Privacy Policy

Last updated: May 11, 2026

This privacy policy (“Policy”) describes how L.L. Studio Software LTD (“Operator,” “we,” “us,” or “our”), the operator of the Frontline mobile application, web platform, and related products and services (collectively, the “Services”), collects, uses, and protects the personally identifiable information (“Personal Information”) you may provide when using the Services. It also explains the choices available to you regarding our use of your Personal Information and how you can access and update this information.

This Policy is a legally binding agreement between you (“User,” “you,” or “your”) and L.L. Studio Software LTD. By accessing and using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Automatic collection of information

When you use the Services, our servers automatically record information that your device sends. This data may include your device’s IP address and location, device name and version, operating system type and version, language preferences, information you search for in the Services, access times and dates, and other usage statistics.

Information collected automatically is used only to identify potential cases of abuse, secure the Services, and produce statistical information regarding usage. This statistical information is not aggregated in a way that would identify any particular user.

TrueDepth API usage

The Frontline mobile application utilizes the front camera, enabled by the TrueDepth API. This API is used solely for video calls via AR Foundation, with no data collection or data sharing through this API.

Collection of personal information

You can access and use parts of the Services without telling us who you are or revealing any information by which you could be identified as a specific individual. If, however, you wish to use certain features in the Services, you may be asked to provide certain Personal Information. We receive and store any information you knowingly provide when you create an account, publish content, or fill any online forms in the Services. When required, this information may include:

Personal details such as name and country of residence
Contact information such as email address and business address
Account details such as user name, unique user ID, and password
Permissions to certain features on your mobile device such as contacts, calendar, and gallery
Content you upload or create within the Services, including videos, images, AR content, training flows, and chat or voice transcripts
Where AI Services are enabled by your organization (see AI Services below), any inputs you submit to AI features — such as text prompts, voice recordings for transcription, and captured frames — and the corresponding outputs

You can choose not to provide us with your Personal Information, but you may not be able to take advantage of some features in the Services

Use and processing of collected information

We use the Personal Information we collect for the following purposes:

We use the Personal Information we collect for the following purposes:

To create and manage user accounts
To provide and operate the Services
To improve user experience and develop new features
To respond to support requests and communicate with you
To detect and prevent abuse, fraud, and security incidents
To comply with legal obligations
Where AI Services are enabled by your organization, to process inputs through the AI sub-processor described in the AI Services section below

Processing of your Personal Information depends on how you interact with the Services, where you are located, and the applicable legal basis: (i) your consent for one or more specific purposes; (ii) performance of an agreement with you or pre-contractual obligations; (iii) compliance with a legal obligation; (iv) a task carried out in the public interest; or (v) the legitimate interests pursued by us or a third party.

AI Services

The Services include optional AI-enabled features (“AI Services”). The following terms apply when AI Services are in use.

Opt-in. AI Services are disabled by default. They are activated only when your organization (the customer of L.L. Studio Software LTD) makes a written request to enable them. If AI Services are not enabled for your organization, this section does not apply to you.

What AI processes. When AI Services are enabled, content you submit to AI features — including text prompts, voice recordings (for transcription and closed captions), uploaded files, and AR content — may be processed by our AI sub-processor in order to return an output to you.

Where AI processes data. AI Services are processed in Germany.

Sub-processors. We currently use Azure OpenAI (a service of Microsoft Corporation) as our AI sub-processor. We may add, change, or replace AI sub-processors over time. A current list of AI sub-processors is available on request from Support@frontline.io.

No model training. Your content is not used to train foundation AI models. Inputs to AI Services are processed solely to return outputs to you and are not retained by the AI subprocessor beyond brief, anonymized abuse-monitoring periods consistent with the subprocessor’s standard terms

Probabilistic outputs. AI outputs are generated using probabilistic models and may be inaccurate, incomplete, or unexpected. AI outputs are not a substitute for human judgment. Your organization is responsible for reviewing AI outputs before relying on them for operational, training, safety, or compliance purposes.

No automated decisions with legal effect. AI Services are not used to make decisions that produce legal effects concerning you or similarly significantly affect you within the meaning of Article 22 GDPR. AI Services assist users; they do not make individual determinations about employment, certification, eligibility, or comparable matters.

Transparency. When you interact with an AI feature, the feature is identified as AI-powered within the user interface. AI-generated content is labeled where required by applicable law.

Your rights regarding AI Services. You may decline to use AI features. Where AI Services are enabled at your organization’s request, you may direct your organization administrator to disable specific AI features for your account. You may also exercise the rights described in The rights of users below in respect of any Personal Information processed through AI Services.

Disclosure of information

Depending on the requested Services or as necessary to provide any service you have requested, we may share your information with trusted third parties that work with us, including:

AI sub-processors (currently Azure OpenAI / Microsoft Corporation), to provide AI Services when enabled
Cloud infrastructure providers used to host the Services
Customer support and analytics providers
Other affiliates and subsidiaries we rely upon to assist in operating the Service

These service providers are bound by contract to use Personal Information only as necessary to perform services on our behalf or to comply with legal requirements.

We do not share Personal Information with unaffiliated third parties for their own marketing or other purposes. We will disclose Personal Information if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request

Retention of information

We retain and use your Personal Information for the period necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law. AI inputs and outputs processed through AI Services are not retained beyond the period necessary to return the output to you, except where retention is required to operate a specific feature you have enabled (for example, persisting a training transcript you have generated).

We may use aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information is deleted. The right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

Transfer of information

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. AI Services are processed in Germany. Where transfers occur outside the European Economic Area, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses. You may obtain information about the specific safeguards applied by contacting us using the details in Contacting us.

The rights of users

You may exercise the following rights regarding your Personal Information:

Withdraw consent where you have previously given consent to processing
Object to processing carried out on a legal basis other than consent
Learn whether your information is being processed and obtain a copy of the information undergoing processing
Verify the accuracy of your information and ask for it to be updated or corrected
Restrict the processing of your information under certain circumstances
Obtain the erasure of your Personal Information under certain circumstances
Receive your information in a structured, commonly used, machine-readable format, and transmit it to another controller where technically feasible
Object to any decision made solely on automated processing that produces legal effects or similarly significantly affects you (see AI Services — we do not currently engage in such automated decision-making)

The right to object to processing

Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for our legitimate interests, you may object to such processing by providing grounds related to your particular situation.

Data protection rights under GDPR

If you are a resident of the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain data protection rights and we aim to take reasonable steps to allow you to exercise them. These include:

The right of access to your Personal Information
The right to rectification of inaccurate or incomplete information
The right to erasure (“right to be forgotten”) under certain conditions
The right to object to processing
The right to restriction of processing
The right to data portability
The right to withdraw consent at any time where processing was based on consent
The right to lodge a complaint with a Data Protection Authority

For more information, please contact your local Data Protection Authority in the EEA, UK, or Switzerland.

California privacy rights

California residents have specific rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), including:

The right to know what categories of Personal Information we collect, the sources, and the purposes for collection
The right to access and obtain a copy of your Personal Information
The right to deletion of your Personal Information, subject to legal exceptions
The right to correct inaccurate Personal Information
The right to opt out of the sale or sharing of Personal Information (we do not sell or share Personal Information as those terms are defined under CPRA)
The right to limit the use and disclosure of Sensitive Personal Information. We may process voice recordings (when AI Services for transcription are enabled) and biometricrelated data via the TrueDepth API. These categories may be considered Sensitive Personal Information; we use them only for the purpose of providing the requested Service and not for inferring characteristics about you
The right to opt out of automated decision-making technology that produces legal or similarly significant effects. We do not use AI Services for such decisions

California residents may also, once per calendar year, request information about Personal Information shared with third parties for those parties’ direct marketing purposes. We do not share Personal Information for third-party direct marketing.

How to exercise these rights

Any requests to exercise your rights can be directed to us through the contact details in this Policy. We may ask you to verify your identity before responding. Your request must include sufficient information to allow us to verify that you are the person you claim to be or an authorized representative, and to properly understand and respond to the request. We cannot respond to your request or provide Personal Information unless we first verify your identity or authority and confirm that the Personal Information relates to you.

Privacy of children

We do not knowingly collect Personal Information from children under the age of 18. AI Services are not directed at, and should not be used by, individuals under 18. If you are under 18, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission. If you have reason to believe that a child under 18 has provided Personal Information to us, please contact us. You must also be at least 16 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).

Links to other resources

The Services may contain links to other resources that are not owned or controlled by us. We are not responsible for the privacy practices of such other resources or third parties. We encourage you to read the privacy statements of each resource that may collect Personal Information.

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards to protect Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. You acknowledge that (i) there are security and privacy limitations of the Internet beyond our control; (ii) the security, integrity, and privacy of any information exchanged between you and the Services cannot be guaranteed; and (iii) any such information may be viewed or tampered with in transit by a third party, despite best efforts.

Data breach

In the event we become aware that the security of the Services has been compromised or users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including security attacks or fraud, we will take reasonably appropriate measures, including investigation, reporting, notification to and cooperation with law enforcement authorities, and notification to affected individuals where there is a reasonable risk of harm or where required by law. When we provide notice, we will post a notice within the Services and send you an email at the address you have provided.

Changes and amendments

We reserve the right to modify this Policy or its terms relating to the Services from time to time at our discretion and will notify you of any material changes to the way in which we treat Personal Information. When we do, we will revise the “Last updated” date at the top of this page. We may also provide notice in other ways, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon posting unless otherwise specified. Your continued use of the Services after the effective date of the revised Policy will constitute your consent to those changes. We will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time it was collected.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all of its terms and conditions. By accessing and using the Services you agree to be bound by this Policy. If you do not agree, you are not authorized to access or use the Services.

Contacting us

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to your rights and your Personal Information, you may send an email to Support@frontline.io.

L.L. Studio Software LTD

This document was last updated on May 11, 2026.