Data Privacy Compliance
We keep the minimum, we keep it in your region — Europe or the United States — and we use it only for learning.
Data privacy commitments
GDPR
Designed and operated in compliance with the GDPR, with a Data Processing Agreement for every client.
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Designed and operated in compliance with the GDPR and the Swiss FADP, with a Data Processing Agreement available for every client.
Data residency
European clients: EU (AWS, Ireland region). US clients: United States.
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Data is processed and stored in the client's own region: the European Union (AWS, Ireland region) for European clients, the United States for US clients.
Minimal data
Name, surname and work email, typically via your SSO. No other personal identifiers.
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Minimal personal data: name, surname and work email, typically received through your single sign-on. No other personal identifiers are requested or collected; what the trainee says in a session is processed as described below.
Pseudonymized processing
Identifiers removed before any content reaches an external service.
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Before any content reaches an external service, direct identifiers are removed and replaced by a transactional identifier. External providers never receive names or emails.
Retention you configure
Recordings kept only for the trainee's own replay, then deleted automatically.
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Audio recordings are kept only to let the trainee listen to their own conversation again, for a period you configure, and are then deleted automatically. Text transcripts follow your retention directives.
Your rights, exercised
Access, update and deletion for every user; client-requested deletion anytime.
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Every registered user can access, update or delete their data. Client-requested deletion is supported at any time.
Data categories and purposes
Account data
Name, surname, work email. Purpose: access and program assignment.
Conversation text
What the trainee typed or said, transcribed. Purpose: feedback and measurement for the learner.
Audio
Only for transcription and the trainee's own replay. Not analyzed.
Self-assessments
The trainee's own ratings. Purpose: the self-awareness measure.
Program data
Participation and aggregate results. Purpose: steering the program.
Never collected
Video, images, biometric or physiological data, device sensors.
Purpose-limited learning data
Learning data exists for one purpose: helping the person who practiced to improve. Detailed data lives in the learner's private space; the organization receives program-level data. Nothing is shared with third parties beyond the processors listed in the Data Processing Agreement, who receive pseudonymized content only, and no client data is used to train models.
Discuss your privacy requirements
Our DPA, data-flow description and questionnaire answers are ready for your DPO.