Privacy Policy

1. Introduction

Silk Clarity ("Silk Clarity", "we", "us", or "our") is committed to protecting the privacy and personal data of its users, clients, and website visitors ("you", "your"). This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit https://www.silkclarity.com (the "Website") or use our communication development and rehearsal services (the "Services").

This Policy is issued in accordance with Regulation (EU) 2016/679 (the "General Data Protection Regulation" or "GDPR") and applicable data protection legislation.

2. Data Controller Information

The data controller responsible for the processing of your personal data is:

• Business Name: Silk Clarity
• Owner: Darcy Renouf
• Website: https://www.silkclarity.com
• Contact email: hello@silkclarity.com

3. Personal Data Collected

3.1 Information You Provide

• Identification data: full name, preferred name, date of birth (where relevant).
• Contact data: email address, telephone number, country of residence, time zone.
• Account data: login credentials, profile preferences, language proficiency information.
• Professional data: occupation, employer (optional), learning objectives.
• Booking and scheduling data: lesson times, attendance records, lesson notes.
• Payment data: billing name, billing address, and tax identification number where required. Card details are never stored on our systems.
• Communication data: messages, support requests, survey responses, feedback.
• Marketing preferences: newsletter subscription status and consent records.

3.2 Information Collected Automatically

• Device and browser information (IP address, browser type, operating system, device identifiers).
• Usage information (pages visited, time on page, referring URLs, session duration).
• Log data (timestamps, error logs, access logs).
• Approximate geolocation data derived from IP address.
• Information collected via cookies and similar technologies (see Section 4).

3.3 Assessment and Rehearsal Data

If you take a Silk Clarity assessment or use the rehearsal features, we additionally collect:

• Spoken responses — audio recordings of your responses to assessment and rehearsal scenarios.
• Written responses — text you provide in response to assessment tasks.
• Transcripts — text transcriptions of your spoken responses. All scoring and analysis operates on the transcript, not the audio.
• Assessment results — dimension scores, extracted evidence quotations, behavioural observations, development guidance, and your Communication Signature™ (including earlier versions, which are preserved as a record of your development).
• Stated demographic controls — limited information you choose to provide for fairness monitoring and research controls (for example, stated language proficiency level).

We do not extract or retain voice biometrics. We do not collect video during assessments. Accent, pitch, and pace are not inputs to any score.

4. Cookies and Tracking Technologies

We use cookies, pixels, local storage, and similar technologies to operate the Website, remember preferences, measure performance, and (where you consent) deliver marketing. Categories include:

• Strictly necessary cookies — required for the Website to function. No consent required.
• Functional cookies — remember preferences (e.g. language, time zone).
• Analytics cookies — measure usage (e.g. Google Analytics).
• Marketing/advertising cookies — personalize and measure marketing (e.g. Meta Pixel).

Non-essential cookies are only set with your prior consent. You may withdraw consent at any time via the cookie settings link in the Website footer.

5. Legal Basis for Processing Under GDPR

• Performance of a contract (Art. 6(1)(b)) — to provide the Services you have requested.
• Legal obligation (Art. 6(1)(c)) — to comply with tax, accounting, and other legal duties.
• Legitimate interests (Art. 6(1)(f)) — to operate, secure, and improve the Website and Services.
• Consent (Art. 6(1)(a)) — for non-essential cookies and marketing. You may withdraw consent at any time.

6. How Personal Data Is Used

• Create and manage your account.
• Schedule, deliver, and manage lessons and rehearsal sessions.
• Process payments and issue invoices.
• Communicate with you about your bookings, account, and Services.
• Send newsletters and marketing communications (where permitted).
• Improve our Services, content, and user experience.
• Comply with legal, tax, and regulatory obligations.
• Detect, prevent, and address fraud, security, or technical issues.

7. Payment Processing

Where payments are accepted, they are processed by a regulated third-party payment provider. Card details are submitted directly to that provider and are governed by their own privacy policy. We receive only transaction metadata necessary to deliver and account for the transaction. We do not store full card numbers.

8. Scheduling and Booking Platforms

We may use third-party booking and scheduling tools (such as Calendly) to manage lesson appointments. These providers process your name, email, time zone, and selected appointment times on our behalf as processors under appropriate data protection agreements.

9. Video Conferencing Platforms

Lessons may be delivered through video conferencing tools such as Zoom or Google Meet. These platforms process your name, email, IP address, device data, and audio/video streams during sessions in accordance with their own privacy policies. Lessons are not recorded unless you are informed in advance and have given consent where required.

10. Email Marketing and Newsletters

If you subscribe to our newsletter or consent to marketing, we will send you communications about lessons, courses, content, and offers. You can unsubscribe at any time via the link in any email or by contacting us.

11. Analytics and Website Performance Tools

We use analytics tools (such as Google Analytics) and may use advertising pixels (such as Meta Pixel) to understand how users interact with the Website and to measure marketing performance. Where these tools rely on non-essential cookies, they are loaded only after you provide consent. IP addresses are anonymized where technically feasible.

12. Data Sharing and Third-Party Providers

We do not sell your personal data. We share personal data only with:

• Service providers acting as processors on our behalf (hosting, payments, scheduling, video conferencing, email marketing, analytics, support).
• Professional advisors (accountants, lawyers, auditors) under duties of confidentiality.
• Competent public authorities where required by law.
• Acquirers or successors in the event of a business reorganization, merger, or sale.

All processors are bound by written agreements meeting the requirements of Article 28 GDPR.

13. International Data Transfers

Some of our providers are located outside the European Economic Area (EEA), including in the United States. Where personal data is transferred outside the EEA, we rely on appropriate safeguards under Chapter V GDPR, including the European Commission's Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework.

14. Data Retention Periods

• Account and lesson records: duration of the client relationship and up to 6 years thereafter.
• Invoicing and payment data: 6 years from issuance, in accordance with applicable commercial law.
• Marketing data: until you withdraw consent or object.
• Website analytics: typically up to 14 months.
• Support communications: up to 3 years from last contact.
• Assessment audio recordings: deleted once transcribed and verified; audio files are not retained.
• Transcripts, assessment results and Communication Signature™ (all versions): duration of your account, then deleted or anonymised within 30 days of account closure or an erasure request.

When no longer required, personal data is deleted or anonymized.

15. User Rights Under GDPR

• Right of access — to obtain confirmation and a copy of your personal data.
• Right to rectification — to correct inaccurate or incomplete data.
• Right to erasure — to request deletion of your personal data.
• Right to restrict processing — to limit processing in certain circumstances.
• Right to data portability — to receive your data in a structured, machine-readable format.
• Right to object — to object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent — at any time, without affecting prior lawful processing.

To exercise these rights, contact us at hello@silkclarity.com. We may need to verify your identity before responding.

16. Children's Privacy

The Services are not directed to children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

17. Data Security Measures

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction, including encryption in transit (TLS), access controls, secure authentication, regular backups, and vendor due diligence. No method of transmission or storage is 100% secure.

18. Complaint Procedures

If you believe your data protection rights have been infringed, you have the right to lodge a complaint with the supervisory authority of your country of residence. We encourage you to contact us first so we can address your concerns.

19. Contact Information

Silk Clarity — Darcy Renouf
Email: hello@silkclarity.com
Website: https://www.silkclarity.com

20. Assessment Data, Communication Signature™ and Research Use

How assessment data is used. Assessment and rehearsal data is used to: produce your Communication Signature™ and development guidance; provide human review where you request it; operate, calibrate and quality-assure the scoring methodology; and — in de-identified form — conduct the validation research described on our website. Legal bases: performance of a contract (Art. 6(1)(b)) for delivering your assessment and results; legitimate interests (Art. 6(1)(f)) for methodology calibration, quality assurance and de-identified research, against which you may object at any time.

Audio recordings. Spoken responses are recorded solely for transcription. Analysis operates on the transcript. Audio recordings are deleted once transcription and basic quality verification are complete; they are not retained as audio files. Human reviews and calibration operate on the transcript and logged evidence, not on retained audio.

Human review. Every assessment report includes a route to request human review. Requested reviews are conducted by a trained practitioner and operate on your responses, transcripts and logged evidence. Audio recordings are not available for review because they are not retained.

Research and validation. Where assessment data is used for validation research, it is de-identified before analysis: names, contact details and employer identifiers are removed. Published research reports aggregate findings only; no individual is identifiable. Score distributions are monitored across demographic groups as part of our bias-monitoring programme.

Your choices. You may request deletion of your assessment data, including audio, transcripts and your Communication Signature™, at any time (see Section 15). Deletion of your Signature removes it from your account permanently; earlier versions are not recoverable. Withdrawal or deletion does not affect research analyses already performed on de-identified data, from which you are no longer identifiable.

Sharing. If you take an assessment through a recruiter or employer programme, that organisation receives your report as described to you at the point of consent for that programme. We do not otherwise share individual assessment results.

21. Updates to this Policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top indicates the latest revision. Material changes will be communicated through the Website or by email where appropriate.