FIORIRE PRIVACY AND DATA RETENTION POLICY

1. SCOPE AND STATUS OF THIS POLICY

This Policy applies to:

• visitors to Fiorire's website and App;
• adults whose stories Fiorire records, whether directly or through an organization;
• people who have a Fiorire account or listen through the Fiorire App;
• people at organizations that consider, purchase, or support Fiorire services; and
• people whose personal information appears in communications or materials supplied to Fiorire.

This Policy describes Fiorire's operational practices. It is not, by itself, a contract and does not replace the Fiorire Participant Recording, Content, Privacy, and Release Agreement (the "Participant Agreement"), the Fiorire Organization Agreement, the separately accepted Fiorire App and Website Terms of Use, a completed Membership Order, or another separately signed special-purpose instrument. The more specific signed or affirmatively accepted instrument controls a conflict on the subject it governs.

Fiorire's standard participant service is limited to adults age eighteen (18) or older. Only the participant and the Fiorire interviewer(s) may be present during a Signature Session. If another person enters, recording stops and does not resume while that person is present. The affected portion is removed as the first step of editing, before the recording is transcribed, further edited, or shared, and no clip containing that voice is created or delivered. A person under eighteen may not participate in or be recorded during the standard service. If Fiorire learns that it collected a minor's voice or other personal information contrary to this rule, it will disable access and delete or otherwise address the information as required by law.

This Policy and Fiorire's voluntary practices may exceed what applicable law requires. They are not a contract, do not create a private right of action, do not establish a legal standard of care, and are not an admission that any law applies to a particular practice. A voluntary practice, remedial step, correction, or improvement is not an admission of prior wrongdoing. Rights and remedies, if any, arise only from a signed agreement or applicable law.

2. INFORMATION WE COLLECT

Participant content

Original audio recordings; edited clips; transcripts and related materials; Signature Session dates; avatar names; privacy choices; consent, release, and arbitration-opt-out records; corrections; requests; communications; and information needed to deliver and support the service.

Oral histories may voluntarily reveal sensitive information about health, family, race or ethnicity, religion, sexuality, immigration, finances, trauma, political beliefs, or other life experiences. Fiorire does not require those disclosures and uses them only to provide the service, follow participant choices, protect the service, and comply with law.

Account and contact information

Name; email address; telephone number when used for account security or contact; authentication and one-time-code information; organization affiliation; profile information; privacy settings; saved playlists; likes; listening history; support requests; account activity, and other features as they become available.

Fiorire does not store full payment-card numbers. A payment processor will handle them when paid memberships are offered. Fiorire may receive limited payment status, transaction identifier, billing contact, card type, and last-four-digit information.

Website, App, device, and security information

Internet Protocol address; browser and device type; operating system; requested pages; date and time; authentication events; account and access logs; error and diagnostic data; content-delivery information; and strictly necessary cookies, local storage, emailed links, or similar session technologies generated by hosting, authentication, content-delivery, and security systems.

Organization and business-contact information

Name; work email; telephone number; title; employer; contract and billing information; scheduling information; purchase-order information; notes from business discussions; communications; and information needed to administer a relationship.

3. SOURCES AND PURPOSES

We receive information directly from you; from an organization that introduces or schedules you; automatically from the website, App, authentication, content-delivery, and security infrastructure; and from service providers performing work for Fiorire.

We use information to:

• schedule and conduct Signature Sessions;
• edit and deliver clips and related materials;
• operate accounts, privacy levels, Community Spaces, and listening features;
• host, transmit, secure, maintain, troubleshoot, and improve the service;
• communicate, authenticate users, provide support, and respond to requests;
• process payments and maintain tax, accounting, insurance, and business records;
• detect, prevent, investigate, and address misuse, fraud, security incidents, unlawful conduct, or violations of agreements;
• preserve evidence, establish or defend legal claims, and comply with law; and
• create aggregate or de-identified operational information that cannot reasonably identify a person, for security, performance measurement, capacity planning, service improvement, and business analysis.

Fiorire does not:

• sell personal information;
• share personal information for cross-context behavioral advertising;
• use participant audio, transcripts, clips, identity, or story in advertising, marketing, public promotion, or sales demonstrations without separate prior written permission authorizing that use;
• intentionally submit participant audio or transcripts for a provider's own model training, benchmarking, testing, evaluation, validation, or improvement, and Fiorire uses available contractual terms, account settings, and documented product controls to prohibit or opt out of such use;
• use voice cloning, synthetic-voice, or digital-replica features;
• infer health, cognition, emotion, impairment, or suitability for housing or care from a voice;
• make automated decisions about housing, care, employment, eligibility, billing, discharge, eviction, or services; or
• attempt to reidentify aggregate or de-identified information.

Fiorire owns aggregate and de-identified operational data that cannot reasonably identify a person and may use it for security, analytics, performance, capacity planning, research, service improvement, financing, and lawful business purposes. Fiorire will not attempt to reidentify it.

4. WHEN INFORMATION IS SHARED AND WHO HELPS US

Fiorire shares information only as needed to provide, secure, support, and administer the service; as directed by a participant; or for the limited legal and business purposes below. Contracted providers receive only the information reasonably needed for their function.

Provider categories include:

• secure file transfer, audio editing, transcription, quality control, and production;
• artificial-intelligence-assisted text analysis used for deliverables and silencing, plus workflow automation;
• database, cloud storage, backup, audio hosting, content delivery, authentication, and security;
• website and application hosting, code deployment, communications, email delivery, and customer support;
• payment processing, accounting, legal, insurance, compliance, and other professional services; and
• contractors who edit or support Signature Sessions under confidentiality, security, and use restrictions.

Some processing occurs locally on encrypted equipment controlled by Fiorire. Fiorire organizes its disclosure by provider category. Fiorire does not publish confidential pipeline order, credentials, nonpublic settings, or detailed security architecture. A current list of material subprocessors may be provided to a contracting organization on reasonable request, subject to appropriate confidentiality for nonpublic security and trade-secret information. Specific vendor names are not part of a participant's permission unless a signed form or applicable law expressly requires otherwise.

Before onboarding a provider that will receive participant content, Fiorire evaluates the provider's security, privacy, retention, training, subprocessor, incident, and contractual posture. Fiorire uses contracts, settings, or both to require confidentiality, reasonable security, processing only for Fiorire's instructions, restrictions on reuse and model training, and appropriate deletion. Fiorire periodically reassesses material providers and documents the result.

Fiorire may replace or add a provider without individual notice when the provider performs a substantially similar function under materially similar use and security restrictions. Fiorire will update this Policy or obtain additional consent before a provider change materially expands a purpose, disclosure, or use authorized by a signed participant agreement or applicable law.

Providers that host active Fiorire content may retain it for the service term under Fiorire's instructions. Fiorire ordinarily implements a deletion instruction in the active systems it controls within thirty (30) days. Transient processing copies, provider backup replicas, and provider-controlled content follow the applicable contractual or configured deletion windows, which vary by provider and in some cases exceed thirty (30) days. Fiorire maintains provider-specific periods internally and updates them when configurations, services, or terms change.

Fiorire may also disclose information:

• to a participant's chosen App audience;
• to service providers and contractors performing authorized functions;
• to professional advisers, insurers, auditors, financing sources, or prospective transaction parties under appropriate confidentiality duties;
• when Fiorire reasonably and in good faith believes disclosure is necessary to address an imminent threat of serious harm; report suspected abuse, abandonment, neglect, exploitation, or self-neglect; summon emergency services; protect Fiorire or another person; investigate fraud or a security incident; or comply with law or legal process; or
• in a merger, financing, reorganization, change of control, or sale of all or substantially all assets, subject to existing participant choices, signed agreements, and this Policy.

The safety and legal-disclosure provisions above are permissions, not promises to detect a problem. Except where nonwaivable law requires otherwise, they create no duty to monitor, diagnose, investigate, verify, report, provide emergency services, or intervene.

5. SECURITY AND INCIDENT RESPONSE

Fiorire uses administrative, technical, and physical safeguards designed for the sensitivity of the information. Depending on the system, these include encryption in transit and at rest where supported; access controls; least-privilege permissions; multi-factor authentication or protected email-link authentication; passkeys or two-step verification for the controlling email account; encrypted devices; logging; backups; vendor review; written security obligations; secure development and change practices; and incident-response procedures.

No system can be guaranteed completely secure. Fiorire's safeguards are risk-based and may change as systems and threats change. This Policy describes categories of controls rather than publishing credentials, detailed architecture, or a security guarantee.

If a confirmed incident affects personal information, Fiorire will investigate, contain, document, remediate, and provide notices to affected people, organizations, regulators, or others as required by applicable law without unreasonable delay. Fiorire will not promise a fixed notification period shorter than the law requires unless it separately agrees in writing and has operationally confirmed that it can satisfy the promise.

6. YOUR CHOICES AND REQUESTS

Subject to identity verification and legal or technical exceptions, you may ask Fiorire to:

• provide a copy of information about you;
• correct inaccurate account information;
• change a clip's privacy level;
• restrict or close an account; or
• delete content.

Send service, access, correction, privacy-level, account-closing, and deletion requests to contact@fiorirearchive.com. Send privacy, retention, or biometric questions to privacy@fiorirearchive.com. A privacy request received at either address will be routed and treated as received when Fiorire receives it.

For an ordinary change, Fiorire may verify the requester through an authenticated App session or the email address or telephone number already on file. For account closure, full deletion, disclosure to another person, a change to account identity, or a request by an agent or representative, Fiorire may require a one-time code and additional reasonably reliable evidence of identity or authority. Fiorire ordinarily completes a verified request in active systems it controls within thirty (30) days and will explain if additional time or information is reasonably required.

After a participant's death, Fiorire may take protective steps on reasonably reliable evidence of death or a dispute. Disclosure, transfer, or control of private content requires a certified death certificate and letters of office, a court order, or other legally sufficient evidence of authority, subject to the participant's directions and applicable law. No person may create a new permission for the participant after death.

Bequest Clause: A participant may name one individual to receive a copy of that participant's clips in the event of a participant's passing. The designation may be made in the Fiorire App where that control is available, or in writing to contact@fiorirearchive.com, and the participant may change or revoke it at any time. On a certified death certificate and verification of the named individual's identity, Fiorire will provide that individual a download of the participant's clips. The designation transfers a copy only; it does not transfer the account, App access, or any license or other right in the recording, and it does not authorize any new permission. No other person receives private content except as stated in the preceding paragraph or as a court order or applicable law requires.

Fiorire will not retaliate against or unlawfully discriminate against a person for making a lawful privacy request or exercising a nonwaivable right.

A request applies going forward and does not undo lawful access that already occurred or copies already delivered, downloaded, recorded, forwarded, or otherwise placed outside Fiorire's control. Fiorire may deny, limit, or delay a request to comply with law, complete a transaction, protect security, prevent fraud, preserve evidence, establish or defend legal claims, honor another person's rights, or retain a minimal record that consent and the request were handled.

Withdrawing the core consent needed to process a recording ends the participant's service relationship and may require closing the profile and deleting content. If you signed a Participant Agreement, that Agreement governs the recording, license, privacy levels, release, arbitration, claims period, and participant remedies; this Policy governs operational details where the Agreement refers to it.

Where these controls are available in the Fiorire App, a participant may make these changes directly; otherwise Fiorire makes them on request.

Withdrawing the separate, optional demonstration permission changes nothing else — the participant's account, clips, and access continue exactly as before.

7. RETENTION AND DELETION SCHEDULE

Active App access

A paid Signature Session ordinarily includes two (2) years of App access from the participant's Signature Session date. A complimentary Demo Day Signature Session includes thirty (30) days of App access from that date. If the Organization enters a paid Fiorire program before the participant's clips are deleted, the participant's included access automatically becomes two (2) years from the original Signature Session date. A valid paid membership or other access arrangement may keep the account and clips active while that arrangement remains in good standing and the participant has not requested deletion.

Original recordings and offline finished-clip copies

Fiorire may keep the original Signature Session recording and accessible offline production or backup copies of finished clips for quality, correction, export, security, and dispute purposes for up to two (2) years from the Signature Session date. A verified deletion request may shorten that period. A legal, litigation, regulatory, insurance, fraud, or evidence-preservation hold may require Fiorire to preserve a restricted copy longer to the extent lawfully necessary.

Working files and full transcripts

Fiorire deletes working files and full transcripts when no longer reasonably needed for editing, delivery, quality correction, security, or dispute resolution, and ordinarily no later than two (2) years from the Signature Session date. Transient provider copies follow the applicable provider deletion windows.

App clips after access ends: 180-day restricted recovery and deletion by day 210

When App access or membership ends, Fiorire removes the profile and clips from ordinary user access immediately. Unless the participant requests earlier deletion or a legal hold applies, Fiorire may retain the clips in a restricted recovery state for up to one hundred eighty (180) days solely to permit correction, export, reactivation, or recovery from accidental loss. At least thirty (30) days before the scheduled deletion, Fiorire will send a final notice to the most recent contact address on file when reasonably available. If access is not restored, Fiorire deletes the clips from active production systems no later than two hundred ten (210) days after access ends.

Long-term members

Clips may remain available for as long as an active membership or other valid access arrangement continues and the participant has not requested deletion. The two-year limits for original recordings, offline finished-clip copies, working files, and full transcripts do not restart merely because App access continues. Based on Fiorire's current documented technical configuration and vendor confirmations, Fiorire's position is that ordinary recordings and clips are not biometric identifiers or biometric information, so the conditional BIPA schedule below does not impose a three-year limit on ordinary audio or App clips.

Demonstration clips

Clips used under a participant's optional demonstration permission remain available for demonstration only while that participant has active App access and for no more than two (2) years, whichever ends first, and are removed from demonstration use earlier on written revocation.

Verified deletion requests

A verified deletion request overrides the 180-day recovery period. Fiorire ordinarily implements the request in active systems it controls within thirty (30) days. The request reaches the original recording, accessible offline finished-clip copies, working files and transcripts, active or suspended App clips, and provider copies Fiorire can direct a provider to delete. Deletion remains subject to the holds and minimal records described below.

Backups, caches, service providers, and legal records

Deletion from active systems does not always remove every residual copy immediately. Isolated backups, disaster-recovery copies, content-delivery caches, and provider replicas expire through restricted ordinary cycles and are not used for routine business. If a backup is restored, Fiorire will reapply completed deletion requests. Provider-controlled copies follow the applicable contractual or configured deletion windows.

Fiorire may retain signed consents, releases, contracts, arbitration opt-outs, payment and tax records, request and deletion logs, security records, incident records, and minimal evidence needed for compliance, insurance, audits, investigations, or disputes for at least seven (7) years after the relevant relationship or authorized use ends, and longer when reasonably necessary for a legal hold, applicable law, or the establishment, exercise, or defense of legal rights.

Copies delivered to a participant or obtained by an authorized listener are outside Fiorire's control and are not affected by Fiorire's deletion schedule. Fiorire does not promise to retrieve or erase those copies.

8. AUDIO PROCESSING, ARTIFICIAL INTELLIGENCE, AND BIOMETRIC DATA

Fiorire uses transcription to assist with silencing identifying details before selected clips enter the App, with the intent of protecting participant anonymity. Some tools also assist with cleanup, production editing, and quality checks. The process is used to create and protect participant content, not to identify a person by voice.

Current legal and technical position

Based on Fiorire's current configuration and written vendor confirmations, Fiorire's position is that it does not create, collect, capture, obtain, possess, store, or use a voiceprint or other biometric identifier or biometric information. Fiorire does not identify or verify a person by voice, enroll or authenticate a voice, match a voice across recordings, retain a voice template or persistent speaker embedding, maintain a speaker index, or use a persistent speaker profile.

Current technical position: During single-file speaker separation, one editing function temporarily computes an anonymous, file-specific, in-memory representation of vocal characteristics solely to group segments by speaker within one recording so an editor can distinguish the interviewer from the participant. According to the provider's written confirmation: that representation cannot identify an actual person, cannot be matched across recordings or projects, is not placed in a speaker database or index, and is not retained after processing. The speaker-labeled transcript is retained; the representation is not. Standard transcription, playback, editing, and export do not create this representation. Fiorire does not use its editing provider's AI speaker, voice cloning, voice generation, or synthetic-presenter features. Fiorire's separate speech-to-text service is configured without speaker diarization or speaker-embedding features.

Fiorire does not use voice cloning, synthetic speech, voice transformation, or digital replicas. Editing preserves the participant's authentic voice, so a familiar listener may still recognize it. In the App, a participant appears under an avatar name rather than a real name, while Fiorire keeps enough account information to authenticate the participant and respond to requests. Fiorire does not knowingly create or distribute an unauthorized digital replica and maintains complaint procedures designed to address applicable publicity and copyright law.

Transcripts and other outputs are text derivatives of the recording. Because the current workflow does not create a biometric identifier used to identify a person, Fiorire does not treat those text derivatives as biometric information. Fiorire nevertheless protects and deletes them under the conservative schedule in Section 7.

Conditional BIPA retention and destruction rule

Nothing in this Policy is an admission that Fiorire collects or possesses biometric identifiers or biometric information. As an additional safeguard, if a court or regulator later determines that the temporary, file-specific speaker-separation representation described above is covered by the Illinois Biometric Information Privacy Act ("BIPA"), Fiorire's public retention rule is to destroy it as soon as the single-recording separation step ends; Fiorire does not retain it.

Any other biometric identifier or biometric information that Fiorire later lawfully collects under a separate written notice and release will be permanently destroyed when the initial purpose is satisfied or within three (3) years after the individual's last interaction with Fiorire, whichever occurs first, unless a shorter period is required by law.

Fiorire will not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. Fiorire will not disclose or redisclose covered biometric data except with the individual's consent, to complete an authorized transaction, as required by law or ordinance, or under a valid warrant or subpoena. Fiorire will protect any covered biometric data using the reasonable standard of care in its industry and no less protectively than it protects other confidential and sensitive information.

Change control

Fiorire will not enable a feature that identifies, verifies, enrolls, persistently represents, or matches a voice, or a future vendor feature reasonably described as biometric, without documented legal, privacy, security, vendor, and insurance review. Before any such use, Fiorire will update its controls and provide any public policy, specific purpose-and-term notice, written release, provider contract, and retention and destruction schedule required by law. Fiorire's separate Standalone Biometric Data Policy and Notice provides additional detail without conceding that BIPA applies.

9. ILLINOIS OPERATIONS, HEALTH-CARE LIMITS, AND OTHER LOCATIONS

Fiorire is an Illinois limited liability company and currently provides its standard participant service. Fiorire designs its practices to comply with applicable Illinois recording, privacy, publicity, data-security, breach-notification, contract, and consumer-protection laws.

Fiorire is an enrichment and storytelling service, not a health-care provider. It does not record for treatment, payment, health-care operations, diagnosis, care planning, monitoring, or emergency response. Organizations should not provide medical records, diagnoses, care plans, or protected health information. Fiorire is not a HIPAA covered entity or business associate for the standard service and does not assume those duties unless it separately signs a written business associate agreement.

Fiorire currently limits its standard participant service to adults in the United States. Where Fiorire has the option, it selects United States hosting; some providers may process or store information in other locations. Fiorire does not intentionally offer the standard service to people in the European Economic Area, United Kingdom, or another jurisdiction requiring a materially different framework. Before expansion, Fiorire will assess the new location and update notices, contracts, transfer safeguards, and rights where required.

Where an applicable comprehensive state privacy law grants a right to access, correct, delete, obtain a portable copy, opt out of a sale or targeted advertising, limit sensitive-data use, appeal a denial, or use an authorized agent, Fiorire will honor the right to the extent required. Fiorire does not currently sell personal information or use participant content for targeted advertising. Requests may be sent to either Fiorire address listed above.

10. BUSINESS CONTACTS

If you work for an organization considering or using Fiorire, we may keep your name, work contact information, title, employer, contract and billing records, and notes from communications so we can respond, schedule, administer the relationship, provide support, maintain records, and protect legal rights. You may request deletion of ordinary contact notes, subject to contracts, transactions, legal requirements, security, insurance, and dispute records.

11. COOKIES AND SIMILAR TECHNOLOGIES

Fiorire does not currently use advertising cookies or third-party behavioral advertising. Its website, App, authentication, hosting, content-delivery, and security providers may use strictly necessary cookies, local storage, emailed links, or similar technologies to keep users signed in, deliver content, remember settings, prevent misuse, and protect accounts. Infrastructure may create Internet Protocol, device, request, access, and error logs.

Disabling necessary technologies may prevent the website or App from functioning. If Fiorire later adds optional analytics, advertising, session-replay, pixels, or other tracking technologies, it will update this Policy and implement consent or opt-out controls where required before using them.

12. CHANGES TO THIS POLICY

Fiorire may update this Policy to reflect new features, providers, security practices, or legal requirements. The current effective date appears at the top of this Policy, and the current version appears in the footer.

For a material change that expands how recordings are used, broadens who may hear clips, or materially lengthens content retention, Fiorire will ordinarily give at least thirty (30) days' advance notice. Notice presented in the Fiorire App, which the participant must acknowledge before continuing to use the App, satisfies this requirement. Fiorire may make nonmaterial, clarifying, security, or legally required changes sooner.

A signed Participant Agreement continues to control where it conflicts. Continued use will not replace new written consent when applicable law or a signed agreement requires one.

13. CONTACT

Service requests, account changes, deletion requests, contractual notices, and arbitration opt-outs: contact@fiorirearchive.com.

Privacy, retention, and biometric questions or complaints: privacy@fiorirearchive.com.