1. Introduction
El8Consulting (“
we”, “
us”, “
our”) operates a web-based software platform that enables businesses and teams to engage in interactive roleplay sessions with AI personas, including real-time conversational feedback and optional video/audio recording (“
Service”).
We are committed to protecting your privacy and processing personal data transparently and securely.
2. Who This Policy Applies To
This Privacy Policy applies to:
- Business users and team members using the Service
- Authorized representatives of customer organizations
The Service is intended
only for users aged 18 or older.
3. Data Controller
For the purposes of data protection laws, including the EU General Data Protection Regulation (“GDPR”):
Data Controller:
El8Consulting
Country of incorporation: Canada
Contact: harsh@eL8consulting.ca
4. Personal Data We Collect
4.1 Account & Profile Data
- Name or username
- Email address
- Profile photo
- Authentication credentials (hashed)
4.2 Conversation Data
- Text-based conversations with AI personas
- Prompts, responses, and contextual inputs provided during sessions
Conversation data is
stored persistently and used solely to provide the Service.
4.3 Audio & Video Data (Opt-in Only)
If you explicitly opt in to recording:
- User video
- User audio
- AI persona audio/video output
Recordings are
not enabled by default and require explicit user consent.
4.4 Technical & Usage Data
- Session identifiers
- Device/browser metadata
- Authentication/session cookies
We
do not use behavioral analytics or marketing tracking cookies.
5. Purpose of Processing
We process personal data to:
- Provide AI roleplay and feedback functionality
- Enable real-time video/audio interactions
- Store and replay recorded sessions (if opted in)
- Ensure platform security and reliability
- Comply with legal obligations
6. Legal Basis for Processing (GDPR)
Where GDPR applies, we rely on:
- Contractual necessity – to deliver the Service
- User consent – for video/audio recordings
- Legitimate interests – security, service improvement
- Legal obligations, where applicable
7. AI & Model Processing
- AI inference is performed using AWS Bedrock
- User data is not used to train or fine-tune AI models
- AWS Bedrock does not retain or reuse data for model training, in accordance with AWS policies
8. Data Retention
We retain data only for as long as necessary:
| Data Type |
Retention Period |
| Conversation text |
365 days |
| Video/audio recordings |
365 days |
| Account data |
Until account deletion |
Users may manually delete recordings before automatic deletion.
9. Data Sharing & Sub-Processors
We use the following sub-processors:
| Provider |
Purpose |
| AWS Bedrock |
AI inference |
| Tavus |
AI persona video generation |
| DailyJS |
Real-time audio/video streaming |
| AWS S3 |
Secure media storage |
| Supabase |
Application & user data storage |
| Vercel |
Frontend hosting & delivery |
All sub-processors are contractually bound to confidentiality and data protection obligations.
10. International Data Transfers
Data may be processed outside your country of residence, including in the United States and other jurisdictions.
We rely on appropriate safeguards such as:
- Standard Contractual Clauses (SCCs)
- Equivalent legal transfer mechanisms
11. Your Rights
Depending on your location, you may have the right to:
- Access your personal data
- Download your data
- Correct inaccurate data
- Delete your account
- Restrict or object to processing
- Withdraw consent (for recordings)
Requests can be sent to
harsh@eL8consulting.ca.
12. Security Measures
We implement appropriate technical and organizational safeguards, including:
- Encryption in transit and at rest
- Access controls and least-privilege access
- Secure infrastructure and vendor due diligence
13. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated via the Service.
14. Contact
For privacy-related inquiries or requests:
📧
harsh@eL8consulting.ca
📄 Data Processing Agreement (DPA)
El8Consulting
1. Scope & Roles
This Data Processing Agreement (“
DPA”) governs the processing of personal data by El8Consulting on behalf of its customers.
- Customer: Data Controller
- El8Consulting: Data Processor (for customer-controlled data)
- Sub-processors: As listed in Section 6
2. Subject Matter & Duration
Processing covers:
- User account data
- AI conversation data
- Optional video/audio recordings
Duration: For the term of the customer agreement plus defined retention periods.
3. Nature & Purpose of Processing
Processing is limited to:
- Enabling AI roleplay functionality
- Real-time audio/video interactions
- Secure storage and playback of sessions
- Platform operation and security
4. Processing Instructions
El8Consulting shall process personal data:
- Only on documented customer instructions
- In compliance with applicable data protection laws
5. Confidentiality
All personnel with access to personal data are bound by confidentiality obligations.
6. Sub-Processors
Approved sub-processors:
- AWS (Bedrock, S3)
- Tavus
- DailyJS
- Supabase
- Vercel
El8Consulting ensures equivalent data protection obligations are imposed on all sub-processors.
7. Security Measures
El8Consulting implements:
- Encryption at rest and in transit
- Logical access controls
- Secure infrastructure practices
8. Data Subject Rights
El8Consulting shall assist customers in responding to data subject requests, including access, deletion, and portability.
9. Data Breach Notification
El8Consulting will notify customers without undue delay upon becoming aware of a personal data breach.
10. Data Deletion & Return
Upon termination or request:
- Personal data will be deleted or returned
- Unless retention is required by law
11. International Transfers
Where data is transferred internationally, El8Consulting relies on lawful transfer mechanisms, including SCCs.
12. Audits
Upon reasonable notice, customers may audit El8Consulting’s compliance, subject to confidentiality and security constraints.
13. Governing Law
This DPA is governed by the laws of
Canada, unless otherwise agreed.
