Privacy notice

01 Who we are

Hark is a CRM and AI outreach product for sales and marketing teams in healthtech and life sciences. Hark is a product of Twentysix Labs LLC, a Delaware limited liability company at 8 The Green #7811, Dover, DE 19901, United States ("Hark", "we", "us").

Questions about this policy or your personal data go to privacy@harkcrm.ai.

02 What this policy covers, and our two roles

Hark handles personal data in two different roles. The role decides who you should ask about it.

Hark as a processor (service provider). Our customers are businesses. A customer's workspace holds its CRM: the people and companies it sells to, its mail and meetings, its notes and files, and its outreach. We call this Customer Data. The customer decides what goes in and why. For Customer Data the customer is the controller (or "business" under California law), and Hark processes it only to provide Hark to that customer, under our agreement with them. If you are a person in a customer's CRM, section 12 explains what to do.

Hark as a controller. We decide how to handle a smaller set of data for our own purposes:

• account data about the people who sign in to Hark;
• billing contacts and records;
• usage analytics, security logs and support conversations;
• data about people we contact to sell Hark, and visitors to Hark's own website.

This policy describes both. For Customer Data, our Terms of Service and our Data Processing Addendum (DPA) take priority over this policy. The DPA is published alongside our Terms and applies automatically to every customer whose data is covered by the GDPR, the UK GDPR or the CCPA, on every plan.

03 Hark is not for protected health information

Hark is built for selling to healthcare organisations, not for patient care. It is not designed to receive, store or send protected health information (PHI) as defined under HIPAA, or equivalent patient health data under other laws.

Customers must not put PHI into Hark: not in records, notes, files, mail they connect, meeting transcripts, call recordings or capture sessions. Hark is not a HIPAA-compliant service and does not sign Business Associate Agreements. If PHI reaches Hark, tell us, and we will help you remove it.

Some features screen for obvious patient identifiers. For example, Hark's writing-style learning skips messages containing labelled patient identifiers. These screens are a safeguard, not a guarantee. They will miss identifiers written without a label. The customer remains responsible for keeping PHI out.

04 What we collect

4.1 Account data (Hark is controller)

When you create an account or are invited to a workspace, we store:

• your name, email address and whether it is verified;
• optional profile details: a photo, phone number, first, last and preferred name, a short biography;
• your password, stored as a one-way hash, if you sign in with a password;
• your workspace memberships and role (owner, admin or member), and invitations you send or receive, including the inviter's name and email;
• your sessions, including the IP address and browser user agent of each sign-in;
• API keys you create, and connections you approve for AI assistants (see 4.10).

You can sign in with an email and password, a one-time code sent by email, or your company's single sign-on (OpenID Connect). If your company has verified its email domain for single sign-on in a workspace, signing in with an address on that domain can add you to that workspace as a member automatically.

4.2 CRM records (Customer Data)

A workspace holds the records its team creates or imports: people, companies, deals, lists, tasks, notes, documents and attached files, and a timeline of interactions. Records can come from:

• people typing them in, or importing a CSV;
• connected tools a customer chooses, such as a connected mailbox or calendar (4.3), LinkedIn (4.6) or a CRM import;
• Hark's AI features, which propose records and field values (section 5);
• enrichment, which looks up work email addresses, phone numbers and company details (4.7);
• the customer's website tracker (4.8).

Hark keeps a change history on records: who changed what, when, and whether the change came from a person, an agent or the system.

4.3 Connected mailboxes and calendars (Customer Data)

A member can connect a Google Workspace or Microsoft 365 mailbox and calendar. An admin can also connect a shared team mailbox, such as a hello@ address.

What Hark asks permission for. For Google: read mail, send mail, read calendar, and read Google Meet transcripts. For Microsoft 365: read mail and read calendar. Hark cannot send mail through Microsoft. Teams meeting transcripts are a separate permission a member chooses to grant.

What Hark reads and stores.

• Hark syncs the connected mailbox going back up to three years, then keeps it current. It reads every folder except spam, trash, drafts and outbox. It is not limited to mail with people already in the CRM.
• For each message Hark stores the headers (from, to, cc, bcc, subject, date and message identifiers), the short preview snippet the provider supplies, and whether the message has attachments.
• Hark does not store message bodies or attachments. When a feature needs a body, Hark reads it from the provider at that moment, uses it for that task, and keeps only the result.
• For calendar events Hark stores the title, organiser, attendees, start and end times, and the meeting link.

What Hark does with it.

• It files mail and meetings on the right people and companies, and updates last-contact dates.
• People the member wrote to or met are added as contacts in the member's own set. A stranger who writes in is only proposed as a contact, for a person to accept or decline.
• When an admin turns on mail intelligence (off by default), Hark's AI reads thread bodies to propose tasks, meeting requests, next steps and follow-ups. It may also read job titles and employers from email signatures.
• When mail intelligence is on, Hark learns each member's writing style from their own sent messages (see 5.4).
• Hark sends email only through a connected Gmail account, using the member's own credential (see 5.3 for when a person approves each message).

A member chooses how much of their mailbox teammates can see. This is the mailbox's sharing level.

4.4 Meetings, calls and recordings (Customer Data)

Meeting transcripts. A member can connect sources that already hold transcripts of their meetings: Google Meet, Microsoft Teams and Zoom (cloud recording files). Hark stores the transcript text as sentences with speakers, and uses AI to write a summary note, propose field changes and tasks, draft a follow-up, and give sales-call coaching. The follow-up draft is never sent from the meeting feature.

AI phone calls. A workspace can set up a voice agent that places outbound phone calls through Twilio. Calls are recorded. Each call begins with an opening that names the company, names the member it calls for, and says the call is recorded. The agent only calls people on a call list a member approved. A do-not-call list is kept and honoured. Hark stores the recording in private storage, plus the transcript and a summary.

4.5 Phone app (Customer Data)

The Hark phone app asks for the microphone and the camera. It does not ask for your contacts or your location.

• Dictated notes. Audio is sent to OpenAI for transcription and is not stored. Only the text you save is kept.
• Voice memos. The audio and its transcript are stored. The audio is deleted automatically after 30 days by default. An admin can change this. The transcript and any note made from it are kept.
• Capture sessions. A member can record conversations at an event, including with the screen off. Before the first session the member must accept: "Record only where and when recording a conversation with one party's consent is legal. You are responsible for this. Hark is not legal counsel." Audio is transcribed by xAI by default, or by Deepgram if the workspace chooses it. Hark matches speakers to contacts from context. It does not create or compare voiceprints. Audio is deleted after 30 days by default, unless a member marks a session to keep. Transcripts are kept.
• Business cards. A card photo is sent to Anthropic's Claude to read the name, title, company and contact details. The photo is not stored. The member checks and confirms every field before anything is saved.
• Notifications. The app registers a push token with Expo, which delivers Hark's notifications.

4.6 LinkedIn, Reddit and the browser extension (Customer Data)

LinkedIn through Unipile. A member can connect their own LinkedIn account through Unipile, a service that holds the connected session on Hark's behalf. Hark then:

• reads the member's LinkedIn inbox metadata (who, when, which conversation), but not the message text, which is read from LinkedIn only when shown;
• reads recent connections, pending invitations and profiles;
• runs people searches through the member's account;
• records people who react to or comment on the member's own posts (including comment text), and commenters on posts the workspace watches;
• copies people's LinkedIn profile photos into Hark's private storage;
• sends connection requests and messages as part of sequences the workspace sets up (see 5.3).

Reddit. Hark finds public Reddit threads through listening services and web search, and through the extension. It stores the thread title and text, the subreddit, the matching comment's author name and text, and Hark's score of the thread. Hark never posts to Reddit. A person copies an approved reply and posts it themselves.

Browser extension. The extension works only on LinkedIn, Gmail, Reddit and Hark's own site. It does not read cookies or browsing history. It reads a page only when the member opens the side panel or asks it to:

• on a LinkedIn profile: name, title and current company;
• on LinkedIn search results: up to 10 people's names, profile links and titles;
• in Gmail: up to 50 participants' names and email addresses, never the subject or message;
• on a Reddit thread: the post and up to 100 comments with their authors.

Opening the panel on a profile checks with Hark whether that person is already in the CRM. The extension never sends LinkedIn messages itself.

4.7 Enrichment and public sources (Customer Data)

When a member asks Hark to enrich a record, Hark sends Apollo the person's email, LinkedIn profile link, or name and company, and receives work email addresses, phone numbers and company details. Enrichment and phone number reveals use the workspace's data credits.

Hark also reads public company information from openFDA and ClinicalTrials.gov by company name, searches the public web through Exa, and watches public competitor web pages through Firecrawl. Search requests can include a person's name and company.

4.8 Website visitor tracking on customers' sites (Customer Data)

A customer can install Hark's tracking script on its own website. On that site, the script:

• sets two first-party cookies, _hk_v (a random visitor ID) and _hk_ft (first touch), each lasting 395 days;
• records page paths, the referrer, campaign tags (UTM and similar) and clicks on outbound links and buttons, including their text;
• records forms submitted on the site, up to 40 fields of 512 characters each. It never reads password, hidden, file or payment card fields, or values that look like a card number;
• if a visitor arrives from a tracked link in an email Hark sent, links that visitor to the contact, including their earlier visits on that browser;
• can create a contact from an email address submitted in a form, up to a per-hour limit the customer sets.

Hark does not store visitors' IP addresses in its tracking records. It uses the IP address briefly to limit request rates. Hark does not use any service to turn IP addresses into company names.

The script does not show a consent banner and does not itself read Do Not Track or Global Privacy Control signals. The customer is responsible for the notice and consent its own visitors are owed (see the Terms).

Email open and click tracking. For a campaign or sequence, a customer can turn on open tracking (a 1x1 image) and click tracking (rewritten links). Both are off by default. Hark records only the kind of event and its time. Every campaign and sequence email carries an unsubscribe link and an unsubscribe header, and Hark keeps a suppression list.

4.9 Usage analytics, logs and devices (Hark is controller)

We use PostHog to understand how Hark is used and to find errors. Hark's app and Hark's marketing website use separate PostHog projects, set up differently.

In the Hark app, once you sign in:

• What PostHog holds about you: your Hark user ID (a random identifier, not your name or email), your role, your workspace's ID, the date you joined it, and a flag marking Hark's own staff; masked session recordings; and product events. We never send PostHog your name or email address. A filter removes free-text fields (names, emails, notes, message bodies, subjects, transcripts, search text) before an event leaves Hark.
• Interactions. We record which controls are clicked, heatmaps, rage clicks and unhandled errors. All text and attributes on the page are masked.
• Session replay. A masked recording of your session in the web app is captured. Every input and every piece of text is masked, and images, video and hidden fields are blocked. Recordings are kept for 30 days. You can ask us to stop recording your sessions by writing to privacy@harkcrm.ai.

• AI traces. Records of AI calls are kept in our own database for 14 days. In production they are also sent to PostHog, after emails, phone numbers and names are removed and long values are cut short.

On Hark's marketing website, PostHog runs in cookieless mode. It sets no cookies and uses no local storage. It creates no personal profiles and never identifies a visitor. It does not record sessions. It counts visits with an anonymous identifier that changes every day, and gives us aggregate counts: pages viewed, referrers, time on page, page performance and errors.

Server logs are kept for a limited period by our hosting provider, Railway.

4.10 AI assistants you connect to Hark

A member can connect Hark to an AI assistant such as Claude or ChatGPT, through Hark's MCP server, or use a personal API key. That assistant then acts in the workspace as that member, with that member's permissions. Whatever the assistant reads from Hark goes to the assistant's provider under the member's own agreement with that provider. Revoking the connection removes its access.

4.11 Billing (Hark is controller)

When a workspace is created we create a customer record with Stripe (the workspace name and the creator's email). Plans, credit allowances, credit packs and auto top-up are managed through Autumn, which works on top of Stripe. Payment card details are collected by Stripe; Hark does not see or store card numbers.

05 How Hark uses AI

AI suggests, and people decide, by default. Hark's AI changes to records go through a review queue. Each proposed change shows its source and waits for a person to accept or decline it. Every AI change is recorded and can be undone.

There are exceptions, and we list them so nothing is a surprise.

5.1 Changes that apply without review by default

• record summaries that refresh on their own;
• people, buyers and companies that AI finds for a workspace's prospecting;
• a new deal opened when a reply books or asks for a meeting;
• a value scored "verified" going into an empty field (for example, a title confirmed by two of a person's own email signatures);
• notes and interactions written by a workspace's named agents.

An admin can set any of these to wait for review. An admin can also set most other kinds of change to apply automatically. Enrichment never overwrites a value a person entered.

5.2 Messages that always wait for a person

AI-written emails, LinkedIn messages, social posts and replies, and paid post boosts always wait for a person's approval. An admin cannot switch these to automatic in general. The only exceptions are the specific opt-ins in 5.3.

5.3 Sending: what a person approves

• One-off emails and replies are sent only when a person sends them.
• Email campaigns are approved as a whole. The approver sees every recipient's message. Later steps in a sequence then send on schedule.
• Unattended email sequences. One admin can switch a specific sequence so that its AI-written steps send without per-message review. This works only from a separate outreach mailbox, within a daily cap, warm-up and bounce limits. Any change to the sequence switches it back to review.
• Unattended AI replies work only inside such a sequence, under its opt-in.
• LinkedIn sequences. Connection requests and messages a member wrote, or a template, are sent on schedule to everyone enrolled in the sequence. People can be enrolled automatically, including people AI found (5.1). AI-written LinkedIn messages wait for review unless an admin switches that sequence to unattended. Daily limits, spacing between actions and an emergency stop apply.
• Unattended LinkedIn posting. A member can let Hark's post suggestions for their own LinkedIn publish under their standing approval. It applies only to that member's own account.
• AI phone calls go only to people on a member-approved call list (4.4).
• Reddit: Hark never posts.

5.4 Writing style

When mail intelligence is on, Hark learns each member's writing style from that member's own sent emails and LinkedIn messages. Hark keeps references to those messages, a numerical representation (an embedding) and tags. It does not keep the text. Hark also keeps a short written style profile. A member's style is used to draft messages sent as that member. A member can see what was learned and delete examples. Team mailboxes are not learned from. Agents in the workspace can read a member's style only to draft a message sent as that member, and each such read is logged and shown to the member.

5.5 Customer Data stays in its workspace

Every CRM table is tied to a single workspace. Search, embeddings and AI context are limited to the workspace that owns the data. We do not use one customer's data to serve another customer.

5.6 Model providers and training

Hark does not train models on Customer Data. Hark has no models of its own.

Hark sends a model provider only the content an AI task needs (for example a thread, a transcript or a record), so that the provider can return a result. Our AI provider for drafting, reading and agents is Anthropic. Other providers are used for specific jobs, listed in section 7.

06 Why we use personal data, and our legal bases

For Customer Data, we process it only to provide, secure and support Hark for the customer, following the customer's instructions. The customer is responsible for its own legal basis.

For data where Hark is controller:

07 Who we share data with

We do not sell personal data. We do not share it for cross-context behavioural advertising.

We share personal data with the service providers (subprocessors) below, only as needed for each to do its job for Hark. Some are used only when a customer turns on the feature they support.

We also share data:

• with the customer's own chosen tools, when a member connects them (for example, an AI assistant through Hark's MCP server, or a Slack workspace);
• when the law requires it, or to protect people's safety, Hark's rights, or the security of the service;
• in a business transfer, such as a merger or sale, under confidentiality and with this policy continuing to apply.

We keep this list current. We email workspace owners 30 days before a new subprocessor receives Customer Data. A customer may object; if we cannot resolve the objection, the customer may end its subscription and receive a pro-rata refund of prepaid fees.

08 Where data is stored and international transfers

Hark is run from the United States, and Hark's servers, databases and file storage are in the United States. Some of our providers may process data in other countries. PostHog processes data in the United States.

When we transfer personal data from the European Economic Area, the United Kingdom or Switzerland to a country without an adequacy decision, we rely on the European Commission's Standard Contractual Clauses (2021) and the UK Addendum, which are built into our DPA, or on a provider's certification under the EU-US Data Privacy Framework where it has one.

09 How long we keep data

10 Deleting and exporting data

Exporting. Members can export people, companies and deals to CSV from any table, and export a list to CSV. A workspace owner can also ask us at support@harkcrm.ai for a full export of the workspace's records, in CSV or JSON. We provide it within 30 days.

Deleting a record. Deleting a record in Hark deletes it from Hark. If the record came from Apollo, Hark remembers not to bring it back; it does not delete it at Apollo.

Deleting a workspace. A workspace owner asks us at support@harkcrm.ai. We confirm the request comes from an owner and delete the workspace within 30 days. Deletion removes every row of the workspace's data at once, deletes its stored files (attachments, memos, capture audio, call recordings and members' uploads), and cancels its billing. It cannot be undone, so export first. Some things remain:

• data already held by third parties the workspace used, such as copies at Twilio, Apollo, Unipile, Google, Microsoft or Stripe, under their own terms;
• analytics in PostHog, labelled with the workspace's ID, until PostHog's retention removes them. Session recordings are deleted after 30 days. Product analytics events are kept for up to 7 years, the longest our analytics provider allows, and we may delete them sooner;
• logs of calls to Hark's MCP server;
• backups, until they expire (up to 35 days).

Deleting your account. Ask us at privacy@harkcrm.ai. We delete your account within 30 days. Records you created in a workspace stay with that workspace, because they belong to the customer.

11 How we protect data

• All connections to Hark use HTTPS, with HTTP Strict Transport Security.
• Sign-in sessions are stored in our database and expire after 30 days. Passwords are stored as one-way hashes.
• Each workspace's data is separated, and access is limited by role. Owners and admins can change settings; members can read and edit records.
• Private files are kept in storage with no public address. They are reached only through signed links that expire within minutes.
• Some third-party secrets, such as tokens for connected business tools and webhook secrets, are encrypted with AES-256-GCM before they are stored.

• Record changes are logged with who made them and when. Each AI proposal records whether it was applied automatically or by a person, and who decided it.
• Requests are rate limited.

Hark does not hold a SOC 2, ISO 27001, HITRUST or HIPAA certification or attestation. No system is perfectly secure. If we confirm a breach that affects Customer Data or your personal data, we will tell affected customers without undue delay, and within 72 hours of confirming it.

12 If you are a person in a Hark customer's CRM

If a company uses Hark to contact you, that company decides what it holds about you and why. Please send your request to that company first. If you write to us, we will pass your request to the customer and help them answer it.

You may have been added because you emailed or met someone at that company, because they found you on LinkedIn or the web, or because you visited their website and later clicked a link they sent you. To stop marketing email from a company that uses Hark, use the unsubscribe link in its email. Hark suppresses that address for that company's whole workspace and stops its remaining campaign and sequence emails to you.

13 Your rights

Everyone. You can ask us what personal data we hold about you as controller, and ask us to correct or delete it. Write to privacy@harkcrm.ai.

EEA, UK and Switzerland. You have the right to access, correct, delete, restrict or object to our processing of your personal data, and to data portability. Where we rely on consent, you can withdraw it at any time. You can complain to your local data protection authority. In the UK, that is the Information Commissioner's Office.

California. Under the CCPA as amended by the CPRA, you have the right to know what personal information we collect, use and disclose; to delete it; to correct it; and to opt out of its sale or sharing. We do not sell or share personal information as those terms are defined, and we do not use sensitive personal information for purposes that would give you a right to limit it. We will not discriminate against you for using these rights. You may use an authorised agent. We will verify requests by matching the email address on the account.

In the last 12 months we collected these categories, for the purposes in section 6: identifiers (name, email, IP address, user ID); commercial information (plan, billing and credit purchase records); internet activity (masked product usage); professional information (role and workspace); and audio recordings, where a member uses voice features. For Customer Data, Hark acts as a service provider to the customer.

We answer verified requests within the time the law sets, usually 30 days (GDPR) or 45 days (CCPA).

14 Cookies and similar technologies

On Hark's web app:

On Hark's marketing website: PostHog runs in cookieless mode and sets no cookies (section 4.9). The site shows no cookie banner because it uses no cookie-setting tools. If we ever add one, such as a tag manager or an advertising pixel, it will load only after you accept it in a consent banner.

On customers' websites (when they install Hark's tracker): _hk_v and _hk_ft, 395 days (section 4.8). The customer is responsible for telling its visitors about them and getting consent where required.

15 Children

Hark is a business product. It is not for anyone under 18, and we do not knowingly collect children's personal data.

16 Changes to this policy

We will post any change here and update the date at the top. If a change is material, we will email workspace owners 30 days before it takes effect. A change the law requires may take effect sooner.

17 Contact

Twentysix Labs LLC 8 The Green #7811, Dover, DE 19901, United States privacy@harkcrm.ai