Privacy Policy for Palantrix

1. Who We Are and What This Policy Covers

   Palantrix is a Conversation Readiness Platform. It lets you rehearse high-value conversations — including mock interviews, client meetings, presentations and difficult workplace conversations — with an AI conversation partner, and gives you personalised coaching afterwards.

   • Palantrix is the data controller for your account and for the practice sessions you create.
   • If you choose to share a session with an employer, an educator or another organisation, that organisation becomes a separate data controller and handles what you shared under its own privacy policy.
   • Where an organisation or school provides Palantrix to you under its own agreement with us, it may also act as a controller for the parts of the service it administers. This policy still describes how we handle your data.

2. What Personal Data We Collect

   We collect and process the following types of personal data so that we can provide the platform to you:

   • Account and identity data (name, email address, contact details, and your organisation or school where relevant)
   • Context you choose to provide to shape a rehearsal (work history, education, documents, notes, role or job specifications, and account context imported from a connected CRM for business users)
   • Practice session data (voice recordings, video recordings and text transcripts of the conversations you rehearse)
   • AI-generated output about you (personalised coaching feedback, readiness scores, skill and confidence indicators, and your history of previous attempts)
   • Billing and subscription data, where you or your organisation pays for a plan
   • Technical and usage data (device and browser information, IP address, and how you use the platform)
   • Any additional information you choose to provide, for example when you contact support

3. Legal Basis for Processing

   We process your data on the following legal bases:

   • Performance of our contract with you — to create your account, run your rehearsals, and deliver your coaching and readiness scores
   • Your consent — for recording voice and video, for optional cookies and analytics, for marketing communications, and for each occasion on which you choose to share a session with someone else
   • Our legitimate interests — keeping the platform secure, preventing fraud and abuse, and improving the service
   • Compliance with legal obligations under Irish and EU law

   Where we rely on consent, you can withdraw it at any time without affecting processing that has already taken place.

4. How We Use Your Data

   We use your data to run the platform for you, including to:

   • Build an AI conversation partner shaped by the context you provide
   • Run your rehearsals by voice, video or text
   • Generate personalised coaching feedback and readiness scores after each session
   • Keep your session history — including previous copies and earlier attempts — available in your account so you can track your progress
   • Provide customer support and respond to your requests
   • Maintain the security and reliability of the platform
   • Improve the platform, using aggregated or anonymised data wherever possible

   We do not use your data for marketing or unrelated purposes without your explicit consent. We do not sell your personal data, and we do not make your sessions or your profile available for employers or educators to search or browse.

5. You Control What Is Shared

   This is the part that matters most, so we will be direct about it. Your practice sessions belong to you.

   • Every session you create is private to your account by default.
   • Nothing is sent to an employer, an educator or any other third party unless you actively choose to share it.
   • Sharing is per item. Choosing to share one session does not share your other sessions, your previous copies or your earlier attempts — those stay private to you.
   • You can keep rehearsing privately for as long as you like and never share anything at all. The platform is fully usable that way.
   • If you join a classroom or a workspace created by an educator or an employer, you will be told what that environment lets them see before you submit anything to it. Submitting work to a classroom is an act of sharing that you initiate.
   • Once you share something, the recipient holds a copy and processes it as a separate data controller, under their own privacy policy and retention schedule. We cannot delete their copy on your behalf, though you can ask them to.
   • You can stop future sharing at any time in your account settings, and you can contact us if you need help doing so.

6. AI and Automated Processing

   Palantrix uses AI to generate your conversation partner and your coaching feedback. Because that involves automated processing of your personal data, we want to be clear about its limits:

   • Palantrix does not make hiring, admission, grading, promotion or any other decision about you. We are a preparation tool, not a decision-maker.
   • Readiness scores and coaching feedback are advisory and are produced for you, to help you improve. They are not a verdict on your ability, and they are not passed to anyone else unless you share them.
   • There is no automated decision-making that produces legal effects concerning you or similarly significantly affects you.
   • You will always be told when you are interacting with AI rather than a person.
   • Your content is not used to train third-party foundation models.
   • We conduct Data Protection Impact Assessments (DPIAs) to identify and mitigate risks related to AI processing.
   • If you want a human to review AI-generated output about you, or you want to challenge it, contact our Data Protection Officer using the details below.

7. Data Sharing, Sub-Processors and International Transfers

   Apart from the sharing you initiate yourself, we share your data only where it is necessary to run the platform:

   • Your data is stored and hosted on Amazon Web Services infrastructure in the European Union, with our primary region in Ireland.
   • Access within Palantrix is limited to authorised personnel who need it to operate the platform or support you.
   • We use third-party service providers as sub-processors, including cloud hosting, AI model providers and voice processing. Each is bound by a written data processing agreement requiring GDPR compliance, and may process your data only on our instructions.
   • The AI model providers we currently use are Amazon Web Services (Amazon Bedrock), Anthropic and OpenAI.
   • Where any processing takes place outside the European Economic Area (EEA), it is covered by appropriate safeguards, including the European Commission’s Standard Contractual Clauses.
   • We may disclose data where we are legally required to do so, for example in response to a valid order from a competent authority.

8. Cookies, Analytics and Consent

   We use cookies and similar technologies on our website. Cookiebot is our consent management platform and is the single point of control for what runs:

   • Strictly necessary cookies are always active, because the site cannot work without them.
   • Preference, statistics and marketing cookies stay blocked until you consent to that category in the Cookiebot banner.
   • Google Consent Mode v2 is initialised with analytics, advertising and personalisation storage all set to denied before any tag loads, so nothing is measured before you decide.
   • Where you consent to statistics, we use Google Analytics 4 with IP anonymisation to understand how the site is used, and Microsoft Clarity on some campaign pages to understand page interaction.
   • You can change or withdraw your cookie consent at any time by reopening the Cookiebot banner from our website.

   Cookie consent is separate from your account. Declining analytics cookies does not affect your ability to use the platform.

9. Data Security

   We implement robust technical and organisational measures to protect your data, including:

   • Encryption of data in transit and at rest
   • Secure servers and encrypted storage
   • Logical separation of customer data
   • Access controls to limit data access to authorised staff only
   • Regular security audits, independent security testing and compliance checks

10. Data Retention

    • Your sessions, transcripts, recordings and feedback are retained while your account is active, so that your history and previous attempts stay available to you.
    • You can delete individual sessions, recordings or previous attempts at any time from your account.
    • If you close your account, we delete or anonymise your personal data after a short grace period, unless we are required to keep it by law — for example, billing records retained for tax purposes.
    • Anything you chose to share with an employer, an educator or another organisation is also held by them, under their own retention schedule.
    • Deleted data may persist in encrypted backups for a limited period before those backups are rotated out.

11. Children’s and Students’ Data

    Palantrix is used in schools and colleges, so some of our users are under 18.

    • Where a user is under the Irish digital age of consent (16), we rely on consent given or authorised by a parent or guardian, gathered through the consent flow provided to the school.
    • Schools and educators are responsible for having the necessary permissions before inviting students to a classroom, and for what they do with any work a student submits to them.
    • Students keep exactly the same control over sharing as any other user. Practice sessions stay private unless the student submits them.
    • A parent or guardian can exercise a child’s data protection rights on their behalf by contacting our Data Protection Officer.
    • We do not knowingly collect data from children below the age at which the platform is offered. If you believe we have, contact us and we will delete it.

12. Your Rights

    Under GDPR, you have the right to:

    • Access your personal data
    • Rectify inaccurate or incomplete data
    • Erase your data (“right to be forgotten”)
    • Restrict or object to processing
    • Data portability (receive your data in a structured format)
    • Withdraw consent at any time without affecting prior processing
    • Lodge a complaint with the Data Protection Commission (DPC) of Ireland

    To exercise any of these rights, contact our Data Protection Officer using the details below. We will respond within one month, and will tell you if we need longer because a request is complex.

13. How to Contact Us

    For questions, requests, or to exercise your rights, contact our Data Protection Officer at dpo@palantrix.com.

14. Updates to This Policy

    We may update this policy to reflect changes in law or our practices. Significant changes will be communicated on our website.

By creating a Palantrix account and using the platform to rehearse conversations, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your data as described above.

Last Updated: 24/08/2026