Privacy Policy

1. Publisher and role

The Engramm platform is published by Solers.io SAS, a simplified joint-stock company with a share capital of €35,681.10, registered office at 3 rue Auguste Bailly, 92400 Courbevoie (France), Nanterre Trade and Companies Register 917 416 166.

When your employees use the platform, Solers.io acts as a processor within the meaning of Article 28 of the GDPR, on behalf of the client company, which remains the data controller. For data you send us directly through this website (contact, demo request), Solers.io acts as the data controller.

2. Data, purposes and legal basis

The data processed through the platform (professional identifier, voice recordings, transcripts, learning scores and technical data) is processed for the purposes of professional training and coaching, on the basis of the performance of the employment contract or the client's legitimate interest in training its teams. Data submitted through the website is processed to respond to your requests.

3. Hosting and sub-processors

Training data is hosted and processed within the European Union and is not subject to any transfer outside the EU. We use sub-processors governed by a processing agreement compliant with Article 28 of the GDPR; the detailed list is provided to clients as part of the contractual documentation.

4. Retention period

Data is retained for 24 months from the last login, unless a different period is agreed contractually. It is deleted or returned to the client at the end of the contractual relationship.

5. Security

Data is encrypted in transit and at rest. Solers.io is SOC 2 Type II attested. In the event of a data breach, the client is notified in accordance with Article 33 of the GDPR.

6. Artificial intelligence

Engramm relies on AI models to simulate training conversations. You are informed when you interact with an AI (Article 50 of Regulation (EU) 2024/1689). The system is not classified as high-risk and does not produce any automated decision with legal or significant effect.

7. Cookies

The training platform uses exclusively cookies strictly necessary for its operation, exempt from consent within the meaning of Article 82 of the French Data Protection Act.

The engramm.ai marketing website additionally uses an audience-measurement tool (Google Analytics) to analyze traffic and improve the site. These cookies are only placed after obtaining your consent, which you can withdraw at any time. No advertising cookies are used.

8. Your rights and contact

You have the rights of access, rectification, erasure, restriction, objection and portability. For platform data, these rights are exercised with the data controller (your employer). You may contact our Data Protection Officer at dpo@solers.io and lodge a complaint with the CNIL (www.cnil.fr).

This policy may be updated; any significant change will be indicated on the website.