Privacy Policy

Latest Update: 6 August, 2026
This document is also available in German: Datenschutzerklärung

‍Protecting your privacy

Your privacy matters to us as much as it does to you. We take great care in handling the personal data of Good Systems’s users safely and responsibly.


‍Our privacy principles:

  • We never sell or rent your data content to third parties.
  • We use limited, anonymized data to improve our services and meet legal obligations.

‍Data sharing policy:

We only share your data:

  • when you explicitly give us permission to do so and with the third parties specifically identified in this policy; or
  • to protect the rights, property, or safety of us, our customers, or others.


What we collect:

  • Basic personal data (name, email, country) when you register.
  • Anonymous statistical or user generated data (crash frequency, feature usage, user feedback) to enhance the app experience.     
  • Depending on your use of our services, we may collect additional data as further set out in Section 1 below.

If data is shared with third parties, we ensure they are bound by data protection agreements or confidentiality obligations.


Good Systems, Inc. and its affiliates (the "Company", "we", "our" or "us") are committed to protecting and respecting your privacy. We are a company incorporated in Delaware with our registered office at 251 Little Falls Drive, Wilmington, Delaware 19808, County of New Castle, United States. This privacy policy (or "Policy") sets out the basis on which any data and information the Company collects from you will be processed by the Company during your interactions with us, including through your use of the Good Systems services, which includes the Good Systems application and any other product or services that links to this Policy), as well as all functionality that Good Systems makes available and any other product or services that links to this Policy (collectively, the "Services").


Through the use of the Services, Good Systems’s users access virtual meeting recording and transcription tools, allowing them to send meeting invites to others and record meeting content. In order to do so, we collect and process the personal data of Good Systems’s users, including the names, email addresses, login details, meeting records, meeting inputs, and transcribed content (only where instructed to do so) of users.


Please note that Good Systems uses the Goodnotes Account ("GNA") infrastructure, which is operated by Goodnotes Limited (a separate legal entity), for user authentication and account management purposes. Authentication and registration data associated with your GNA account is held by Goodnotes Limited. Goodnotes Limited will also process your registration date and T&C acceptance date. Meeting recordings, transcripts, notes, summaries and other Good Systems product data are processed separately by Good Systems and are not shared with Goodnotes Limited. The respective roles of Good Systems, Inc.      and Goodnotes Limited in relation to the processing of your personal data are described further in this Policy.


We provide the Services to: (i) individual customers who access the Services via the Good Systems application ("End Users"); and (ii) individuals who visit or communicate with us via the Good Systems website and our Good Systems Help Centre ("Website Users"). We have outlined in this Policy which sections of the Policy shall apply to End Users and Website Users respectively.


Please note that we may provide you with additional privacy information which relates to our collection and processing of your data in the context of your use of specific Services. Any such additional privacy information should be read in conjunction with this Policy.

  1. 1. What kind of data is being collected and how do we collect it?

    We may collect and process "Personal Data" (which is defined as any data that identifies or can be used to identify you) about you when you visit, install, download, access, register for or use our Services, or contact us in relation to the Services. The nature of the Personal Data that we may process will be determined by how you are using our Services. We will only use your Personal Data as set out below and always in accordance with applicable data protection laws, including but not limited to the European Union's General Data Protection Regulation 2016/679 (the "EU GDPR"), together with the version of the EU GDPR which is incorporated into the domestic law of the United Kingdom (the "UK GDPR") (the EU GDPR and the UK GDPR are collectively referred to as the "GDPR"). We are a US-based entity, but are subject to both UK and EU data protection law, due to the extra-territorial application of the UK GDPR and the EU GDPR. We are also subject to the Laws of California, including the CCPA (please see the CCPA Annex at the end of this privacy policy). To the extent that we are subject to the data protection laws of any other jurisdictions, we may publish supplementary privacy policies to the extent required by applicable law.
    We do not collect special categories of Personal Data (as defined in the GDPR), which means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, trade union membership, genetic and biometric data, or data concerning health, sex life or sexual orientation. We do not expect our users to share or provide us with special categories of Personal Data.
    1. End User Data
      1. Information that you provide to us:
        Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below in relation to you to enable us to provide our Services to you. To the extent applicable, such information may include:
        • basic Personal Data about you (personal identifiers and contact information such as first name, family name, email address, country and your language);
        • for certain support requests and issues, we may ask you to export and send us diagnostic data of your Good Systems application which includes information necessary to diagnose and resolve issues you might experience with our Services including details of your meeting history, notes and summaries;
        • any information that you choose to share through the Services which may be considered Personal Data, including any information that you upload containing details about you. But please note that we will not:
          • access or collect data (including any Personal Data) from your meeting recordings, transcripts, notes or summaries without your consent; or
          • if you make a purchase, your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by third party payment processors with which we work. We may also collect some limited information, such as your postal code and details of your transaction history.
        Good Systems Services are not intended for use by covered entities (as such term is defined in the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") in the United States) for the transmission of Protected Health Information (as defined by HIPAA. 45 C.F.R. §160.103), nor intended for the transmission of sensitive personal information (as defined by the California Consumer Privacy Act, Cal. Civ. Code §1798.140(ae), as amended) such as payment card or financial information (except when making a purchase), so please do not share this information with us.
      2. Information that we automatically collect or generate about you:
        When you use our Services, we automatically receive and collect information about you and your device. The information we automatically collect includes:
        • any information regarding the Services accessed and/or used by you and our interactions with you;
        • a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the Services which we have provided to you;
        • usage data when you visit or otherwise use the Services, including details of the location of the device used and IP address;
        • marketing and communications data collected regarding marketing, promotions and communicating new features;
        • activity data relating to your usage of the Services, which reveal your preferences, interests, or manner of use of the Services and the times of use, e.g., IP address, device type, other unique device identification, data usage, time zone settings, etc.; and
        • additional diagnostic data, including hardware information and model performance data, in order to monitor and improve the Services.
        Where possible, we anonymise statistical data about End Users and how they interact with the Services by using unique identifiers which are linked to user accounts but do not contain any Personal Data.
        Please note that Good Systems accesses only your device's microphone and speaker audio stream; it does not access, collect or process any data (including participant lists, chat messages or platform metadata) from third-party communication platforms (such as Microsoft Teams, Zoom or Google Meet) that you may use in connection with a meeting.
      3. Information we obtain from other sources: We sometimes collect Personal Data provided to us by third parties, service providers, agencies or other publicly available sources where applicable. This includes (by way of non-exhaustive list):
        • which page you are visiting on one of our sites or sub-domains;
        • we may obtain certain data from Google Workspace APIs to enable certain Good Systems Services, including calendar integration functionality. If you choose to connect your calendar, calendar details (such as event titles, attendees, dates and times, and join links) and the access permission you grant remain on your own device and are not uploaded to our servers. Prior to accessing any data through these APIs, users will be required to log in to their Google account and provide explicit consent for the collection and use of such data. The use of raw or derived user data received from Google Workspace APIs will adhere to applicable third party policies governing the use of this data;
        • the use of Cookies to enable the feature or Service to function properly; and
        • feature requests or feature feedback from social media pages relating to our Services – this feedback data is anonymised through an automated script which removes all personal identifiers and Personal Data from such feedback.
        To the extent that you access our website, we will also collect certain data from you. If you would like more information about this, see Section 1.3 – Website Users.
    2. Website User Data
      1. Information that you provide to us and Personal Data we may collect:
        When you get in contact with us via our website, you provide us with your Personal Data, in the form of your name, email address and any other information that you choose to tell us either through communications that you send to us which pass through our servers.
      2. Information that we automatically collect or generate about you:
        We collect a limited amount of data from our Website Users that we use to help us improve your experience when using our website and to help us manage the services we provide. Such information may include (by way of a non-exhaustive list):
        • how you use our website;
        • the frequency with which you access our website;
        • internet protocol (IP) address;
        • location and time zone; and
        • the language you choose to view our website in.
        We collect your data automatically via Cookies, in line with your Cookie settings in your browser. If you would like to find out more about Cookies, including how we use them and what choices are available to you, see Section 12 – Cookies.
    3. Customer Support Data
      1. If you make enquiries via the Good Systems Help Center by using our submission form, interacting with our Answer Bot or by raising a customer support ticket to report an issue, we will process some of the Personal Data that we have set out above (e.g. basic Personal Data such as your personal identifiers and contact information and information that we automatically collect or generate about you such as your IP address and device type) together with any information that you include in your enquiry and that forms part of the chat log documenting our interaction ("Customer Support Data").
      2. It is not our intention to collect any sensitive or special category Personal Data about you (including any data relating to race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual life or criminal record or that is otherwise confidential or privileged) in this context and we ask that you do not include any such data in the enquiries that you send to us.
      3. We will use Customer Support Data to respond to your enquiries and we may use AI models to assist us with this e.g. to validate your customer support ticket, trouble shoot the underlying issue, generate replies, summarise the contents of customer support tickets that you have raised and help streamline the technical support that may be required to remedy the issue. We may also use Customer Support Data in AI models to help us carry out data analysis and identify any trends in reoccurring issues, in order to help improve our services.
      4. We may also anonymise Customer Support Data (e.g. by passing customer support tickets you have raised through a cleansing system to remove all Personal Data and summarise their contents) and use the anonymised information for other customer support related purposes including troubleshooting, data analysis, testing, security, and research.
    4. Good Systems AI
      1. The Good Systems AI features add certain artificial intelligence technology functionalities (as communicated by us from time to time) to our Services.
      2. To help us provide and improve the Good Systems AI features (including by training the AI model that powers the Good Systems AI features, and carrying out analytics to better understand queries/prompts from different types of users and to troubleshoot issues), we will collect, use, store, and otherwise process personal data relating to your use of the Good Systems AI features where we have obtained your explicit opt-in consent to do so (to the extent this is required by applicable data protection legislation). Please note that transcription and summarisation are performed locally on your device; no meeting content is sent to third-party AI model providers in connection with these core AI functionalities.
      3. This may include any personal data you provide in the form of or contained within:
        • any feedback that you provide to us in relation to or when using the Good Systems AI features;
        • meeting histories and transcripts, summaries and conversation logs of your interactions with us when using the Good Systems AI features;
        • any audio recordings, transcripts, documents, or other materials and content that you submit when using the Good Systems AI features ("Input") and any responses generated by the Good Systems AI features based on your Input ("Output"); and
        • any other data relating to your meetings and use of the Good Systems AI features that you access or generate when using the Good Systems AI features.

  1. 2. What is this data being used for?

    1. Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
    2. When we use your Personal Data, we make sure that our usage complies with applicable data protection laws. The law allows or requires us to use your Personal Data for a variety of reasons. These include where:
      • we need to do so in order to perform our contractual obligations with our customers and third-party providers;
      • we have obtained your consent;
      • we have legal and regulatory obligations that we have to discharge;
      • we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
      • the use of your Personal Data as described is necessary for our legitimate business interests, such as:
        • allowing us to effectively and efficiently manage and administer the operation of our business and the Services;
        • to enforce contracts and applicable Terms of Use, including investigation of potential violations thereof;
        • maintaining compliance with internal policies and procedures;
        • monitoring the use of our copyrighted materials; and
        • protect against harm to the rights, property or safety of Good Systems, its users, or the public as required or permitted by law.
    3. End Users
      Why and how we process your information
      To allow you to use and access the features and functionality provided by the Services, including scheduling and joining meetings, sending meeting invitations, utilising microphone recording features, generating transcripts and meeting summaries (which are performed locally on your device), and integrating with your calendar.
      Types of Personal Data Used
      • Personal identifiers and contact information of you and of the attendees of meetings.
      • Voice data.
      • Diagnostic data.
      • The contact details (including, as applicable, names, email addresses, phone numbers) that you upload when sharing a meeting invitation, calendar details (such as event titles, attendees, dates and times, and join links) where you choose to connect your calendar, and any personal identifiers captured from the audio stream during transcription of a meeting. Please note that Good Systems only accesses your device's microphone and speaker; it does not collect participant information or other data from third-party communication platforms (such as Microsoft Teams, Zoom or Google Meet).
      • Any information that you tell us or a Good Systems staff member.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests for us to provide our Services to you, including allowing us access to your microphone for the purposes of call transcription.
      We will rely on consent if we deem that this is required in the context of a specific Service.
      It is your responsibility to ensure that you seek the consent of other meeting participants for the recording and transcription of the call, including the potential capture of their personal data.
      Why and how we process your information
      To set you up to use the Services, including creating and managing your Goodnotes Account (GNA) for authentication purposes, and monitoring your account.
      Types of Personal Data Used
      • Personal identifiers and contact information.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests for us to provide our Services to you.
      Why and how we process your information
      To obtain feedback on the Services via surveys and similar methods.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests to improve and develop our offering by considering your feedback and feeding this into our processes where we deem necessary.
      Why and how we process your information
      To provide customer support and respond to customer enquiries e.g. via the submission form on our customer support page, Answer Bot or if you raise a customer support ticket to report an issue. This may also include for the purposes of troubleshooting the underlying issue, data analysis on any user-reported issues to identify trends, and streamline technical support.
      Once we have removed all Personal Data from a customer support ticket that you have raised, to use the anonymised information for other related purposes including testing, security, and research.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member, including the contents of any enquiries.
      • Customer Support Data
      Legal basis relied upon
      Legitimate interests, namely it is in our interests to respond to customer enquiries, remedy any issues with the Services and improve our Services, and also to remove Personal Data from customer support tickets so that we can use the anonymised information for testing, security and research.
      We may also need to process your Personal Data to comply with our legal obligations.
      Why and how we process your information
      To allow you to register and participate in sweepstakes or contests.
      Types of Personal Data Used
      • Personal identifiers and contact information.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests for us to be able to inform you about and allow you to participate in any of our sweepstakes and contests and for other promotional, marketing and business purposes. We will obtain your consent (or ensure we can rely on soft opt-in consent) prior to sending you marketing communications.
      Why and how we process your information
      Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to our activities including changes to our terms or policies or modifications to the products or other important notices.
      Types of Personal Data Used
      • Personal identifiers and contact information.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests to ensure we have an accurate record of all of our End Users so that we can communicate with them.
      Why and how we process your information
      To communicate with you in order to provide you with the Services or information about us and the Services.
      Types of Personal Data Used
      • Personal identifiers and contact information.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests to ensure we have an accurate record of all of our End Users so that we can communicate with them.
      Why and how we process your information
      For optimising the Services and your experience using the Services, and for ongoing review and improvement of the information provided on the Services to ensure that it is user friendly.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data
      • Information that we automatically collect or generate about you
      • Information we obtain from other sources.
      • Customer Support Data (in order to identify issues raised in customer support tickets)
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests to manage and maintain our provision of the Services to you.
      Why and how we process your information
      To take measures to protect against and try to prevent any potential disruptions or cyber-attacks.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data.
      Legal basis relied upon
      Legitimate interest, namely it is in our interests that the provision of the Services is uninterrupted and secure from any cyber-attacks.
      Why and how we process your information
      To understand your needs and interests and, where you have provided your consent, to send you marketing communications about our Services.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member
      • Information that we automatically collect or generate about you
      • Information we obtain from other sources.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests to manage and maintain the provision of the Services to you.
      We will obtain your consent (or ensure we can rely on soft opt-in consent) prior to sending you marketing communications.
      Why and how we process your information
      To provide you with technical and other support.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member
      • Emails that may be recorded.
      Legal basis relied upon
      Legitimate interests, namely to ensure that your access to the Services is continuous and satisfactory.
      Why and how we process your information
      For the management and administration of our business or in relation to a sale, reorganization, financing or other similar corporate transaction involving our business.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member
      • Information that we automatically collect or generate about you
      • Information we obtain from other sources
      • Emails that may be recorded.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests to ensure that a smooth handover or transition takes place in the context of such a transaction to enable you to continue to receive the Services.
      Why and how we process your information
      In order to comply with and in order to assess compliance with applicable laws, rules and regulations, subpoenas, legal processes, governmental requests, and internal policies and procedures.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member
      • Information that we automatically collect or generate about you
      • Information we obtain from other sources
      • Emails that may be recorded.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests for us to be enabled to establish and evidence compliance with applicable laws, rules and regulations, subpoenas, legal processes, governmental requests, and internal policies and procedures. We may also need to process your personal data to comply with our legal obligations.
      Why and how we process your information
      For the administration and maintenance of our databases storing Personal Data.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member
      • Information that we automatically collect or generate about you
      • Information we obtain from other sources
      • Emails that may be recorded.
      Legal basis relied upon
      Legitimate interests, namely to ensure that our databases are up to date and adequately maintained so that the provision of the Services and our business runs smoothly.
      Why and how we process your information
      To detect, prevent, or otherwise address fraud, security or technical issues.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member
      • Information that we automatically collect or generate about you
      • Information we obtain from other sources
      • Emails that may be recorded.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests for us to detect, prevent and address fraud, security and technical issues to ensure that we are in compliance with applicable laws and regulations, and that the provision of the Services and our business runs smoothly.
      Why and how we process your information
      To help us to establish, exercise, or defend legal claims.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Diagnostic data
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member
      • Information that we automatically collect or generate about you
      • Information we obtain from other sources
      • Emails that may be recorded.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests for us to be enabled to establish and defend our legal rights and understand our obligations and seek legal advice in connection with them.
      Why and how we process your information
      To help us provide and improve the quality and design of our Good Systems AI features including by training the AI model that powers the Good Systems AI features, and carrying out analytics to better understand queries/prompts from different types of users and to troubleshoot issues.
      Types of Personal Data Used
      • Any feedback that you provide to us in relation to or when using the Good Systems AI features
      • Meeting histories and logs of your interactions with us when using the Good Systems AI features
      • Transcripts and meeting summaries (together with related usage metadata) that you create using the Good Systems AI features, including the content of such transcripts and summaries
      • Any Inputs that you submit into and any Outputs generated by the Good Systems AI features
      • Any search requests that you input into our search functionality when using the Good Systems AI features
      Legal basis relied upon
      We will obtain your explicit opt-in consent to collect, use, store, and otherwise process personal data relating to your use of the Good Systems AI features (to the extent this is required by applicable data protection legislation).
      Why and how we process your information
      To obtain feedback on and optimise the Services, using data that you may provide on our discord server or other social media pages or other feedback channels.
      Once we have removed all Personal Data from any feedback or feature requests raised on our discord server or other social media pages or other feedback channels, to use the anonymised information for business improvement and data analysis purposes.
      Types of Personal Data Used
      • Any information/feature requests that you choose to upload in comments or chats on our discord server or publicly on our other social media pages or feedback channels (but excluding any Personal Data)
      Legal basis relied upon
      Legitimate interests, namely it is in our interests to improve and develop our offering by considering your feedback and feeding this into our processes where we deem necessary.
    4. Website Users
      Why and how we process your information
      To keep a record of your enquiries and suggestions and so that we can respond to them.
      Types of Personal Data Used
      • Personal identifiers and contact information
      • Any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests for us to consider and respond to enquiries and suggestions that you submit to us.
      Why and how we process your information
      To help us to improve your experience when using our website and to help us manage the services we provide.
      Types of Personal Data Used
      • Information that we automatically collect or generate about you.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests to manage and maintain our provision of our website to you.
      Why and how we process your information
      When you complete form submissions on our website.
      Types of Personal Data Used
      • any information/ selections that you choose to upload or share through the Services or that you choose to tell us or a Good Systems staff member
      • Personal identifiers and contact information
      • Emails that may be recorded.
      Legal basis relied upon
      Legitimate interests, namely it is in our interests and your interests to manage and maintain our provision of our website to you.

  1. 3. Who is my data disclosed to?

    1. We may disclose your Personal Data to other companies within our group for the purposes set out in "What is this data being used for?" above, as well as to law enforcement and regulatory agencies as may be required by law.
    2. The following information will be made visible to any other person who attends a meeting to which you have sent an invitation through the Services (for the avoidance of doubt, this relates only to invitations sent via Good Systems and not to any data obtained from third-party communication platforms):
      • your name, account ID and email address; and
      • any Personal Data contained in the meeting invitation that you share.
      We will not share your information this way unless you direct us to do so through your use of the Services.
    3. It is your responsibility to ensure that you seek the consent of other meeting participants for the recording and transcription of the call, including the potential capture of their Personal Data.
    4. When you use the Services in signed-in mode, your meeting content (including recordings, transcripts, notes and summaries) is end-to-end encrypted, synced and stored in AWS cloud infrastructure operated by Good Systems. In guest mode (without sign-in), nothing is uploaded and all content remains local on your device. Data is currently stored in the United States. If you would like more information about international transfers of your Personal Data, please see Section 5 below.
    5. If you have already signed up through Goodnotes, you can access Good Systems through your existing account. New users of Good Systems will be required to create an account through Goodnotes. Authentication and registration data associated with your Goodnotes Account ("GNA") is held by Goodnotes Limited, which operates the GNA authentication infrastructure. Goodnotes Limited provides authentication and account infrastructure services in connection with the Good Systems Services. Goodnotes Limited acts as a Processor on behalf of us. Goodnotes Limited’s role is limited to providing authentication/account infrastructure services on behalf of Good Systems.
    6. We may disclose and transfer your Personal Data to our agents, contractors or vendors ("Service Providers"). When we do this, we will ensure that they are under a duty of confidentiality to us and we have imposed contractual obligations to ensure they can only use your Personal Data to provide agreed services to us and to you. Such Service Providers may provide administrative, data processing or other similar services to us to enable us to better provide the Services.
    7. We may provide your Personal Data to actual or proposed assignees or transferees of our rights with respect to you in connection with a merger, sale or transfer (whether of assets or shares), reorganization, liquidation or dissolution of a company within our group, or steps taken in anticipation of such events (e.g., due diligence in a transaction). In such cases, information will only be shared where necessary.
    8. In particular, certain of the specific third parties that we disclose data to include:
      • In order to log aggregated statistical, non-Personal Data, we use Google Analytics for Firebase.
      • We use Mailchimp for sending newsletters and tips and tricks to subscribers that subscribe voluntarily.
      • To collect feedback and ideas from Good Systems’s users, we may use community forums or other feedback channels. In order to submit feedback, you may need to create an account with the relevant service provider.
      • We use Amazon Web Services to power the infrastructure for Good Systems cloud storage.
      • We use Datadog to collect diagnostic and usage data and monitor the infrastructure for Good Systems Cloud.
      • We provide optional functionalities which allow you to sync your files on the Good Systems application to your iCloud account.
      • We use Mixpanel and Amplitude to collect information about the usage of our app to maintain and improve the Good Systems application, our products and services, and features.
      • Transcription and summarisation are performed locally on your device; no meeting content is sent to third-party AI model providers in connection with these core AI functionalities. We may use externally trained AI models incorporated into services provided by third parties such as Amazon Web Services and Microsoft for other purposes such as customer support and analytics. We may also work with these third parties to test and develop these AI models.
      • We use Plain.com and other third party providers (which may incorporate externally trained AI models) to provide you with customer support services (including handling customer support emails, online submission of customer enquiries and customer support tickets and Answer Bot functionalities on the Good Systems Help Centre) and help us analyse or identify trends in user-reported issues in order to help us improve our services.
      • We may use Paddle to assist us with processing payments data, in the event that paid Good Systems utilises paid subscription features.
      • We may use Braze or other third party providers to notify you of important events about the Services and provide you with an enhanced user experience when using the Services.
      • We may use Sprig, User Testing, Google Forms, Lyssna and other third party tools from time to time for user research purposes.
      • We may use Hex and StreamNative, third-party service providers, to support the operation of our Services. Hex assists with data analysis and visualization to improve our internal decision-making, while StreamNative provides data streaming infrastructure to facilitate real-time processing within our cloud environment. We may use Statsig to run feature experiments and collect usage analytics, while Snowflake is used as a backend data warehouse to store and analyze that product and business data.

  2. 4. Retention Process

    1. How long we will hold your Personal Data for will vary and will be determined by the following criteria:
      • the purpose for which we are using it – we will need to keep your Personal Data for as long as is necessary for that purpose; and
      • legal obligations – laws or regulation may set a minimum period that we have to keep your Personal Data.

  3. 5. International Processing and Transfers of Personal Data

    1. We are established in the United States. Personal Data that you provide through our Services will generally be collected, accessed, processed and stored in the United States.
    2. If you are located in the United Kingdom, the European Economic Area ("EEA") or any other jurisdiction that imposes restrictions on international data transfers, please note that your Personal Data may be processed in countries whose data protection laws differ from those of your country of residence.
    3. Where we make restricted transfers of Personal Data that are subject to the UK GDPR or the EU GDPR, we will ensure that appropriate safeguards are implemented in accordance with applicable data protection laws. Such safeguards may include, depending on the circumstances:
      • transfers to countries that have been recognised by the relevant authorities as providing an adequate level of protection for Personal Data;
      • transfers to organisations that participate in an approved data transfer framework recognised by the relevant authorities (including, where applicable, the EU-US Data Privacy Framework and/or the UK Extension thereto);
      • the use of contracts incorporating the European Commission's Standard Contractual Clauses and/or the UK International Data Transfer Agreement or UK Addendum; or
      • any other transfer mechanism or derogation permitted under applicable data protection laws.
    4. If you would like further information regarding the safeguards that we use in connection with international processing and transfers of Personal Data, please contact us using the details set out in the "How to Contact Us" section below.

  4. 6. Keeping your data secure

    1. We will use technical and organisational measures designed to safeguard your Personal Data, for example:
      • access to your account is controlled by your Goodnotes Account (GNA) credentials and a password that is unique to you;
      • we encrypt your Personal Data;
      • any Personal Data that we process or store is done on secure servers.
    2. All processing of your Personal Data shall be conducted according to the data protection principles as follows:
      • Personal Data must be processed lawfully, fairly and transparently;
      • Personal Data must be accurate and kept up to date with every effort to erase or correct;
      • Personal Data must be processed in a manner that ensures the appropriate security.
    3. In addition, we have appropriate security measures in place designed to prevent Personal Data from being accidentally or unlawfully lost, used or accessed. We limit access to your Personal Data to those who have a genuine business need to access it. We take steps designed to ensure that those processing your Personal Data will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to respond to data security breaches. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

  5. 7. Recording Consent and Third-Party Participants

    1. If you give us information on behalf of someone else, you confirm and represent that you have the consent of such person to do so and such person has appointed you to act on his/her behalf to:
      • give consent on his/her behalf to the processing and transfer of his/her Personal Data; and
      • receive on his/her behalf any notices relating to data protection.
    2. When you use the recording functionality within the Services, the application provides a system notification to you as the recording user when a meeting is about to start. The application does not automatically notify or seek consent from other participants in the meeting. You are solely responsible for ensuring that you have obtained any consent required from other participants in the meeting before recording commences, in accordance with applicable laws. Personal data relating to other participants (including their voice and any other information captured in the recording) will be processed in accordance with this Policy. We recommend that you inform all participants that a meeting is being recorded prior to commencing any recording.

  6. 8. Third Party Websites

    Our Services may contain links to other websites operated by third parties and may include social media features such as Facebook, Twitter, YouTube, and Instagram buttons or links. You may also submit content to our blog through Medium. These third-party websites may collect information about you if you click on a link or visit those websites, and the social media sites may automatically record information about your browsing behaviour every time you visit a website with a social media button. Your interactions with these features and third parties are governed by the privacy policy of the third party, not by this Policy.

  7. 9. Your rights under the GDPR

    1. Under certain circumstances, you may have rights under data protection laws in relation to your Personal Data, which you can exercise free of charge. These rights include:
      • The right to know whether we hold your Personal Data and to request access to your Personal Data held by us.
      • The right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation.
      • The right to request that we rectify your Personal Data if it is inaccurate or incomplete.
      • The right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it.
      • In some circumstances, the right to receive the Personal Data you provided to us in a structured, commonly used and machine-readable format and/or to instruct us to transmit that data to a third party.
      • The right to object at any time to your Personal Data being processed for direct marketing and in other certain circumstances, such as if we change our legitimate interests from the basis on which we initially collected and processed your Personal Data.
      • The right to request that we restrict our processing of your Personal Data in certain circumstances. We can only continue to store your data, and will not be able to carry out any further processing activities with it until either: (i) you consent; or (ii) further processing is necessary for either the establishment, exercise, or defence of legal claims, the protection of the rights of another individual, or reasons of important EU public interest.
      • The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
    2. If you wish to exercise any of the above rights, or make any related complaint or request in relation to your Personal Data, please contact us by using the contact details in the "How to Contact Us" section below. You may also exercise some of your rights (e.g. the right to request that we erase your Personal Data) via the Good Systems application.
    3. Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction.

  8. 10. Children

    Children under the age of 16 are not permitted to sign up by themselves for the Services.

  9. 11. Who is responsible for processing your Personal Data

    Details of the controller and company responsible for compliance with this Policy are set out in Annex 1.

  10. 12. Cookies

    To the extent that we collect Personal Data with the help of Cookies (which are small text files that include a small quantity of information sent to the browser of users, by a web server, and stored on the hard disk drive of a computer for purposes of archiving, collecting navigation data for statistical analysis purposes, and offering services related to your interests or location), in combination with similar technologies such as tracking pixels, local storage objects and similar devices which distinguish you from other users (collectively, "Cookies" unless otherwise noted), we will process it in accordance with this Policy and our Cookies Policy which can be found at Cookies Policy.

  11. 13. More questions

    1. We commit to resolving complaints about our collection or use of your Personal Data. Individuals with inquiries or complaints should first contact support@goodsystems.com.
    2. You also have a right to lodge a complaint with a competent supervisory authority situated in a member state of your habitual residence, place of work, or place of alleged infringement.

  12. 14. Changes to this policy

    The Company reserves the right to make changes to this Policy at any time by giving notice to its users on the site, the Good Systems application, or as notified by us to you (by email for example), where possible. We recommend checking this page to stay up to date with the latest changes.

  13. ANNEX 1 – HOW TO CONTACT US

    How you can get in touch with us:
    • our Data Protection Officer can be reached via email to legal@goodnotesapp.com;
    • to access, amend or take back the Personal Data that you have given to us;
    • if you suspect any misuse or loss of or unauthorised access to your Personal Data;
    • to withdraw your consent to the processing of your Personal Data (where consent is the legal basis on which we process your Personal Data); or
    • with any comments or suggestions concerning this Policy.
    You can write to us at the following address: Good Systems, Inc. at 251 Little Falls Drive, Wilmington, Delaware 19808, County of New Castle, United States.
    Alternatively, you can send an email to: support@goodsystems.com.
    UK and EU Representatives
    You can contact our UK representative at the following address:
    Goodnotes Limited, 5 Churchill Place, 10th Floor, Canary Wharf, London, E14 5HU
    You will also be able to contact our EU representative. Details of our EU representative will be made available here once available. In the meantime, please direct any enquiries to us using any of the contact details set out above.

  14. ANNEX 2 – CALIFORNIA RESIDENTS

    This Annex applies to California residents and supplements the information contained in this Privacy Policy.
    Your California Privacy Rights
    Subject to applicable law, California residents may have the right to:
    • know what personal information we collect, use and disclose;
    • request access to personal information we hold about them;
    • request correction of inaccurate personal information;
    • request deletion of personal information;
    • obtain a copy of certain personal information in a portable format; and
    • not be discriminated against for exercising their privacy rights.
    The categories of personal information we collect, the sources from which we collect it, the purposes for which we use it, and the categories of third parties to whom we disclose it are described in this Privacy Policy.
    Sale or Sharing of Personal Information
    We do not sell personal information.
    We do not share personal information for cross-context behavioural advertising.
    Sensitive Personal Information
    We do not use or disclose sensitive personal information for purposes other than those permitted by applicable California law.
    Exercising Your Rights
    To exercise any of the rights described above, please contact us using the details set out in Annex 1.
    We may need to verify your identity before responding to your request. You may also designate an authorised agent to submit a request on your behalf, subject to applicable legal requirements.
    Changes to This Annex
    We may update this Annex from time to time. Any changes will be published in accordance with the "Changes to this Policy" section of the Privacy Policy.

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