party providers (e.g., OpenAI, Twilio, Deepgram). APEK is not liable for service interruptions caused by outages at these upstream providers.

3. DATA OWNERSHIP & LICENSE

3.1. Customer Ownership: You retain full ownership of Your Content (e.g., audio inputs, transcripts, system prompts, and custom knowledge bases).

3.2. Limited License to APEK: You grant APEK a limited, worldwide, royalty-free license to process Your Content solely to provide, secure, and maintain the Service.

3.3. NO TRAINING GUARANTEE: APEK does not use Your Content to train, fine-tune, or improve our foundation models or third-party LLMs (e.g., OpenAI) without your explicit, written opt-in.

3.4. Aggregated Data: APEK may collect anonymous, aggregated metadata (e.g., "Average Call Duration," "Latency Metrics") that does not identify you or your end users, for platform optimization.

3.5. Feedback: If you provide suggestions or feedback regarding the Service, APEK is free to use such feedback without obligation or compensation to you.

4. ACCEPTABLE USE & RESTRICTIONS

You agree NOT to use the Service to:

4.1. Impersonate: Create "Deepfakes" or clone the voice of any person (including celebrities or politicians) without their explicit written consent.

4.2. Deceive: Deploy voice agents that fail to disclose they are AI when asked, or use the Service for "Caller ID Spoofing" or illegal robocalling in violation of TCPA/FCC rules.

4.3. Harm: Generate hate speech, harassment, sexually explicit content, or facilitate illegal acts.

4.4. Reverse Engineer: Attempt to discover the source code, model weights, or proprietary algorithms of the Service.

4.5. High Risk Use: Use the Service for critical life-safety decisions (e.g., 911 dispatch, autonomous medical diagnosis) where AI error could result in death or injury.

4.6. PROHIBITED "HIGH-RISK" REGULATORY USE CASES (STANDARD TIER) Unless you have executed a specific Enterprise Master Services Agreement (MSA) with APEK that explicitly authorizes such use, you are strictly prohibited from using the Service for "High-Risk AI Systems" as defined by the EU AI Act (Annex III) or similar regulations. Specifically, you may NOT use the Standard or Self-Service tiers for:

• (a) Employment & HR: Screening candidates, filtering resumes, or making automated hiring/firing decisions.

• (b) Financial Services: Assessing creditworthiness, loan eligibility, or insurance risk pricing.

• (c) Essential Services: Determining eligibility for public benefits, housing, or healthcare services.

• (d) Critical Infrastructure: Management of traffic, water, energy, or digital infrastructure where failure could endanger life.

• (e) Biometric Identification: Remote biometric identification or emotion recognition.

5. SECURITY & DATA PROTECTION

5.1. Standards: APEK implements enterprise-grade security controls (TLS 1.3, AES-256) aligned with SOC 2 and ISO 27001 standards.

5.2. Data Processing Addendum (DPA): To the extent APEK processes Personal Data on your behalf, the terms of the APEK Data Processing Addendum are hereby incorporated by reference.

5.3. Subprocessors: You acknowledge APEK utilizes trusted third-party providers (e.g., OpenAI, Deepgram, LiveKit, Supabase, Twilio) to deliver the Service.

6. FEES & PAYMENT

6.1. Usage-Based Billing: Services are billed based on consumption (e.g., minutes of audio, tokens generated) unless a fixed SaaS seat model is agreed upon in an Order Form.

6.2. Auto-Reload: If you use a prepaid credit balance, you authorize APEK to auto-reload your balance when it falls below a defined threshold to prevent service interruption.

6.3. Taxes: Fees are exclusive of taxes. You are responsible for all applicable sales, use, and VAT taxes.

6.4. Late Payment: Overdue amounts may accrue interest at 1.5% per month. APEK reserves the right to suspend access immediately for non-payment.

7. CONFIDENTIALITY

7.1. Definition: "Confidential Information" means non-public information disclosed by one party to the other (e.g., business plans, source code, customer data).

7.2. Obligations: The receiving party agrees to: (i) hold Confidential Information in strict confidence; (ii) not disclose it to third parties (except to authorized employees/contractors); and (iii) use it only to fulfill obligations under these Terms.

8. TERM & TERMINATION

8.1. Term: These Terms remain in effect until your account is terminated.

8.2. Termination for Cause: APEK may suspend or terminate your access immediately if: (i) you breach Section 4 (Acceptable Use); (ii) your account is in arrears; or (iii) compelled by law enforcement.

8.3. Effect of Termination: Upon termination, your right to use the Service ceases. You are responsible for exporting Your Content prior to termination.

9. DISCLAIMER OF WARRANTIES

THE SERVICE IS PROVIDED "AS IS." APEK DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, NON-INFRINGEMENT, AND FITNESS FOR A PARTICULAR PURPOSE. WE DO NOT WARRANT THAT THE AI WILL BE ERROR-FREE OR THAT VOICE AGENTS WILL NEVER "HALLUCINATE" INCORRECT INFORMATION.

10. LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY LAW: 10.1. Indirect Damages: APEK SHALL NOT BE LIABLE FOR LOST PROFITS, DATA LOSS, REPUTATIONAL HARM, OR CONSEQUENTIAL DAMAGES. 10.2. Liability Cap: APEK'S TOTAL LIABILITY FOR ALL CLAIMS RELATED TO THE SERVICE SHALL NOT EXCEED THE AMOUNT PAID BY YOU TO APEK IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM.

11. INDEMNIFICATION

You agree to indemnify, defend, and hold APEK harmless from claims arising out of: (i) Your use of the Service in violation of applicable law (e.g., wiretapping laws); (ii) Your Content infringing third-party intellectual property rights; or (iii) Your violation of these Terms.

12. MISCELLANEOUS

12.1. Publicity: APEK may use your name and logo in marketing materials to identify you as a customer, subject to your standard trademark usage guidelines.

12.2. Export Control: You represent that you are not located in a US-embargoed country and will not use the Service for prohibited end-uses (e.g., weapons development).

12.3. Severability: If any provision of these Terms is held invalid, the remaining provisions shall continue in full force.

13. DISPUTE RESOLUTION

13.1. Governing Law: These Terms are governed by the laws of the Commonwealth of Virginia, USA, without regard to conflict of law principles.

13.2. Arbitration: Any dispute arising out of these Terms shall be resolved via binding arbitration in Fairfax, Virginia, administered by the American Arbitration Association (AAA). You waive the right to a jury trial or class action.