1. Data Controller

Jamdd LTD (trading as "Project Robin") is the data controller responsible for your personal data. We are a company registered in England and Wales. For data protection enquiries, contact us at privacy@projectrobin.org.

2. Information We Collect

We collect and process the following categories of personal data:

Identity Data: Name, job title, organisation
Contact Data: Email address, telephone number
Account Data: Username, password, account preferences
Usage Data: Information about how you use our Service, including practice session metadata
Voice Data: Audio recordings from practice sessions (processed by AI systems, not reviewed by humans)
Technical Data: IP address, browser type, device information, cookies

3. Legal Basis for Processing

Under UK GDPR, we process your personal data on the following legal bases:

Contract: Processing necessary for the performance of our contract with you or your organisation
Legitimate Interests: Processing necessary for our legitimate interests (improving our Service, analytics) where not overridden by your rights
Consent: Where you have given specific consent (e.g., marketing communications)
Legal Obligation: Processing necessary to comply with our legal obligations

4. AI Processing

Project Robin is a software-only service. All practice sessions and feedback are generated by artificial intelligence. Your voice recordings and usage data are processed by automated AI systems—not reviewed by human staff. We use third-party AI providers to power our Service; your data may be processed by these providers in accordance with our data processing agreements.

5. How We Use Your Data

We use your personal data to:

Provide and maintain the Service
Process and complete transactions
Generate AI-powered feedback on practice sessions
Send service-related communications
Improve and develop our Service
Ensure security and prevent fraud
Comply with legal obligations

6. Data Sharing

We may share your personal data with:

Service Providers: Third parties who provide services on our behalf (hosting, analytics, AI processing)
Your Organisation: Administrators within your organisation (for organisational accounts)
Legal Authorities: When required by law or to protect our rights
Business Transfers: In connection with any merger, acquisition, or sale of assets

We do not sell your personal data to third parties.

7. International Transfers

Your data may be transferred to, and processed in, countries outside the UK. Where we transfer data outside the UK, we ensure appropriate safeguards are in place, including UK GDPR-approved Standard Contractual Clauses or transfers to countries with an adequacy decision.

8. Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this policy. Specifically:

Account data: Retained while your account is active, plus 2 years after closure
Voice recordings: Retained for 90 days unless you request earlier deletion
Usage analytics: Retained in anonymised form indefinitely

9. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

Right of Access: Request a copy of your personal data
Right to Rectification: Request correction of inaccurate data
Right to Erasure: Request deletion of your data ("right to be forgotten")
Right to Restrict Processing: Request limitation of processing
Right to Data Portability: Receive your data in a structured, machine-readable format
Right to Object: Object to processing based on legitimate interests
Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact us at privacy@projectrobin.org. We will respond within one month.

10. Cookies

We use the following types of cookies:

Essential Cookies: Required for the Service to function properly
Analytics Cookies: Help us understand how the Service is used (with your consent)

You can manage cookie preferences through your browser settings.

11. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including encryption, access controls, and regular security assessments. However, no method of transmission over the Internet is 100% secure.

12. Complaints

If you have concerns about our data practices, please contact us first. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection: ico.org.uk/make-a-complaint

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through the Service. The "Last updated" date at the top indicates when the policy was last revised.

14. Contact

For questions about this Privacy Policy or to exercise your data rights, contact us at: privacy@projectrobin.org