Privacy Policy

Effective: 2026-08-04 Last updated: 2026-08-04

This Privacy Policy explains how Mindcom Media Ltd (“we”, “us”, “our”) collects, uses, and protects your information when you use Frontier Voice, our iOS application.

1. Who We Are

Frontier Voice is developed and operated by Mindcom Media Ltd, a company incorporated in England and Wales. We are the data controller for the purposes of the UK GDPR and EU GDPR.

Registered office: Holly Cottage, Pond Road, Bradfield, Norfolk, UK Contact: Tim O’Shea — hello@getunlocked.ai

2. Data We Collect

2.1 Data Collected and Processed

Data Type	Purpose	Where It Goes
Microphone audio	Live voice conversations with the AI agent	Streamed to LiveKit Cloud (us-east, USA) for real-time processing; not stored on our servers
Voice transcripts	Conversation history and context	Stored only on your device (SwiftData + iOS UserDefaults); never uploaded to our servers
User preferences and settings	App configuration	Stored only on your device
Text chat input	Conversations with the AI agent	Processed by AI providers (see Section 4); not stored on our servers
Product analytics (usage events)	Understand feature usage and improve the app	Sent to PostHog (US cloud, USA), tied to a pseudonymous device identifier — not your name, email, or any account (see Section 4.9)

2.2 Data We Do Not Collect

We do not operate user accounts or store any personal data (name, email, etc.) on our own servers.
We do not send your microphone audio, conversation transcripts, or message content to our analytics provider. Our analytics capture only anonymous usage events (see Section 4.9).
We do not track your activity across other companies’ apps or websites (see Section 3 on tracking).
We do not collect financial payment information directly (handled by Apple).

3. App Tracking Transparency

We do not track you across third-party apps or websites for advertising or data-broker purposes. We do not participate in cross-context behavioural advertising.

Our product analytics (PostHog — see Section 4.9) use a first-party, pseudonymous device identifier that we generate ourselves. It is not the Apple advertising identifier (IDFA), is not linked to data from other companies, and is never used to advertise to you across other apps or websites. Under Apple’s App Tracking Transparency (ATT) framework this is not “tracking,” so no ATT prompt is shown.

4. Third-Party Services and Data Processors

Frontier Voice routes voice and text data through the following third-party services to deliver its functionality. These providers act as data processors on our behalf.

4.0 Your Permission Comes First

Before Frontier Voice sends anything to the AI services listed below, the app shows you an in-app screen — “Before you start talking” — that names the data being sent (your microphone audio and the conversation transcript) and every company that receives it. Voice calls are disabled until you tap “Agree and continue”. You can re-read that disclosure, and withdraw your permission, at any time under Settings → AI processing & your data. Withdrawing permission stops all further processing by disabling voice calls.

4.1 LiveKit (LiveKit Inc., USA)

What it does: Manages real-time voice sessions (audio streaming, speech-to-text, text-to-speech, and AI model routing).
Data processed: Microphone audio and conversation content during an active session.
LiveKit Inference routes AI model requests to the selected model provider (see 4.2 and 4.3 below). Audio and transcripts are transient — processed in real time and not stored by LiveKit beyond session duration.
Privacy: livekit.io/privacy

4.2 Anthropic (Anthropic, PBC, USA) — default LLM

What it does: Powers AI responses using Claude models.
Data processed: Conversation text passed to the model for each turn.
Privacy: anthropic.com/privacy

4.3 Optional / Alternative AI Providers (routed via LiveKit Inference)

When you select an alternative AI model, your conversation data may be routed to the relevant provider:

OpenAI (OpenAI, LLC, USA) — for GPT models. Privacy: openai.com/privacy
Google (Google LLC, USA) — for Gemini models. Privacy: policies.google.com/privacy
DeepSeek (DeepSeek, China) — for DeepSeek models.
xAI (xAI Corp, USA) — for Grok models.

4.4 Voice Synthesis Provider (routed via LiveKit Inference)

Text-to-speech synthesis for spoken responses:

Cartesia (Cartesia AI, Inc., USA) — the voice synthesis provider for all spoken responses. Privacy: cartesia.ai

4.5 Brave Search (Brave Software, Inc., USA)

What it does: Enables the AI agent to perform live web lookups when searching the internet.
Data processed: Search queries generated by the AI model based on your conversation.
Privacy: brave.com/privacy/browser

4.6 Audio Processing Plugins (within the LiveKit session)

The following components run inside the LiveKit-hosted agent session to make voice conversations work. They process microphone audio transiently in real time and do not retain it after the session ends.

ai-coustics (ai-coustics GmbH, Germany) — real-time noise and echo suppression on the inbound microphone stream. Privacy: ai-coustics.com
Silero VAD (Silero Team) — open-source voice activity detection that determines when you have started or stopped speaking. Runs as a model inside the agent worker; no data is sent to a third-party service.
LiveKit turn-detector (LiveKit Inc., USA) — open-source end-of-turn detection model that decides when it’s the AI’s turn to respond. Runs as a model inside the LiveKit agent worker.

4.7 Apple Foundation Models (on-device)

What it does: Used for transcript compaction (summarising older conversation history) when you resume a chat session, on iOS 26 and later.
Data processed: Chat transcripts — processed entirely on your device. No transcript data is sent off-device for this feature.
This is fully on-device processing by Apple’s system framework.

4.8 Apple (App Store / In-App Purchases)

Payment processing and subscription management are handled by Apple. We do not receive your full payment card details.
Privacy: apple.com/legal/privacy

4.9 PostHog (PostHog, Inc., USA) — product analytics

What it does: Records anonymous usage events (for example, “call started”, “voice selected”) together with basic app and device metadata (app version, iOS version, device model) so we can understand how the app is used and improve it.
Identifier: A pseudonymous device identifier that we generate on first launch and store in your device Keychain. It persists for the life of the device (surviving reinstalls) so usage metrics stay accurate. It is not linked to your name, email, or any account — we operate none.
What PostHog does NOT receive: Your microphone audio, conversation transcripts, or message content are never sent to PostHog.
Where it goes: PostHog US Cloud, USA.
Your control: Deleting the app stops further collection. To request deletion of analytics associated with your device identifier, contact us (Section 14).
Privacy: posthog.com/privacy

5. How We Use Your Data

We use your data solely to:

Provide the core functionality of Frontier Voice (voice and text AI conversations).
Maintain your conversation history and preferences on your device.
Route requests to the AI providers needed to respond to you.
Comply with legal obligations.

We do not use your data for advertising, profiling, or sale to third parties.

Processing Activity	Lawful Basis
Streaming audio to LiveKit and AI providers	Contract performance (Article 6(1)(b)) — necessary to provide the service you requested
Processing voice data (special category consideration)	Explicit consent (Article 9(2)(a)) — you grant microphone permission in iOS before any audio is processed
Storing transcripts and preferences on-device	Contract performance (Article 6(1)(b))
Complying with legal obligations	Legal obligation (Article 6(1)(c))

7. International Data Transfers

All third-party AI providers listed in Section 4 are based in the USA (with DeepSeek based in China). We rely on the following safeguards for international transfers:

Standard Contractual Clauses (SCCs): We rely on SCCs approved by the European Commission and incorporated into UK adequacy frameworks (UK IDTA or addendum) with each provider where required.
We select providers that publish their own data processing agreements and transfer mechanisms.

If you have concerns about transfers to a specific jurisdiction (e.g., DeepSeek / China), you can avoid those models by not selecting them in the app.

8. Data Retention

On-Device Data

Conversation transcripts and preferences are stored solely on your device.
Deleting the app removes all locally stored data.
Tapping “Delete account” within the app also wipes all local data.
No data is held on our servers, so there is nothing further to delete server-side.

Data Held by Third-Party Processors

Audio and transcript data processed by LiveKit and AI providers during a session is transient. Please refer to each provider’s retention policies (links in Section 4).
Analytics events held by PostHog are retained per PostHog’s retention settings and are tied to a pseudonymous device identifier, not your identity.

Because we hold no personal data on our own servers, most rights can be exercised directly by managing data on your device. However, you have the following rights and can exercise them by contacting us:

Right	How to exercise it
Access	Request a description of what data we hold or process about you
Rectification	Correct inaccurate data stored in the app (edit directly in-app, or contact us)
Erasure (“right to be forgotten”)	Use “Delete account” in-app, or contact us
Data portability	Your transcripts are stored on your device and accessible to you directly
Objection	Object to processing; noting this may prevent use of the service
Restriction	Request we restrict processing in certain circumstances
Withdraw consent	Use Settings → AI processing & your data → Withdraw permission in the app, and/or revoke microphone permission in iOS Settings, at any time

To exercise any right, contact: hello@getunlocked.ai

You also have the right to lodge a complaint with your supervisory authority:

UK: Information Commissioner’s Office (ICO) — ico.org.uk
EU: Your local Data Protection Authority

10. US Privacy Rights (CCPA / CPRA — California Residents)

10.1 Categories of Personal Information Collected

Category	Examples	Collected?
Identifiers	Name, email	No
Identifiers	Pseudonymous device identifier (analytics)	Yes — not linked to your name, email, or any account
Audio/voice data	Microphone audio during voice sessions	Yes — processed transiently; not stored by us
Internet/network activity	Anonymous app usage events (via PostHog)	Yes — no browsing history or cross-app activity
Geolocation	Precise location	No
Inferences	Profile drawn from personal info	No

We do not sell your personal information. We do not share your personal information for cross-context behavioural advertising.

10.3 Your California Rights

California residents have the right to:

Know what personal information we collect, use, disclose, or sell.
Delete personal information we hold about you.
Correct inaccurate personal information.
Limit the use or disclosure of sensitive personal information.
Non-discrimination — we will not discriminate against you for exercising these rights.

10.4 How to Submit a Request

Email: hello@getunlocked.ai with the subject line “CCPA Privacy Request”.

10.5 Authorised Agent

You may designate an authorised agent to submit a request on your behalf. We will require written proof of authorisation and may verify your identity directly.

11. Children’s Privacy

Frontier Voice is not directed at children under 13 (or under 16 in the EU/UK). We do not knowingly collect personal information from children. If you believe a child has provided us with information, please contact us so we can take appropriate action.

12. Security

We take reasonable technical and organisational measures to protect data. Because user data is primarily stored on-device and streamed (not stored) to third-party processors, the primary security layer is your device’s own security (Face ID, passcode, iOS encryption at rest) and the TLS-encrypted connections used by LiveKit and AI providers.

13. Changes to This Policy

We may update this policy from time to time. We will notify you of material changes by updating the “Last updated” date and, where required, by in-app notice. Continued use of the app after changes constitutes acceptance of the updated policy.

14. Contact

Mindcom Media Ltd Holly Cottage, Pond Road Bradfield, Norfolk, UK Contact: Tim O’Shea Email: hello@getunlocked.ai