Privacy and Data Residency Policy

Last Updated: October 1, 2026

1. Privacy at a Glance

We believe that training tools should be safe, transparent, and private by default. Our platform is used by healthcare professionals, educators and their learners, so we hold ourselves to a high standard of data protection.

2. Introduction

This Privacy Policy explains how Zenobits Ltd (“we”, “us”, “our”) collects, uses, and protects personal data when you use our roleplay training platform, including the MI Practice Lab and the roleplay authoring platform (together, the “Service”), and our website at zenobits.co.uk.

We are a company incorporated in the United Kingdom.

This policy adheres to the UK General Data Protection Regulation (UK GDPR), the Data (Use and Access) Act 2025, and the EU GDPR.

3. Data We Collect

We collect and process the following categories of personal data:

A. Account Data (Learners, Trainers, Authors and Administrators)

B. Data Generated During Roleplays (Learners and End Users)

C. Technical Data

D. Website Data (zenobits.co.uk)

E. Uploaded Recordings (“Analyse a recording”, MI Practice Lab)

Where your organisation has the feature enabled, a learner or trainer can upload a recording of a real conversation (for example a supervised session with a client) to have the practitioner’s skills scored by our feedback models.

How it is processed:

  1. The file is uploaded to private storage in Sweden. The audio track is extracted on our own servers, and the original file (including any video, and so any faces) is deleted as soon as the audio has been extracted.
  2. The audio is transcribed by Microsoft Azure AI Speech in Sweden. Microsoft does not store the audio or the transcript once the request completes, and no voice profile is created.
  3. The text of the scored part of the transcript (never the audio) is analysed by Anthropic’s Claude models, provided through Microsoft Azure AI Foundry (Section 5).
  4. Speech from anyone you exclude is transcribed with the rest of the recording but never analysed. It is deleted once the analysis is complete, and if you exclude anyone, no audio is kept with the report at all.

Uploaded recordings are treated as real-client work, not practice: they are not counted towards practice time or CPD records, are not included in any trainer practice statistics or survey, cannot be shared by link, and are not used for our internal quality dashboards.

4. How We Use Your Data & Lawful Basis

We only process your personal data when we have a legal basis to do so.

PurposeLawful Basis (UK GDPR)
To provide the Service (hosting roleplays, streaming your voice to the AI character, generating AI responses, storing transcripts and recordings, generating feedback)Performance of Contract
To manage your account (login, email verification, password resets, cohort enrolment, practice-minute balances)Performance of Contract
To take payment and issue invoices, quotes and CPD recordsPerformance of Contract; Legal Obligation (financial records)
To send service emails (welcome, verification, feedback-ready links, low-balance notices, survey invitations for a programme you joined)Performance of Contract; Legitimate Interests
To ensure security (fraud prevention, bot protection, abuse monitoring, safeguarding)Legitimate Interests (and “Recognised Legitimate Interests” for safeguarding under DUAA 2025)
To improve our Service (quality scoring, debugging technical issues, aggregate analytics)Legitimate Interests
Masked session replay and website analytics cookiesConsent
To analyse an uploaded recording (storing, transcribing and scoring it, and showing you the report)For your own data, Performance of Contract. For the people heard in the recording, we act on your instructions as your Data Processor (see below)
To keep the consent confirmation for each uploadLegitimate Interests (being able to show that consent was confirmed for every recording we processed)

Special category data in uploaded recordings: as the Data Controller for the people heard in a recording, you are responsible for having a lawful basis to share it with us and, for health or other special category data, a condition under Article 9 UK GDPR. The Service requires that condition to be the explicit consent of everyone who can be heard, which you confirm on every upload. We process that data only to provide the analysis you asked for.

5. Artificial Intelligence and Automated Processing

Transparency regarding AI is a core part of our commitment to you. The Service uses the following AI systems:

No Model Training

Microsoft does not use your prompts, completions, transcripts or audio to train its foundation models. Anthropic does not use the data sent to Claude models through Azure AI Foundry to train its models under its commercial terms. Zenobits itself never uses your data, including uploaded recordings, to train any model.

Abuse Monitoring & Retention

To prevent the generation of harmful content (e.g., hate speech, violence), Azure OpenAI may retain prompts and completions for up to 30 days in a secure environment.

Anthropic’s automated safety systems may flag content sent to Claude models for review, and Anthropic may retain prompts and outputs for a limited period for trust and safety purposes under its terms. Anthropic staff review content only on an exceptions basis, to investigate a potential safety violation.

Automated Decision Making

The AI provides feedback and scoring on a roleplay. These scores are generated to support your learning and reflection; they are not used by Zenobits to make decisions with legal or similarly significant effects on you. Users have the right to request a human review if they believe an AI-generated evaluation significantly impacts their educational or professional progress.

6. Data Residency and International Transfers

We have architected our system so that stored data remains within the European Economic Area (EEA). AI processing is a different matter and we want to be precise about it: our Azure AI deployments are Microsoft “Global Standard” deployments. Under that deployment type, data at rest (including the abuse-monitoring store described in Section 5) stays in the geography of our Azure resource, but Microsoft may route the live inference request itself to Azure data centres anywhere in the world to balance capacity.

Location of Data

ComponentProviderRegionStatus
Primary Database (accounts, transcripts, feedback, CPD records)Microsoft AzureSweden CentralData At Rest (Storage)
Audio RecordingsMicrosoft Azure Blob StorageSweden CentralData At Rest (Storage), deleted after 90 days
Live Voice AI Processing (Realtime API)Microsoft AzureGlobal Standard deployments on our Sweden Central resource, with an overflow resource in France Central (EU) used only when Swedish capacity is full. Inference may be processed in any Microsoft regionProcessing
Coaching and Evaluation AI (Claude on Azure AI Foundry)Anthropic, through Microsoft AzureAccessed through our Sweden Central resource. Processing may take place outside the EU and UK, including in the United StatesProcessing
Uploaded Recordings (original file and extracted audio, before analysis)Microsoft Azure Blob StorageSweden CentralData At Rest (Storage), short-lived (Section 9)
Transcription of Uploaded RecordingsMicrosoft Azure AI SpeechSweden CentralProcessing, nothing retained by Microsoft
Application HostingRenderFrankfurt, GermanyProcessing (Compute)
Voice Relay (TURN)CloudflareGlobal edge network, nearest location to youEncrypted media relay, only when your network blocks a direct connection
Transactional EmailResendUnited StatesEmail delivery
PaymentsStripeEU / United StatesPayment processing
Product AnalyticsPostHogEU (Frankfurt)Analytics (consent-based)
Email & SupportGoogle WorkspaceGlobalCommunication

International Transfers

While our primary infrastructure is in the EU/EEA, some subprocessors are US-headquartered, and Microsoft’s Global Standard AI deployments may process a request outside the EEA and UK. We ensure these transfers are legal under UK and EU law:

7. Who Can See Your Session Data

If we email you a link to your own feedback (for example because you closed the browser before your report was generated), that link is a private, time-limited magic link to your own session. Keep it private.

8. Children’s Privacy (Age Appropriate Design)

Where the Service is used with children, we comply with the UK Age Appropriate Design Code (AADC).

9. Data Retention

10. Your Rights

Under the UK GDPR and EU GDPR, you have the following rights:

If you were heard in an uploaded recording: the person who uploaded it (or their organisation) is the Data Controller for your data, so please contact them first to exercise your rights. If you contact us, we will pass your request to them and help them respond.

For International Users:

11. Security

We use industry-standard security measures:

12. Subprocessors

We use the following third-party service providers to help us provide the Service:

SubprocessorRoleLocation
Microsoft Corporation (Azure)Database, audio and uploaded-recording storage, AI inference (Azure OpenAI Realtime), transcription of uploaded recordings (Azure AI Speech), and access to Anthropic Claude models on Azure AI FoundryStorage and transcription in Sweden (EU), with a voice-AI overflow resource in France (EU); AI inference on Global Standard deployments may run in any Microsoft region
Anthropic, PBCClaude models used for coaching, evaluation and the analysis of uploaded recordings (receives transcript text, never audio), provided through Microsoft Azure AI FoundryUnited States / may process outside the EU and UK
ElevenLabs, Inc.Optional synthesised character voices, only on scenarios where the author has chosen one (receives AI reply text only; standard terms, see Section 5)United States
Render Services, Inc.Application HostingGermany (EU)
Cloudflare, Inc.Encrypted voice relay (TURN) for restricted networksGlobal (US HQ)
Resend, Inc.Transactional email delivery (verification, password reset, feedback links, notices)United States
Stripe, Inc. / Stripe Payments Europe LtdPayments, invoices and subscription managementIreland / United States
PostHog, Inc.Product analytics and masked session replay (consent-based)EU Cloud (Germany)
SurveyMonkey (Momentive)Post-session evaluation surveys for partner training programmes you have joined. The survey link carries a pseudonymous participant code, not your emailUnited States
Google LLCGoogle Workspace (email and customer support), Google Analytics on our website (consent-based), reCAPTCHA (bot protection), Google Fonts and enquiry-form deliveryGlobal (US HQ)

We will update this list when we add or replace a subprocessor.

13. Contact Us

If you have any questions about this policy, or if you wish to exercise your rights, please contact our Privacy Lead:

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) in the UK (www.ico.org.uk).