Privacy Policy
This Privacy Policy explains how Prestance Lab handles personal data in connection with the Clauzy voice-first rehearsal and coaching application for retail teams and the related service (together, the “Solution”). It is written to be read alongside the Data Processing Agreement and the Security policy, which govern in the event of any conflict for business-customer relationships.
1. Who we are and our role
Prestance Lab (“Prestance Lab”, “we”, “us”) provides a business-to-business, voice-first rehearsal and coaching Solution for retail teams. The Solution is made available to professionals (“Authorized Users”) by their employer or principal (the “Customer”) under a subscription agreement.
Our role depends on the data in question:
- As a processor. For the personal data generated when an Authorized User runs a coaching drill — voice audio, transcripts, scores, and coaching feedback — the Customer is the data controller and Prestance Lab acts as its processor, processing that data only on the Customer’s documented instructions under the Data Processing Agreement. If you are an Authorized User, your employer determines why and how this data is used; please direct rights requests to them in the first instance (see Section 10).
- As a controller. For a limited set of data we need to run the Solution as a business — account administration, authentication and security logs, billing records, and aggregated product analytics — Prestance Lab acts as the controller.
2. The data we process
| Category | Examples | Our role |
|---|---|---|
| Account & identity | Name, professional email address, workspace and role assignment, login credentials. | Controller |
| Voice & conversation | Microphone audio captured during a drill, real-time and stored transcripts of the simulated conversation; voice of telephone calls with the assistant and message content on the telephone, SMS, email and WhatsApp channels, where the Customer activates them. Calls with the assistant and drill sessions are recorded; recordings are anonymized and de-identified before they are stored. | Processor |
| Coaching outputs | Performance scores, skill maps, coaching letters, and other feedback derived from a drill. | Processor |
| Visit slips (bons de visite) | Identity and contact details of the visitor (buyer), the property visited, and the visit date, recorded on a legal document a real-estate agent (a “mandataire”) issues through the Solution. | Processor |
| Google Calendar (optional) | Events on the calendars a mandataire owns — title, time, location, attendee names — read and written when she connects her Google Calendar. See section 6. | Processor |
| Device & technical | Device type and operating-system version, app version, IP address, crash and diagnostic logs, connection quality metrics. | Controller |
| Product analytics | Pseudonymous events about how features are used (for example, a drill started or completed), to operate and improve the Solution. | Controller |
The Solution is a professional tool. It is not directed at the general public and should not be used to submit special-category personal data or the personal data of real third parties as drill content — see the Acceptable Use Policy.
3. Voice data
A coaching drill requires access to your device’s microphone. Audio is captured only while a drill is active and is used to power the live spoken interaction, to produce a transcript, and to generate coaching feedback.
Voice data is used for speech interaction and communication coaching only. We do not use your voice to identify you biometrically, and we do not deploy emotion-inference models, nor do we use the content of drills to build advertising profiles. Microphone access can be revoked at any time in your device settings; doing so disables voice drills.
4. Why we process personal data
Where Prestance Lab acts as a controller, we rely on the following legal bases under the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and equivalent laws:
- Performance of a contract — to provision accounts, authenticate users, and deliver the Solution.
- Legitimate interests — to keep the Solution secure, prevent abuse, and understand and improve how it is used, balanced against your rights and freedoms.
- Legal obligation — to meet accounting, tax, and security obligations.
Where Prestance Lab acts as a processor, the legal basis for processing drill data is determined by the Customer as controller.
5. Sub-processors and how data is shared
We do not sell personal data and we do not share it for third-party advertising. We rely on a small set of vetted infrastructure and artificial-intelligence sub-processors to operate the Solution — for hosting and storage, real-time audio transport, speech and language processing, and product analytics. The authoritative, current list, together with their locations and the safeguards that apply, is maintained in the Data Processing Agreement and the Security policy.
Sub-processors are bound by contract to process personal data only to provide their service to us, and our AI sub-processors operate under a no-training posture — your data is not used to train their models. We may also disclose data where required by law or to establish, exercise, or defend legal claims.
International transfers
We host and store personal data in the European Union. Where a sub-processor processes data outside the European Economic Area, the transfer is covered by an adequacy decision or by Standard Contractual Clauses, as detailed in the Data Processing Agreement.
6. Google Calendar, Gmail drafts and Google user data
A real-estate agent (a “mandataire”) may choose to connect her Google account to Clauzy. The connection is optional, initiated by her through Google’s own consent screen, and can be revoked at any time.
What we access. We request two Google permissions
on one consent screen:
https://www.googleapis.com/auth/calendar.events.owned
(“see, edit, share, and permanently delete calendar events you
own”) and
https://www.googleapis.com/auth/gmail.drafts.create
(“create drafts in your Gmail”). We read and write events
on the calendars the mandataire owns, and we create drafts in her own
Gmail mailbox. We do not read her email, do not send email from her
mailbox, do not list, modify, or delete her drafts, and do not
request access to Drive, Contacts, or any other Google service. We do
not read other people’s calendars.
Why. Clauzy creates, updates, and cancels appointments she has agreed to (property visits, client meetings, call-backs) directly in her calendar, and reads those events to answer her questions such as “when is my next visit?” and to prepare the appointment. After she debriefs a property visit, by phone or by email, Clauzy writes the follow-up emails she owes — typically a factual report to the seller and a thank-you with the next step to the buyer — and files them as drafts in her Gmail, with no recipient, so that she reads, completes, and sends them herself under her own name. Google data is used for no other purpose.
How it is stored. Google access and refresh tokens are held by our authentication sub-processor (Nango) and are never written to our own database. Event data we create or read (title, time, location, attendee names as entered by the mandataire) is stored in our database in the European Union, encrypted at rest, and is visible only to the mandataire who owns the calendar. We keep no copy of the drafts we create: each draft exists only in her Gmail mailbox, at Google. The text of a draft is generated by Clauzy from her own call or email and is processed by automated systems only, like the rest of her data. Google user data is not used to train artificial-intelligence models, ours or our sub-processors’.
Sharing. We do not sell Google user data, do not use it for advertising, and do not transfer it to third parties other than the sub-processors needed to operate the connection. Prestance Lab staff do not read calendar data except to resolve a support request the mandataire has made, or where required by law.
Retention and revocation. One revocation removes both permissions. Calendar tokens and the event data we hold are deleted when the mandataire disconnects her Google account in Clauzy, revokes Clauzy’s access from her Google account (myaccount.google.com/permissions), asks us to erase her data (privacy@clauzy.ai), or closes her account. We hold no Gmail data to delete: drafts already filed remain in her Gmail mailbox and are hers to keep or delete.
Clauzy’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
7. Retention
Drill data (audio, transcripts, and coaching outputs) is retained for the duration of the Customer’s subscription, after which it is deleted or returned in line with the Data Processing Agreement — on termination, permanently deleted within 30 days, save for backups which are purged on the next scheduled rotation (90 days maximum). Account, security, and billing records that we hold as controller are kept only as long as necessary for the purposes above and to meet our legal obligations.
Visit slips (bons de visite). A visit slip records personal data about a third party who has no contract with Prestance Lab: the visitor (buyer) of a property. For that data, the real-estate agent (the “mandataire”) who issues the slip is the controller — she collects the data and decides the purpose — and Prestance Lab acts as her processor on her documented instructions. Visit-slip records are kept for five years from the visit date, the ordinary limitation period of article 2224 of the French Civil Code, because the slip is the mandataire’s evidence that the visit took place; they are deleted earlier on her instruction. A visitor who wishes to exercise a right over this data should contact the mandataire in the first instance, or privacy@clauzy.ai when in doubt.
8. Security
Personal data is encrypted in transit and at rest, access is restricted on a need-to-know basis, and the Solution is operated under the controls described in our Security policy. Suspected security issues can be reported to security@clauzy.ai.
9. Children
The Solution is a workplace tool intended for professional use by adults. It is not directed at children and we do not knowingly collect personal data from anyone under the age of 16.
10. Your rights
Subject to applicable law, you have the right to access, rectify, erase, restrict, or object to the processing of your personal data, and the right to data portability.
If you are an Authorized User, your employer (the Customer) is the controller of your drill data. Please send rights requests to your employer first; we will assist them in responding, as required by the Data Processing Agreement. For data we hold as controller, or if you are unsure who to contact, write to privacy@clauzy.ai.
You also have the right to lodge a complaint with a supervisory authority. In France, this is the Commission Nationale de l’Informatique et des Libertés (CNIL).
11. Changes to this Policy
We may update this Policy from time to time. Material changes affecting business Customers are notified at least 30 days in advance in line with our general terms, unless a shorter period is required by law or to address a security risk. The date at the top of this page records the latest revision.
12. Contact
- Privacy and data-protection matters: privacy@clauzy.ai
- Security incidents: security@clauzy.ai
- General legal enquiries: legal@clauzy.ai