Privacy policy

Accelertrain Company Limited (“Accelertrain”, “Atiom”, “we”, “our”, or “us”) is committed to protecting the privacy of individuals who use our mobile application, websites, and associated services (the “Service”). This Privacy Policy explains what personal data we collect, how we use it, how we share it, and the rights you have.

This Privacy Policy applies to:
- employees and contractors who use the Atiom mobile app or web app as part of their employer’s training program (“Users”)
- administrators and managers who access Atiom’s management tools
- visitors of our public websites (atiom.app, acelertrain.com, atiom.cn)
Because Atiom is provided through employers, some personal data is supplied directly by your employer, and some is generated through your use of the platform.

1. Personal Data We Collect

1.1 Data provided by your employer
Your employer controls your Atiom account and determines what information to provide. Required fields normally include:
- name
- department / region / property
Your employer may optionally upload:
- email address
- employee ID
- job title
- date of birth
- other profile fields
All such data is governed by your employer’s internal policies.

1.2 Data you provide
When using the app, you may submit:
- profile photo (optional)
- training activity (quiz answers, scores, completions)
- text, audio recordings, or responses when using Atiom’s AI roleplay or tutoring features
- support requests or messages sent to us
- If you use voice inputs for roleplays or learning modules, audio is sent to OpenAI for transcription.
- For all AI related activities only your first name is shared with OpenAI.

1.3 Data collected automatically
We collect:
- timestamps of actions taken in the app
- IP addresses for security and troubleshooting
- device information (OS version, device model)
- crash logs
- app interaction events and basic usage analytics (via Mixpanel)
- performance metrics and diagnostic information

2. How We Use Your Personal Data

We process personal data to:
- provide access to the Atiom Service
- deliver training modules, roleplays, assessments, and gamified features
- show your learning history, completions, badges, and streaks
- support your employer’s training compliance, performance tracking, and reporting
- provide internal administration and reporting across your employer’s corporate group, where permitted under applicable data protection laws (e.g., legitimate interest under GDPR)
- send necessary operational messages such as password reset emails, welcome emails, or event notifications
- maintain platform security (fraud detection, access validation)
- troubleshoot performance issues and improve app features
- comply with law and enforce our Terms of Service
We do not sell personal data and do not use it for advertising.

3. Legal Basis for Processing (GDPR and similar laws)

Where required by law, we rely on one or more of the following legal bases:
- Legitimate Interests: providing training services to your employer, internal corporate reporting, platform analytics, security, service improvement.
- Performance of Contract: delivering the Atiom platform as part of your employment training program.
- Consent: only where explicitly required (e.g., optional profile fields, audio submissions).
- Legal Obligation: where data must be retained or disclosed by law.

4. How We Share Personal Data

We may share your personal data with:
4.1 Your employer and its corporate group
Authorized individuals in your employer’s organization may access:
- your name and profile
- training progress, scores, and quiz answers
- timestamps and activity history
- analytics dashboards and data exports
This may include head office or affiliated entities for internal administration, reporting, or training management purposes, permitted under applicable data protection laws (such as GDPR legitimate interest).
Your employer controls access permissions.

4.2 Service providers
We use trusted third-party processors who help us operate the Service, including:
- AWS (cloud hosting, storage, and email delivery)
- Mixpanel (analytics)
- OpenAI (AI roleplay/tutoring features; only your first name + audio is shared)
All processors are bound by confidentiality and data-processing agreements.

4.3 Legal and safety requirements
We may disclose data when required to:
- comply with law, regulation, or legal request
- protect the rights and safety of users or the publicenforce our Terms of Service
- respond to security threats, fraud, or abuse

4.4 Business transfers
If Accelertrain is involved in a merger, acquisition, or asset sale, personal data may be transferred as part of that transaction under applicable safeguards.

5. Data Storage and Transfers

Atiom, together with your employer select the AWS data center region used for your account. All data is stored securely using respected cloud infrastructure providers.
Data may be processed in countries outside your own, where our employees, contractors, or service providers are located. When doing so, we use appropriate safeguards such as contractual commitments and access controls.

6. Data Retention

We retain personal data:
- for as long as your employer maintains an active Atiom subscription, or
- until your employer requests deletion
unless a longer retention period is required for legal, regulatory, or audit reasons.

7. Your Rights

Depending on your location, you may have the right to:
- access your personal data
- correct inaccurate information
- request deletion
- object to or restrict certain processing
- request a copy of your data (data portability)
Requests involving your employment data will be handled in coordination with your employer, who is the controller of your account.
To submit a request, contact support@atiom.app.

8. Security

We employ administrative, technical, and physical safeguards designed to protect personal data. However, no system can be completely secure, and we cannot guarantee absolute protection.

9. Children

The Service is not intended for individuals under 16 unless used strictly within employer-controlled training programs.

10. Changes to This Policy

We may update this Privacy Policy periodically. When we make significant changes, we will update the date above and, when appropriate, notify users or administrators.

11. Contact Us

If you have questions about this Privacy Policy, please contact:
Accelertrain Company Limited
support@atiom.app.

Privacy Policy Changes

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at support@atiom.app.