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Changes to our data-protection terms
Every change to the Data Processing Agreement template, the sub-processor list and the Privacy Policy is listed here. Academies with a signed Data Processing Agreement are notified by e-mail and in their admin console. A change takes effect 14 days after that notice. Before then an Academy may object on reasonable data-protection grounds by writing to security@proficienthub.ai. We then work with it in good faith on an alternative. If none is available, it may stop using the affected feature, or end the affected service without penalty, before the change takes effect.
Live avatar (Simli): EU processing by default, with per-session exceptions
- Published
- 22 October 2026
- Notice to Academies
- Not sent yet
- Effective for Academies with a signed DPA
- 14 days after the notice is sent
- Documents
- DPA template v1.2 · Privacy Policy v1.6
- Sub-processor list: Simli (the live speaking avatar) now processes in the EEA by default. Its entry also says what it receives: the avatar's own synthesised speech, the avatar video it renders, session metadata and the learner's IP address. It never receives the learner's microphone or camera.
- Sub-processor list: two exceptions can apply to an individual session only, never as a default. (a) For learners outside the EU, the avatar's audio/video stream may travel over LiveKit Cloud's global network, while rendering, logs and storage stay in the EEA. (b) If Simli has no EU capacity for a session, that session may be processed in Simli's other regions under the Standard Contractual Clauses in Simli's DPA. Each such session is logged with its reason. The LiveKit entry is updated to match.
- Data Processing Agreement template v1.2: new clause 8.3 sets out the same default and the two per-session exceptions, and the Academy's right to the per-session log. Schedule 3 is updated.
- Privacy notice v1.6: section 6 (international transfers) explains the live avatar's EEA default and the two exceptions in plain words.