PRIVACY POLICY

This Privacy Policy for Dialog Lab LLC (“Company,” “we,” “us,” or “our”) describes how and why we may access, collect, store, use, and/or share (“process”) your personal information when you use our mobile application Dialog Lab (the “App”), and any related services that link to this Privacy Policy (collectively, the “Services”).

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use the Services. If you have questions, contact us at spencer@joindialoglab.com.

Our data practices described here may evolve as the App develops. We will update this Privacy Policy to reflect material changes and, where required, notify users directly.

The Services are currently offered solely to residents of the United States. If you are not located in the United States, you are not permitted to use the Services.

2. SUMMARY OF KEY POINTS

• What personal information do we process? Account information you provide (such as name, email, username, state, and a personalized icon), conversation content you submit through the App, and information automatically collected through your use of the Services (such as device and usage data).
• Do we process sensitive personal information? Yes. We explicitly collect political opinions and topical viewpoints as part of the App's core functionality. We do not ask you to provide other sensitive personal information (such as data revealing racial or ethnic origin, religious beliefs, health, or sexual orientation), but this type of information may incidentally appear if you choose to include it in a conversation. See Section 3.
• Do other users see my information? Yes. Dialog Lab matches you with other users for conversations, and certain profile and conversation information is visible to your conversation partner(s) as part of that experience. See Section 6.
• Do we use your information to improve and train our AI models? Yes. Conversation data you submit may be used to evaluate, improve, and train or fine-tune the AI models underlying the App, and may also be used to generate shared conversation summaries. See Sections 5 and 6.
• Do we share your information with third parties? Yes, with the specific service providers listed in Section 7 who help us operate the App (including our AI provider(s), messaging infrastructure, form/invite processing, hosting/database, and analytics providers). We do not sell or share your personal information with third parties for their own marketing purposes.
• Can Dialog Lab staff see my conversations? Yes. See Section 8.
• What happens to my data if I delete my account? See Sections 9 and 10 for what is deleted, what may be retained, and how to request deletion.
• How do you exercise your rights? Contact us at spencer@joindialoglab.com, or submit a data subject access request as described in Section 16.

3. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide when you register for or use the Services, or otherwise contact us. This may include:

• names
• email addresses
• usernames and account credentials
• state (location within the United States)
• a personalized icon or avatar you select or are assigned
• political opinions, topical viewpoints, or affiliations you provide as part of using the App's core features
• conversation content and other input you submit through the App
• appreciation notes or similar feedback you send to other users
• matching preferences you set to help us pair you with conversation partners

All personal information you provide must be true, accurate, and current, and you must notify us of any changes.

Sensitive information

We explicitly collect political opinions and topical viewpoints as part of the App's core functionality, and by using the Services and providing this information, you consent to our processing of it as described in this Policy, including for the AI training and improvement purposes described in Section 5 and the second-party visibility described in Section 6.

We do not ask you to provide other categories of sensitive personal information (such as data revealing racial or ethnic origin, religious or philosophical beliefs, health information, or sexual orientation). However, because the App accepts open-ended conversational input, this type of information may incidentally appear if you choose to include it in a message. If you do, we process and retain it in the same manner as other conversation content described in this Policy, including for the AI training purposes described in Section 5, unless you choose not to include it. We also process account login credentials as sensitive personal information, only as necessary to operate the Services.

You have the right to limit our use of sensitive personal information — including political opinions — to purposes necessary to provide the Services, and we will honor requests to do so; contact us at spencer@joindialoglab.com to make such a request. See Section 16 for more on your rights regarding sensitive personal information.

The Services are currently offered solely to residents of the United States; see Section 1. Because the Services are not offered outside the United States, this Policy is written with reference to United States privacy law and does not address obligations under non-US frameworks such as the EU General Data Protection Regulation.

Information automatically collected

We automatically collect certain information when you use the Services, including device information, IP address, browser and operating system details, log and usage data (such as crash reports, error logs, feature usage, and session timestamps), and diagnostic and telemetry data. This information is used primarily to operate, secure, and improve the Services.

4. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for the following purposes:

• To create and manage your account, including authentication.
• To provide, operate, and deliver the Services you request, including matching you with conversation partners.
• To respond to inquiries and provide support, including by reviewing conversations as described in Section 8.
• To request and process feedback about the Services.
• To identify usage trends and evaluate and improve the Services, including troubleshooting and diagnosing issues.
• To train, fine-tune, evaluate, and otherwise improve the AI models that power the App, including future versions, using conversation data and other content you submit. See Section 5 for more detail.
• To generate shared conversation summaries visible to your conversation partner(s). See Section 6.
• To maintain the security and integrity of the Services and prevent fraud or abuse.
• To comply with legal obligations.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

As part of the Services, we offer features powered by artificial intelligence and machine learning (“AI Products”). This section describes two distinct uses of your data in connection with AI Products, which we want to be clear about separately. A third use — generating shared summaries visible to other users — is described in Section 6.

Serving your requests

We use third-party AI service providers (see Section 7) to process your inputs and generate responses within the App. Your input, output, and related personal information are shared with these providers under contractual terms restricting their use of your data to providing this service to us, consistent with Section 7 below.

Training and improving our own models

Separately from the above, we may use conversation data and other content you submit through the Services to train, fine-tune, evaluate, and otherwise improve the AI models underlying the App, including future versions. By using the Services, you consent to this use of your conversation data.

We do not currently apply any technical anonymization or de-identification process to conversation data before using it for this purpose. Conversation content is open-ended, and we cannot guarantee removal of any personal or sensitive personal information you choose to include in your messages before it is used for training. You may request that we limit the use of sensitive personal information you have submitted, as described in Section 3.

6. WHAT DO OTHER USERS SEE ABOUT YOU?

Dialog Lab's core purpose is connecting you with other users for conversations across differing viewpoints. This means that, unlike a typical app where your data is only visible to the Company, certain information about you is necessarily visible to the other user(s) you are matched with (each, a “ conversation partner”). This is a distinct privacy consideration from how we ourselves handle your data, and we want to be explicit about what is and isn't shared this way.

What we share with a conversation partner

When you are matched with a conversation partner, they can see:

• your username
• your state
• your personalized icon or avatar
• the topical viewpoints or political opinions you've associated with the conversation topic
• the full, unredacted transcript of your conversation with them, in real time and for as long as it remains accessible in the App
• any appreciation notes you send to or receive from them

We do not share your account signup email with a conversation partner. The one exception involving email addresses relates to invitations, not matching: if you invite another person to join Dialog Lab, the email address associated with your account may be visible to the person you invite (for example, so they know who invited them). If you would prefer your email not be shared this way, do not use the invite feature, or contact us at spencer@joindialoglab.com.

We also use your matching preferences (see Section 3) to determine who you are paired with, but we do not disclose another user's specific preferences to you or yours to them beyond what is inherent in being matched.

Shared conversation summaries

In addition to the live transcript, we may use the same AI systems described in Section 5 to generate a summary of a conversation — for example, to help each participant understand the other's perspective. These summaries are generated automatically and may inaccurately or incompletely represent what you actually said or believe. A summary of your side of a conversation may be shown to your conversation partner, and a summary of their side may be shown to you. We do not review every summary for accuracy before it is shown, and you should not treat a summary — yours or a partner's — as a verified or complete record of what was said. If you believe a summary misrepresents you, contact us at spencer@joindialoglab.com.

Why this matters

Because Dialog Lab pairs you with people you don't know, information you share in a conversation — including incidental personal details you choose to type, even if not explicitly requested by the App — may become known to that person in a way that is different from data we hold internally. Please use discretion about what you share in a conversation, in appreciation notes, or elsewhere in the App, since we cannot control what a conversation partner does with information you disclose to them directly.

7. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Separately from what other users see (Section 6), we work with the following categories of third-party service providers to operate the App. These providers process personal information on our behalf, under terms that restrict their use of it to providing services to us:

• AI service provider(s). We use third-party AI providers, including Anthropic and OpenRouter, to process your inputs, generate responses, and generate the conversation summaries described in Section 6.
• Stream (StreamChat). We use Stream to deliver and store in-app conversations and enable real-time messaging between matched users.
• Formspree. We use Formspree to process certain forms submitted through our website, such as signup or contact requests.
• Supabase. We use Supabase to host our application database, including account, matching, and conversation data.
• PostHog. We use PostHog to collect product analytics and usage data to help us understand how the Services are used and to identify issues.

We may also share 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.
• Legal Obligations. We may disclose information where required to comply with a legal obligation, protect our rights, or investigate potential violations of our Terms of Use. See Section 11 for more detail on law enforcement and legal requests specifically.

Disclosures to service providers under the restrictions described above are not considered a “sale” or “share” of personal information under applicable law. Apart from these situations and the second-party visibility described in Section 6, we have not sold or shared personal information with third parties for their own marketing or commercial purposes in the preceding twelve (12) months, and we do not intend to do so.

8. CAN DIALOG LAB STAFF SEE MY CONVERSATIONS?

Yes. Dialog Lab staff are able to view the content of conversations conducted through the App. We do this primarily to provide support, respond to reports of abuse or misconduct, moderate content that may violate our Terms of Use, and maintain the safety and integrity of the Services. As part of support and moderation, staff may respond to you directly inside a conversation. We do not use staff access to conversations to single out individual users outside of these purposes, and staff access is subject to the same use limitations described elsewhere in this Policy (including the training and sharing purposes described in Sections 5 through 7).

9. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your personal information only as long as necessary for the purposes described in this Privacy Policy, unless a longer period is required by law. Account information is generally retained for as long as you maintain an account with us. Conversation data used for the AI training purposes described in Section 5, and conversation summaries described in Section 6, may be retained separately from your account for as long as reasonably necessary to support model development and the conversation experience, including in de-identified or aggregated form where feasible — though, as noted in Section 5, we do not currently apply de-identification to conversation data used for training.

10. ACCOUNT AND DATA DELETION

You may delete your account and associated personal information at any time by deleting your account directly within the App. You may also request deletion by emailing spencer@joindialoglab.com; where we process a deletion request this way, we will verify your identity and process your request within a reasonable time.

We do not currently have a formal, fixed retention schedule for post-deletion data, and this section will be updated as that practice matures. As a general matter, upon a verified deletion request we will delete or de-identify your personal information from our active systems and backups within a reasonable period, except that:

• data already incorporated into AI model training (see Section 5) generally cannot be extracted or reversed out of a trained model once training has occurred, and we do not represent that deletion will remove your data's influence on already-trained models;
• information may be retained where necessary to comply with a legal obligation, resolve disputes, enforce our agreements, or address security or fraud concerns; and
• content you shared with a conversation partner (such as a transcript or appreciation note) may remain accessible to that conversation partner independent of your account, in the same way a message remains with its recipient after you delete your own account elsewhere.

See Section 11 for how account deletion affects our ability to respond to law enforcement or legal requests.

11. LAW ENFORCEMENT AND LEGAL REQUESTS

We may disclose personal information, including conversation content and the topical viewpoints or political opinions associated with your account, in response to a valid request from law enforcement or as otherwise required by law. This may include viewpoints or opinions you have shared through the App, since we process and, unless deleted, retain that information as described elsewhere in this Policy.

However, we can only produce data that we still have. If you have deleted your account and the associated data has in fact been deleted from our systems as described in Section 10, we will not have that data to produce — including in response to a subpoena or court order — because it no longer exists in our possession. Deletion is therefore one of the most effective ways to limit what could ever be disclosed about you in response to a future legal request, subject to the limitations described in Section 10 (for example, data already used to train an AI model, or content still held by a conversation partner, may not be affected by deleting your own account).

12. HOW DO WE KEEP YOUR INFORMATION SAFE?

We use reasonable technical and organizational security measures designed to protect your personal information. However, no method of transmission or storage is 100% secure, and we cannot guarantee that unauthorized third parties will never be able to defeat our security measures. Use of the Services is at your own risk.

13. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that we have collected personal information from a user under 18, we will deactivate the account and delete such data as reasonably possible. Contact us at spencer@joindialoglab.com if you become aware of any such data.

14. WHAT ARE YOUR PRIVACY RIGHTS?

You may review, update, or delete your account information at any time by contacting us at spencer@joindialoglab.com, or request account deletion specifically as described in Section 10. If we are relying on your consent to process your information, you may withdraw that consent at any time; this will not affect the lawfulness of processing before withdrawal. Upon request to terminate your account, we will deactivate or delete your information from our active systems, except where retention is necessary for legal, security, or fraud-prevention purposes, or as otherwise described in Section 10.

15. CONTROLS FOR DO-NOT-TRACK FEATURES

Most browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature. Because no uniform standard for recognizing DNT signals currently exists, we do not respond to DNT signals at this time. If a standard is adopted that we must follow, we will update this Privacy Policy accordingly.

16. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a resident of California or another state with a comprehensive privacy law, you may have the right to know, access, correct, delete, and obtain a copy of your personal information, opt out of certain processing, and not be discriminated against for exercising these rights. The table below shows categories of personal information we have collected in the past twelve months.

We have not sold or shared personal information with third parties for their own commercial purposes in the preceding twelve months and do not intend to in the future, other than disclosures to service providers as described in Section 7 and the second-party visibility described in Section 6.

Right to limit use of sensitive personal information

Some sensitive personal information may appear in conversation content you submit, as described in Section 3. You have the right to request that we limit our use of sensitive personal information to purposes necessary to provide the Services (such as security and fraud prevention), which would exclude use of that information for the AI training purposes described in Section 5. To make this request, contact us at spencer@joindialoglab.com identifying the account or conversation content at issue.

How to exercise your rights

To exercise these rights, contact us at spencer@joindialoglab.com, or submit a data subject access request through the process described in Section 18. We will verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf, subject to verification. If we decline to act on your request, you may appeal by emailing us; if your appeal is denied, you may contact your state attorney general.

California “Shine the Light” law

California Civil Code Section 1798.83 permits California residents to request, once a year and free of charge, information about categories of personal information we disclosed to third parties for direct marketing purposes in the prior calendar year. To make such a request, contact us using the details in Section 18.

17. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Policy from time to time. The updated version will be indicated by a revised “Last updated” date. If we make material changes, we will notify you by posting a notice or contacting you directly. We encourage you to review this Privacy Policy periodically.

18. HOW CAN YOU CONTACT US ABOUT THIS NOTICE, OR REVIEW, UPDATE, OR DELETE YOUR DATA?

If you have questions or comments about this Privacy Policy, or would like to review or update your personal information, contact us at:

Dialog Lab LLC
7609 Errol Dr
El Cerrito, CA 94530
United States
Phone: 954-632-4571
spencer@joindialoglab.com

To request deletion of your account and personal information specifically, email spencer@joindialoglab.com.

VERSION HISTORY

We revise this Privacy Policy from time to time as the Services evolve. Below is a summary of substantive changes and links to prior versions as they are superseded.

• v2 — September 16, 2026 (current). Updated the contracting entity to Dialog Lab LLC and removed beta-specific language throughout, reflecting the App's transition from a pre-release beta to a general release.
• v1 — July 20, 2026. Initial published Privacy Policy for the Dialog Lab beta, under the contracting entity Spencer Frank Consulting.