1. Who we are and what this policy covers

This Privacy Policy explains how S2C Virtual Reality Ltd ("HumanVantage", "we", "us", "our") collects, uses, shares, and protects personal data when you use our website at humanvantageai.com, our AI role-play and behavioural coaching platform, and any related services (together, the "Services").

S2C Virtual Reality Ltd is a company registered in England and Wales, registered address 20-22 Wenlock Road, London, N1 7GU, company number 14410433. We are the data controller for the personal data described in this policy, except where noted below.

Two roles, two relationships. HumanVantage's Services are typically accessed in one of two ways, and our role under data protection law differs accordingly:

  • As a controller — for data we collect directly through our website, marketing, sales conversations, and account administration (for example, your name and email when you request a demo).

  • As a processor — where an organisation (your employer, or another institution) has a contract with HumanVantage and gives its people access to the platform, we process the personal data generated through your use of the Services (practice session recordings, transcripts, scores) on that organisation's instructions. That processing is governed primarily by our Data Processing Agreement with the organisation; this policy describes our practices for context, but the organisation's own privacy notice to you may also apply and, where the two conflict on matters within the organisation's control, the organisation's instructions govern.

If you are using HumanVantage as an individual, outside of any organisation's account, we act as controller for all of your data.

2. Information we collect

Information you give us directly:

  • Account and registration information — name, work email, job title, organisation name, and password (or SSO identifier).

  • Information you provide in support requests, feedback, surveys, or when you register for a demo, webinar, or event.

  • Payment and billing details, where applicable (processed by our third-party payment provider — we do not store full card details ourselves).

Practice session content — the core of what we handle. When you take part in an AI role-play scenario, we collect the content of that session: your spoken responses, and the feedback. This is sensitive by nature — it's you rehearsing a difficult conversation — and we treat it accordingly (see Section 4 and Section 6).

Information we collect automatically:

  • Usage data — log-in times, features used, scenarios completed, session duration, and navigation within the platform.

  • Device and technical data — IP address, browser type, device type, operating system, and approximate location inferred from IP address.

  • Cookies and similar technologies — used for authentication, remembering preferences, and (where you consent) analytics.

Information we receive from your organisation or third parties:

  • If your organisation provisions your account, they may give us your name, work email, department, and role.

  • If you sign in via single sign-on or your organisation integrates HumanVantage with an LMS or HR system, we receive the identity and profile information that integration is configured to share.

  • We do not buy or use third-party lead-generation or contact-enrichment databases populated with stale or purchased data to build outbound contact lists

3. How we use your information

We use personal data to:

  • Create and administer your account and deliver the Services, including running your practice sessions and generating feedback.

  • Personalise your experience — for example, surfacing scenarios relevant to your role or past practice history.

  • Provide reporting to the organisation that has contracted for the Services, consistent with Section 5 below.

  • Improve the platform — analysing (in aggregate and, wherever possible, de-identified form) how scenarios perform, where users struggle, and how our scoring model can be made fairer and more consistent.

  • Communicate with you — service messages, security alerts, and, where you've opted in, product updates and marketing.

  • Maintain security, prevent abuse, and meet our legal obligations.

We do not use your practice session content to make automated decisions about your employment (for example, promotion, discipline, or termination) without meaningful human involvement, and the Services are not a promotion-screening or hiring tool — they are designed to help existing managers practise and improve.

4. AI processing — how the role-play and scoring work

HumanVantage's Services use third-party AI model providers and speech/avatar technology providers to power conversational role-play and to help generate feedback. We choose providers on the basis of security and data-handling commitments, and we do not name individual sub-processors in this public policy; a full sub-processor list is available on request.

  • Your content is not used to train third-party foundation models. Where our AI providers offer a no-training / no-retention commitment for API traffic, we rely on it; session content is sent to these providers only to generate the response or feedback for your session, not to improve their general-purpose models.

  • Human oversight. Scores and feedback from our conversational judgment model are intended to support your development, not to stand alone as a verdict — treat AI-generated feedback as a starting point for reflection or a coaching conversation, not an infallible assessment.

  • Aggregate-first reporting. Where HumanVantage provides analytics to an organisation, our default is to report at an aggregate, team, or cohort level rather than surfacing individual identifiable scores to administrators, unless the organisation's plan and your consent (or your organisation's contractual arrangement with its own people) specifically provides for individual-level reporting.

5. How we share your information

We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.

We share personal data with:

  • Service providers (processors) who host our infrastructure, provide our AI model and avatar/speech technology, process payments, or provide customer support tooling — bound by contract to use data only to provide their service to us and to protect it appropriately.

  • Your organisation, where you access the Services through an employer or institutional account — subject to the aggregate-first approach described in Section 4, and to whatever reporting arrangement your organisation has contracted for.

  • Professional advisers such as our lawyers, accountants, and auditors, where necessary.

  • Regulators, courts, or law enforcement, where required by law or necessary to protect the rights, safety, or property of HumanVantage, our users, or others.

  • A buyer or successor, in the event of a merger, acquisition, financing, or sale of some or all of our business — you would be notified of any resulting change in how your data is controlled.

  • Aggregated or de-identified data that cannot reasonably be used to identify you, which we may share more freely — for example, in research, benchmarking, or marketing statistics about typical improvement patterns.

6. Special category and sensitive-by-context data

We do not ask you to submit special category data (health information, information about race, religion, sexual orientation, trade union membership, and similar) as part of a scenario, and we ask that you avoid volunteering it in free-text or spoken responses during a session. Practice conversations may nonetheless touch on sensitive workplace topics (for example, a simulated conversation about a team member's wellbeing or a disciplinary matter) — the content of the simulation is fictional and generated for training purposes, but we treat session recordings and transcripts with the same security controls as if they contained sensitive data, given the realistic and personal nature of the coaching context.

7. International data transfers

HumanVantage is based in the UK. Our service providers may process data outside the UK and European Economic Area, including in the United States. Where we transfer personal data outside the UK/EEA, we rely on recognised safeguards — UK International Data Transfer Agreements or Addenda, the European Commission's Standard Contractual Clauses (as extended for UK use), or transfers to jurisdictions covered by an adequacy decision. Details of the specific safeguard used for a given transfer are available on request.

8. Data retention

We retain personal data only as long as necessary for the purposes it was collected for:

  • Account data is retained while your account is active and for a limited period afterwards in case of reactivation or as required for legal/accounting purposes.

  • Practice session recordings, transcripts, and scores are retained for as long as necessary, after which they are deleted or anonymised.

  • We may retain de-identified or aggregated data indefinitely for research and product improvement, since it can no longer identify you.

  • On termination of an organisation's contract, we will make data available for export for a defined period 90 days before deletion, except where we're required to retain it for legal reasons.

9. Security

We use technical and organisational measures appropriate to the sensitivity of practice session content, including encryption in transit, access controls limiting data to staff and contractors who need it, and regular review of our security practices. No method of transmission or storage is completely secure, and we encourage you to use a strong, unique password and to report any suspected unauthorised access immediately.

10. Your rights

Under UK GDPR, you have the right to:

  • Access the personal data we hold about you.

  • Correct inaccurate or incomplete data.

  • Request erasure, subject to legal and contractual retention requirements.

  • Restrict or object to certain processing, particularly processing based on legitimate interests or for direct marketing.

  • Receive your data in a portable format, where processing is based on consent or contract and carried out by automated means.

  • Withdraw consent at any time, where processing relies on consent, without affecting the lawfulness of processing before withdrawal.

Where you access the Services through an organisation, some rights (particularly erasure and correction of practice session data) may need to be exercised through that organisation as the party best placed to instruct us, since we act as their processor for that data — we'll direct you accordingly and assist the organisation in responding.

To exercise your rights, contact us at . We may need to verify your identity first. You also have the right to complain to the Information Commissioner's Office (ico.org.uk) if you believe we have not handled your data properly — we'd appreciate the chance to address your concerns directly first.

11. Children

The Services are designed for working professionals and are not directed at, or intended for use by, anyone under 18. We do not knowingly collect personal data from children.

12. Cookies

We use cookies and similar technologies for authentication, remembering your preferences, and — where you consent — analytics. You can control cookies through your browser settings; disabling them may affect parts of the Services.

13. Changes to this policy

We may update this Privacy Policy from time to time. We'll post the updated version on our website with a revised "Last Updated" date, and where changes are material, we'll take reasonable steps to notify you directly.

14. Contact us

Email:

Last Updated: 12 July 2026