Privacy Policy

Last updated: February 2026 | Version 2.1

1. About This Policy

This Privacy Policy applies to the Real Talk Studio platform (the "Platform") operated by Toby Sinclair Coaching Limited (company number 15722676), trading as Real Talk Studio, whose registered office is at 13 Highfield Road, Croston, Lancashire, PR26 9HH ("RealTalk", "we", "us", "our").

The Platform operates across two distinct contexts. Enterprise customers ("Customers") access the Platform under a Subscription Agreement, with their employees and contractors ("End Users") using it through their organisation. Separately, individuals may create a free account to evaluate the Platform before entering into any commercial arrangement ("Free Account Users").

This Policy explains how we collect, process, and protect personal data across all three groups. It should be read alongside our Free Account Terms and, where applicable, our Subscription Agreement and Data Protection Schedule, which together govern the data processing obligations between RealTalk and our Customers.

2. Our Role: Controller and Processor

Because the Platform is an enterprise service, our role in relation to personal data varies depending on context.

Where we act as a Data Controller

We are the data controller for personal data we collect about our Customer contacts — for example, names and email addresses of those who enquire about, purchase, or administer the Platform on behalf of their organisation. We determine the purposes and means of this processing.

We are also the data controller for personal data collected from Free Account Users — specifically, the name and email address provided at registration, and any data input into the Platform during their evaluation period.

Where we act as a Data Processor

When Customers use the Platform and their End Users interact with it, the Customer is the data controller and RealTalk is the data processor. This means we process End User personal data (such as names, email addresses, conversation transcripts, scores and feedback) strictly on the Customer's documented instructions, as set out in our Data Protection Schedule.

Customers are responsible for ensuring they have a lawful basis to share End User personal data with us, for providing appropriate notices to End Users, and for ensuring their use of the Platform complies with applicable data protection law.

3. Personal Data We Collect

3.1 Customer Contact Data (where we are controller)

When organisations contact us, purchase the Platform, or administer an account, we may collect:

• Name and job title
• Business email address
• Organisation name and address
• Payment information (processed via our third-party payment provider)
• Communications exchanged with us

3.2 End User Data (where we are processor, on behalf of Customers)

When Customers use the Platform in invite mode, the following personal data relating to End Users may be processed:

• Email address (used to invite End Users to Roleplays)
• Roleplay titles and descriptions created by Admin Users
• Conversation transcripts generated during Roleplay interactions
• Scores, feedback, and behavioural analytics generated as Output Data
• Login credentials (held securely; not accessible to RealTalk staff)

Where Customers operate the Platform in embed link mode, End Users can access Roleplays anonymously without providing any personal data. In this mode, all Output Data is generated on an anonymous basis and no End User personal data is processed by us.

We do not knowingly collect or process special category data (as defined under the UK GDPR). Our Subscription Agreement and Free Account Terms expressly prohibit Customers, End Users, and Free Account Users from uploading special category data to the Platform.

3.3 Free Account User Data (where we are controller)

When an individual creates a free account, we collect:

• Name and email address (provided at registration)
• Roleplay content and Concepts created during the evaluation period
• Conversation transcripts generated during Roleplay interactions
• Output Data including scores and feedback
• Login credentials (held securely; not accessible to RealTalk staff)

We strongly recommend that Free Account Users do not input real personal data about third parties during evaluation. The Platform is designed to operate effectively using fictional scenarios and placeholder information.

4. AI Providers and Sub-Processors

The Platform uses artificial intelligence providers ("AI Providers") to power Roleplay simulations, generate feedback, and produce Output Data. To deliver these services, Customer Input Data — including conversation transcripts — is shared with AI Providers as part of the Platform's operation.

RealTalk contractually requires all AI Providers engaged in processing Customer Input Data to have AI model training disabled in respect of that data. Customer personal data is not used to train AI models by any AI Provider we work with.

Our current categories of sub-processors include:

• AI Providers
• Cloud hosting and infrastructure providers
• Payment processors

We will notify Customers of any intended addition or replacement of sub-processors in accordance with our Subscription Agreement. An up-to-date list of sub-processors is available on request by contacting privacy@realtalkstudio.com.

All sub-processors are contractually bound to process personal data only on our instructions, maintain appropriate technical and organisational security measures, and comply with applicable data protection law.

5. How We Use Personal Data

5.1 Customer Contact Data (as controller)

We use this data to:

• Manage your account and deliver the Platform
• Process payments and issue invoices
• Communicate with you about your subscription, service updates, or changes to this Policy
• Maintain internal records and comply with legal obligations

Our lawful basis for this processing is the performance of a contract with you (or taking steps to enter into one), and where applicable, our legitimate interests in operating and improving the Platform.

5.2 End User Data (as processor)

We process End User personal data solely to provide the Platform to the Customer and in accordance with the Customer's documented instructions, as set out in our Data Protection Schedule. We do not use End User data for any purpose beyond delivering the Platform's core functionality — specifically, enabling Roleplay interactions, generating Output Data, and providing analytics to Admin Users.

5.3 Free Account User Data (as controller)

We use Free Account User data solely to provide access to the Platform during the evaluation period. Specifically:

• To create and maintain your free account
• To enable Roleplay interactions and generate Output Data during your trial
• To communicate with you about your account or any conversion to a commercial agreement
• To maintain internal records

Our lawful basis for this processing is the performance of a contract with you (your acceptance of the Free Account Terms) and, where applicable, our legitimate interests in evaluating product fit and facilitating conversion to a commercial arrangement.

6. Data Retention

6.1 Customer Contact Data

We retain Customer contact data for as long as you hold an active account with us and for a reasonable period thereafter as required for legal, tax, or regulatory purposes, or to respond to any claims arising from the contract.

6.2 End User Data

Customer Input Data and Output Data are retained within the Platform for the duration of the Customer's active subscription. Specifically:

• On termination or expiry of a Subscription Agreement, we will delete all Customer Input Data and Output Data within 30 days of the termination or expiry date, unless we are required by applicable law to retain it for longer.
• Where a Customer account has been inactive for six months or more (meaning no further Credits have been purchased), we are entitled to deactivate the account and delete all associated data, following which the Subscription Agreement terminates automatically.

Even where data is deleted from live systems, residual copies may persist on backup or archival systems for a limited period as required for system integrity. Such data will not be actively used.

6.3 Free Account User Data

Data associated with a free account is retained for as long as the account is active. On account deletion or deactivation — including where an account has been inactive for six months or more — all associated data will be permanently deleted within 30 days.

Where a Free Account User converts to a commercial Subscription Agreement and explicitly requests that their trial data be carried over, that data will from that point be governed by the Subscription Agreement and Data Protection Schedule rather than these Free Account retention terms.

7. International Data Transfers

Personal data processed in connection with the Platform may be transferred to, and stored in, countries outside the United Kingdom and the European Economic Area — for example, where our AI Providers or cloud hosting providers are located.

We ensure that any such transfers are made in compliance with applicable data protection law, including through the use of appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or standard contractual clauses adopted by the EU Commission, as applicable. Further detail on the transfer mechanisms in place for specific sub-processors is available on request.

8. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage. These measures include:

• Access controls requiring unique credentials per Authorised User
• Secure server infrastructure provided by our hosting providers
• Contractual security obligations imposed on all sub-processors
• Staff confidentiality obligations in respect of personal data

In the event of a personal data breach involving Customer Personal Data, we will notify the relevant Customer without undue delay in accordance with our Data Protection Schedule and applicable law.

If you suspect any unauthorised access to or misuse of personal data processed via the Platform, please contact us immediately at privacy@realtalkstudio.com.

9. Your Rights

Where we act as data controller (in respect of Customer Contact Data), individuals have the following rights under the UK GDPR:

• Right of access
• Right to rectification
• Right to erasure
• Right to restriction
• Right to data portability
• Right to object

To exercise any of these rights, please contact us at privacy@realtalkstudio.com.

Where we act as data processor (in respect of End User Data), data subject rights requests should be directed to the relevant Customer, who is the data controller responsible for responding to such requests. We will assist Customers in meeting their obligations in this regard, as set out in our Data Protection Schedule.

If you are not satisfied with how we handle a data-related complaint, you may refer the matter to the Information Commissioner's Office (ICO) at ico.org.uk.

10. Cookies

Our website (realtalkstudio.com) uses cookies in accordance with UK and EU cookie law. We use the following categories of cookies:

• Strictly necessary cookies
• Analytical/performance cookies
• Functionality cookies

You will be presented with a cookie consent notice on your first visit to our website. You may withdraw or adjust your consent at any time via your browser settings. For further information, please visit aboutcookies.org.

11. Changes to This Policy

We reserve the right to update this Privacy Policy from time to time to reflect changes in law, our services, or our data processing practices. Where we make material changes, we will notify active Customers by email or via the Platform. The current version of this Policy is always available at realtalkstudio.com/policies/privacy.

Continued use of the Platform following notification of changes constitutes acceptance of the updated Policy.

12. Contact Us

If you have any questions about this Privacy Policy, or wish to exercise your data subject rights, please contact:

Toby Sinclair Toby Sinclair Coaching Limited (t/a Real Talk Studio) 13 Highfield Road, Croston, Lancashire, PR26 9HH Email: privacy@realtalkstudio.com Website: realtalkstudio.com