Privacy Policy

• Each processing purpose has its own consent, switched independently, with history; withdrawal takes effect within 60 seconds.
• Nobody but you and your assigned reviewer can listen to your recordings. Managers see aggregates only.
• Recordings are kept for 30 days by default, then deleted. You can delete earlier.
• We do not sell data, do not use your data for advertising, and do not use the documents you upload to train third-party models.
• You export all your data or delete your account from inside the app; no email needed.

The rest of this page explains each point in detail.

We classify all data into 5 classes, and every access right in the system is tied to a class. The table below is how we answer “who can see what” in practice.

When you create an account: email, display name, market, interface language and organisation (if invited).

When you learn: your answers about goals, voice recordings and transcripts (with your consent), attempts, feedback, progress, and pseudonymised usage events (for example “session started”, duration).

When you upload documents: the document content (P4), used only to extract structured vocabulary and situations.

When you pay: we do not store card numbers; the payment provider processes them and sends us a transaction reference.

Technical: IP address (abuse prevention and rate limiting), browser type, error-tracking identifiers. Cookies are essential-only by default; analytics use a pseudonymous id and require you to opt in.

• Building your study plan and choosing tasks (rule-based software, explainable, with reason codes).
• Scoring and feedback: voice features, AI models, and calibrated human raters when needed.
• Creating evidence and conditional capability claims.
• Aggregate reporting for the organisation that provides your account (only if you consent to sharing with your manager).
• Support, billing, fraud prevention, legal compliance.
• Improving scoring quality with anonymised data (only if you consent to the research purpose).

We make no automated decisions with legal effect on you; capability claims are learning results, not HR assessments, and your organisation cannot view your private attempts to make personnel decisions.

• Assigned raters and teachers: only the data for the turn or session they are assigned, through purpose-bound views.
• The organisation providing your account: name, role, activation status, and aggregate reports (k ≥ 5) if you consent to sharing with your manager.
• Infrastructure and AI providers: storage, speech and language processing, email, payments, video for live sessions. They process under our contracts and may not use the data for their own purposes.
• Authorities: when required by law, to the minimum extent necessary, and we tell you when permitted.

We do not sell personal data and do not share it for advertising.

• Voice recordings and live recordings: 30 days, then deleted; your organisation can only set a shorter period. A recording that is evidence for a verified claim is kept longer only with your consent, and you can delete it at any time.
• Transcripts and voice features: same as the source recording.
• Documents you upload: until you delete them or withdraw consent.
• Progress, claims, plans: for the life of the account.
• Identity and invoices: for the periods required by accounting and tax law.
• Technical logs: at most 90 days, with emails and secrets redacted.

When you delete your account there is a 30-day grace period to change your mind; after that, data is hard-deleted except invoices and mandatory audit records.

Data is encrypted in transit and at rest. Every data table has a per-organisation access policy; cross-organisation access is tested automatically on every release.

Operations staff have no standing access to learning, voice or document data. Emergency access requires a reason, a second approver, expires automatically and is audited; you may be notified afterwards.

Staff with elevated rights must use two-factor authentication. We log authorisation decisions for risky actions.

If an incident affects your data, we notify you and the competent authority within the statutory deadline.

• View and edit: account details and goals under Me.
• Toggle each consent: Me → Privacy; effective within 60 seconds, with history.
• Export: request in the app, processed in the background, download link by email that expires after 7 days.
• Delete single recordings, documents, or your whole account (30-day grace period).
• Object to or restrict processing, and complain to the data-protection authority in your market.

We answer data requests within 30 days. Free of charge, except for excessive repeated requests.

The platform is not for people under 18 and we do not knowingly collect children's data. If you believe a child has created an account, contact us so we can delete it.

Changes that affect how we use your data are announced at least 30 days in advance by email and in the app, with a version and effective date. If a new purpose needs consent, we ask separately, off by default.

This is a draft; the official policy per market (Vietnam, Australia and later markets) will be finalised by counsel before launch.