Privacy & cookies policy

In this Policy, the following terms shall have the following meanings:

• "Account" means an account required to access and/or use SimChat;
• "Cookie" means a small text file placed on your computer or device by Our Platform when you visit certain parts of Our Platform and/or when you use certain features of Our Platform. Details of the Cookies used by Our Platform are set out in section 14, below;
• "Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
• "Personal data" means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Platform.
• This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 2018 and UK GDPR; and
• "We/Us/Our" means Geeky Medics Limited, a company incorporated and registered in England and Wales with company number 09523980 whose registered office is at Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA.

2.1. SimChat is owned and operated by Geeky Medics Limited of Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA.

2.2. You can contact us by writing to us at the address above, or by emailing us at support@simchat.ai.

2.3. Our Data Protection Lead is Dr Lewis Potter.

This Policy applies only to your use of Our Platform at simchat.ai.

Our Platform may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

SimChat uses a cookie consent tool to control analytics and tracking cookies (including Meta Pixel and LinkedIn Insight Tag). These cookies do not fire until consent is given. You can manage your cookie preferences at any time using the "Cookie Preferences" link in the footer.

5.1. As a data subject, you have the following rights under the UK GDPR, which this Policy and Our use of personal data have been designed to uphold:

5.1.1. The right to be informed about Our collection and use of personal data;

5.1.2. The right of access to the personal data We hold about you (see section 13);

5.1.3. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 2.2);

5.1.4. The right to be forgotten - i.e. the right to ask Us to delete any personal data We hold about you. We only hold your personal data for as long as it is needed for the purposes set out in this policy, as explained in section 7, but if you would like Us to delete it sooner, please contact Us via the methods set out in section 2.2;

5.1.5. The right to restrict (i.e. prevent) the processing of your personal data;

5.1.6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

5.1.7. The right to object to Us using your personal data for particular purposes; and

5.1.8. Rights with respect to automated decision making and profiling.

5.2. If you have any cause for complaint about Our use of your personal data, please contact Us via the methods set out in section 2.2 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK's supervisory authority, the Information Commissioner's Office.

5.3. For further information about your rights, please contact the Information Commissioner's Office or your local Citizens Advice Bureau.

Depending upon your use of Our Platform, We may collect some or all of the following personal and non-personal data (please also see section 14 on Our use of Cookies and similar technologies):

• 6.1 Name
• 6.2 Organisation name and details
• 6.3 Email address
• 6.4 Country of residence
• 6.5 IP address
• 6.6 Web browser type and version
• 6.7 Operating system
• 6.8 Conversations and interactions with AI-powered simulation scenarios, including text inputs, voice recordings, responses, and transcripts
• 6.9 Performance data from simulation scenarios and assessments

7.1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 2018 and UK GDPR at all times. For more details on security see section 8, below.

7.2. Our use of your personal data will always have a lawful basis. The lawful bases we rely on are:

• Performance of a contract – for processing during AI simulation scenarios, providing access to your account, and storing transcripts for your later review.
• Legitimate interests – for long-term storage of transcripts for research, quality assurance, analytics, and product improvement. We have assessed that these interests do not override your rights.
• Consent – for sending marketing emails and setting non-essential cookies.

7.3. Specifically, We may use your data for the following purposes:

7.3.1. Providing and managing your Account;

7.3.2. Providing and managing your access to Our Platform;

7.3.3. Personalising and tailoring your experience on Our Platform;

7.3.4. Supplying Our products and/or services to you (please note that We require your personal data in order to enter into a contract with you);

7.3.5. Personalising and tailoring Our products and/or services for you;

7.3.6. Replying to emails from you;

7.3.7. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the bottom of our emails);

7.3.8. Market research

7.3.9. Educational research

7.4. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone or text message or by post with information, news and offers on Our products and/or our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 2018, UK GDPR, and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

7.5. Where we rely on consent, you have the right to withdraw that consent at any time. You can also request that we delete your personal data, subject to our obligations and lawful bases for processing as set out in this policy.

7.6. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

7.6.1. Data that could be used to personally identify you will be kept for as long as you have an active account registered with us to enable us to continue to provide you with our services.

7.6.2. We retain text transcripts of simulation conversations for as long as they are useful for our training, research, quality assurance, and product development purposes. These may be retained after account deletion. Anonymised transcripts may be kept permanently. You may request deletion of your identifiable transcripts at any time by contacting us at support@simchat.ai.

8.1. We only keep your personal data for as long as We need to in order to use it as described above in section 7, and/or for as long as We have your permission to keep it.

8.2. Some or all of your data may be stored outside of the European Economic Area ("the EEA") (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer data outside the UK or EEA, We rely on appropriate safeguards under UK GDPR, including UK adequacy regulations, the UK International Data Transfer Addendum (IDTA), or standard contractual clauses approved by the UK Information Commissioner's Office.

8.3. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Platform.

8.4. Steps We take to secure and protect your data include:

8.4.1. We store your data on a secure server managed by a GDPR compliant vendor.

8.4.2. Any data transferred to and from the server is encrypted during transfer.

8.4.3. Passwords are secured using the latest security algorithms and are not stored in plain text.

9.1. Geeky Medics Limited remains the Data Controller for all personal data processed through SimChat. All third-party service providers listed below act as Data Processors on Our behalf and process data only according to Our documented instructions.

9.2. We may share anonymised aggregated data sets with third parties for research and marketing purposes.

9.3. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

9.4. When using SimChat's AI-powered simulation scenarios, the content you type and audio you record may be processed by the following AI service providers:

• OpenAI – processes text and audio content to generate AI responses. This data is not used by OpenAI for any other purpose and is deleted from their servers according to OpenAI's published retention policy (typically within 30 days).
• Microsoft Azure OpenAI Service - available as an alternative to OpenAI on request. Azure OpenAI provides the same AI capabilities with data stored and processed within the EU, offering enhanced data residency for organisations with specific compliance requirements. Contact us at support@simchat.ai to discuss this option.
• Anam.ai – a UK-based company (company number 15214363) that provides AI-powered digital avatar technology for our video avatar features. Anam acts solely as a Data Processor on Our behalf and processes conversation data only according to Our instructions. Any data retention by Anam is under Our instruction and subject to Our data retention policies. Anam does not use conversation data for its own independent purposes or AI model training. For more information, see Anam.ai's Privacy Policy and Data Processing Addendum.

We store text transcripts of all simulation conversations on Our servers to enable users to review these transcripts at a later date, for performance assessment, and to facilitate our internal research and development.

9.5. We use DigitalOcean for hosting our platform, where we store user names, email addresses, organisation information, and passwords (encrypted using PBKDF2).

9.6. We use Brevo for sending marketing emails, but only to users who have explicitly consented to receive such communications at signup.

9.7. We use Crisp as our customer support platform, which stores user names, email addresses, and IP addresses to facilitate communication through our website's chat widget. Crisp cookies are classified as functionality cookies and require consent before being set.

9.8. For payment processing, we use:

• Stripe for UK-based online sales
• Paddle for international online sales

These payment processors store necessary user information including names, addresses, and payment details in accordance with their respective privacy policies.

9.9. We use Sentry for debugging and error tracking purposes, which may collect relevant user names, email addresses, and IP addresses when errors occur to help us improve our platform.

9.10. We work with analytics partners to measure the effectiveness of our marketing. These partners may collect data about your browsing behaviour and preferences:

• Meta Pixel is used for analytics and retargeting purposes
• LinkedIn Insight Tag is used for analytics and retargeting purposes

These services are managed via our cookie consent tool and do not fire until consent is given. You can update your preferences at any time using the "Cookie Preferences" link in the footer. No advertising cookies are used within the logged-in learning environment. Analytics and retargeting pixels (if consented) are only used on our marketing pages to understand and improve the performance of our campaigns.

These partners operate according to their own privacy policies and may use cookies and similar technologies to collect and process data. Analytics data is anonymised where possible.

9.11. Our processors may engage sub-processors to support the delivery of their services. Such sub-processors operate under data protection terms and appropriate safeguards. Details can be provided upon request.

10.1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

10.2. In the event that any of your data is to be transferred in such a manner, we will handle this in accordance with applicable data protection law and will inform you where we are required to do so.

11.1. In addition to your rights under the UK GDPR, set out in section 5, when you submit personal data via Our Platform, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).

11.2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service ("the TPS"), the Corporate Telephone Preference Service ("the CTPS"), and the Mailing Preference Service ("the MPS"). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12.1. To use SimChat, you will be required to create an account and provide certain personal data. SimChat is a platform designed for organisational use and requires authentication to access.

12.2. You may restrict Our use of Cookies. For more information, see section 14.

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Simulation transcripts form part of the personal data you may request access to. We will provide any and all information in response to your request free of charge. Please contact Us for more details at support@simchat.ai.

14.1. Our platform uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our platform and also allows us to improve it.

14.2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive.

14.3. Strictly necessary cookies are always set as they are required for the operation of our platform. They include, for example, cookies that enable you to log into secure areas of our platform.

14.4. Analytics and functionality cookies are only set once you consent via the cookie consent tool. These include:

• Analytics cookies (including Meta Pixel and LinkedIn Insight Tag). These allow us to recognise and count the number of visitors and to see how visitors move around our platform when they are using it. This helps us to improve the way our platform works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies (including Crisp live chat). These are used to recognise you when you return to our platform and enable features like live chat support. Crisp cookies are not set until you consent.

14.5. Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytics cookies.

14.6. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our platform.

14.7. Non-essential cookies typically expire within up to two years, though exact durations vary by provider.

14.8. You can change your cookie preferences at any time using the "Cookie Preferences" link in the footer.

SimChat is an AI-powered simulation platform that uses artificial intelligence technology to create realistic conversational scenarios for training and education purposes.

You may provide input to be processed by SimChat's AI ("Input"), and receive output generated and returned by the AI based on the Input ("Output"). Input and Output are your Content or Data, as applicable.

SimChat uses technology from the following AI providers, who act as Data Processors on Our behalf:

• OpenAI, LLC ("OpenAI") – provides the underlying language model for generating AI responses. When using SimChat's AI-powered simulation scenarios, the content you type and audio you record is uploaded to the servers of OpenAI to be analysed so that a relevant response can be generated. This data is deleted from their servers according to OpenAI's published retention policy (typically within 30 days).
• Microsoft Azure OpenAI Service - available as an alternative to OpenAI on request. Azure OpenAI provides the same AI capabilities with data stored and processed within the EU, offering enhanced data residency for organisations with specific compliance requirements. Contact us at support@simchat.ai to discuss this option.
• Anam.ai Ltd ("Anam") – a UK-based company that provides AI-powered digital avatar technology for our video avatar features. Anam acts solely as a Data Processor on Our behalf and processes conversation data only according to Our instructions. Anam does not store webcam or video input data from users, and does not use conversation data for AI model training.

SimChat does not store webcam or video input from users. We store text transcripts of all simulation conversations on Our servers to enable users to review these transcripts at a later date, for performance assessment, and to facilitate our internal research and development.

You acknowledge that due to the nature of machine learning and the technology powering SimChat, Output may not be unique and the platform may generate the same or similar output to other users.

Any changes we make to our privacy or cookies policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.