Product Privacy Notice

Effective Date: 1 July 2026

This Product Privacy Notice explains how TurboHelp processes information when Customer uses TurboHelp on Customer Properties to provide support, automate responses, route conversations, and analyze support activity.

This notice is intended to help Customers understand what to disclose to End Users. It is not a substitute for Customer's own privacy policy.

1. Customer Controls the End User Relationship

Customer decides how to use TurboHelp on Customer Properties, what Customer Data to submit, which End Users may interact with Turbo, what knowledge sources to connect, and how support workflows are configured.

Customer is responsible for providing required notices, obtaining required consents, and maintaining a privacy policy that accurately describes Customer's use of TurboHelp.

2. What TurboHelp Processes for Customers

TurboHelp may process Customer Data, including:

• Support conversations, chat logs, messages, tickets, and replies.
• Help center content, product documentation, and other knowledge sources.
• End User identifiers such as name, email address, account ID, or user ID if provided.
• Conversation metadata such as timestamps, channel, status, routing, handoffs, escalation reasons, and resolution status.
• Input and Output from AI features.
• User feedback, ratings, corrections, and support team notes.
• Technical data such as IP address, browser, device, page URL, cookie identifiers, and event logs where applicable.

3. How TurboHelp Uses Customer Data

TurboHelp uses Customer Data to:

• Provide AI-assisted and human-assisted support workflows.
• Generate, summarize, classify, route, and evaluate support responses.
• Retrieve relevant knowledge base content.
• Escalate conversations to Customer's team.
• Display conversation history and analytics to Customer.
• Maintain security, prevent abuse, troubleshoot issues, and provide support.
• Analyze and improve the Services as described in the Terms and Data Use and Model Training Addendum.

4. AI-Assisted Support

Customer may use TurboHelp's AI agent, Turbo, to respond to End User questions or assist human support teams.

AI-generated Output may be inaccurate, incomplete, biased, unsafe, or unsuitable. Customer is responsible for configuring Turbo, reviewing Output where appropriate, and deciding when human review or handoff is needed.

Customer must notify End Users or obtain consent for AI-assisted support where required by law.

5. Cookies, Scripts, and Similar Technologies

TurboHelp may provide scripts, SDKs, cookies, local storage, pixels, or similar technologies to enable chat, support messaging, session continuity, product analytics, security, and troubleshooting.

Customer is responsible for:

• Disclosing TurboHelp's use on Customer Properties.
• Classifying cookies or tracking technologies under applicable law.
• Obtaining consent where required.
• Providing opt-out or preference controls where required.
• Configuring TurboHelp in a way that matches Customer's privacy commitments.

6. Service Improvement and Model Training

TurboHelp may create De-identified Data, Anonymized Data, Aggregated Data, Usage Data, and derived analytics from Customer Data.

TurboHelp may use this data during and after the customer relationship to operate, analyze, improve, train, fine-tune, evaluate, benchmark, secure, and support the Services and models, as described in the Data Use and Model Training Addendum.

Unless Customer has opted out, TurboHelp may also use Customer Data, including End User conversations, Input, Output, feedback, human corrections, resolution status, escalation reasons, handoffs, and workflow traces, to train, fine-tune, evaluate, benchmark, and improve TurboHelp models and AI systems.

Customer may opt out of use of Customer Data for model training by emailing [email protected] or using an in-product opt-out control if available. The opt-out does not limit use of Usage Data, Aggregated Data, security data, billing data, diagnostic data, or operational analytics needed to provide, secure, analyze, and improve the Services.

7. Third-Party Providers

TurboHelp may use third-party providers to host infrastructure, process data, send emails, monitor errors, process payments, provide analytics, and power AI features.

TurboHelp contractually restricts third-party LLM providers from using Customer Data to train or improve their own models. Third-party LLM providers may process Input and Output only to provide, secure, monitor, or support AI functionality, subject to applicable subprocessor terms.

Current and planned subprocessors are described in the Subprocessors List.

8. Sensitive Data

TurboHelp is not HIPAA-compliant at launch and does not offer a Business Associate Agreement at launch.

Customer must not submit Protected Health Information, medical records, diagnosis or treatment data, health insurance data, payment card data, government IDs, children's data, or other sensitive regulated data unless TurboHelp expressly agrees in writing.

9. End User Rights Requests

End Users should contact Customer to exercise privacy rights relating to Customer Data. TurboHelp generally acts as Customer's processor or service provider for Customer Data and will assist Customer as described in the Data Processing Addendum.

10. Ready-to-Copy End User Disclosure Snippet

Customer may adapt the following language for its privacy policy, support widget, or help center:

We use TurboHelp, an AI-assisted customer support platform operated by Textly Inc., to help answer support questions, route requests, summarize conversations, and improve our support experience. When you contact us through our support channels, your messages, account details you provide, conversation history, and related technical information may be processed by TurboHelp. Some responses may be generated or assisted by AI. AI responses may be inaccurate or incomplete, and we may review, correct, or escalate conversations to human support. We may use support interactions and feedback to improve our products and support operations. For more information about our privacy practices or to exercise privacy rights, contact us using the details in this policy.

Optional expanded model-improvement disclosure:

Unless we opt out or configure our account differently where available, TurboHelp may use support interactions, AI inputs and outputs, feedback, corrections, and resolution signals to improve TurboHelp services and AI systems. TurboHelp contractually restricts third-party LLM providers from using our customer support data to train or improve their own models.

Customer should review this snippet with counsel and tailor it to Customer's actual use of TurboHelp, cookie practices, AI disclosures, data retention, international transfers, and privacy rights process.

11. Contact

Questions for TurboHelp about this notice may be sent to [email protected].