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Version 002Last updated 21.08.24Privacy Policy




1                     Introduction

This Privacy Policy provides information on how Personal Data is processed by Simli AS (“Simli”). Personal Data means any information relating to an identified or identifiable natural person.

This statement describes how we collect and process your Personal Data when you visit our website, use our Simli Services (the “Services”) as defined in our Terms of Service, or when you communicate with us in other ways. This Privacy Policy also describes how you may request additional information and exercise your privacy rights.

All references to “you” and “your” refer to the data subject which is every person who accesses our websites or uses the Service. The words "Simli," “us,” and “we” mean Simli AS, organization number 926 743 384, headquartered at Gaustadalléen 21, 0349 Oslo, Norway. 

We may change this Privacy Policy at any time by posting the revised version on this website and indicating the effective date of the revised Privacy Policy. 

If you have any further questions after reading this statement, do not hesitate to email us at support@simli.com

2                     Simli as a processor

Simli may process your data due to our agreement with our Customer, which is a company or entity that uses our Service and/or includes our Service for its own business purposes. In such cases, Simli does not act as a controller, and any questions related to processing Personal Data under the control of our customers will be directed to our Customer. 

3                     How we collect Personal Data

We collect Personal Data about you from the following categories of sources: 

You, when you create an account or use our Services, if you voluntarily provide personal information as part of your User Content while interacting with the Simli Services, and when you in other ways communicate directly with us. We also automatically collect information about you from your use of the Services and your actions on our website, by the use of cookies as described in section 8.

Third Parties, such as our service providers, advertising partners and social networks. 

  • Service providers: We may use analytics providers to analyze how you interact and engage with the Services
  • Advertising Partners: We may receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements, or communications.
  • Social Networks: If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

4                     Why we collect Personal Data and the lawful basis for doing so

We collect Personal Data for the purposes of providing the Services, to train our models, conduct research and improve our services, website analysis and improvement, direct marketing, and product updates as described below.

4.1                Free Trial Demo 

When you try out the Free Trial Demo, we process your first name and any Personal Data you include in your User Content when communicating with the Simli Services. We also collect information about your device. Our processing of these data is necessary for us to let you test our Services and for us to train our models and conduct research, which is fundamental for our development and improvement of our Services. We base our processing of Personal Data generated by your use of the Free Trial Model on our legitimate interest in providing you with the possibility to try out the Services and our interest in developing our products. If you object to our processing of Personal Data, you should not use our Free Trial Demo. 

4.2                Providing you with your user account

For us to create and administer your account and provide you access to our Services, we will collect your full name, the account credentials provided by you when registering for the account, your email address, and information from our Security Logs, such as IP address, time stamps, user actions, and device information. The processing is necessary for us to fulfill our agreement with you or to take steps as requested by you before entering into the Agreement. 

 

4.3                Payment and invoicing

We process your Stripe User-ID to direct you to our third-party payment provider. This processing is necessary to fulfill our Agreement with you.  

 

4.4                Training our model and improving our Service: 

We use User Content and activity data to train our models, conduct research and improve our services. This means that any Personal Data you include in your User Content (as defined in Terms of Service), API requests, analysis of use and user patterns and information from Security Logs are processed. This processing is necessary to fulfill our Agreement with you.

 

 

4.5                Monitoring the Services

We monitor the Services for billing purposes and to detect and prevent violation or attempted violation of the Terms of Use. Our monitoring of the Service is necessary for us to fulfill our Agreement with you and to deliver the Service in accordance with our obligations as stated in the Terms of Service. Monitoring of the Service means we will process activity data, any Personal Data included in User Content, API requests and Security Logs. 

 

4.6                Customer support and customer feedback 

We may process your contact information such as your name and email and your usage logs when you submit a request for troubleshooting, support for your use of the Service or suggestions for improvements. Usage logs include IP-addresses, time stamps and your actions when using the Service or navigating on our website.  We do not use usage logs for any other purposes than to provide you with the requested support or troubleshooting. The processing is necessary for us to fulfil our Agreement with you. 

 

4.7                Direct marketing and product updates

Simli will use your name and contact information to keep you updated on any product launches, software updates or similar marketing related communications related to the Service. You may opt out of any marketing communications by sending an email to support@simli.com or by accessing the link in the email you received or by administering your consents in your account settings.  We base our use of your data for these purposes on our legitimate interest in promoting our Services to our users or on your explicit consent to our use of cookies for direct marketing purposes. 

 

4.8                Recruitment

If you apply for a position in Simli, we will process your submitted data. We use your information to consider whether you are a potential candidate for our positions, and we need to process it before entering into a potential agreement with you. 

 

4.9                Cookies 

To improve our website and the Service, we use cookies to track your use of the Service and your activity on the Simli domains. Some cookies are considered strictly necessary for us to provide the services, while others are optional and will be used based on your consent. Read more about the cookies we use in section 8 below.  

5                     Retention period

We will delete Personal Data, such as your account information upon your request or within 12 months after termination of your Account unless we have a legal obligation to retain the data for accounting purposes. We will delete your name and email-address within a period of 24 months or upon your request. 

Your User Content will be retained for as long as necessary. Simli will use such User Content and Output for the purpose of training our models and developing our products.

We will delete applications we receive for open positions when the recruitment period is finalized, unless you become an employee, or you consent to us keeping the application for future recruitment purposes. 

Please see section 8 for retention periods for Personal Data collected by our use of cookies. 

6                     Who we share your information with

We do not sell or rent Personal Data to third parties for marketing purposes. We will not share your Personal Data with any third parties unless we have legal grounds for sharing the data or it is required under any statutory obligations. We may share your Personal Data with the following persons on a need-to-know basis: The authorized members of our teams, financial organizations (banks, etc.), supervisory authorities, where appropriate, the competent courts, mediators, accountants, auditors, lawyers, bailiffs, and debt collection agencies. 

We cooperate with Stripe as the payment service provider. Stripe is the controller of payment details and contact information you provide for billing purposes. We share your email and user-ID with Stripe, along with the billable amount for Stripe to conduct payment. Stripe is located in the United States. Stripe is subject to the EU-US Privacy Framework Agreement and guarantees that Personal Data is processed in accordance with GDPR and international privacy regulations.

We also share your Personal Data with our service providers, who process it on our behalf to provide the Service to you. 

We share User Content with third-party service providers that provide large language models and artificial intelligence services. Such User Content will not include Personal Data unless you explicitly provide it when interacting with the avatar. Simli may change such service providers from time to time. We take the necessary steps to ensure that all service providers have implemented adequate safeguards to ensure safe processing of Personal Data in compliance with our obligations under GDPR. Our main service providers who process Personal Data on our behalf are 

  • Google - Provider of cloud services
  • Mailchimp - Provider of communications such as emails and newsletters. Located in the United States. 
  • Mixpanel - Provider of analytics tool enabling us to analyze how users interact with our digital product.
  • Hubspot - Provider of our CRM platform. 
  • Buffer – Provider of analytics tool enabling us to analyze how users related with our social media channels.

 

Our main providers of Large Language Models (“LLMS), third-party APIS and other services, processing User Content on our behalf are

  • OpenAI - Provider of large language models.
  • Groq – Provider of large language models.
  • ElevenLabs– Provider of voice technology.
  • Microsoft – Provider of Microsoft Azure speech to text technology.  
  • Daily – Provider of streaming of audio and video.
  • PlayHT – Provider of voice technology.
  • DeepGram – Provider of voice technology.
  • ReTell – Provider of voice technology.
  • Meta – provider of large language models.

7                     Your rights as a data subject

7.1               Your right to control your Personal Data

Simli value your privacy rights regardless of where you live. Subject to GDPR, we have a legal obligation to grant our users the right to make requests as listed below:

  • access your Personal Data. You may request information on the purposes of the processing, the categories of Personal Data concerned, the envisaged period for which the personal data will be stored, any available information as to the Personal Data’s source, amongst others. 
  • rectification of inaccurate Personal Data concerning you. Considering the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement correction of any errors in the Personal Data we have stored about you, 
  • deletion of Personal Data concerning you, unless processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims; 
  • receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller ('right to data portability'); 
  • lodge a complaint with a supervisory authority.

7.2                Exercising your rights

Requests pursuant to the above rights may submitted to support@simli.com 

We will respond to your request within 30 days. 

If you have any concerns about how we process your Personal Data, you are welcome to file a complaint to the Norwegian Data Protection Authority or the relevant data protection authority in your country. 

8                     Use of cookies

Cookies are text files containing small amounts of information that are downloaded to your computer or mobile device when you visit Simli’s website. They allow us to recognize your device.

We use cookies that are strictly necessary for the performance of our services (Necessary Cookies) and cookies that provide us with analytics about the performance of our website (Performance Cookies). If you do not agree to our use of Necessary Cookies, you must leave the website and stop using our services.

You can administrate your consent to our use of Performance Cookies and the use of cookies for marketing purposes by changing your preferences in the cookie settings.

Based on your consent, we use Performance Cookies for the following purposes:

  • Website and product analysis and improvement
  • To analyze trends and usage patterns on the website
  • To improve the website by adapting its configuration and design to behavioral patterns

Activity data collected by the use of “cookies” is analyzed to help us understand how visitors to our website and Users interact with the Service and how they navigate when visiting the website or using the Service.  

8.1                Third-party cookies:

We use the following cookies:

Category

Description

Personal Data

Necessary cookies (Authentication)

Cookies give our visitors the possibility to keep their acceptance or non-acceptance setting of our cookie policy for their next visit. 

The cookies also allow us to authenticate our Users and keep them logged into their accounts. 

IP address, User ID (on the website), Browser details, Time of visit, Pages viewed 

Google Analytics

Performance cookies (Analytics)

 

Google Analytics cookies help us understand how visitors interact with our website, by collecting and reporting information anonymously. This includes tracking page views, site usage, and the effectiveness of marketing campaigns.

Storage Time: Up to 2 years.

IP address, User ID (on the website), Browser details, Time of visit, Pages viewed.

 

Google Ads

Advertising cookies

 

Enables us to engage with users who have previously visited our website, providing tailored advertising based on past site interactions and preferences.

Storage Time: Up to 120 days.

IP address, User interactions with ads, User preferences.

Meta (Facebook) Ads: Facebook Pixel

Advertising cookies

 

Collects data that helps track conversions from Facebook ads, optimize ads, build targeted audiences for future ads, and remarket to people who have already taken some kind of action on our website.

Storage Time: Up to 180 days.

IP address, Social media user ID, Web browsing behaviour on the site

Hotjar 

Performance cookies (Analytics)

 

Hotjar cookies collect information on how users interact with our website, providing insights into clicks, mouse movements, and non-sensitive text entered into forms.

Storage Time: Up to 365 days.

Device IP address (stored in a de-identified form), Screen resolution, Type of device (unique device identifiers), Geographic location (country only), Preferred language.

Hubspot

Performance cookies (Analytics)

and

Advertising cookies

 

 

HubSpot’s tracking cookies allow us to understand visitor interactions with our website, enhancing user experience and enabling personalized marketing efforts. This includes tracking visitor behaviour, such as page views and clicks, to improve website functionality and effectiveness of marketing campaigns.

Storage Time: Up to 13 months

IP address, Email address (if provided), Name (if provided), Phone number (if provided), Browser details, Time of visit, Pages viewed, Interactions with site (e.g., form submissions).

Twitter Pixel

Performance cookies (Analytics)

and

Advertising cookies

 

Enables tracking of visitor activity on the website from a Twitter ad, optimizing ad campaigns, and retargeting users for ads.

Storage Time: Up to 120 days.

 

Twitter user ID (for users logged into Twitter), Browser type, Time of visit, Pages visited.

 

 

 

 

 

 

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