AVA Trainer
Privacy Policy for Ava: AI-driven simulations
Privacy Policy
Last updated: January 01, 2025This Privacy Policy outlines how we collect, store, use, disclose, and protect your personal information when you use the Avatar AI Simulation Platform ('Platform'). By accessing or using the Platform, you agree to the terms of this Privacy Policy. It also explains your rights in relation to your personal data and how to contact us in the event you have a complaint.This website is operated by Vivanty SA, a public limited company registered in Belgium (we, us, our).When we collect and use your personal data we act as a Data Controller. We are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to the services we provide to individuals who are based in the European Economic Area (EEA).“Personal data” means any information relating to an identified or identifiable individual. We may also refer to the “data subject” which means the individual who the personal data relates to.
1. Information We Collect
1.1 Personal Information
We collect personal information that you provide directly to us when you register for an account, including but not limited to:
- Name
- Email address
- Job title
- Company name
- Country and City
1.2 Usage Data
We automatically collect certain information when you use the Platform, such as:
- Your username and password
- IP address
- Operating system, browser type and version
- Pages visited on the Platform
- Time and date of visits
- Time spent on those pages
- Type of device and unique device identifiers
- Results of simulations
1.3 Cookies and Tracking Technologies
We use cookies and similar tracking technologies to monitor activity on our Platform and store certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
2. How We Use Your Information
We may use the information we collect for various purposes, including:
- To provide and maintain our Platform
- To notify you about changes to our Platform
- To allow you to participate in interactive features of our Platform when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Platform
- To monitor the usage of our Platform
- To detect, prevent, and address technical issues
- To send you newsletters, marketing communications, or other information that may be of interest to you (with your consent)
- The Platform uses the data from the simulations to provide feedback on the performance of the simulated activities. This assists in enhancing the user experience and improving future simulations.
3. Legal Basis for Processing Personal Data
Under data protection law, we must have a legal basis for processing your personal data.We process your personal data based on the following legal grounds:
You have the right to opt-out of receiving marketing communications at any time by contacting us at info@vivanti.eu or using the “unsubscribe” link in emails.
We are committed to safeguarding your personal data and will never sell it to any third party, whether within or outside our group, for marketing purposes.
- Consent: When you provide your explicit consent for us to process your personal data for specific purposes.
- Contractual Necessity: When processing is necessary for the performance of a contract with you.
- Legal Obligation: When we need to comply with a legal obligation.
- Legitimate Interests: We may process your personal data when it is necessary for our legitimate interests or those of a third party, as long as your interests and fundamental rights do not outweigh those interests. Our legitimate interest includes using your personal data for marketing purposes, which typically does not require your consent. However, when consent is required, we will request it separately and clearly.
You have the right to opt-out of receiving marketing communications at any time by contacting us at info@vivanti.eu or using the “unsubscribe” link in emails.
We are committed to safeguarding your personal data and will never sell it to any third party, whether within or outside our group, for marketing purposes.
4. Disclosure of Your Information
We may share your personal information in the following situations:
- With Service Providers: We may share your personal information with service providers who assist us in operating our Platform or providing services.
- With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
- With Consent: We may disclose your personal information for any other purpose with your consent.
- For Legal Reasons: We may disclose your personal information if required by law or in response to valid requests by public authorities.
5. Data Security
We take the security of your personal information seriously and implement appropriate technical and organisational measures designed to protect it from unauthorised access, use, alteration, or destruction. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure.
6. Data Retention
We will retain your personal information only for as long as is necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. When we no longer need your personal data, we will securely delete it.
7. Your Rights Under GDPR
As a user in the European Economic Area (EEA), you have certain rights regarding your personal data:
- Right to Access: You have the right to request copies of your personal data.
- Right to Rectification: You have the right to request that we correct any inaccurate or incomplete information.
- Right to Erasure: You have the right to request that we delete your personal data under certain conditions.
- Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
- Right to Data Portability: You have the right to request that we transfer the data that we have collected about you to another organisation or directly to you under certain conditions.
- Right to Object: You have the right to object to our processing of your personal data under certain conditions.
8. International Data Transfers
If we transfer your personal data outside of the European Economic Area (EEA), we will ensure that adequate safeguards are in place as required by GDPR. This may include using Standard Contractual Clauses approved by the European Commission.
9. Data Breach Notification
In the event of a data breach affecting your personal data, we will notify you and any applicable regulatory authority within 72 hours if required by law.
10. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page with an updated effective date at the top. You are advised to review this Privacy Policy periodically for any changes.
11. Contact Us
If you have any questions about this Privacy Policy or wish to exercise any of your rights regarding your personal data, please contact us at info@vivanti.eu
AVA Companion
Privacy Policy for Ava: AI-driven simulations
Privacy Policy
Last updated: July 05, 2026This Privacy Policy and Data Processing Policy contains information about how we collect, store, use, disclose, and protect your personal information when you use the AVA Companion software and services, including the mobile app and web platform (Personal Account) (hereinafter collectively referred to as the 'Service').By accessing and using the Service, by logging in to it or using it (whether through the mobile app or the web platform), you agree to the terms of this Privacy Policy and Data Processing Policy (hereinafter referred to as 'Policy'). The Policy also explains your rights in relation to your personal data and describes how to contact us in the event you have a complaint.The management of this Service is carried out by Vivanti SA, a public limited company registered in Belgium (hereinafter 'we', 'us', 'our'). When we collect and use your personal data, we act as a Data Controller. We are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to the services we provide to individuals who are based in the European Economic Area (EEA).«Personal Data» – any information relating to a physical person (subject of personal data).
«User» – any physical person using the Service. The Service provides for different user roles:
«User» – any physical person using the Service. The Service provides for different user roles:
- Employees – users of the mobile app;
- Managers – users of the Personal Account (web platform), having access to data of employees assigned to them;
- Administrators – users of the Personal Account (web platform), having full access to the Service and analytics.
1. Information We Collect
1.1 Personal Information
We collect personal data that you provide us directly. The amount of collected data depends on the part of the Service you use:
- email address (e-mail) – exclusively for user authentication;
- audio recordings of voice (recording is only started after it is started by the user). During active recording, the application may continue to work in the background mode, preserving the ability to record audio. Before further processing, audio data is automatically transformed so as to exclude the possibility of identifying the user by voice. The system does not store the original voice recording of the user. Only transformed audio data necessary for the operation of the functionality of the application is used for processing. The mobile app does not request and does not collect your personal data, including your surname, name or region, as well as biometric personal data, such as voice.
- surname and first name;
- email address (e-mail);
- information about the region (territorial belonging) of the employee;
- data determining the role in the Service (employee, manager, administrator) and the link of the employee to the manager and region;
- settings and evaluation criteria set by Managers and Administrators.
1.2. Usage data and technical information
We automatically collect certain information when you use the Service:
- metadata of audio recordings (date and duration of the audio recording);
- results of server analysis of audio recordings (text transcriptions cleaned of personal data, distribution by dialogue roles, evaluation of adherence to scripts and criteria, recommendations);
- technical session data when using the Personal Account (IP address, authentication token/cookie data, necessary for maintaining the session connection and security);
- for diagnostic purposes and to ensure stable operation of the mobile app, the service Sentry/Bugsink is used. Technical data may be transmitted to the service: device model, operating system version, application version, information about a failure, diagnostic messages. The mobile app does not collect data for advertising or tracking (including IDFA).
1.3. System permissions
To ensure the key functionality of the mobile app, it requests access to the microphone of the device. Audio recording, including in the background mode, is only performed after explicit permission is granted by the operating system.
2. How we use the information you provide
We may use the information we collect for purposes related to the operation of the AVA Companion product at all of its levels, including:
- For profile management and authentication: authentication of Users by e-mail in the app and the web platform; maintaining profiles (full name, region) on the web platform side; providing role-based access on the web platform side (so that each Manager sees sessions only of the employees assigned to them, and the Administrator sees sessions across the entire organisation).
- For data collection (mobile app): performing voice recording (including operation in the background) and synchronisation (transmission) of data to the server upon the user's button action.
- For local anonymisation (mobile app): real-time processing of the audio recording on the device (pitch shifting, formant filtering) and saving the audio recording with a distorted voice in order to protect biometric characteristics.
- For server-side AI analysis and de-identification: transmission of audio recordings to the secure servers of Vivanti SA for transcription and role assignment. Automatic de-identification algorithms are applied: any incidental personal data (phone numbers, client addresses, names, e-mail) spoken during the audio recording are automatically recognised and removed from text transcripts and metadata, which excludes their further storage and use.
- For providing results in the mobile app: returning detailed feedback on the recorded audio to the field employee (score, recommendations).
- For providing Personal Account functionality (web platform):
- providing Managers and Administrators with an interface for configuring evaluation criteria;
- displaying the history of dialogue sessions (containing strictly de-identified transcripts, text analysis, and scores) linked to the full name and region of the specific employee;
- generating analytics for selected periods, for selected employees and regions;
- generating aggregated feedback.
- For support: ensuring the operability, support, quality improvement of the Service, and resolution of technical issues.
3. Legal grounds for the processing of personal data
We process your personal data on the following legal grounds:
- Consent: given by way of consecutive actions (entering data during registration/authentication, providing a system permission to access the microphone). The user confirms that the data has been provided voluntarily. Consent may be revoked by sending a written notification to the email address in the “Contacts” section.
- Contractual necessity: for the performance of contracts (including a User Agreement with you or a commercial contract with your employer/client) and the provision of the services of the Service.
- Legal obligation: for the performance of requirements of the current legislation before state authorities.
4. Disclosure of the information you provided
We may transfer your personal information in the following cases:
- Within your organisation (Client): in accordance with the role model of the Service, the profile of the employee (surname, first name, region) and the results of their work (scores, transcriptions, analytics) are available to the Managers and Administrators of your organisation through the Personal Account (web platform).
- Transfer to service providers and affiliated persons: to persons providing us with assistance in the work of the Service (provided that a confidentiality agreement is signed obligatorily).
- On request of state authorities: if this is required in accordance with the law or in response to justified requests of state authorities.
5. Data security
We do everything possible to protect your data from unauthorised access. The distortion of voice characteristics and the automatic removal of personal data spoken from transcripts before their storage and display in the Personal Account are key security measures.
All processing and analysis of audio recordings is strictly carried out using local AI models located on the secure servers of Vivanti SA, without transferring audio data to external third-party AI services. The access of users to the Personal Account is protected by authentication mechanisms and strict rights separation (depending on the role: the Manager has access only to the data of their team, the Administrator – to all data).
All processing and analysis of audio recordings is strictly carried out using local AI models located on the secure servers of Vivanti SA, without transferring audio data to external third-party AI services. The access of users to the Personal Account is protected by authentication mechanisms and strict rights separation (depending on the role: the Manager has access only to the data of their team, the Administrator – to all data).
6. Data storage and deletion
- De-identified audio recordings: stored strictly in the device memory and on the servers of Vivanti SA for 14 (fourteen) calendar days from the moment of creation and synchronisation with the server. After this period, the original audio recordings are automatically and irrevocably deleted.
- Profile data and accounting information: your surname, first name, e-mail, region linkage, and technical information are stored for the time necessary to maintain the operation of the accounting record and achieve the purposes of this Policy (including the term of the contract with your organisation).
- De-identified transcriptions and analytics: text transcriptions of dialogues (fully cleared of personal data), scores, and aggregated statistics are stored in the Service for the term of the contract to ensure the history in the Personal Account. When a profile is deleted, the transcriptions and analytics about it are also deleted.
7. Your rights
- Right to access and correction: request copies of your data or demand correction of inaccurate information (e.g., change your surname or region).
- Right to early deletion: you can request deletion of your data before the automatic storage period expires.
- Right to restrict processing and withdrawal of consent: you have the right to withdraw consent at any time (by sending a written request to the contacts below) or restrict the mobile app's access to the microphone in the operating system's system settings.
8. Notification of data security breach
In the event of a data security breach affecting your personal data, we will notify you and the Roskomnadzor in the timeframes prescribed by the current legislation of the Russian Federation.
9. Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page with an updated effective date at the top. You are advised to review this Privacy Policy periodically for any changes.
10. Contact Information
If you have any questions about this Privacy Policy or wish to exercise any of your rights regarding your personal data, please contact us at info@vivanti.eu.