Privacy Policy

Scope of This Policy

Mantra Systems, Inc. d/b/a Practis ("Practis," "we," "us," "our") respects your privacy and values your trust. The purpose of this Privacy Policy is to inform you of the treatment and handling of personal information that we may learn about you from using our website at gopractis.com (the "Site"), by use of our mobile application (the "App"), and/or by use of any of our products or services (collectively, with the Site and App, the "Service"). "You" or "your" or similar terms refer to you as a user of our Service. If you have any questions regarding this information or our privacy practices, please contact us via the methods set out in the How to Contact Us section at the end of this Privacy Policy.

Agreement to Terms

By using our Service, you consent to our Privacy Policy and our Terms of Use. If you do not agree with the terms of this Privacy Policy or our Terms of Use, then you should immediately discontinue use of the Service without providing any personal information to us.

Information We Collect

Practis collects the following categories of personal information (a) directly from you, such as through forms on our Site or App or when you engage with training content, (b) from third parties, such as your employer who may enroll you in the Service, (c) from the device and browser that you use to access our Site and/or App, and (d) cookies and similar technologies.

Identifiers

We may collect your name, email address, phone number, and username and password.

Professional Information

We may collect the name of your employer and your title and/or position.

Audio-Visual Information

We may collect video and audio recordings as part of our learning methodology. These recordings are accessible to you to help you for training purposes as well as to your employer. Practis also uses these recordings to enhance our learning methodology and improve our products and services. When audio or video recordings are used with AI-powered features, they may also be processed as described in the Artificial Intelligence (AI) Features and Third-Party AI Processing section below.

Artificial Intelligence (AI) Features and Third-Party AI Processing

Practis provides AI-powered features, including Scrimmage AI voice roleplay, scenario creation, feedback, scoring, and related analytics. When you choose to use these features, Practis may process personal information and content submitted through the Service, including voice audio, video, transcripts, prompts, training content, scenario content, usage information, and performance information, to deliver the AI-powered experience and improve the Service.

Practis uses third-party AI service providers to support these features, including Deepgram for speech-to-text and transcription, OpenAI for AI-generated responses, scenario creation, feedback, scoring, and related analysis, and ElevenLabs for text-to-speech and speech generation. We provide these providers with the information needed for them to process it on our behalf and support the Service. These providers are required to process this information only as needed to provide services to Practis, maintain privacy and security protections consistent with this Privacy Policy and our agreements with them, and not use the information to train their models except as permitted by Practis's agreements or instructions.

Where required, Practis presents an in-app notice or consent prompt before sending audio or related content to these third-party AI service providers. If you do not agree to the AI processing described in that prompt, you should not use the applicable AI-powered feature.

Training Information

We may collect information about trainings that you participate in through the Service, including whether or not the training is completed and your performance in the training. This information is also available to your employer.

Device Information

We collect device information when you visit the Site or use our App. This includes your computer or mobile device type, browser type, online and/or unique personal identifiers, IP address, and geolocation information.

Internet Activity

We may collect information concerning your interaction with the Site and App, including when you access the Site and/or App and your browsing activity on the Site and/or App (such as which pages you visited, in what order, and for how long). This may include "traffic" data or tracking information provided by the Site's host or similar providers (e.g., Google Analytics) and may be helpful for marketing purposes or for improving the Service.

Inferences

We may also draw inferences from the information described above. Such inferences may reflect your characteristics, behavior, and abilities. You are not required to provide all personal information identified in this Privacy Policy to use our Service or to interact with us, but certain functionality will not be available if you do not provide certain personal information. For example, if you do not provide certain personal information, we may not be able to respond to your requests or allow you to register an account.

Cookies

We store certain information that gets collected automatically at our end through cookies and other similar technologies on our Site. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for marketing purposes, including targeted advertising (as discussed in more detail below). The cookies and similar technologies that we use are generally divided into the following categories:

• Strictly Necessary Cookies: These are required for the operation of the Site. They include, for example, cookies that enable you to log into password-protected portions of the Site.
• Analytical/Performance Cookies: These allow us to recognize and count the number of users on our Site and understand how such users navigate through the Site (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located). This helps improve how our Site works, for example, by ensuring that users can find what they are looking for easily. We use Hubspot and Google Analytics for part of this process.
• Functional Cookies: These improve the functional performance of the Site and make it easier for you to use. For example, cookies are used to remember that you previously visited the Site and asked to remain logged into it. We also embed certain videos that are hosted on Google's YouTube website. Google sets certain functional cookies to remember your preferences (e.g., your preferred language), to remember user input, and to detect and resolve problems with Google's services. These cookies may qualify as persistent cookies because they remain on your device for us to use during your next visit to the Site.

You can prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections "Help," "Internet Options," or "Settings." If you disable or delete certain cookies in your Internet browser settings, you may still access our Site, however, you might not be able to access or use important functions or features of the Sites, and you may, for example, be required to re-enter your log-in details.

Do-Not-Track Signals

At this time, Practis does not recognize automated browser signals regarding tracking mechanisms, which may include "do-not-track" instructions.

Children's Privacy

The Service is not intended for users under the age of 13 and Practis does not knowingly collect personal information from individuals under the age of 13. If you are aware of, or suspect that, someone under the age of 13 is using the Service without permission, please notify us immediately by contacting us as detailed below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child's privacy online.

Our Use of Personal Information

We collect and use personal information for the following purposes:

• Providing the Service to you and providing services requested by, or reasonably anticipated within the context of our relationship with, you;
• Managing our relationship with you;
• Responding to your inquiries or requests and requesting feedback;
• Tracking use of your username and password to access our Site and App;
• Personalizing the Site and App (e.g., displaying your name when you log in);
• Administering promotions, events, and surveys;
• Analyzing use of our Site and App;
• Providing promotional material or other marketing that we believe will be relevant to you;
• Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible;
• Complying with legal and regulatory obligations.

Our Disclosure of Personal Information

Practis may share personal information with the following third parties:

• Service providers, who help us provide, maintain, and improve the Service, including IT service and hosting providers, web analytics providers, and customer relationship management software providers. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
• Third-party AI service providers, including OpenAI, ElevenLabs, and Deepgram, who help us provide, maintain, and improve AI-powered features such as roleplay, voice interactions, speech generation, transcription, scenario creation, feedback, scoring, and related analytics.
• Business partners, such as when we work with other businesses to offer products or services to you.
• Your employer and colleagues, for example, information pertaining to your participation in trainings and audio-video recordings can be accessed and reviewed by your employer. Your employer may also choose to share audio-video recordings with your colleagues.
• Advisers and financial institutions, including auditors, notaries, business continuity support services providers, and legal, tax, and risk and compliance advisors.
• Third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
• Government bodies, dispute resolution organizations, law enforcement agencies or third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for information we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.

Your Privacy Choices

If you no longer want to receive our newsletter or other marketing communications, you may unsubscribe at any time by following the unsubscribe link in the communication itself. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account. If you wish to update information associated with your account or cancel your account, please contact the administrator for your organization.

Security

We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect both the personal information and the general information that we receive from you through the Service. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.

You play an important role in keeping your information secure. You should not share your username or password with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately at the contact information in the How to Contact Us section below.

Additional Disclosures for Residents of the European Union (EU) and United Kingdom (UK)

Data Transfers

As a US company, most of our operations are conducted in the United States and in order to provide the Service, personal information will be processed in the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. With respect to transfers originating from the European Economic Area, we implement the standard contractual clauses approved by the European Commission. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

Retention of Your Personal Information

We typically retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as otherwise needed to address tax, corporate, compliance, employment, litigation, and other legal rights and obligations; and as otherwise permitted by law.

Legal Basis for Processing Your Personal Information

Where required, we have several different legal grounds on which we collect and process your personal information for the purposes set out in the Our Use of Personal Information section above, including: (i) as may be necessary to perform a contract with you; (ii) as necessary to comply with a legal obligation; (iii) consent (where consent has been provided as appropriate under applicable law); and (iv) as necessary for our legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Service).

Automated Decision-Making

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.

Your Rights

As available and except as limited under applicable law, individuals in the EU and UK have the rights described below:

• Access. You have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
• Rectification. You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
• Deletion. You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend a legal claim.
• Restriction. You have the right to request that we restrict our processing of your personal information where: (i) you believe such data to be inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
• Portability. You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
• Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation (e.g., direct marketing). We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise or defend a legal claim.
• Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us at support@gopractis.com with the subject line "EU Privacy" so that we can get your email to the right team, or log-in to your account. We will respond to your request consistent with applicable law. If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.

Additional Disclosures for Residents of Canada

This section contains additional disclosures for residents of Canada. If you wish to request access to or correction of your personal information, or to opt-out of the processing of your personal information or request that we delete your personal information, you may contact us at support@gopractis.com with the subject line "Canada Privacy" so that we can get your email to the right team. You may also contact us for information about how foreign-based service providers process your personal information or if you have any questions or complaints about the manner in which we treat your personal information. We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise permitted by law.

Effective Date and Changes to This Privacy Policy

This Privacy Policy is effective as of the date at the top of this policy. Practis has the discretion to update this Privacy Policy at any time. When we do, we will revise the effective date at the top of this page. We encourage users to frequently check this page for any changes and to stay informed about how we are helping to protect the personal information we collect, especially before you provide information, and particularly personal information, directly to us through the Service. In the event of a material change to this Privacy Policy, we will provide a message through our website or via email informing you of the change.

How to Contact Us

If you have any questions or comments, please contact us at support@gopractis.com.