Privacy Policy

Last updated: 9/7/2026

1. Introduction

Welcome to IACOMO by Aurelia. We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect, process, and safeguard your information when you use our leadership sparring platform.

2. Data We Collect

We collect information you provide directly to us, including:

  • Account details (name, email, role, industry)
  • Leadership challenges and reflections
  • Role-play conversation transcripts
  • Feedback and AI-generated summaries

3. How We Use AI

IACOMO utilizes advanced AI models to process your session data. We ensure that:

  • Your data is transmitted securely to our AI providers.
  • Your sensitive corporate data is not used to train public AI models.
  • You can disable AI memory context at any time in your Profile.

4. Data Export & Deletion

You have full control over your data. You can export your entire history as a JSON file or permanently delete your account and all associated records directly from your Privacy Settings.

5. Data Handling Details (EU/GDPR)

For users in the European Union, the following specifics apply in addition to sections 2–4:

  • Legal basis. We process your data to perform our contract with you and — for AI sparring features — on the basis of your explicit consent, captured during onboarding and withdrawable at any time.
  • Your rights. Access, portability (JSON export), rectification and erasure are available self-service from Profile → Privacy & Data. You may also contact us via Support to exercise any right.
  • Processors (subprocessors). We use: Supabase (database & authentication), Vercel (web hosting), Railway (application backend) and OpenAI (AI language models). Each processes data on our instructions under a data processing agreement.
  • International transfers. AI requests are transmitted to OpenAI in the United States. Transfers rely on the EU–US Data Privacy Framework and/or Standard Contractual Clauses.
  • No training on your data. Your conversations, reflections and documents are used only to provide sparring to you. They are not used to train AI models.
  • Retention. Your sparring data is retained until you delete it. Deleting a document removes its text and vector embeddings immediately; deleting your account permanently erases all records with no grace period.
  • Cookies. Essential cookies keep you signed in and protect your account. Optional cookies (analytics and preferences) are used only if you accept them in the cookie box. You can change this anytime from the footer or Profile → Privacy & Data.
  • Security. Data is isolated per user with database row-level security, encrypted in transit (TLS) and at rest, and session tokens are stored in HttpOnly cookies.
  • AI transparency. IACOMO is an AI system. All sparring responses and session summaries are AI-generated and labelled as such in the product; they do not constitute professional advice (see our Terms).

6. Contact

Questions about this policy or your data? Use the in-app Support page or the contact form — we respond to every request.