NewAudia Systems, LLC

Important — Please Read Carefully

This Privacy Policy describes how NewAudia Systems, LLC collects, uses, discloses, protects, and retains personal information when you access or use the NewAudia website, applications, and services (collectively, the "Services"). By accessing or using the Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

Company Identification

The Services are operated by NewAudia Systems, LLC, a limited liability company organized under the laws of the State of Colorado, with its principal place of business in Colorado Springs, Colorado (hereinafter "NewAudia," "Company," "we," "us," or "our"). "NewAudia" is a registered trade name of NewAudia Systems, LLC in the State of Colorado.

This Privacy Policy is incorporated by reference into the NewAudia Terms of Service. For Authors and Publishers, it is additionally subject to the NewAudia Author Publishing Agreement, Acceptable Use Policy, and AI Usage Policy. Where those documents address specific data processing practices (such as Ephemeral Intelligence generation or AI narration processing), this Privacy Policy supplements that disclosure with additional detail regarding collection, retention, and user rights.

1. Scope of This Policy

This Privacy Policy applies to:

• Visitors to the NewAudia website
• Registered users, including Readers, Authors, Publishers, and Administrators
• Users of AI-assisted, interactive, and audiobook features, including the Audia AI reading assistant
• Authors and Publishers whose Manuscripts are processed through the NewAudia ingestion pipeline
• Communications with NewAudia via email, forms, or support channels

This Policy does not apply to third-party websites, platforms, or services that may be linked to or integrated with the Services. Users should review the privacy policies of those third parties independently.

2. Information We Collect

We collect information that you provide directly and information that is automatically collected through your use of the Services.

2.1 Information You Provide Directly

This may include:

• Account Information: Name, email address, username, password, and user role (Reader, Author, Publisher, or Administrator)
• Profile Information: Preferences, settings, and optional biographical or professional details
• Payment Information: Billing address, transaction records, and payment status. Payment card information is processed directly by Stripe, our third-party payment processor, and is not stored by NewAudia
• Manuscript and Content Submissions: Uploaded EPUB Manuscripts, cover images, metadata, author bios, and other materials submitted through the platform. See Section 4 for details on how Manuscript content is processed
• Communications: Support inquiries, feedback, survey responses, and other correspondence submitted to NewAudia

2.2 Information Collected Automatically

This may include:

• Usage Data: Feature interactions, audiobook listening activity, Audia query submissions, session duration, and navigation patterns
• Device and Technical Data: IP address, browser type, operating system, and device identifiers
• Log and Diagnostic Data: Error logs, performance metrics, and timestamps
• Cookies and Similar Technologies: As described in Section 11

3. How We Use Your Information

We process personal information for legitimate business purposes, including to:

• Provide, operate, and maintain the Services
• Create, authenticate, and manage user accounts
• Deliver audiobooks, AI-assisted features, and interactive content
• Process Manuscript ingestion, AI narration, and Audiobook publication
• Process transactions and manage billing via Stripe
• Generate and maintain Ephemeral Intelligence data to power the Audia AI reading assistant
• Improve performance, reliability, and usability of the Services
• Personalize content and user experience
• Communicate updates, notices, Commission reports, and support responses
• Detect, prevent, and mitigate fraud, abuse, or security incidents
• Comply with legal, regulatory, and contractual obligations

NewAudia does not sell personal information to third parties.

4. AI-Assisted Processing and Data Flows

Certain Services rely on AI-assisted technologies. The following subsections describe how personal data and user content are handled in connection with those features. For a full description of how AI features work, see the NewAudia AI Usage Policy.

4.1 Author Manuscript Processing

When an Author or Publisher submits a Manuscript through the ingestion pipeline, the Manuscript text is transmitted to OpenAI's Text-to-Speech (TTS) API to generate AI-narrated audio. This transmission is governed by NewAudia's agreement with OpenAI. NewAudia does not authorize OpenAI to use Manuscript content to train general-purpose AI models under the terms of that agreement.

Additionally, NewAudia generates "Ephemeral Intelligence" data from each ingested Manuscript — consisting of AI-generated indexing, segmentation metadata, and conversational context data — used exclusively to power the Audia AI reading assistant for that title. Ephemeral Intelligence is not shared with third parties for commercial purposes beyond what is necessary to operate the platform.

Authors who remove a Manuscript or terminate their Author Publishing Agreement may request deletion of associated Audiobook files. Ephemeral Intelligence data and associated metadata may be retained by NewAudia for a reasonable period following removal for archival, legal, or compliance purposes, consistent with Section 7.2 of the Author Publishing Agreement.

4.2 Reader Query Processing (Audia)

When a Reader submits a question to Audia, that query — along with relevant context retrieved from the Manuscript's Ephemeral Intelligence index — is transmitted to OpenAI's language model API to generate a response. Reader queries are not stored for the purpose of training generalized AI models. Query data may be retained in platform logs for quality assurance, abuse prevention, and system improvement purposes.

4.3 General AI Output Limitations

AI outputs are generated algorithmically and do not constitute professional, legal, financial, or medical advice. Users are responsible for ensuring they have the necessary rights to submit any content they provide through the Services.

5. Information Sharing and Disclosure

We share information only as necessary and under appropriate safeguards. We do not sell personal information.

5.1 Service Providers

We share information with trusted service providers that perform services on our behalf. Material third-party processors currently engaged include:

These providers are contractually required to protect information and use it only for authorized purposes. NewAudia will update this Policy if its material third-party provider relationships change.

5.2 Legal and Compliance Obligations

We may disclose information where required to:

• Comply with applicable law, regulation, or lawful legal process
• Enforce our Terms of Service, Author Publishing Agreement, Acceptable Use Policy, or other platform policies
• Protect the rights, property, or safety of NewAudia, our users, or others
• Respond to copyright infringement claims or other third-party legal notices relating to Manuscripts published on the platform

5.3 Business Transfers

If NewAudia undergoes a merger, reorganization, asset sale, or transfer of ownership, personal information and platform data may be transferred as part of that transaction. Users will be notified of any such transfer and of any material changes to this Privacy Policy that result from it, as required by applicable law.

6. Data Retention

Personal information is retained only for as long as reasonably necessary to fulfill the purposes described in this Policy, meet legal or regulatory requirements, resolve disputes, and enforce agreements. Specific considerations include:

• Account data is retained for the duration of the account and for a reasonable period thereafter to comply with legal obligations or resolve outstanding matters
• Manuscript and Audiobook files are removed from public access within thirty (30) business days following a valid termination or removal request, consistent with Section 7.2 of the Author Publishing Agreement
• Ephemeral Intelligence data and associated Manuscript metadata may be retained for archival, legal, or compliance purposes following Manuscript removal, as permitted under the Author Publishing Agreement
• Audia query log data is retained for quality assurance, abuse prevention, and platform improvement, subject to applicable legal requirements
• Payment and transaction records are retained as required by applicable tax, accounting, and financial regulations

7. Data Security

NewAudia employs reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. These measures include access controls, encrypted data transmission, and routine security reviews.

No system is completely secure. While we take appropriate precautions, we cannot guarantee absolute security of information transmitted to or stored on the Services. Users are responsible for maintaining the confidentiality of their account credentials.

8. User Rights and Choices

Depending on your jurisdiction, you may have rights with respect to your personal information, including the right to:

• Access and review the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your personal information, subject to our legal obligations and retention requirements
• Object to or request restriction of certain processing activities
• Withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing

To exercise any of these rights, please submit a request using the contact information in Section 13. NewAudia may require identity verification before processing any request. Some requests may be limited by applicable law or by our obligations under the Author Publishing Agreement or other contracts.

9. Author Rights Regarding Manuscript Data

Authors and Publishers have specific rights regarding their Manuscripts and the data derived from them, governed primarily by the Author Publishing Agreement. The following summarizes the key data rights in that context:

• Authors retain full copyright and ownership of their Manuscripts. NewAudia holds only a non-exclusive license to process and distribute content as described in Article 4 of the Author Publishing Agreement
• Authors may request removal of their Manuscripts and associated Audiobooks at any time by contacting admin@newaudia.com. Removal is processed within thirty (30) business days
• Ephemeral Intelligence data derived from a Manuscript may be retained after removal for archival and legal compliance purposes, as permitted under Section 7.2 of the Author Publishing Agreement
• Authors may submit data access or correction requests for their account information using the contact details in Section 13

10. Children's Privacy

The Services are intended for adults only. Per Section 1.1 of the NewAudia Author & Publisher Addendum, Authors and Publishers must be at least 18 years of age or the age of majority in their jurisdiction. Reader accounts are similarly restricted to users who are 18 or older.

NewAudia does not knowingly collect personal information from individuals under 18 years of age. If we become aware that personal information has been collected from a minor without verifiable parental consent, we will take steps to delete that information promptly. If you believe a minor has provided personal information through the Services, please contact us at privacy@newaudia.com.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to enable core site functionality, analyze usage and performance, and remember user preferences. Cookies used on the Services are limited to those necessary for platform operation and analytics.

You may control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of some features of the Services.

12. International Data Processing

NewAudia is based in Colorado, USA. Information collected through the Services may be processed and stored in the United States or in other jurisdictions where our service providers operate. By using the Services, you consent to the transfer of your information to jurisdictions that may have data protection rules different from those in your country of residence, subject to the safeguards described in this Policy.

13. Contact Information

For questions, concerns, or privacy requests — including data access, correction, deletion, or rights inquiries — please contact NewAudia using the information below.

14. Changes to This Privacy Policy

NewAudia may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or platform features. Updates will be posted on the Services with a revised "Last Updated" date. NewAudia will use reasonable efforts to notify users of material changes via email to the address on file. Continued use of the Services following notice of any update constitutes acceptance of the revised Policy.

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