At PocketConfidant we take your privacy seriously. We have created this document to help you learn about how we collect, store, use, and process your Personal Data as well as how your data could be disclosed to third parties.
In this document, we explain our data processes when you interact with, or use any of the following websites: www.pocketconfidant.com, support.pocketconfidant.com, or other websites under the *.pocketconfidant.com domain (hereinafter collectively referred to as the “Websites”); or any related events, trade shows, sales or marketing; and/or if you access any of our services through one of the messaging apps (e.g., on Skype) or via Web App through your browser at coach.pocketconfidant.com, via email, or other applications in any manner (hereinafter collectively referred to as the “Solutions”).At PocketConfidant we have a designated role to address your privacy-related questions. You can always contact our Data Protection Officer by email email@example.com.
“PocketConfidant,” “we,” and “us” here collectively refer to “PocketConfidant Artificial Intelligence SAS” company.
What data does PocketConfidant collect?
PocketConfidant collects data to operate effectively and to provide you the best experiences with our Solutions and Websites. You provide some of this data directly, such as when you create a PocketConfidant account, administer your organization’s account, purchase a PocketConfidant Subscription, or contact us for support. We get some of the data automatically by recording how you interact with our Solutions by, for example, using technologies like cookies, and receiving error reports.
Personal Data you provide to us:
When you use the Websites:
- We may collect Personal Data that you choose to send us or provide us with, for example, on our “Contact” and “Create Support Ticket” (or similar) online forms. If you contact us through the Websites, we will keep a record of our correspondence.
When you use our Solutions:
- We receive and store data you provide directly to us. For example, when setting up a new user account in the PocketConfidant Solution for the real-time coaching conversations, we collect Personal Data, such as your email address, to provide you access to the real-time coaching conversations powered by Artificial Intelligence.
- Important note: With respect to the use of the PocketConfidant Solution for the real-time coaching conversations, the only Personal Data that is required to create and use an account is the user’s email address.
- The types of data we may collect directly from our customers and their users include: names, usernames, email addresses, postal addresses, phone numbers, job titles, transactional data (including Subscriptions purchased), as well as any other contact or other data they choose to provide to us or upload to our systems in connection with the Solutions.
Other Data we automatically collect:
When you use the Websites:
- We collect certain data related to your device, such as your device’s IP address, screen resolution, referring website, what pages your device visited, and the time that your device visited our Website.
When you use the Solutions:
- Usage data: We keep track of activity in relation to the types of Solutions our customers and their users use, the device data, operating system, browser version, and performance metrics related to the use of the Solutions.
How do we use your Personal Data?
We will use the data we collect via our Websites:
- To administer our Website, our events, and for internal operations, including troubleshooting, data analysis, testing, and statistical and survey purposes;
- To improve our Website to ensure that content is presented in the most effective manner for you and for your computer;
- To analyze user’s use of the Websites for trend monitoring and marketing and advertising purposes;
- For purposes made clear to you at the time you submit your data – for example, to fulfill your request for a demo, provide you with access to one of our whitepapers, or provide you with data you have requested about our Solutions;
- As part of our efforts to keep our Websites safe and secure.
We may use data we collect from our customers and their users in connection with the Solutions we provide for a range of reasons, including:
- To set up a user account;
- To provide, operate, and maintain the Solutions;
- To process and complete transactions and send related data, including transaction confirmations and invoices;
- To manage our customers’ use of the Solutions, respond to inquiries and comments, and provide customer service and support;
- To send customers technical alerts, updates, security notifications, and administrative communications;
- To investigate and prevent fraudulent activities, unauthorized use of the Solutions, and other illegal activities;
- For any other purposes about which we notify customers and users. We may also use the data you send to us via the Websites and/or Solutions to communicate with you via email, and potentially other means, regarding products, services, offers, promotions, and events we think may be of interest to you, or to send you our newsletter, if this is in alignment with your marketing preferences.
How do we process your Personal Data?
Processing of the Personal Data by Websites and Solutions that we manage
When you use the Websites:
- The connection between our Websites and your browser is encrypted using Transport Layer Security protocols so that data that you send and receive is not visible to your local network or the internet provider.
- When you are submitting your request using an online form, it is processed by our Website application before storage. For example, we ensure that the submitted data does not contain malicious code that can compromise the security of our systems.
- After processing, the data of your request is physically stored on our behalf in an encrypted database by the servers of our cloud hosting provider.
- Our website application may send the email message to notify a dedicated professional from our team about your request.
When you use our Solution for real-time coaching conversations:
- When you are using the web browser, the connection between our Web App and your browser is encrypted using Transport Layer Security protocols so that data that you send and receive is not visible to your local network or the internet provider.
- When you are using PocketConfidant Solution through one of the Messaging app Channels (e.g., Skype), your personal data is first processed through a third-party before entering our systems.
- When you interact with one of our Solutions, you may be required to use your email address to log into your personal or organizational accounts.
- When you log in, request a password reset or perform an action that requires an email confirmation, we employ a third-party emailing service (as listed in our list of vendors) to send you a transactional email on our behalf.
- When you decide to share your conversational data (such as session summary) with your friend, we employ a third-party emailing service (as listed in our list of vendors) to send an email to the recipient that you have specified.
- We employ a fully-separated application architecture where the processing and transformation of the data by the algorithms and the physical storage of the data is performed on different and isolated virtual servers, ensuring higher stability and security.
- After processing, the data is physically stored on our behalf in the encrypted databases by the servers of our cloud hosting provider.
- The conversational data is anonymized and is never stored in the same database with identity data such as the user’s email address.
When you use our Solution for asynchronous coaching via email:
- When you are using our Solution via email, you may send email messages via third-party email service providers (such as Gmail, Microsoft 365, or Outlook.com). The third-party email service providers or their administrators may have access to the content of your email messages.
- When we receive an email message from you, the email is parsed and the content of your message is analyzed by our Solution in accordance with the coaching protocol.
- After the content of the message is analyzed and response is generated, the response is assembled into an email message and sent back to you.
- All the emails are stored on our behalf in the encrypted storage by our hosting and email service providers.
- In addition to algorithmic processing, the email messages may be supervised by human coaching experts from the PocketConfidant team in accordance with our Code of Ethics to improve the quality of the coaching conversations.
- We are using your email address solely to deliver the Solution.
Artificial Intelligence and Analytics
- Personal Data is not used for machine learning purposes and is used solely to give you the possibility to securely access PocketConfidant Solution, retrieve history, process transactions, receive notifications and email messages.
- Anonymized conversational data is processed by deep learning algorithms (such as neuronal network classifiers) to identify the linguistic patterns in text or voice messages.
- Anonymized metadata regarding the timing of message interaction can be used to correctly identify conversational states.
- Subject matter experts such as coaches, linguists and psychologists may participate in the manual analysis of anonymized conversations.
- Analytics that is a part of PocketConfidant Solution for client organizations is processing only anonymized information and is providing only aggregate usage and linguistic information across groups of users.
Our Open Vendor Policy
We employ a transparent and Open Vendor Policy. Our goal is to make sure that you understand how and in which cases your data is handled and processed by third parties. We publish the list of our vendors and service providers online.
Is my Personal Data secure?
- We use Transport Layer Security (TLS) protocols to encrypt all the data that we transfer from the Web App or Website to our servers over the Internet.
- When using real-time coaching Solution via Web App or Messaging Channels, conversations are anonymized before storage.
- We use appropriate technical, organizational, and administrative security measures to protect any Personal Data we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
- Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user data at any time. You must prevent unauthorized access to your PocketConfidant accounts by limiting access to your computer or device and browser by logging out after you have finished accessing the Solutions. If you are using the Solutions through one of the available messaging app channels (e.g., Slack or Skype) or embedded into a third-party platform, you must ensure that you are preventing unauthorized access to these systems as well.
How to Control my Personal Data?
You can request to download or delete your Personal Data online for any of PocketConfidant Solutions. How you access or control your Personal Data will depend on which Solution you use.
You can always choose whether you wish to receive newsletter emails, notifications, telephone calls from PocketConfidant and its Solutions. You can also request to delete Personal Data that you have submitted on our Websites using a dedicated page.
Disclosing Personal Data to third parties
We do not sell or rent your Personal Data to anyone.
How we may disclose data to third parties
We may share and disclose data (including Personal Data) about our customers in the following limited circumstances:
- Vendors, consultants, and other service providers: We may share your data with third-party vendors, consultants, and other service providers we employ to perform tasks on our behalf. These companies include (for example) our payment processing providers (e.g., Stripe), website analytics companies (e.g., Google Analytics), product feedback or help-desk software providers (e.g., Zoho Desk), CRM service providers (e.g., HubSpot), email service providers (e.g., Sendgrid), and others.
- Business transfers: We may choose to buy or sell assets and may share and/or transfer customer data in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change in company control, Personal Data could be one of the assets transferred to or acquired by a third party.
- Protection of PocketConfidant and others: We reserve the right to access, read, preserve, and disclose any data necessary to comply with the law or any court order; enforce or apply our agreements with you and other agreements; or protect the rights, property, and/or safety of PocketConfidant, our employees, our users, or others.
- Disclosures for national security or law enforcement: Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
How you may disclose data to third parties
- You may decide to use PocketConfidant Solutions through one of the messaging app channels (e.g., Skype). In this case, your data will enter our systems through a third-party and, thus, will be shared with this third-party service or application.
- You may decide to use the sharing capability of our Solutions (for example, to share your conversations with someone you trust by email or other means). In this case, our application will be collecting your data from the database and sending it to the destination per your request.
International data transfers
When transferring the data of European customers and users of our Solutions in the United States., we make sure that the vendor that we employ is a participant of the Privacy Shield agreement. Some of our Solution offerings will include the option of having your data hosted on servers located in the European Union or other countries.
Notice to End Users
Some of the PocketConfidant Solutions are intended for use by organizations. In this case, your Subscription to PocketConfidant services is granted to you and administered by your organization. Your use of PocketConfidant Solutions may be subject to your organization’s policies if any. However, data about your personal use, such as conversations that you engage in with PocketConfidant Solutions, is never disclosed by us to the organization without your direct request and remains private. You can always decide to download or to delete your Personal Data.
For any questions, contact our Data Protection Officer by email firstname.lastname@example.org.