Privacy Policy

This Privacy Policy describes how Copient AI LLC and its affiliated companies (collectively, "Copient AI", "we", "our" or "us") collects, stores, uses and discloses the following categories of personal data:

Customer Data: personal data (as defined in Section 1) that we collect, process, and manage on behalf of our business customers (each, a "Customer"; collectively, "Customers"), as part of the Copient AI products and services described on one or more applicable order forms ("Platform").
Student Data: If our Customer's use of the Platform involves the collection and processing of student data (e.g., training participants in educational or corporate learning environments), this data is processed on behalf of and under the instruction of the respective Customer, in compliance with applicable laws, such as FERPA or similar regulations.
User Data: personal data concerning individuals acting on behalf of our Customers in respect of their engagement with Copient AI, and users of the Platform on behalf of such Customers, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the Customer (collectively, "Users"); as well as the Customer's business needs and preferences, as identified to us or recognized through our engagement with them.
Prospect Data: data relating to visitors of our website (www.Copient.ai), participants at our events, and any other prospective customer, user or partner (collectively, "Prospects") who visits or otherwise interacts with our website, online ads and content, emails, integrations or communications under our control (the "Sites", and collectively with the Platform, the "Services").

By default, the terms and conditions and this Privacy Policy apply to all Customers. In cases where specific processing instructions or additional requirements are necessary, such Customer Data is processed on behalf of and under the instruction of the respective Customer, as outlined in a mutually agreed upon Data Processing Addendum.

If you are a Customer, User or Prospect, please read this Privacy Policy carefully and make sure that you fully understand it.

Our Services are designed for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Policy, including information about any visitors to our Sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.

You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use our Services.

1. Data Collection & Processing

When we use the terms "personal data" or "personal information" in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Sometimes we collect personal data automatically when an individual interacts with our Services or Sites (such as through our website chat feature) and sometimes we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as our Customers and Service Providers), even before our first direct interaction. Copient AI does not collect, use, or disclose sensitive personal data.

We may collect or generate the following types of personal data about individuals through the Services:

Automatically collected data: Usage, login credentials, and device information concerning Users and Prospects (e.g., connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, device data like type, OS, device ID, browser version, locale and language settings used, activity logs, session recordings, log-in credentials to the Services, cookies and pixels installed or utilized on their device, and inferred or presumed data generated from their use of the Services).
User-provided data: Contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback, testimonials, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement). Additionally, any other data voluntarily provided by individuals, such as gender, title, resumes, or other information relevant to applications or engagements, may also be collected.
Customer Data: Personal data contained in Customer Data provided by our Customers or processed on their behalf and under their instruction. This may include any of the types of personal data described above (with respect to Users or other individuals whose data is contained in the Customer Data).

2. Data Uses

We use personal data as necessary for the performance of our Services ("Performance of Contract"); to comply with our legal and contractual obligations ("Legal Obligation"); and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Customers, Users, Prospects, ourselves and our Services ("Legitimate Interests").

If you reside or are using the Services in a territory governed by privacy laws under which "consent" is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing) ("Consent"), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@copient.ai

Specifically, we use personal data for the following business and commercial purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

Customer and User personal data

To facilitate, operate, enhance, and provide our Services (Performance of Contract; Legitimate Interests);
To provide our Customers and Users with assistance and support, to test and monitor the Services, or diagnose or fix technology problems, and to train our Customers and Customer-facing staff (Performance of Contract; Legitimate Interests);
To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities to make our Services easier to use (Performance of Contract; Legitimate Interests);
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners (Legitimate Interests; Consent);
To facilitate, sponsor and offer certain events, contests and promotions (Legitimate Interests).

Customer, User and Prospect personal data

To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others' user experience and the value they can generate from using the Services, so we could continue improving our products, offerings and the overall performance of our Services, including through the utilization and optimization of Artificial Intelligence and Machine Learning capabilities (Legitimate Interests);
To contact our Customers, Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract; Legitimate Interests; Consent);
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity (Performance of Contract; Legitimate Interests; Legal Obligation);
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests);
To enforce our Terms and Conditions, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests);
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract; Legitimate Interests; Legal Obligation); and
For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent).

3. Data Location

We and our authorized Service Providers (defined below) currently, as of January 2025, maintain, store and process personal data in the United States of America and may expand to other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Copient AI is committed to protect personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

4. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to provide our Services, comply with legal and contractual obligations, resolve disputes, and enforce our agreements, in accordance with our data retention policy.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes of processing, and applicable legal requirements. Personal data will be deleted or anonymized when no longer required, unless we are legally obligated to retain it or it is needed to establish, exercise, or defend legal claims.

If you have any questions about our data retention policy, please contact us by e-mail at privacy@copient.ai

5. Data Disclosure

We disclose personal data in the following ways:

Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers may include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, our website chat feature, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, LLMs, voice-to-text, error/logging services, and our legal, financial and compliance advisors (collectively, "Service Providers"). Our Service Providers may have access to personal information, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
Partnerships: We engage selected business and channel partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our Customers, Users and Prospects. In such instances, we may share relevant contact, business and usage details with the respective partner, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any of our partners, please note that any aspect of that engagement which is not directly related to the Services and directed by Copient AI is beyond the scope of Copient AI's Terms and Conditions and Privacy Policy, and may therefore be covered by the partner's terms and privacy policy.
Service Integrations: You may choose to use a third-party service to integrate with our Services, for example in order to upload or retrieve personal data to or from the Services, or to enrich the data you have processed on either service or enhance your usage thereof (provided that such integration is supported by our Services). The provider of this integrated third-party service may receive certain relevant data about or from your account on the Services, or share certain relevant data from your account on the third-party provider's service with our Services, depending on the nature and purpose of such integration. This could include your Customer Data and/or User Data. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them).
Event Sponsors: If you attend an event or webinar organized by us, or download or access an asset on our Sites related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your personal data with them. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will be subject to the sponsors' privacy statements. If you do not wish for your personal data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 9 below;
Business Customers: As a processor, we process personal data on behalf of our Customers in accordance with their instructions. We provide reasonable assistance to our Customers to enable them to fulfill their obligations under applicable data protection laws, including responding to data subject requests and ensuring access to personal data as required.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Copient AI, any of our Users or Customers, or any members of the general public.
Copient AI Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Copient AI or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.

For the avoidance of doubt, Copient AI may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

6. Cookies and Data Collection Technologies

We and our Service Providers use cookies, logs, pixels and other technologies to enable and improve the Services we provide, to track the performance of our Sites, perform analytics and gain insights on the use of our Services and the performance of our activities, and for personalization purposes.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the "Session Cookies". Some last for longer periods and are called "Persistent Cookies". We use both types.

We use "Persistent Cookies" to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services' features and tools.

Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless you delete and block them through your web browser settings. Some cookies are essential for the proper functioning of our Services and cannot be declined or disabled unless you choose to delete or block them through your web browser settings. Other cookies are optional and are used to enhance functionality, improve performance, analyze usage, and support marketing efforts.

We use analytics and tracking technologies to understand how Users interact with our Services. These tools may collect information such as page content viewed, clicks, touch interactions, movements, scrolls, and other engagement activities. This information helps us improve the user experience and the effectiveness of our Services.

For additional information on managing cookies and analytics settings, including how to opt out of certain tracking technologies, please refer to your browser settings or the opt-out options provided by relevant analytics services. For updated list of analytics tools used by Copient AI, you may reach out to privacy@copient.ai.

Please note that if you get a new device, install a new browser, erase or otherwise alter your browser's cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

7. Communications

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. If you are registered as a User to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Copient AI at any time by sending an e-mail to: privacy@copient.ai, changing your communications preferences in your profile settings whilst being logged as a User to our Services, or by following the "unsubscribe", "stop", "opt-out" or "change e-mail preferences" instructions contained in the promotional communications you receive.

8. Data Security

We are committed to protecting your personal data and take reasonable steps to secure it. Our systems, applications, and procedures are designed to minimize the risks of theft, damage, loss, unauthorized access, or misuse of your personal data. We rely on industry-leading cloud infrastructure providers, including Heroku and AWS, for the physical and virtual security of our systems. However, we cannot guarantee that our Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

9. Data Subject Rights

Your Rights
Individuals have rights regarding their personal data, depending on the applicable laws (e.g., GDPR, LGPD, CCPA, FADP). These may include:

Access: Request access to specific personal data, categories of data, sources, purposes of processing, and third parties with whom data is shared.
Correction or Erasure: Request correction of inaccurate data or deletion of data where legally permissible.
Restrict or Object: Restrict or object to data processing, including opting out of the sale or sharing of personal data.
Data Portability: Request a copy of your data in a machine-readable format.
Freedom from Discrimination: Exercise your rights without discrimination.
Lodge Complaints: File complaints with supervisory authorities (e.g., EU Data Protection Authorities, UK ICO, Brazilian ANPD).

How to Exercise Your Rights
To exercise your rights, contact us at privacy@copient.ai. You may also designate an authorized agent to submit requests on your behalf. Verification of your identity or authorization may be required to process your request.

Verification Process
When submitting a request, we may:

Ask for credentials to confirm your identity and ensure compliance with privacy laws.
Request additional details to understand the scope of your request.
Forward requests to the appropriate Customer if we act as their "data processor" or "service provider." We recommend contacting the Customer directly for such requests.

Special Considerations

FERPA Compliance: If you are a student or parent subject to FERPA, requests related to educational records will be processed in accordance with FERPA regulations.
Redaction: We may redact personal or confidential information related to others when fulfilling your requests.

Dispute Resolution
If you have unresolved concerns about our data practices, you may escalate your complaint:

EU, UK, and Swiss Residents: Contact relevant Data Protection Authorities (DPAs) or invoke binding arbitration as outlined under the EU-U.S. and Swiss-U.S. Data Privacy Frameworks.
Federal Oversight: Copient AI LLC is subject to the Federal Trade Commission (FTC) for compliance investigations.

10. Data Controller/Processor

Certain data protection laws, such as the GDPR, CCPA, and LGPD, define two main roles in handling personal data:

Data Controller (or "Business" under CCPA): Determines the purposes and means of data processing.
Data Processor (or "Service Provider" under CCPA): Processes data on behalf of the data controller.

Our Roles

Customer Data:

Your Role: As our Customer, you act as the data controller. You define how personal data—such as training scripts, voice recordings, or interaction data—is used in the context of our Services.
Our Role: Copient AI acts as the data processor, processing Customer Data based on your instructions. We do not make independent decisions about this data. Any third-party tools we use to deliver our services (e.g., speech-to-text, text-to-speech, AI avatars, or LLMs) function as sub-processors on our behalf.

Prospect and User Data:
For personal data collected directly by Copient AI, such as user account information or platform analytics, we act as the data controller and assume responsibilities for compliance under applicable law.

Customer Responsibilities

Consent and Transparency: As the data controller, you are responsible for providing notice to your end users (e.g., trainees, employees, or participants) and obtaining any required consents for data collection and processing within the platform.
Legal Compliance: You must ensure compliance with all applicable laws, including GDPR, CCPA, and FERPA (if relevant), particularly when processing personal data within an employment or training context.

Data Subject Requests
If an end user submits a request regarding their personal data (e.g., access, deletion, or correction), we will refer the request to you as the data controller. We will assist you in fulfilling such requests, as outlined in our agreements.

Third-Party Tools and Sub-Processors
To deliver our services, we rely on third-party tools (e.g., speech-to-text, text-to-speech, and AI-powered technologies). These tools process data on your behalf as sub-processors. A list of our sub-processors and their privacy practices can be provided upon request or as outlined in our agreements.

How We Process Data
Copient AI processes Customer Data strictly in accordance with your instructions, as detailed in our Data Processing Addendum and commercial agreements. We do not sell or share Customer Data for purposes outside of providing our services.

11. Additional Notices & Contact Details

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe that the changes involved materially alter your rights, via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Children: Our Services are not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such a child. If you believe that we might have any such data, please contact us by e-mail at privacy@copient.ai