ArisTurtle Privacy Policy

1. Scope and U.S.-only use

This Privacy Policy applies to the ArisTurtle website, application, related account services, and communications from SmartTurtle. ArisTurtle is intended for users located in the United States only and is not offered for use outside the United States at this time.

2. Information we collect

Account and profile information

When you create or use an ArisTurtle account, we collect information needed to identify you, manage your account, and personalize the experience. This may include:

• first and last name;
• email address and login credentials;
• company or employer name;
• job title;
• management profile information, such as management type and number-of-direct-reports range;
• account role, subscription or seat information, and account status; and
• other information you choose to provide through your account or when contacting us.

Login credentials are handled in the ArisTurtle backend rather than stored in the browser. We use reasonable safeguards appropriate to the information we maintain.

Practice-session information

During an ArisTurtle practice session, the service may process your voice, a speech-to-text transcription, information you provide about the practice scenario, AI character responses, scoring information, and coaching feedback. We use this information to conduct the practice interaction and provide feedback to you.

ArisTurtle is intended to be a safe and personal learning environment, therefore we do not retain the following practice-session content after the session ends:

• audio recordings of your practice conversation;
• the full speech-to-text transcript;
• specific scenario details you enter or say during the conversation;
• the AI character's conversation responses;
• detailed per-session coaching feedback and session summaries; and
• historical per-attempt scores.

ArisTurtle may retain the best score you have achieved for each practice scenario so that the application can show your progress. We do not retain the complete history of your practice attempts.

Even though we have built ArisTurtle to not retain your conversational data, it is also your responsibility to not share certain data with us when using the software.

Please use fictional names and avoid entering unnecessary confidential, sensitive, medical, financial, or other personally identifiable information about employees, customers, prospects, or other third parties during practice sessions.

Payment information

If you purchase ArisTurtle directly, payments are handled by a third-party payment processor. SmartTurtle does not store your full payment-card details. We may receive and retain transaction-related information such as subscription status, payment status, billing dates, and transaction identifiers needed to administer your account and maintain business records.

Usage, device, and website information

When you use the ArisTurtle website or application, we may collect technical and usage information needed to operate, secure, understand, and improve the service. Depending on how our systems are configured, this may include browser or device information, log information, security events, feature or scenario usage, account activity, and similar operational information.

We may also use cookies and similar technologies for authentication, security, preferences, performance, analytics, marketing attribution, and related purposes. Where applicable law requires a choice or consent, we will provide the appropriate controls.

Surveys and product feedback

We may invite users to provide optional survey responses, suggestions, ideas, bug reports, enhancement requests, or other feedback. We may use this information to evaluate and improve ArisTurtle. Any use of this information is subject to this Privacy Policy and applicable confidentiality obligations.

Individual survey responses are not provided to an employer or organization administrator. If we provide an organization with aggregate survey or outcome reporting, we will use a minimum group size of five respondents to reduce the risk that an individual response can be identified.

3. How we use information

We use personal information and other information we collect to:

• create, authenticate, and administer accounts;
• provide practice sessions, scoring, coaching, and other ArisTurtle features;
• manage subscriptions, seats, billing status, and customer support;
• maintain the reliability, security, and performance of the service;
• understand product adoption and how features and scenarios are used;
• improve existing features and develop new features, scenarios, training content, and services;
• communicate with users about their account, service updates, support matters, and, where permitted, relevant product or marketing information;
• detect, investigate, and prevent fraud, abuse, security incidents, and violations of our terms; and
• comply with legal obligations and protect the rights, safety, and property of SmartTurtle, our users, and others.

When we use usage information for long-term product analytics, our goal is to use aggregated or de-identified information that does not identify an individual user or customer.

4. What your employer or organization can see

If your ArisTurtle access is provided through an employer or other organization, an authorized organization administrator may see information needed to manage the organization's subscription, such as seat assignment, account activation or status, and high-level adoption or usage information.

Organization administrators are not given access to the substance of your private practice sessions. They do not receive your practice-session audio, full transcripts, specific scenario details, AI conversation responses, detailed coaching feedback, session summaries, or individual practice scores.

ArisTurtle is designed as a practice environment to help managers learn and practice. It is not designed or intended to be used a performance evaluation system, human resource system, or for any employee-surveillance purposes.

5. How we share information

We do not currently sell personal information or share personal information for marketing or advertising. We may disclose information in the following limited circumstances:

• Service providers and subprocessors. We may use third-party providers to host, operate, secure, support, analyze, process payments for, or otherwise provide parts of the service, including technologies needed for AI and voice features. These providers receive information only as reasonably necessary to perform services for us and are subject to appropriate contractual, privacy, confidentiality, or security obligations as applicable.
• Organization customers. We may provide the limited account, seat, and high-level adoption information described above to an organization that sponsors your account.
• Legal and safety reasons. We may disclose information if required by law, legal process, or a valid governmental request, or when reasonably necessary to protect rights, prevent fraud or abuse, investigate security issues, or protect users or others.
• Business transactions. If SmartTurtle is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, information may be disclosed as part of that transaction subject to appropriate protections.
• With your direction or consent. We may disclose information when you ask us to or otherwise authorize the disclosure.

If our practices regarding the sale or sharing of personal information change in the future, we will update this Privacy Policy and provide any notice, consent, or choice required by applicable law.

6. Data retention and deletion

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, to provide the service, or to meet legitimate legal, security, accounting, backup, dispute-resolution, or compliance needs.

Our current product design includes the following retention practices:

• Practice-session audio, full transcripts, specific scenario details, AI conversation responses, detailed coaching feedback, session summaries, and historical per-attempt scores are not retained after the practice session.
• The best score achieved by a user for each scenario may be retained while the account remains eligible for retention.
• Identifiable learner and practice data is scheduled for deletion or de-identification within 30 days after an eligible B2C subscription cancellation, B2B seat deactivation, B2B organization termination, or eligible full-account deletion request, subject to legitimate legal, security, accounting, backup, or compliance requirements.
• Previously created aggregated or de-identified analytics may be retained for longer periods because they no longer identify an individual user.

If an organization or user requests an export of information, any export can include only information that SmartTurtle actually retains in the ordinary operation of the service. Information that is processed transiently and not retained cannot be exported later.

7. De-identified and aggregated information

We may create and use aggregated or de-identified information to understand product usage, evaluate outcomes, measure costs and performance, improve ArisTurtle, plan new features, and conduct business analysis. We do not intend to use de-identified information to identify an individual user.

8. Security

We use administrative, technical, and organizational safeguards designed to protect the information we maintain. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

If we confirm a security incident affecting personal information, we will take appropriate steps to investigate, contain, and address the incident and will provide notice as required by applicable law.

9. Your privacy choices and rights

Depending on where you live and the circumstances, you may have rights regarding your personal information, such as asking to access, correct, or delete information we maintain about you, or to receive information about how it is used or disclosed.

To make a privacy request, use the Contact Us form on our website. We may need to verify your identity before completing certain requests. Some information may be retained when required or permitted by law or when reasonably necessary for security, fraud prevention, accounting, dispute resolution, or other legitimate purposes.

You may also manage certain account, communication, cookie, or browser preferences through the applicable settings or controls made available to you.

10. Children's privacy

ArisTurtle is designed for working professionals and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 in a manner not permitted by law, we will take appropriate steps to delete it.

11. Third-party websites and services

ArisTurtle may link to or interact with third-party websites, services, or technologies. Their privacy practices are governed by their own policies. This Privacy Policy applies to SmartTurtle's handling of information and does not control the independent practices of third parties.

12. Changes to this Privacy Policy

We may update this Privacy Policy as ArisTurtle evolves, our business practices change, or legal requirements change. When we make material changes, we will update the effective date and provide additional notice when required by law or when we believe the change is significant to users.

13. Contact us

If you have questions about this Privacy Policy or want to make a privacy request, contact:

SmartTurtle Solutions LLC
9 Cornerstone Square, B400-264
Westford, MA 01886

Email us using the Contact form on our website.