This Privacy Policy explains how Or8tor collects, uses, shares, and protects personal data when you use the Or8tor app, website, and related services (the Service).
1. Who We Are
1.1 The Service is operated by Projekt Rising Ltd (we, us, our).
1.2 If we appoint a Data Protection Officer, we will publish their contact details here.
2. What Or8tor Does
2.1 Or8tor helps you practise public speaking by analysing your recordings and providing feedback, scores, and progress insights.
2.2 Your practice content is private by default. You choose if, when, and how you share.
3. Privacy by Default and Anonymity
3.1 You can use a display name. You do not need to use your legal name.
3.2 Your recordings, transcripts, and practice materials are Private Content by default.
3.3 If you choose to share, publish, or post content, it becomes Shared Content and may be viewed, copied, saved, recorded, or reposted by others. We cannot control what others do with Shared Content.
3.4 Even if you use a display name, audio or video may still identify you.
4. The Information We Collect
We collect information in the following categories.
4.1 Information you provide
- Account details such as email address, sign in method, and subscription status
- Profile settings such as display name and preferences
- User content such as recordings, uploads, text inputs, templates, and comments
- Support communications when you contact us
4.2 Information we generate from your use of the Service
- Transcripts of recordings
- Coaching feedback and insights
- Scores, timestamps, and practice metrics
- Progress history and summaries
4.3 Information collected automatically
- Usage data such as feature usage, session activity, and interactions
- Device and app data such as device type, operating system, app version, language, and identifiers
- Log data such as IP address, event logs, and error reports
- Diagnostics such as crash reports and performance data
4.4 Payment data
If you purchase a subscription, payments are processed by our payment provider. We receive confirmation of payment and subscription status, but we do not receive full card details.
4.5 Information about other people
Do not upload or share content that includes other people unless you have their permission. If you do, you are responsible for making sure you have a lawful basis to do so.
5. How We Use Information
We use information for the purposes below.
5.1 To provide the Service
- Create and manage your account
- Store and display your content
- Analyse recordings, create transcripts, and generate coaching metrics
- Provide feedback, scoring, and progress tracking
- Deliver community features you choose to use
5.2 To keep the Service safe and reliable
- Prevent fraud, abuse, and unauthorised access
- Enforce our Terms and community rules
- Investigate misuse and security incidents
- Maintain, debug, and improve performance
5.3 To communicate with you
- Service messages about your account, billing, changes, and security
- Support responses and troubleshooting
- Optional product updates if you choose to receive them
5.4 To improve the Service
- Analytics and performance monitoring
- Testing and quality assurance
- Research and development of features
5.5 Optional uses of deidentified and aggregated data
If you choose to opt in using Optional Choices in the app settings, we may create and use Deidentified Data and Aggregated Data derived from your usage and content for:
- improving, training, and evaluating models and features
- creating and publishing aggregated benchmarks and statistics
- creating and licensing aggregated insights to third parties
These Optional Choices are separate from accepting the Terms, and they are off by default.
6. Our Legal Bases
This section applies where UK data protection law applies.
6.1 Contract
We process personal data when it is needed to provide the Service you request.
6.2 Legitimate interests
We process personal data where it is in our legitimate interests to run, secure, and improve the Service, and where those interests are not overridden by your rights. Examples include security monitoring, fraud prevention, and service analytics.
6.3 Consent
We rely on consent where you opt in to Optional Choices. You can withdraw consent at any time in settings.
6.4 Legal obligations
We may process personal data to comply with legal and regulatory obligations.
7. Optional Choices and Model Training Clarification
7.1 If you opt in to model training and evaluation, we may use Deidentified Data and Aggregated Data derived from your usage and content, such as transcripts and extracted coaching signals.
7.2 If you later withdraw this option, we will stop using new data for that purpose. Models already trained may continue to be used, because it may not be reasonably possible to remove the influence of one person's data from a trained model.
8. Deidentified and Aggregated Data Safeguards
8.1 Deidentified Data is data processed so it cannot reasonably be used to identify you, directly or indirectly, and we apply safeguards designed to reduce the risk of reidentification.
8.2 Aggregated Data is data combined across multiple users so it is not linked to a single person.
8.3 We do not attempt to reidentify Deidentified Data, except for limited testing to validate deidentification safeguards.
8.4 If we share or license Deidentified Data or Aggregated Data, we require recipients to agree not to attempt reidentification and to apply appropriate safeguards.
9. How We Share Information
9.1 Service providers
We share information with suppliers that help us operate the Service, such as cloud hosting, storage, analytics, customer support tools, payment processing, and AI processing. They are required to protect information and use it only on our instructions.
9.2 Legal and safety
We may disclose information if required by law, to respond to lawful requests, or to protect users, the public, and the Service.
9.3 Business changes
If we are involved in a merger, acquisition, reorganisation, or sale of assets, information may be transferred as part of that transaction, subject to appropriate protections.
9.4 No sale and no advertising sharing
We do not sell personal information.
We do not share personal information for cross context behavioural advertising.
10. International Transfers
10.1 Your information may be processed in countries outside the United Kingdom.
10.2 Where UK data protection law applies and we transfer personal data internationally, we use appropriate safeguards, which may include adequacy regulations where available, or contractual protections such as the UK International Data Transfer Agreement or the UK Addendum.
11. Data Retention
11.1 We keep personal data for as long as needed to provide the Service and for legitimate business purposes such as security, dispute resolution, and legal compliance.
11.2 You can delete content and close your account in settings. Some information may remain in backups for a limited period.
11.3 Deidentified Data and Aggregated Data may be kept for longer to support long term analysis, benchmarking, and model evaluation, subject to safeguards.
12. Security
12.1 We use reasonable technical and organisational measures designed to protect information, including access controls and encryption where appropriate.
12.2 No system is completely secure. You should protect your account and devices.
13. Cookies and Similar Technologies
13.1 Our websites may use cookies and similar technologies for sign in, security, preferences, and analytics.
13.2 Where required, we provide choices for non essential cookies.
13.3 Our apps may use similar technologies, such as software development kits, to provide features, security, and analytics.
14. Your Rights in the United Kingdom
If UK data protection law applies, you may have rights to:
- access your personal data
- correct inaccurate personal data
- delete personal data in certain circumstances
- restrict or object to processing in certain circumstances
- data portability in certain circumstances
- withdraw consent where processing is based on consent
You can make a request by contacting privacy@or8tor.com. You also have the right to complain to the Information Commissioner's Office.
15. California Residents
15.1 This section applies to California residents where the California Consumer Privacy Act applies to our processing.
15.2 You may have rights to request access to, correction of, and deletion of personal information, and to obtain information about our collection, use, and disclosure of personal information, subject to legal exceptions.
15.3 You can make a request by contacting privacy@or8tor.com. We will take reasonable steps to verify your request.
15.4 You may use an authorised agent where permitted, subject to verification.
15.5 We will not discriminate against you for exercising applicable rights.
15.6 We do not sell personal information. We do not share personal information for cross context behavioural advertising. If this changes, we will update this policy and provide any required choices.
16. Children
16.1 The Service is not designed for children under 13.
16.2 If you believe a child has provided personal data without appropriate consent, contact us and we will take appropriate steps.
17. Changes to This Policy
17.1 We may update this Privacy Policy. If changes are material, we will provide notice in the Service or by email.
17.2 The updated version will be effective from the date shown at the top.