Virtual Sapiens, Inc. understands the sensitivity of personal data, and we are committed to ensuring our users’ privacy at every step. Virtual Sapiens is a privacy-first company, built to protect your information through advanced, on-device processing and strict data security protocols. Our platform prioritizes the confidentiality of our users’ interactions, giving our users’ control over their own experience without compromising safety.
This Privacy Policy explains what information Virtual Sapiens, Inc., a Delaware C Corp (“Virtual Sapiens, Inc.”, “us”, “we”, or “our”) collects about our users and why; what we may do with that information and how we handle information, including Personal Data (as defined below).
This Privacy Policy applies to the information obtained by us through your use of www.virtualsapiens.co (the “Site”) and other products and services offered by Virtual Sapiens, Inc. and its affiliates (“Services”).
What information do we collect?
Virtual Sapiens, Inc. may collect the following types of Personal Data (information that identifies you, or your device), for the reasons set forth below:
Your name, email address, calendar (Sidekick Coach users only) and meeting metadata (Sidekick Coach users only).
This lets us notify you of any updates to your account. This information also helps us communicate with you about your use of our Services, product announcements and updates, as well as respond to your requests for assistance. In addition, we may use your name and email to send you email correspondence as further provided below.
Virtual Sapiens stores minimal calendar and meeting data that is necessary to provide a seamless integration with our Services including the convenience of auto-launch and video event reminders to help users get the most out of our coaching service. This is for the Sidekick Coach solution users only.
Audio/Video
- We do not default store or transmit video recordings. We can optionally save a user’s video if the client organization allows it, and the individual user explicitly requests their video saved for their own review and playback – an important part of training and self-reflection for improvement purposes. This is only available for our practice assessment types, and not for meetings. The video is saved solely for playback (ie all video AI still happens on-device only).
- We store text-based metadata (e.g. numerical coordinates representing body positioning) that is necessary for us to train and optimize our machine learning models. For Sidekick Coach users, we can optionally save screenshots which serve to help users visually see their own nonverbal behaviors as they align with the AI feedback.
- We do not store audio recordings. We only save transcripts of your assessments. Transcription is needed to provide you with a full analysis of your behavior. The transcription feature while extremely valuable, may be turned off upon request.
Other User Generated Content:
Other user content such as survey responses and other data-points provided through interaction with our site may be stored by Virtual Sapiens, Inc.. We do not use this information for any purpose other than to provide you with the most relevant feedback and suggestions for improvement and to improve our products to serve our customers better.
We may use third party providers to support payment, e-mail communications and certain GenAI offerings (see our section on the use of GenerativeAI).
Log data
As with most websites and technology services delivered over the internet, we may automatically collect data when you access or use our Site and/or Services and record it in log files. This log data may include the IP address, browser type, the date and time of use, information about browser configuration, language preferences, cookie data, and information about your computer or mobile device, such as the type of hardware and software you are using.
- This log data does not contain any video, images or audio, not visually identifiable data.
Gathering this kind of information helps us administer our Services and provide convenient and direct communications. It also helps us improve and further develop our Products.
Use of Generative AI Services
Summary of AI Usage:
Our platform leverages API-level generative AI services provided by third party generative AI partners to enhance user experience through the following features:
- Summarizing meeting transcriptions
- Extracting key takeaways and suggested next steps
- Providing advance verbal analytics to help users improve their communication
- Facilitating compelling role plays
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.
Scope of Data Shared:
The data we share with our 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.
Retention and Use of AI-Generated Content:
- AI-generated outputs, such as summaries, key takeaways, and feedback, may be stored by us to improve our service and for your convenience.
- Our GenAI partners may retain anonymized inputs and outputs per their data usage policy. For more information on how our GenAI partners protect your privacy, please reach out to us at [email protected] for more information.
User Control and Opt-Out Options:
Our clients and partners have the right to opt-out of this feature at any time. If you do so, no data related to your communications will be processed by our GenAI partners for the purposes of advance verbal feedback and coaching. Please contact [email protected] to exercise this option.
How do we use your information?
We may use the limited 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 allow us to better service you in responding to your customer service requests and resolve any technical issues experienced by and/or reported to us by our users.
To quickly process your transactions.
To administer a promotion, 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.
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.
However, non-personally identifiable information may be provided to other parties for industry or communication research, analysis, demographic profiling, publications, norm development or other uses.
Do we review user content?
Virtual Sapiens, Inc. does not record video meetings in our systems . Virtual Sapiens, Inc. provides users with the option to save practice assessments for user review and playback to better understand and improve their communication. 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’.
Virtual Sapiens, Inc. maintains the right to review other relevant data in order to deliver on the promise of automated and individualized feedback that is accurate. 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 in order to comply with our legal obligations, such as responding to warrants, court orders, discovery obligations or other legal process.
Do we ever make any of your Personal Data or user content public?
No.
Information access and disclosure
Does Virtual Sapiens, Inc. share my information?
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. We also use service providers for specific services and functions, including email communication, customer support services, and analytics. 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 [email protected].
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.
We may disclose anonymized, non-personally identifiable information publicly and to third parties – for example, as part of progress reports or comparisons for other users in connection with virtual presence metrics and progress trend analytics.
Virtual Sapiens, Inc. does not share your Personal Data with third parties for the purpose of enabling them to deliver their advertisements to you.
Does Virtual Sapiens, Inc. use 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. does not use its own tracking cookies. Our partners use cookies to ensure that the site works properly, to detect and prevent fraud and understand how people interact with their services. For more information on these cookies, please refer to our partners’ terms of service and privacy documentation.
Will Virtual Sapiens, Inc. send me emails?
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 Virtual Sapiens, Inc. 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.
For EEA users: We only send marketing communications to users located in the EEA with your prior consent.
Does Virtual Sapiens, Inc. collect information from children?
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.
Billing Information
Virtual Sapiens, Inc. partners with a third-party payment processing platform (Stripe) to process any platform-based payments. We will 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.
Data storage, transfer, retention, and deletion
How is my Information stored?
Identifying information such as your name and email are collected and stored through our user contact service, Mailchimp 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 Virtual Sapiens, Inc. learns 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.
How long is Personal Data retained ?
You can remove your Personal Data and account from Virtual Sapiens, Inc. at any time by sending a request to [email protected]. We routinely purge all data after 60 days post-access termination date unless requested otherwise. However, we may keep some of your Personal Data for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.
For EEA Users:
Virtual Sapiens, Inc. under the General Data Protection Regulation (“GDPR”), to the extent applicable, acts as a data controller (as defined in the GDPR) with respect to your Personal Data when it processes such information in connection with its lawful business purposes.
What is the lawful basis for the processing of my Personal Data?
We generally use, process, and store Personal Data on the basis of consent.
We may also process Personal Data on other bases permitted by the GDPR and applicable laws, such as when the processing is necessary for (i) compliance with our legal obligations, (ii) performance of a contract with the data subject, or (iii) protecting vital interests.
Will my Personal Data be transferred outside of the European Economic Area (EEA)?
Virtual Sapiens, Inc. is based in the United States of America and that is where the processing of Personal Data we collect occurs. By providing us with Personal Data, you hereby consent to (i) our processing and disclosure of such Personal Data in accordance with this Privacy Policy; (ii) the transfer of such Personal Data to the United States; and (iii) our disclosure of such information in compliance with lawful requests by public authorities, including to meet national security or law enforcement requirements. The United States does not have an adequacy decision from the European Commission, which means that the Commission has not determined that the laws of the United States provide adequate protection for Personal Data. Although the laws of the United State do not provide legal protection that is equivalent to European Union data protection laws, we safeguard your Personal Data by treating it in accordance with this Privacy Policy. We take appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Data in storage.
What rights do I have, and how can I exercise them?
Under the GDPR, Individuals located in the EEA have the following rights in respect to their Personal Data:
The right to access – You have the right to request that we provide copies of your Personal Data.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your Personal Data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your Personal Data, under certain conditions. This includes our use of your Personal Data to send you marketing emails. We only send marketing communications to users located in the EEA with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within Virtual Sapiens, Inc. emails and changing your contact preferences. Please note you will continue to receive transactional messages related to our Services, even if you unsubscribe from marketing emails.
The right to object to processing – You have the right to object to our processing of your Personal Data, under certain conditions.
The right to data portability – You have the right to request that we transfer the information that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us pursuant to the contract information listed below.
You may exercise your data protections rights provide any other questions, comments, complaints or requests regarding, by contacting us at:
Virtual Sapiens, Inc.
Attention: Data Protection Officer
37 Blodgett Ave,
Swampscott, MA
01907
617-981-3292
[email protected]
How do I contact the appropriate authority?
Should you wish to file a complaint concerning our processing of your Personal Data with your national (or in some countries, regional) data protection authority, the European Union Commission provides a list here.
Will this Privacy Policy ever change?
Virtual Sapiens is a dynamic software company. As such, this privacy policy will evolve alongside the continued development of this Product and Service. This Policy will be updated in order to keep pace with changes in our Site and Services, our business, and laws applicable to us and you. We will, however, always maintain our commitment to respect your privacy. We will notify you of any material changes that impact your rights under this Policy by email (to your most recently provided email address) or post any other revisions to this Policy, along with their effective date, in an easy-to-find area of the Site, so we recommend that you periodically check back here to stay informed of any changes. Please note that your continued use of Virtual Sapiens, Inc. after any change means that you agree with, and consent to be bound by, the new Policy. If you disagree with any changes in this Policy and do not wish your information to be subject to it, you will need to delete your Virtual Sapiens, Inc. account.
Last updated: 09/30/2024