Your Privacy Matters

This Privacy Policy explains how Front Office Solutions LLC, DBA MagellanCRM ("Magellan", "we", "us", "our") collects, uses, and shares personal information when you use our website(s), mobile application(s), and related services (collectively, the "Service").

This Privacy Policy retains the protections and coverage of the prior MagellanCRM web privacy policy and adds additional disclosures needed for our voice-first AI mobile app and App Store compliance.

Interpretation

Words with capital letters have specific meanings defined below. These definitions apply whether the terms are singular or plural.

Definitions

• You: The individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
• Company (referred to as either "the Company", "We", "Us" or "Our"): Refers to Front Office Solutions LLC, DBA MagellanCRM, located at 115 Cherokee Way, Boulder, CO 80303.
• Account: A unique account created for you to access our services or parts of them (if applicable).
• Client: Any individual or entity with an approved account.
• Website: MagellanCRM, accessible at https://magellancrm.com (or other Company-controlled domains).
• App: Our mobile application(s), including our iOS app.
• Service: Refers to the App, Website, platform, and all related services provided by the Company.
• Contact: Refers to your website visitors or leads who are identified or reasonably identifiable using personal information collected by you.
• Consumer: As defined by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), means a natural person who is a California resident.
• Country: United States (primary operations in Colorado).
• Cookies: Small files placed on your computer, mobile device, or any other device by a website, containing details of your browsing history among other uses.
• Usage Data: Information automatically collected from your use of the Service, such as page visits, IP address, device identifiers, and app diagnostics.
• Personal Data: Any information that relates to an identified or identifiable individual.
• Voice Data: Raw audio captured from your device microphone and audio streams transmitted for processing, plus associated metadata (such as timestamps).
• Transcripts: Text created from Voice Data (speech-to-text) and any edits you make.
• AI Interaction Data: Content you provide or generate through AI-assisted features, including Voice Data, Transcripts, typed commands, and resulting drafts.

Front Office Solutions LLC considers customer privacy of the utmost importance. We will never sell your phone number, email, or any other personal information to unrelated third parties as described in this Privacy Policy.

We may collect the following types of information:

• Personal Identifiers: Name, email address, phone number, company information.
• Account Credentials: Login information, password hashes (where applicable).
• Usage Data: Pages visited, device information, diagnostics, and location data (as provided by your browser or device).
• Marketing Preferences: Opt-ins/opt-outs for email, SMS, or push notifications.
• AI Interaction Data: When you use our AI-powered features (including voice agents), we may process the content you submit for service delivery and improvement.
• Payment and Billing Data: If you subscribe to paid services, we collect payment-related information via secure third-party processors.

We use your information for purposes including:

• Delivering and maintaining the Service.
• Communicating with you about your account, updates, and customer support.
• Improving and developing new features and functionality (including improving the performance, reliability, and safety of AI features), including AI-driven insights.
• Compliance with applicable laws and regulations.
• Security, fraud prevention, and debugging.
• Personalized marketing (only where consented).

4.1 How voice + AI processing works (plain language)

When you use voice or AI features, the flow generally works like this:

• You record Voice Data in the App.
• Voice Data and/or Transcripts may be transmitted to speech and AI service providers to produce Transcripts and understand intent.
• The Service generates drafts (for example, a CRM note, task, or a message draft).
• Human-in-the-loop safeguard: drafts are shown to you for review and editing, and you (a human user) must take the final action (for example, tapping "Send").

4.2 Not used for biometric identification

We do not use Voice Data for biometric identification (for example, voiceprint identification or authentication). Voice is used for functional transcription and command processing.

We do not sell your personal information. We may share information as follows:

• Service Providers: With trusted vendors who process data on our behalf (hosting, analytics/diagnostics, payment processing, support).
• Third-Party AI and Speech Providers: As described in Section 6 below.
• Legal Requirements: Where required by law, regulation, legal process, or enforceable governmental request.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred with notice provided.

All third-party partners are required to follow data protection standards equivalent to this Privacy Policy.

6.1 Providers we may share data with

Depending on your use of features, we may share limited data with:

• Amazon Web Services (AWS): hosting, storage, and core infrastructure.
• Amazon Bedrock: AI/LLM inference for intent analysis and drafting.
• Deepgram: speech-to-text and/or text-to-speech.
• LiveKit: real-time audio transport.
• GoHighLevel (GHL): CRM API integration to read/write CRM Data you authorize.

6.2 Explicit permission before sharing with third-party AI

Before you first use AI features that share content with third-party AI providers, we will provide an in-app disclosure and request your explicit permission before sharing your content (including Voice Data and/or Transcripts) with third-party AI providers.

6.3 Not used to train models

We do not use your Voice Data, Transcripts, or CRM Data to train our own AI models.

For third-party AI providers, we contractually and/or technically configure providers so that content we send for processing is not used to train their foundation models, to the extent offered by the provider and applicable to the service configuration.

7.1 Website cookies (including advertising)

We use session and persistent cookies and similar technologies on our Website for essential services, functionality, analytics, and advertising. These may include cookies set by us and by third-party partners (such as analytics and advertising providers) subject to their own policies.

You can control or delete cookies through your browser settings and, where required, we will request your consent for certain cookie categories.

7.2 Mobile app analytics (no ad tracking)

The App may use diagnostics and basic analytics to understand performance and usage. We do not use the App to track you across other companies' apps and websites for targeted advertising.

You have the right to opt out of receiving text messages from us at any time. Reply "STOP" to any text message or contact our support team to be removed from SMS lists.

By providing your phone number, email address, or other contact details and opting in to receive communications, you consent to the collection and use of your Personal Information as described in this policy. We will clearly describe the types of messages you will receive and provide opt-out instructions.

We work with trusted third-party services (e.g., marketing tools, analytics platforms, cloud AI providers) to deliver a customized experience. These third parties may collect personally identifiable information under their own privacy policies. You can opt out of third-party data collection where applicable using browser settings, industry opt-out tools, or by contacting us.

Depending on where you live, you may have the following rights:

U.S. State Privacy Rights

• California/CPRA: Right to know, delete, correct, and opt out of the sale/sharing of Personal Data.
• Colorado Privacy Act: Right to access, delete, correct, opt out of targeted advertising, and data portability.
• Virginia/Connecticut Privacy Laws: Similar rights to access, delete, correct, opt out of targeted ads and profiling.

EU/EEA (GDPR) Rights

If you are in the EU/EEA, you may have rights under the GDPR, including:

• Accessing and correcting your data.
• Requesting deletion of your data.
• Restricting or objecting to processing.
• Data portability.
• Lodging a complaint with your local supervisory authority.

To exercise your rights, contact us at privacy@magellancrm.com. We will verify your identity before processing requests.

We retain Personal Data only as long as necessary to provide services, comply with legal obligations, resolve disputes, and enforce agreements.

• Raw audio (Voice Data): retained for up to 30 days for service quality, troubleshooting, and support, then deleted or de-identified unless a longer period is required by law or needed for security investigations.
• Transcripts and AI outputs: retained as needed to provide the Service and to populate your requested CRM entries, unless you delete them or request deletion.

Data may be analyzed to improve the Service (including AI feature performance, safety, and usability). Data collected for AI model improvement may be retained in anonymized or aggregated form.

13.1 Request deletion

You can request deletion of Personal Data associated with your use of the Service:

• In the App: go to Settings → Privacy → Request Data Deletion (or similar wording), and follow the prompts; and/or
• By email: contact us at privacy@magellancrm.com.

13.2 Revoking consent

You can revoke consent for certain processing by stopping use of the relevant feature, disabling microphone access in iOS settings, and/or disconnecting third-party integrations (where available). Some processing may be required to provide core functionality you request.

We use reasonable administrative, technical, and physical safeguards to protect your Personal Data against unauthorized access, loss, misuse, or disclosure. However, no transmission over the Internet or method of storage is 100% secure.

Where our platform uses AI features or automated decision-making (e.g., lead scoring, automated messaging), we disclose it within the Service. You have the right to opt out of profiling for marketing or sales purposes in accordance with applicable laws.

Our Services are not directed to children under 13, and we do not knowingly collect Personal Data from children. If we become aware that a child under 13 has provided Personal Data, we will delete it promptly.

We may update our Privacy Policy from time to time. Any changes will be posted with an updated "Last Updated" date. If changes are material, we will provide notice through email or the Service.