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Privacy Policy

Last updated: October 5, 2026

This privacy notice for SalesCoach365 ("SalesCoach365," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Visit our website at https://salescoach365.net, or any website of ours that links to this privacy notice
  • Use the SalesCoach365 web application to practice sales conversations through AI-driven roleplay scenarios, by text or by voice
  • Engage with us in other related ways, including sales, marketing, demos, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the features you use. This includes account details (such as your name, work email, and organization) and the content of your practice sessions: the messages you type, and, if you use voice mode, the audio of your voice, transcripts, and a recording of the practice call, along with the AI-generated responses, scores, and feedback.

Do we process any sensitive personal information? We do not intentionally collect sensitive personal information. Please do not enter or say real customer information (such as Social Security numbers, financing details, or health information) in practice sessions. Account log-in credentials are collected only to authenticate you. Voice practice sessions are recorded, but we do not use recordings or your voice to identify you.

Do you receive any information from third parties? Yes. Your organization (for example, your dealership's administrator) may provide us with your name and work email to set up your account. We may also collect business contact information about dealership personnel from public sources for business-to-business outreach.

How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

Who can see my practice sessions? Managers at your own organization can view essentially all of your data in the Services, including your practice sessions, results, and voice recordings. Our platform administrator can also access information across organizations to operate and support the Services. See Section 3.

Do we use AI? Yes. Our roleplay characters and feedback are generated by AI models operated by Google. Your typed messages, and in voice mode the audio of your voice, are sent to Google to produce responses. See Section 7.

Do we sell your information? No. We do not sell or share your personal information for advertising.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties, such as cloud, hosting, authentication, email, analytics, and AI service providers.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information.

How do I exercise my rights? The easiest way is to contact us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the notice in full below.

TABLE OF CONTENTS

  1. What information do we collect?
  2. How do we process your information?
  3. What is our role, and who can see your information?
  4. When and with whom do we share your personal information?
  5. What is our stance on third-party websites?
  6. Do we use cookies and other tracking technologies?
  7. How do we use artificial intelligence?
  8. Where is your information stored?
  9. How long do we keep your information?
  10. How do we keep your information safe?
  11. Do we collect information from minors?
  12. What are your privacy rights?
  13. Controls for do-not-track features
  14. Do California residents have specific privacy rights?
  15. Do Virginia residents have specific privacy rights?
  16. Do we make updates to this notice?
  17. How can you contact us about this notice?
  18. How can you review, update, or delete the data we collect from you?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us, including the content of your practice sessions.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services (such as roleplay practice sessions), or otherwise contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the features you use. The personal information we collect may include the following:

  • Names
  • Work email addresses
  • Your role within your organization (for example, sales representative or manager) and your organization's name
  • Email and password credentials (handled through Google Firebase Authentication)
  • Billing contact information
  • Practice session content (text): the messages you type during roleplay scenarios, the AI-generated responses, session transcripts, the scenarios you select, and session outcomes
  • Practice session content (voice): if you use voice mode, the audio of your voice as you speak, transcripts of both sides of the conversation, and a recording of the practice call that includes your voice and the AI character's voice
  • Results and feedback: scores, AI-generated feedback, key moments, the AI's read of the simulated buyer's sentiment, and which scenario criteria you met
  • Information your manager adds: comments on your practice sessions (and your replies), and scenarios assigned to you, including due dates and target scores
  • Scenarios your organization creates, which may include information about your organization's products and sales process
  • Demo requests: if you request a demo on our website, your name, work email, company, team size, industry, and any message you include
  • Communications with us, such as support requests and feedback

Sensitive Information. We do not intentionally collect sensitive personal information, such as Social Security numbers, driver's license or government ID numbers, health information, or financial account numbers. Our practice scenarios are fictional. Please do not enter or say real customer personal information or confidential deal information in practice sessions. The only information we collect that some privacy laws treat as sensitive is your account log-in credentials, which we use solely to authenticate you and secure your account.

Voice Recordings. Voice mode is optional. Before a voice session starts, the app tells you that the call is recorded, saved to your performance review, and that your manager can listen to it. Voice mode requires your permission to use your device's microphone, which your browser will ask for; if you decline, you can still use text mode. We use recordings only so that you and your manager can review your practice. We do not use recordings or your voice to identify you, and we do not create voiceprints.

Payment Data. We do not currently collect payment card or bank account details through the Services. We collect billing contact information (such as a billing name and email address) so that we can invoice your organization. If we later add online payments, payment details will be collected and stored by a third-party payment processor, and we will update this notice to identify it.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also use cookies and similar technologies. You can find out more about this, and about the analytics we use on our website and in the application, in Section 6.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings, and information about your activity in the Services (such as date/time stamps, pages viewed, scenarios started and completed, session length, and other actions you take), and device event information (such as system activity and error reports).
  • Device Data. We collect device data such as information about the computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this may include your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider, operating system, and system configuration information.
  • Location Data. We collect approximate location information derived from your IP address. We do not request precise (GPS) location from your device.

Information collected from other sources

In Short: We may collect limited data from your organization and from public sources.

  • From your organization. If your dealership or company is a customer, its administrators may provide us with your name, work email, and role so that we can create your account.
  • From public sources (business outreach). To tell dealerships about our Services, we may compile business contact information about dealership personnel, such as general managers, from publicly available sources like dealership websites and business directories. This information may include name, job title, dealership name, business address, business phone number, and business email address. We use it only for business-to-business communications, and you can ask us to remove you at any time (see Section 12).

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of the Services. We process your information to run text and voice roleplay sessions, generate AI character responses and feedback, save your session history and voice recordings so you and your manager can review them, and provide progress and performance reporting to you and your organization.
  • To support coaching within your organization. We process your information so that your managers can review your sessions, leave comments, and assign scenarios to you.
  • To respond to user inquiries and offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with the Services.
  • To respond to demo requests. We process the information you submit through our website's demo form to contact you and schedule a demo.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To manage subscriptions and billing. We may process your information to set up, invoice, and manage your organization's subscription.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us, and business contact information obtained from public sources, for our business-to-business marketing purposes, in accordance with your marketing preferences. You can opt out of our marketing emails at any time (see Section 12).
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention, abuse prevention, rate limiting, limiting each account to one active sign-in, and automatically signing out inactive sessions.
  • To identify usage trends and improve the Services. We may process information about how you use our Services to better understand how they are being used, to improve scenarios and features, and to manage costs and performance. In the application, we use PostHog for this product analytics (see Section 6).
  • To find and fix errors. We record errors that occur in the application, along with the screen where they happened and technical details, so we can diagnose and fix problems.
  • To determine the effectiveness of our marketing and promotional campaigns.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

We do not use your personal information for targeted advertising.

3. WHAT IS OUR ROLE, AND WHO CAN SEE YOUR INFORMATION?

In Short: For information about users at our customers, we generally act on behalf of the customer. Managers at your organization can see your practice sessions, including voice recordings, and our platform administrator can access information across organizations to run the Services.

Our role. When a dealership or other organization (a "Customer") signs up for the Services and its personnel use them, we process user account information and practice session content on the Customer's behalf and under our agreement with the Customer. In those situations, the Customer decides who has access and how the information is used, and we act as its service provider (or "processor"). This privacy notice does not replace the Customer's own privacy policies. If you want to know more about how your employer uses your information, please contact your employer.

For information about website visitors, prospective customers, and people who contact us directly, and for our own business operations, we act as the business or "controller."

Who can see your practice sessions. The Services are designed for sales training. Managers within your organization can view essentially all of the information associated with users in their organization, including practice session transcripts, scores, feedback, progress, and account details, and they can listen to voice session recordings. Managers can also comment on your sessions and assign scenarios to you. Users at other Customers' organizations cannot see your information.

Our access. Our platform administrator account can view information across all Customer organizations, including practice session content and voice recordings. We use this access only as needed to operate, secure, support, and improve the Services, and we treat Customer information as confidential.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we share personal information with are as follows:

  • AI Model Providers: Google LLC, through the Gemini API (text roleplays, feedback, and sentiment reads) and the Gemini Live API (real-time voice roleplays)
  • Cloud Computing and Data Storage Services: Google LLC, through Firebase and Google Cloud (Cloud Firestore for account and session data; Cloud Storage for voice recordings)
  • User Account Registration & Authentication Services: Google Firebase Authentication (email and password)
  • Website and Application Hosting: Vercel Inc., which hosts our website, the web application, and our server functions
  • Network, Security, and DNS Services: Cloudflare, Inc., which provides DNS for our domain, routes email sent to our addresses, and proxies traffic to our website, which means it processes visitor IP addresses and request information
  • Data Analytics and Error Monitoring Services: PostHog, Inc., in the web application (product analytics and error tracking), and Vercel Web Analytics, on our marketing website (see Section 6)
  • Email Delivery Services: Resend, which delivers demo requests submitted on our website to us
  • Performance Monitoring Tools
  • Communication & Collaboration Tools
  • Sales & Marketing Tools
  • Product Engineering & Design Tools, and Testing Tools
  • Government Entities (where required by law)

We also may need to share your personal information in the following situations:

  • With your organization. As described in Section 3, managers at your organization may view information about your use of the Services, including listening to voice session recordings.
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Legal and Safety Reasons. We may disclose information where we believe it is necessary to comply with law, legal process, or a lawful request from a government authority; to enforce our agreements; or to protect the rights, property, or safety of our users, the public, or us.

We do not sell your personal information, and we do not share it with third parties for cross-context behavioral advertising.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to, but that are not affiliated with, our Services.

The Services may link to third-party websites, online services, or applications that are not affiliated with us. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use browser storage mainly to keep you signed in and to operate the Services securely. We use product analytics in the application to understand how it is used and to fix errors. Our marketing website uses privacy-friendly analytics that do not use cookies.

In the web application. We use cookies and similar technologies (such as local storage and IndexedDB) that are necessary for the Services to work. Google Firebase Authentication uses them to keep you signed in. The application also uses local storage to limit each account to one active sign-in, to sign you out automatically after 30 minutes of inactivity, and to remember that you have dismissed the welcome screen. We do not use advertising, retargeting, or cross-site tracking technologies in the application.

Product analytics in the web application. We use PostHog to understand how the application is used and to find and fix errors. PostHog uses a cookie and local storage to recognize your browser. When you sign in, we link this activity to your internal account ID, your role, and your organization. We send PostHog the screens you view and actions you take (such as starting or finishing a roleplay, assigning or saving a scenario, or adding a comment), with details such as scores, counts, session length, and scenario identifiers, as well as technical details of errors. PostHog also receives your IP address, which it may use to estimate your approximate location, and your browser and device type. We do not send PostHog your name, your email address, or the content of your practice sessions, such as transcripts, chat messages, feedback text, comments, or voice audio. Session recording is turned off, and on-screen text is masked.

On our marketing website. We use Vercel Web Analytics to understand how visitors use salescoach365.net. It does not use cookies and does not track you across other websites. It collects information such as the pages viewed, the referring website, your approximate country, and your browser, operating system, and device type.

Microphone. Voice mode uses your device's microphone only while a voice session is running, and only after you grant permission in your browser. You can revoke this permission in your browser settings at any time.

We do not currently use advertising, retargeting, or cross-site tracking cookies.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies and site data. If you do, some features of the Services, including signing in, may not work.

7. HOW DO WE USE ARTIFICIAL INTELLIGENCE?

In Short: Our roleplay characters and feedback are generated by AI models operated by Google. Your typed messages, and in voice mode the audio of your voice, are sent to Google to produce responses.

The Services use artificial intelligence to play the role of customers in practice scenarios and to generate responses, feedback, and scores.

  • Text sessions. The messages you type, along with the scenario instructions, are sent from our servers to our third-party AI model provider, Google LLC, through its Gemini API.
  • Voice sessions. The audio of your voice is streamed directly from your browser to Google's Gemini Live API, using a short-lived access credential issued by our servers, so that the AI character can reply in real time. Both sides of the conversation are transcribed. The transcript is also sent through our servers to the Gemini API to generate the simulated buyer's sentiment during the call and your feedback afterward.
  • Model training. We use Google's paid Gemini API. Google's terms state that content sent through its paid API services is not used to train Google's models, and we do not use your practice session content to train AI models.
  • AI-generated responses may be inaccurate, incomplete, or inappropriate. They are for training purposes only and are not legal, financial, or professional advice.
  • Practice scenarios are fictional. Please do not enter or say real customer information.

8. WHERE IS YOUR INFORMATION STORED?

In Short: Your information is stored and processed in the United States.

Our Services are intended for users in the United States. Our database (Cloud Firestore) and our voice recording storage (Cloud Storage) are hosted by Google Cloud in the United States. Our website, web application, and server functions are hosted by Vercel. Our AI provider, Google, processes the text and audio we send to its Gemini APIs. Our product analytics provider, PostHog, stores analytics and error data in the United States. If you access our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your location.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. Voice recordings are deleted automatically after 90 days.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

  • Voice recordings are deleted automatically 90 days after they are created. The transcript, score, and feedback from a voice session remain with your session history as described below.
  • Account and practice session information (other than voice recordings) is kept while your organization's account is active and for no longer than 90 days after termination of the account.
  • Demo requests submitted on our website are kept for 24 months or until you ask us to delete them.
  • Business contact information we obtain from public sources for outreach is kept until you ask us to remove it or until it is no longer needed for that purpose.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These include access controls that separate each organization's data from others' and limit who within an organization can see what; keeping our AI provider credentials on our servers and issuing only short-lived, single-use credentials for voice sessions; limiting each account to one active sign-in and signing out inactive sessions after 30 minutes; and encrypting connections to our website and application. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

The Services are intended for business users. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on where you live, you may have rights that allow you greater access to and control over your personal information. You can ask us or your organization's administrator to review, change, or delete your account information.

Depending on your state of residence, you may have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request correction or deletion, (iii) to restrict or object to certain processing of your personal information, and (iv) where applicable, to data portability. You can make such a request by contacting us using the details in Section 17. We will consider and act upon any request in accordance with applicable data protection laws.

Requests about Customer accounts. If your information is in an account created by your organization, we may need to direct your request to your organization, because it decides how that information is used. We will tell you if we do so.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the details in Section 17 or by updating your preferences. However, please note that this will not affect the lawfulness of the processing before its withdrawal.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails that we send, or by contacting us using the details in Section 17. You will then be removed from the marketing lists. However, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. If we obtained your business contact information from a public source, you can also ask us to delete it.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us using the contact information provided.
  • Ask your organization's administrator, who manages accounts for your organization.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies: See Section 6.

If you have questions or comments about your privacy rights, you may email us at [email protected].

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name YES
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information YES
C. Protected classification characteristics under California or federal law Gender and date of birth NO
D. Commercial information Transaction information, purchase history, financial details, and payment information YES (subscription and billing-contact records only)
E. Biometric information Fingerprints and voiceprints NO (voice sessions are recorded, but we do not create voiceprints or use recordings to identify anyone)
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements YES
G. Geolocation data Device location YES (approximate, from IP address only)
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities YES (audio and recordings of voice practice sessions)
I. Professional or employment-related information Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us YES
J. Education information Student records and directory information NO
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics YES (performance scores, AI-generated feedback, and sentiment reads about practice sessions)
L. Sensitive personal information Account login information, drivers' licenses, health data, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, and sex life or sexual orientation YES (account log-in credentials only)

We will use and retain the collected personal information as needed to provide the Services, for the periods described in Section 9.

We may also collect other personal information outside of these categories in instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

We collect and use your personal information as described in Sections 1 and 2. We use cookies and similar technologies as described in Section 6. We do not use targeting or marketing cookies, social media cookies, or advertising pixels.

You may contact us by email at [email protected], or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

  • Category A. Identifiers, such as contact details like your real name, postal address, telephone number, online identifier, Internet Protocol address, email address, and account name.
  • Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, and employment information.
  • Category D. Commercial information, such as subscription and billing-contact records.
  • Category F. Internet or other electronic network activity information, such as interactions with our Services.
  • Category G. Geolocation data (approximate, derived from IP address).
  • Category H. Audio information, such as voice practice session audio sent to our AI provider and recordings stored with our cloud storage provider.
  • Category I. Professional or employment-related information, such as business contact details and job title.
  • Category K. Inferences drawn from the personal information listed above, such as performance scores and feedback.
  • Category L. Sensitive personal information (account log-in credentials only).

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found in Section 4.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Your rights with respect to your personal data

Right to request deletion of the data: Request to delete. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed: Request to know. Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell or share personal information to third parties;
  • the categories of personal information that we sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, sharing, or selling personal information; and
  • the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights. We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information. The only sensitive personal information we collect is account log-in credentials, which we use solely to authenticate you and provide the Services. We do not use or disclose sensitive personal information for purposes that would give rise to a right to limit under California law.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

To exercise these rights, you can contact us by email at [email protected], or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

15. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with us and our Services. To find out more, please visit the following sections above:

  • Section 1: What information do we collect?
  • Section 2: How do we process your information?
  • Section 4: When and with whom do we share your personal information?

Your rights with respect to your personal data

  • Right to be informed whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

We have not sold any personal data to third parties for business or commercial purposes, and we will not sell personal data in the future belonging to website visitors, users, and other consumers. We do not process personal data for targeted advertising.

Exercise your rights provided under the Virginia CDPA

You may contact us by email at [email protected], or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at [email protected]. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

16. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by email at [email protected].

18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your state, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email us at [email protected]. If your account was created by your organization, you may also contact your organization's administrator.