Privacy Policy

Last updated: September 16, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Dialog Dynamo Limited (trading as “Skylar”), registered in England and Wales.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: United Kingdom
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to our website, web application and related services.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Skylar, accessible from https://getskylar.com
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Our Role

Dialog Dynamo Limited acts in different capacities depending on how you interact with our Service:

For our website and marketing activities, Dialog Dynamo Limited is the data controller. We determine how and why your personal data is processed.
For use of the Skylar platform by customer users, we act as a data processor (under UK/EU GDPR) and service provider (under CPRA). In this capacity, we process personal data only on the customer’s documented instructions under a Data Processing Agreement (DPA).

If you are a customer organization, please refer to our DPA for details on our processor obligations. If you are an end user of a customer organization, your organization is the controller of your data, and you should contact them regarding your data rights.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

The categories of personal data we collect depend on whether you are interacting with our website (controller scope) or using the Skylar platform as a customer user (processor scope):

Website and Marketing (Controller Scope):

Account data: Name, work email address, company name, job role
Authentication data: Login credentials, authentication tokens
Support communications: Email correspondence, support tickets
Usage and technical data: IP address, browser type, device information, pages visited, time spent on pages

Skylar Platform (Processor Scope):

Account data: Name, work email, role/team assignment
Authentication and audit logs: Login timestamps, IP addresses, device identifiers
Training interaction data: Prompts, responses, scores, feedback from AI roleplay sessions
Support communications: Help requests and correspondence
Usage and technical data: Platform events, feature usage, device and browser information

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

In the UK/EU, we use non-essential cookies only with your consent; you can manage preferences via the cookie banner at any time.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Legal Bases for Processing (Controller Scope)

When we act as a data controller (for our website and marketing activities), we process your personal data based on the following legal bases under UK GDPR:

Performance of a contract: To provide you with access to our Service, manage your account, and fulfill our contractual obligations
Legitimate interests: For security and fraud prevention, product analytics (proportionate to our business needs), improving our Service, and internal business operations
Legal obligation: To comply with legal requirements such as tax, accounting, and regulatory obligations
Consent: Where we rely on your consent (for example, for non-essential cookies or marketing communications), we will clearly request it and explain how you can withdraw it at any time

When we act as a processor for customer organizations, we process data only on their documented instructions under our Data Processing Agreement.

Use of Your Personal Data

Use of Personal Data – Controller Scope (Website/Marketing)

When we act as a data controller for our website and marketing activities, we may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

Use of Personal Data – Processor Scope (Skylar Platform)

When acting as a processor/service provider, we process customer user data only to deliver and support the Skylar platform (authentication, training sessions and feedback, security, support, and compliance). We do not use customer user data for advertising or our own marketing purposes.

We may share Your personal information in the following situations:

Controller Scope (Website and Marketing):

With Service Providers: We may share your personal information with carefully selected service providers who assist us in operating our website and providing our services (e.g., hosting, analytics, customer support tools)
For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company
With Your consent: We may disclose your personal information for any other purpose with your consent

We do not sell or share personal information for cross-context behavioral advertising purposes.

Processor Scope (Skylar Platform): When we act as a processor for customer organizations:

We do not sell or share personal information
We disclose data only to sub-processors necessary to provide the Service (see Sub-Processors section below)
We process data only as instructed by the customer organization under our Data Processing Agreement
We do not use customer user data for marketing or any purpose unrelated to providing the Service

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Specific retention periods are as follows:

Controller Scope (Website and Marketing):

Account and profile data: Retained for the duration of your account plus 30 days after account closure
Support communications: Up to 12 months after case closure
Marketing communications: Until you unsubscribe or withdraw consent
Usage and analytics data: Generally retained for 12 months

Processor Scope (Skylar Platform - Customer User Data):

Customer user data: Retained for the term of the customer contract
Active system deletion: Within 30 days of account deactivation or contract termination
Backup retention: Backups age out within 30 days after deletion from active systems
Security and audit logs: Approximately 12 months for security and compliance purposes

We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Data Location and Transfer of Your Personal Data

Primary Hosting Location: Our Service is primarily hosted on Google Cloud Platform in the europe-west1 region (Belgium), ensuring that your data remains within the European Economic Area.

Your information, including Personal Data, may be processed at the Company’s operating offices and by our sub-processors. While we primarily host data in the EU, certain support and operational tools may involve transfers outside of the UK/EU.

When we transfer your Personal Data outside of the UK or EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government or European Commission
Where we use certain service providers, we use specific contracts approved by the UK Information Commissioner’s Office (International Data Transfer Agreement or “IDTA”) or European Commission (Standard Contractual Clauses or “SCCs”) which give personal data the same protection it has in the UK/EU

Where feasible we also apply technical measures (e.g., encryption in transit and at rest).

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Sub-Processors

When acting as a data processor for customer organizations, we engage the following categories of sub-processors to help us provide the Skylar Service:

Cloud Infrastructure: Google Cloud Platform (hosting and infrastructure services)
Authentication Services: Firebase Authentication (user authentication and identity management)
Support and Communication Tools: Google Workspace (customer support and internal communications)
Development and Deployment: GitHub (code repository and CI/CD, if applicable)

We maintain appropriate data processing agreements with all sub-processors to ensure they provide adequate protection for personal data. We conduct due diligence on our sub-processors and ensure they comply with applicable data protection laws.

For an up-to-date list of our sub-processors or to receive notifications of changes to our sub-processor list, please contact us at [email protected].

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

If you are an end user of a customer organization, please direct your request to your organization (the controller). We will support the controller and act on their instructions.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

Under UK data protection law, children aged 13 or over are generally regarded as having the appropriate level of understanding to provide their own consent for the processing of their personal data. If we need to rely on consent as a legal basis for processing information and the individual is under 13, we will obtain consent from a person with parental responsibility.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Under the UK GDPR, you have several rights regarding your personal data:

Right to be informed about how we use your personal data
Right of access to the personal data we hold about you
Right to rectification if your personal data is inaccurate or incomplete
Right to erasure (“right to be forgotten”) in certain circumstances
Right to restrict processing of your personal data in certain circumstances
Right to data portability, allowing you to obtain and reuse your data
Right to object to our processing of your personal data
Rights related to automated decision making and profiling

If you are an end user of a customer organization, please direct your request to your organization (the controller). We will support the controller and act on their instructions.

To exercise any of these rights, please contact us using the details in the “Contact Us” section. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

Notice at Collection (California Residents)

This section provides specific information for California residents as required by the California Privacy Rights Act (CPRA).

Categories of Personal Information We Collect:

Identifiers (name, email address, IP address, device identifiers)
Professional or employment-related information (company name, job role)
Internet or network activity (browsing history, interactions with our Service)
Electronic or similar information (training interaction data such as text prompts, responses, scores)

Sensitive Personal Information: not collected for this Service.

Purposes for Collection:

Providing and maintaining our Service
Account management and authentication
Customer support
Security and fraud prevention
Service improvement and analytics
Legal compliance

Retention Periods: See the “Retention of Your Personal Data” section above for specific retention periods.

Sale or Sharing: We do not sell or share personal information for cross-context behavioral advertising purposes.

Your California Privacy Rights: California residents have the right to:

Know what personal information we collect, use, disclose, and sell
Request deletion of personal information
Opt-out of the sale or sharing of personal information (note: we do not sell or share)
Correct inaccurate personal information
Limit the use of sensitive personal information
Non-discrimination for exercising these rights

To exercise these rights, please contact us at [email protected].

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: [email protected]
By post: Dialog Dynamo Limited (trading as Skylar), Address: 86-90, Paul Street, London EC2A 4NE