Cool Cloud — Privacy Policy

Effective date: September 2, 2026 · Last updated: September 3, 2026 Who we are: Cool Cloud LLC, a Wyoming limited liability company operated from Michigan, United States ("Cool Cloud", "we", "us") Contact: hello@coolcloud.com · Cool Cloud LLC, 61675 M 40, Paw Paw, MI 49079

The short version

• Cool is a personal AI assistant that runs on a server provisioned for you alone, in the United States by default. Your conversations, notes, connected accounts, and meeting transcripts live on that server, not in a shared database.
• Cool thinks and speaks with the help of third-party AI services. The text of your conversations is sent to a large-language-model provider to generate answers; your voice is streamed to a speech-recognition provider and converted to text in real time; Cool's spoken replies are produced by a speech-synthesis provider. Your voice is not recorded or stored by us.
• We do not train AI models on your data, and we do not sell it or use it for advertising. Cool does learn on your own server, from your own conversations, to serve you better. That learning stays on your server.
• Whose AI account is used matters. If your plan uses our commercial account with the model provider, the provider is contractually barred from training on your content. If you connect your own provider account, your own agreement and settings with that provider apply.
• When you connect Google Workspace or Microsoft 365, Cool reads what you ask it to read and keeps a small index of your mail headers on your server. Excerpts of what it reads are sent to the model provider to answer you.
• If you use Cool in a meeting, everyone in the room is transcribed. You are responsible for telling them. Recordings are not kept; transcripts are, on your server, until you delete them.
• We keep very little about you on coolcloud.com itself: your email, a password hash, your organisation's name, your subscription status, and login records. No analytics, no advertising trackers.
• Your server tells us whether it is up and which capabilities it is running, so we can operate it. It does not send us your content.
• Backups of your server are encrypted before they leave it. They are deleted with your server when your subscription ends.
• You can export your data and delete your account from your server's settings. Deletion of your coolcloud.com account is done on request.

The rest of this document is the detail.

1. Scope, roles, and definitions

This policy covers two things:

1. coolcloud.com and your Cool Cloud account — the website, registration, billing, and the dashboard from which you manage your subscription. For this, Cool Cloud LLC is the controller (in GDPR terms) or the business (in California terms).
2. Your Cool Instance — the dedicated server, software, databases, and backups we provision and operate for you, and the assistant ("Cool") that runs on it.

For the content inside your Instance — your conversations, files, connected-account data, meeting transcripts, the people you invite, and the people in your meetings — you (the customer) decide what goes in and what Cool does with it. You are the controller of that data and we act as your processor: we run the infrastructure, keep it updated and backed up, and do not read your content in the ordinary course of business. Data-processing terms for business customers are available on request.

We act as controller for a small set of Instance-related data that exists so we can operate the service: account and billing records, the operational status signals your Instance sends us, deployment records, and our own operational logs. These are described in Section 3.5.

"Instance", "Customer Data", "Connected Account", "Agent Actions", and "Users" have the meanings given in our Terms of Use. "Personal data" means information relating to an identified or identifiable person.

2. Where your data is

Your Instance is in the United States, while your Cool Cloud account record is in Germany and Cool Cloud LLC and most of our providers are in the United States. If you are in the EU, EEA, UK, or Switzerland, your personal data is transferred to the United States when your Instance processes it, when providers process it, and when we administer the service. Section 8 explains the safeguards.

3. What we collect, from where, and why

3.1 When you create and use a Cool Cloud account

We do not ask for your name, phone number, or postal address to create an account.

3.2 Billing

We use a third-party payment processor to take payment. When you subscribe you are redirected to the processor's hosted checkout. We never see or store your card number. We send the processor your email address, your organisation's name, and our internal identifiers for your account, and it returns to us a customer identifier, a subscription identifier, your plan, your billing status, and your billing-period dates, which we keep in order to run your subscription. Invoices are held by the processor and shown to you from there. The processor's own privacy policy governs its processing.

3.3 Visiting coolcloud.com

• No analytics, no advertising. We do not run analytics, tag managers, advertising pixels, session-recording tools, or any third-party analytics on coolcloud.com, and we set no marketing cookies.
• Strictly necessary cookies only. When you sign in we set session cookies so that you stay signed in across coolcloud.com and your Instance's pages. They are not used for tracking and expire within seven days. We also keep your sign-in token and interface preferences in your browser's local storage.
• Web fonts and other assets are served from our own servers. No third-party font, script, or image service receives your visit.
• Bot protection. On sign-up and sign-in forms we may use a bot-protection service, which receives your IP address and technical signals from your browser to decide whether you are a person.
• Server logs. Our servers write logs that can include IP addresses, requested URLs, and timestamps. They are rotated automatically and used only to operate and secure the site.
• Contacting us. If you email us, we keep the correspondence for as long as needed to deal with it and for our records.

3.4 Your Instance — the data Cool holds for you

Your Instance is yours. This section describes what Cool stores there so that you know what you are responsible for and what to expect when you export or delete.

People on your Instance. Each User has an account on your Instance: email, name, a password hash, a role, and settings. Accounts are created only by you (or your administrators) by invitation; there is no open sign-up on an Instance. Your Instance keeps a security audit log with IP addresses and, for some actions, browser user agents.

Conversations. What you and your Users type or say to Cool, and what Cool answers, is stored as text on your Instance so that Cool has context. Common personal identifiers such as email addresses, phone numbers, card numbers, and government ID numbers in what you type are masked before storage where our systems recognise them.

Voice. When you talk to Cool, your microphone audio is streamed through your Instance to our speech-recognition provider and converted to text in real time. Audio is not recorded or stored on your Instance or by us. Cool does not create voiceprints, does not identify who is speaking, and does not use any biometric technique. Transcripts of voice sessions are stored on your Instance (see "Learning", Section 5).

Connected Accounts. If you connect Google Workspace or Microsoft 365, Cool stores the access credentials the provider issues, encrypted, on your Instance, along with the account's email address, display name, and the permissions you granted. Section 6 describes what Cool reads and keeps.

Meetings. If you ask Cool to listen to a meeting, it transcribes everyone speaking in the room into text on your Instance, drafts notes and follow-ups, and files a report and the full transcript into your Instance's archive. Section 7 explains this in detail, including your responsibilities to other people in the room.

Shopping. If you ask Cool to search a merchant's catalogue or build a cart, your search terms and cart contents are sent to that merchant. Cool sends no name, email, address, or payment details, and cannot complete a purchase (Section 6.4).

Documents and notes. Files, reports, and notes you or Cool add to your Instance's archive are stored on your Instance. The archive keeps history: entries can be superseded but not silently rewritten.

Record of what Cool did. Your Instance keeps a record of the consequential actions Cool took for you (for example sending an email or changing a calendar event): who asked, what was done, and when. For 90 days it also keeps a copy of the affected content before and after the change so that the action can be undone; after 90 days those copies are erased and only the summary record remains.

Coding sessions (where enabled on your plan). When Cool does development work for you, the prompts, the code changes it made, and session logs are stored on your Instance so that you can review, reuse, and undo them.

Usage and cost records. Your Instance records how much AI and speech usage each User generates (for example tokens and seconds of audio, and their cost) so that budgets and, where applicable, metered billing can work. These records contain counts and amounts, not the content of conversations.

Push notifications. If you install a mobile client and enable notifications, your device's push token is stored on your Instance, and notification text is delivered through a third-party push-notification service.

3.5 What your Instance sends to us

Your Instance is single-tenant, but we operate it, so it sends us a small set of operational signals: whether it is up, its software version, which capabilities are running, whether the last configuration we sent it was applied, and, on failure, a short excerpt of the installation log. These signals never include your conversations, files, or connected-account data. Where error reporting is enabled for an Instance, error reports contain technical context only, with request contents and personal identifiers suppressed at source.

3.6 Backups

Your Instance takes regular encrypted backups of its databases, configuration, and certificates and copies them to cloud object storage in a container created for your Instance alone, where they are kept for up to 30 days. Backups are encrypted on your Instance before they leave it. They exist so that your Instance can be restored after a failure; they are deleted, and the storage container destroyed, when your Instance is decommissioned (see the Terms, Section 12).

4. Purposes and legal bases

We process personal data for the following purposes. For customers and Users in the EU/EEA and UK, the legal basis is shown.

We do not process special categories of personal data on purpose. If you put such data into Cool (for example, health details in a conversation), you are responsible for having a lawful basis to do so.

We do not sell personal data, we do not share it for cross-context behavioural advertising, and we do not use it to train AI models.

5. AI providers, learning, and training — read this section

5.1 What leaves your Instance, and to whom

Cool does not run its own large language model. To answer you it sends text to a model provider and receives text back; to hear and speak it uses speech providers.

Where Cool can read a web page for you (Section 6.5), the page's content enters the model provider's processing like any other tool result.

5.2 Whose account the model runs under, and why it matters

Cool can reach the model provider in two ways. Your plan description tells you which applies.

Under Cool Cloud's commercial account. Requests are governed by our commercial agreement with the provider, under which the provider may not train models on your content, and under which you retain all rights to your inputs and own the outputs. The provider retains inputs and outputs for a limited period for abuse monitoring under its commercial data-retention terms.

Under your own provider account. If you connect your own account or API key with the model provider, requests run under your agreement with that provider and under your account's settings. In particular, if you connect a consumer subscription, the provider's consumer privacy terms apply, under which the provider may use your inputs and outputs to train its models unless you opt out in your account settings there, and may retain them for the periods stated in its own policy. We cannot change those settings for you. Check them. When you connect an account through Cool's sign-in flow, the permissions Cool requests include running inference, reading your profile, and creating API keys in your provider organisation; Cool stores the resulting credentials encrypted on your Instance and refreshes them automatically. Disconnecting in Cool deletes them from your Instance but does not revoke the authorisation on the provider's side — do that in your provider account if you want it fully withdrawn.

On an Instance with several Users, requests that are not tied to a specific User's own connected account run under the Instance's default account — the account connected by an administrator, or Cool Cloud's, depending on your plan. Administrators should tell their Users which applies.

5.3 Cool learns on your Instance — and what that means

Cool improves its behaviour for you by learning from your own use. Concretely, your Instance:

• stores transcripts of voice sessions and conversations so Cool can recall context and recognise how you phrase requests;
• turns explicit corrections you give ("no, I meant X") into rules that Cool applies later;
• counts which capabilities each User uses so Cool can route requests better.

This learning happens only on your Instance, is used only for your Instance, is never pooled across customers, and is never used to train or fine-tune a foundation model. Each User can turn voice-session learning off for themselves under Settings → Voice → Privacy → "Voice session learning", and your Instance administrator can turn it off for the whole Instance.

5.4 Coding sessions

Where your plan includes Cool Development, completed coding sessions are stored on your Instance with their prompts, resulting code changes, and logs so that you can review, reuse, and undo them. Customer Instances run a build of our platform that does not collect training data and does not report usage to a central registry. Nothing from your coding sessions is exported to us or to any model provider for training.

5.5 Our providers and training

• Model provider: under our commercial account, contractually barred from training on your content (Section 5.2). Under your own consumer account, your settings govern.
• Speech and text-analysis providers: we do not permit them to use your content to train their models. Where a provider's standard terms would allow it, we have opted out or excluded it by agreement.

5.6 The agent's conduct

Cool is an AI system, not a person. When Cool contacts a website, service, or business on your behalf, it says so and says who it is acting for. This is our practice everywhere and, for customers in the EU, our compliance with Article 50 of the EU AI Act. Cool acts only on a person's instruction, in the moment; it does not crawl, index, or fetch on its own initiative; it does not solve CAPTCHAs, disguise itself, or log in to third-party sites as you; it builds carts but never pays. Our full agent policy, written for the operators of the sites Cool visits, is at coolcloud.com/agent and is part of our commitments to you.

Cool makes no decisions about you that have legal or similarly significant effects without a human in the loop. Everything Cool proposes to send or change is shown to you first, and you can undo most actions.

6. Connected accounts, commerce, and the web

6.1 Google Workspace

When you connect Google, Cool asks for the permissions shown on Google's consent screen. At launch these let Cool send email on your behalf and manage labels, read and write your calendar events and availability, read and write your contacts, and access files you open with Cool. Reading your inbox requires additional restricted permissions that are available only when your organisation runs Cool under its own Google application. You can revoke access at any time in Cool's settings or at myaccount.google.com/permissions.

What Cool reads and keeps. Cool reads a message, event, contact, or file when you ask it to, in memory, and passes the parts needed to answer you (for example the sender, subject, and a short gist of an email) to the model provider. Message bodies are not stored on your Instance. Separately, Cool maintains a small index of your recent mail on your Instance: subject lines, short preview snippets, labels, attachment names, the addresses and names of the people on each message, and a short AI-generated summary of each thread. Calendar data is not indexed. This index lets Cool find and reference conversations quickly.

Disconnecting revokes Cool's access at Google and deletes the stored credentials, the account record, and the mail index from your Instance. Data already copied into your conversations stays until you delete it.

Google's rules. Cool's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. In plain terms: we use Google user data only to provide the features you asked for, we do not sell it, we do not use it for advertising, and humans at Cool Cloud do not read it except with your consent, for security, or as the law requires. Google user data is transferred to our AI model provider only as needed to generate the answer or action you requested, and is not used to train generalised AI or machine-learning models.

6.2 Microsoft 365

When you connect Microsoft 365, Cool asks for the permissions shown on Microsoft's consent screen: read and write mail, send mail, read and write calendars, read and write contacts, read your files and files shared with you, read your organisation's document sites, read your profile, and keep access when you are not signed in. These are broader than the Google permissions in Section 6.1 because Microsoft does not offer a narrower send-only mail permission that meets Cool's needs. Your organisation's Microsoft administrator may need to approve the connection. Everything in Section 6.1 about what Cool reads, what it keeps in the mail index, what reaches the model provider, and what disconnecting deletes applies to Microsoft 365 in the same way. Microsoft's terms and the Microsoft Privacy Statement govern Microsoft's side, and you can also revoke Cool's access at myapps.microsoft.com.

6.3 Emails and actions Cool takes for you

When Cool sends an email or creates a calendar event for you, it does so from your connected account, under your name. For meeting follow-up emails, Cool holds the message for a short grace period during which you can cancel it, and keeps the message body in your Instance's action record for 90 days so that you can see exactly what was sent.

6.4 Shopping through Cool

When you ask Cool to search a merchant's catalogue or build a cart, Cool sends the merchant your search terms, the products and quantities you choose, and the cart identifier. Cool never sends the merchant your name, email, address, or payment details, and cannot complete a purchase. Checkout happens in your own session with the merchant, under the merchant's privacy policy.

Where a merchant supports an agent-commerce interface that requires it, the merchant may also receive the IP address and browser identifier of the person shopping, so that the merchant can detect fraud. When Cool builds such a cart for you, it forwards yours and records the disclosure in your Instance's action record.

6.5 Reading the web (as we introduce it)

Where Cool can read a web page for you, it does so only when you ask, one page per request, through a fetching service that identifies itself to websites as an automated assistant and honours websites' robots.txt rules. The page's content is used to answer you and is shown to you with its source and the time it was retrieved. Nothing Cool reads on your behalf is used by Cool Cloud to train any model, and the same provider commitments as Section 5.2 apply to the fetched content. Cool does not crawl, does not solve CAPTCHAs, and does not log in to sites for you.

7. Meetings, and people who are not Cool users

When a host asks Cool to listen to a meeting:

• Everyone speaking in the room is transcribed. Cool does not know or record who said what; it stores the words with timestamps and no speaker labels. Common personal identifiers our systems recognise are masked before storage.
• Audio is not recorded. It is streamed to the speech-recognition provider and discarded.
• The transcript and Cool's notes are stored on the host's Instance and, at the end of the meeting, filed into the Instance's archive as a report and a full transcript. Segments of the transcript are sent to the model provider during the meeting to produce notes and after it to produce the report.
• The host is responsible for telling everyone present and for obtaining any consent the law where they are requires. Cool shows a visible "listening" indicator on the host's screen, and the host can ask Cool to introduce itself to the room. Any participant can say "Cool, stop" to end listening.
• Deleting a meeting removes the transcript and notes from the Instance's working store immediately and supersedes the archived copies with empty versions so that they no longer appear in search or recall. Because the archive keeps history, a record that a meeting took place remains.

If you were in a meeting where Cool was used and you are not a Cool user, the host's organisation controls that transcript. Ask the host to delete it, or write to us at hello@coolcloud.com and we will pass your request to the host.

8. International transfers

Your Instance is in the United States by default. Your Cool Cloud account record is in Germany. Cool Cloud LLC is in the United States, and our AI, speech, payment, hosting, and storage providers process data in the United States. If you are in the EU/EEA, UK, or Switzerland, personal data therefore leaves that area when your Instance and those providers process it and when we administer the service.

For those transfers we rely on: the EU-U.S. Data Privacy Framework where the recipient is certified; otherwise the European Commission's Standard Contractual Clauses — incorporated in our agreements with providers, and, for the Customer Data on your Instance, in our data-processing terms with you, under which you (as controller in the EU) transfer to us (as processor in the US); plus the UK Addendum and Swiss equivalents where applicable.

Backups are stored in cloud object storage in a container dedicated to your Instance; the storage provider chooses the physical location, which may be outside your country.

9. How long we keep data

When your subscription ends, the Terms of Use (Section 12) describe the export window, the destruction of your Instance, and the deletion of its backups.

10. Security, in honest terms

• In transit: all connections to coolcloud.com and to your Instance use TLS. Connections from your Instance to our providers use TLS.
• Your Instance's secrets are generated on your Instance. Its database credentials, signing keys, and the key that encrypts its backups are created on your server during setup and are not held by us. We keep no standing login to your Instance; we control the server through our hosting provider's management interface (Section 5.2 of the Terms).
• Credentials you give Cool (model-provider, Google, Microsoft, and speech-provider credentials) are encrypted at rest on your Instance.
• Backups are encrypted on your Instance before they are uploaded.
• Databases on your Instance are stored on the server's disk; we rely on the hosting provider's platform-level disk encryption and do not add a second layer of encryption to the live database.
• Network: your Instance accepts inbound connections only on the ports the service needs; its internal services are not reachable from the internet.
• Personal-identifier masking is applied on several storage and disclosure paths but is pattern-based and not perfect; do not rely on it as a substitute for care about what you share.
• Access by us to your Instance's content is exceptional and is described in the Terms, Section 5.2.
• Passwords are stored as salted hashes. Multi-factor authentication is not yet available; use a strong, unique password.
• If a breach affects your personal data, we will notify the competent supervisory authority where the law requires (within 72 hours under GDPR) and notify you without undue delay with what we know and what you can do.

No security is perfect. Sections 17 and 18 of the Terms set out the limits of our responsibility.

11. Your rights and how to exercise them

11.1 Rights

Depending on where you live you may have the right to access your personal data, correct it, delete it, export it in a portable form, restrict or object to some processing, and withdraw consent where consent is the basis. You also have the right to complain to a supervisory authority; in the EU, to the authority in your member state; in the UK, to the ICO. We do not make automated decisions with legal or similarly significant effects about you.

11.2 For your coolcloud.com account

Email hello@coolcloud.com from the address on your account. We will verify it is you and respond within 30 days (GDPR) or 45 days (California). Account deletion is completed by us on request; a self-service control is being added. Deleting your account requires your subscription to be cancelled and your Instance decommissioned first (Terms, Section 12). We keep billing records the law requires us to keep.

11.3 For data on your Instance

• Export: every User can download their own data — account details, settings, conversations, voice-session transcripts and learned corrections, notifications, devices, connected-account details (never credentials), invitations sent, and recent security-log entries — from Settings → Privacy → Download my data on their Instance. The action record is not in the download today; ask us for it.
• Deletion: every User can delete their own account and data from Settings → Account → "Delete my account" on their Instance (or ask their administrator, or email us). Erasure removes the User's account details, conversations, voice-session transcripts and learned corrections, settings, devices, notifications, cost records, security-log entries, stored credentials, connected-account credentials and mail index, invitations, and the meetings the User hosted, and erases the content copies in the action record. It does not remove the summary record of actions (an internal id, an action, a time), the archived copies of filed meeting reports (which are superseded, not deleted; ask us if a filed meeting must be retracted), or backups, which age out within 30 days.
• Correction: Users can edit their own profile and settings; ask an administrator for anything else.
• Because you (the customer) control your Instance, if one of your Users or a third party asks us to exercise a right over data on your Instance, we will normally refer them to you and help you respond.

11.4 EU and UK representation

Cool Cloud is offered from the United States and we have not appointed a representative in the European Union or the United Kingdom. If you are in the EU, EEA, UK, or Switzerland and wish to exercise your rights, write to hello@coolcloud.com.

12. California privacy notice

This section applies to California residents and supplements the rest of this policy.

Categories of personal information we have collected in the last 12 months, and their sources and purposes are described in Section 3. In CCPA terms they are: identifiers (email, account ids, IP address); commercial information (subscription and billing status); internet or network activity (session records, logs); audio and electronic information (voice, streamed to our speech-recognition provider and not retained; conversation text); geolocation data (coarse — the city you set for weather, if any); professional information (your organisation); and inferences (the behavioural rules Cool learns on your Instance from your corrections). Sensitive personal information: account log-in credentials (stored as hashes), and, if you put them into conversations, any sensitive information you choose to share. We use sensitive personal information only to provide the service you asked for.

Disclosure for a business purpose: we disclose personal information to the categories of service providers listed in Section 13 to provide the service. We do not sell personal information and we do not share it for cross-context behavioural advertising, and have not in the preceding 12 months. We do not knowingly collect personal information of consumers under 16. Because we do not sell or share, there is no opt-out to exercise, and we honour Global Privacy Control signals by default. Do Not Sell or Share My Personal Information: not applicable — we do not.

Your rights: to know what we collect and disclose, to delete, to correct, to limit the use of sensitive personal information, and not to be discriminated against for exercising them. Exercise them by emailing hello@coolcloud.com. We verify requests by confirming control of the account email; an authorised agent must provide signed permission. We respond within 45 days, extendable once by 45 days with notice.

Retention is described in Section 9. Notice of financial incentive: none. Shine the Light: we do not disclose personal information to third parties for their direct marketing.

13. Our service providers

Every supporting service that runs on your Instance is a component on your own server and is not a third party. The following categories of external providers process personal data for us or for you through Cool:

A named list of our sub-processors, with their locations and roles, is available to customers on request at hello@coolcloud.com and forms part of our data-processing terms. We will update that list before adding a provider that processes Customer Data and, for business customers with a data-processing agreement, give notice as that agreement provides.

14. Children

The Service is for adults. We do not knowingly collect personal data from anyone under 18, and you may not create an account if you are under 18. If you believe a child has provided us personal data, write to hello@coolcloud.com and we will delete it.

15. Public share links

An Instance's owner can publish a report from the archive at a link anyone can open. Anyone with the link can read that report and, if the owner allowed it, talk to Cool about it by voice without an account. A visitor's speech is processed by the same speech and model providers as any voice session and is not stored; notes a visitor leaves are stored on the Instance for the owner to review. Visitors are not identified. Owners can pause or permanently revoke a link at any time.

16. Changes to this policy

We will post changes here with a new "last updated" date. For material changes we will give account holders at least 30 days' notice by email and in the dashboard. Continued use after the effective date means you accept the change.

17. Contact

Cool Cloud LLC · 61675 M 40, Paw Paw, MI 49079, United States (a Wyoming limited liability company) Privacy questions and requests: hello@coolcloud.com EU / UK representative: none appointed (see Section 11.4) Agent policy (for website operators): coolcloud.com/agent

Effective September 2, 2026 · last updated September 3, 2026. Previous version: September 2, 2026 (named individual providers; superseded by this version, which describes providers by category).