Privacy Policy

Virtual Sapiens is SOC 2 Type II Certified & GDPR Compliant

 

Privacy Policy

Effective Date: May 30, 2025

Virtual Sapiens, Inc. (“Virtual Sapiens,” “we,” “us,” or “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy outlines how we collect, use, and safeguard your information in accordance with the General Data Protection Regulation (GDPR). More specific policy information can be found by request at https://trust.virtualsapiens.co/.

1. Data Controller

 Virtual Sapiens, Inc.
 Email: compliance@virtualsapiens.co

2. Information We Collect

We may collect and process the following categories of personal data:

2.1. Contact Information
  • Name and Email Address: To manage your account, communicate with you about our services, product announcements, updates, and respond to your requests for assistance.
2.2. Calendar and Meeting Metadata (Sidekick Coach Users Only)
  • Calendar Information: To facilitate seamless integration and provide reminders.
  • Meeting Metadata: To enhance user experience through features like auto-launch and video meeting reminders.
2.3. Audio/Video Data
  • Video Recordings: We do not store or transmit video recordings by default. Optional storage is available for practice assessments upon explicit user request and organizational permission. These videos are saved solely for playback; all video AI processing occurs on-device.
  • Screenshots: For Sidekick Coach users, optional screenshots may be saved to help users visualize their nonverbal behaviors in alignment with AI feedback.
  • Audio Recordings: We do not store audio recordings by default. Transcripts of assessments are saved to provide full analysis of user behavior. Transcription features can be turned off upon request. Optional storage of audio is available for assessments upon explicit user request and organizational permission.
2.4. User-Generated Content
  • Survey Responses and Other Data Points: Collected through interactions with our site to provide relevant feedback and suggestions for improvement and to enhance our products.
2.5. Log Data
  • Technical Information: IP address, browser type, date and time of use, browser configuration, language preferences, cookie data, and information about your computer or mobile device.

This log data does not contain any video, images, audio, or visually identifiable data.

3. Use of Generative AI Services

3.1. Summary of AI Usage

Our platform leverages securely hosted,  API-level generative AI services provided by third-party partners to enhance user experience through features such as:

  • Summarizing meeting transcriptions.
  • Providing advanced verbal analytics to help users improve their communication.
  • Facilitating compelling voice to voice role plays.
3.2. Data Processing and Sharing

To enable these features, we send certain user-provided audio transcriptions of specific communication practice events, assessments, or meetings (if transcriptions are enabled by user preference) to our third-party APIs. This data is processed by our GenAI partners’ models in real-time to generate responses, summaries, and feedback.  

3.3. Scope of Data Shared

The data we share with our securely hosted GenAI partners may include, but is not limited to:

  • Transcriptions of specific user practice scenarios and meetings—always based on user consent.
  • Contextual information necessary for providing feedback.

We do not share personally identifiable information (PII) or sensitive data unless explicitly needed for the feature. For example, we may share the user’s name so the AI can more personally address the user during a role play scenario.

3.4. Retention and Use of AI-Generated Content
  • AI-generated outputs, such as summaries and feedback, may be stored by us to improve our service and for your convenience.
  • Virtual Sapiens does not use any user data—including inputs, outputs, transcripts, or metadata—to train, fine-tune, or otherwise develop our AI models or our partner’s AI models.
3.5. User Control and Opt-Out Options

Our clients and partners have the right to opt-out of GenAI features at any time. If you do so, no data related to your communications will be processed by our GenAI partners for the purposes of advanced verbal feedback and coaching. Please contact compliance@virtualsapiens.co to exercise this option.

4. How We Use Your Information

We may use the information we collect from you when you use Virtual Sapiens, answer a survey, or otherwise interact with the Site, in the following ways:

  • To operate and improve Virtual Sapiens, Inc. and services offered through the Site.
  • Further development of our products.
  • To better service you in responding to your customer service requests and resolve any technical issues.
  • To quickly process your transactions.
  • To administer a survey, or other Virtual Sapiens, Inc. features.
  • For industry communication or other research (though we do not use user data to train models), analysis, publications, norm development, and similar uses.

5. Personal Data or User Content

Virtual Sapiens, Inc. does not sell or rent user information.

We do not share your personal information with third parties for the purpose of enabling them to deliver their advertisements to you.

6. Review of User Content

Virtual Sapiens, Inc. does not record video meetings in our systems. We provide users with the option to save practice assessments for user review and playback to better understand and improve their communication and leadership skills. These videos can optionally and privately be shared with coaches and/or managers if the user desires and this feature is enabled. These features are default ‘off’.

We maintain the right to review other relevant data to deliver accurate automated and individualized feedback. Your personal data may also be viewed where necessary to protect the rights, property, or personal safety of Virtual Sapiens, Inc. and its users, or to comply with our legal obligations, such as responding to warrants, court orders, discovery obligations, or other legal processes.

7. Information Access and Disclosure

We only disclose personal data to third parties when:

  • We use service providers who assist us in meeting business operations needs, including hosting, delivering, and improving our services. These service providers may only access, process, or store personal data pursuant to our instructions and to perform their duties to us. You can request exact details of our service providers by contacting us at compliance@virtualsapiens.co.
  • We have your explicit consent to share your personal data.
  • We believe it is necessary to investigate potential violations of any contract we have entered with you, including the Terms of Service for any service, to enforce those Terms of Service, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which we operate our Site and/or services.
  • We determine that the access, preservation, or disclosure of your personal data is required by law to protect the rights, property, or personal safety of Virtual Sapiens, Inc. and users of our Site and/or services, or to respond to lawful requests by public authorities, including national security or law enforcement requests.
  • We need to do so in connection with a merger, acquisition, bankruptcy, reorganization, sale of some or all of our assets or stock, public offering of securities, or steps in consideration of such activities (e.g., due diligence). In these cases, some or all of your personal data may be shared with or transferred to another entity, subject to this Privacy Policy.

8. Cookies

Cookies are small text files stored on your device and used by web browsers to deliver personalized content and remember logins and account settings. Virtual Sapiens, Inc. only uses cookies for platform functionality, never for advertising or externally tracking. Our partners use cookies to ensure that the site works properly. For more information on these cookies, please refer to our partners’ terms of service and privacy documentation.

9. Email Communications

Once you have an account with Virtual Sapiens, we will contact you with information about product announcements, updates, and special offers. You may opt out of such communications at any time by clicking the “unsubscribe” link found within Virtual Sapiens, Inc. emails and changing your contact preferences. All users will continue to receive transactional messages related to our services and your personal dashboard or account activities, even if you unsubscribe from promotional emails.

10. Children’s Privacy

Virtual Sapiens, Inc. does not knowingly collect personal data from children under the age of 18. If we determine we have collected personal data from a child younger than 18 years of age, we will take reasonable measures to remove that information from our systems. If you are under the age of 18, please do not submit any personal data through the Site or service. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this Policy by instructing their children never to provide personal data through the Site without their permission.

11. Billing Information

We partner with a third-party payment processing platform (Stripe) to process any platform-based payments. We do not store or transmit any payment information beyond the transaction reports provided by our payment partner. All credit card information is entered directly into Stripe and not seen by Virtual Sapiens, Inc.

12. Data Storage, Transfer, Retention, and Deletion

12.1. Data Storage

Identifying information such as your name and email are collected and stored through our user contact service and on our servers through Amazon Web Services (AWS). We store log data in AWS that is necessary for us to ensure the reliability and uptime of our services.

Please refer to the above-referenced service providers for more information about the storage and security characteristics of each service.

If we learn of a data breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site.

12.2. Data Retention

You can remove your personal data and account from Virtual Sapiens, Inc. at any time by sending a request to compliance@virtualsapiens.co. We routinely purge all data after 60 days post-access termination date unless requested otherwise. 

12.3. International Data Transfers

Virtual Sapiens, Inc. is based in the United States, and the personal data we collect is processed and stored in the U.S. By providing us with your personal data, you consent to the transfer and processing of your data in the United States. While the U.S. may not have data protection laws equivalent to those in your jurisdiction, we implement appropriate safeguards to protect your personal data in accordance with this Privacy Policy.

13. Your Rights Under GDPR

You have the following rights under the General Data Protection Regulation (GDPR):

  • Right to Access: You can request copies of your personal data.
  • Right to Rectification: You can request correction of inaccurate or incomplete data.
  • Right to Erasure: You can request deletion of your personal data under certain conditions.
  • Right to Restrict Processing: You can request restriction of processing under certain circumstances.
  • Right to Object to Processing: You can object to processing based on legitimate interests.
  • Right to Data Portability: You can request transfer of your data to another organization or directly to you.

To exercise any of these rights, please contact us at compliance@virtualsapiens.co. We will respond within one week of receiving your request.

14. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, and regular security assessments. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new policy on our website and updating the “Effective Date” at the top. We encourage you to review this policy periodically.

16. Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

Virtual Sapiens, Inc.
 Email: compliance@virtualsapiens.co