Research Terms and Research Privacy Notice – AIMY™

The following applies on top of – and takes precedence over – our general privacy policy.

AIMY™ is a virtual coach that uses so-called generative AI. This enables a dynamic and personalized human-machine conversation. AI applications such as AIMY™ are characterized by the fact that they can process large volumes of data and are subject to constant development in terms of their functionality and performance.

You agree that CoachHub® may process the information you exchange with AIMY™, which may include particularly sensitive data (if you share any), in voice and text for the purposes of AI training and product improvement. You understand that in addition to the AI technology, AIMY™ uses and transfers data to other advanced technologies, including those provided by third parties such as Amazon AWS and OpenAI, These third parties may also process the data for their own purposes. Your consent also extends to the fact that data processing may also take place in EU foreign countries. More detailed information on the associated risks as well as further information on data processing can be found in the section below and in the rules on unlawful content . You know that you can revoke your consent at any time.

In order to use AIMY™, you must first register. This requires that you provide your email address to set up and verify an account.

AIMY™ is a research project provided by CoachHub Ltd., Spaces Monument, The Minster Building, Great Tower St, London EC3R 7AG, UK (hereafter “CoachHub®”) and CoachHub Ltd acts as data controller.

For further privacy information, please see below and in our privacy policy. In any case, please see the inappropriate content and acceptable use policy below.

What is AIMY™?
AIMY™ is a CoachHub® AI Coach based on the CoachHub® Coaching Framework, which ensures that each coaching session is tailored to the individual needs of the coachee. Hence using AIMY™’s AI process requires individual content and needs. The data processed is the information you provide via text or voice input. This information is not linked to your person, unless you make such a link yourself (for example, by telling AIMY™ what your name is and where you live or by providing your email address). Please note, however, that AI applications like AIMY™ have a high degree of autonomy and are constantly evolving. You cannot easily detect or regain control over the parts of data integrated into an AI, for example during AI training. You should be aware of the high degree of complexity of the algorithms, the limited possibility of human influence on AI-supported decision-making and the corresponding lack of predictability of future data processing when using AIMY™. This applies especially during a research phase.

Who provides AIMY™?
Under data protection law, CoachHub® is responsible for both the provision of AIMY™ and the personal data processing that takes place via it, as well as the capturing of the communication between you and AIMY™ for the purpose of further research. The research serves the sole purpose of making AIMY™ even better. Only the dynamics of the conversation are of importance, i.e. only the contents of the communication between you and AIMY™ are processed. Conclusions about your person are not drawn and are also not important for the AI. AIMY™ is currently not capable of causal reasoning.

What is the legal basis of processing?
The legal basis for the processing of your personal data by AIMY™ is your consent within the meaning of Art. 6 (1) sentence 1 lit. a GDPR (for the capturing and research for the purpose of AI training and product improvement), whereby the processing of so-called special categories of personal data, e.g. data on health or religious affiliation, is also justified via your consent in accordance with Art. 9 (2) lit. a GDPR (but cf. below the section “Inadmissible content”). By your consent declared to us, we are authorized to capture the non-publicly spoken word of you and to make it available to a third party, if necessary. The statements and recommendations made by AIMY™ do not have any legal or otherwise significant effect on you and are therefore not to be classified as automated decision-making within the meaning of Article 22 (1) of the GDPR.

Consent and Your Right to Revoke Consent
You can revoke your consent at any time with effect for the future. The legality of processing carried out until your revocation remains unaffected by your revocation. In the event of a revocation, we point out that the information you shared with AIMY™ that was integrated into the AI cannot be deleted (a case of Art. 17 para. 1 lit. b GDPR). Further processing of information shared by you with AIMY™ until the time of your revocation is based on Art. 6 para. 1 sentence 1 lit. f GDPR. Being allowed to process information provided by users for the purpose of AIMY™’s AI training and the resulting product improvement is to be classified as a legitimate interest within the meaning of this provision. Overriding interests of exclusion are not recognizable, in particular, because the data previously provided by you and processed by AIMY™ is not processed with regard to your person, but exclusively in aggregated form.

Who Helps us Provide AIMY™?
For the technical provision of AIMY™, CoachHub® uses services (such hosting, transcription, text-to-speech, and voice recognition) of Amazon Web Services Ireland (“AWS”). We have entered into a data processing agreement with AWS. This means that AWS may process the data collected when using AIMY™ only for us and on our instructions. AWS does not exclude the transfer of data to third countries outside the EU or EEA for the purpose of providing the hosting service. If these third countries are so-called non-secure third countries, AWS uses EU standard contractual clauses to ensure an adequate level of data protection in these non-secure third countries as well. We will be happy to provide you with the specific clauses concluded upon request.

AIMY™ incorporates offerings from specialized service providers in the areas of noise cancellation, voice transcription, text modulation, real-time audio and video streaming, text-to-speech conversion, and data storage. Of significant importance is the AI application ChatGPT from the provider OpenAI, L.L.C., 3180 18th St, San Francisco, CA 94110, USA (“OpenAI”). We have also concluded a data processing agreement (“Data Processing Addendum”) with OpenAI, incorporating the EU standard contractual clauses . We will be happy to provide you with the specific clauses upon request.

Insofar as other service providers are processors, CoachHub has also concluded data processing agreements with them. Also, insofar as a transfer of data to a non-secure third country occurs in connection with the provision of a specialized component of AIMY™ by a service provider, we have ensured the guarantee of an adequate level of protection by concluding EU standard contractual clauses.

How do we Secure AIMY™ Data Transfers?
Unless there are standard contractual clauses or other guarantees within the meaning of Art. 46f. GDPR, we base data transfers to the USA as a non-secure third country on your explicit consent pursuant to Art. 49 (1) p. 1 lit. a GDPR. By way of explanation: A third country is a country outside the European Economic Area (EEA) in which the GDPR is not directly applicable. A third country is considered insecure if the EU Commission has not issued an adequacy decision for that country pursuant to Article 45(1) of the GDPR confirming that adequate protection for personal data exists in that country. With the ECJ ruling of July 16, 2020 (C-311/18), the adequacy decision for the USA, the so-called Privacy Shield, was declared null and void. The USA is thus a so-called unsafe third country. This means that the USA does not offer a level of data protection comparable to that in the EU. The following risks exist when personal data is transferred to the USA: There is a risk that U.S. authorities may gain access to personal data on the basis of the PRISM and UPSTREAM surveillance programs based on Section 702 of FISA (Foreign Intelligence Surveillance Act), as well as on the basis of Executive Order 12333 or Presidential Police Directive 28. EU citizens have no effective legal protection against these accesses in the U.S. or the EU.

Inappropriate content:
You decide what information and questions you confront AIMY™ with. Please note that you should only share information with AIMY™ that relates to yourself. For information about third parties, you should make sure that these third parties agree to the disclosure of this information. As a general rule, the information you share with AIMY™ should not include the following:

  • information about diseases,
  • information about ethnicity,
  • political, religious or philosophical beliefs,
  • information about possible pregnancy,
  • union affiliation and sexual orientation,
  • defamatory or degrading information,
  • information that is not specifically related to your coaching.

In addition, the information you exchange with AIMY™ must not violate any third party rights, trade secrets, public law or morality (“Prohibited Content”). Please note that you must indemnify and hold us harmless from any claims we may have based on information containing Prohibited Content that is processed by us as a result of your interaction with AIMY™.

Acceptable Use Policy
You shall use AIMY in an acceptable fashion and nobody shall:

  • pass on their login credentials, individual accounts or any content in their account to third parties ( Coaches can request another account to (sub-)commission work to other certified Coaches);
  • publish or otherwise make publicly available (including on social media) any CoachHub Platform content without prior express written permission by CoachHub;
  • use CoachHub® AIMY™ for any purposes other than those described in these ToU;
  • infringe any of CoachHub’s or third- parties’ rights (including under copyright or other intellectual property law) when using the Coaching Services;
  • use the chat tool or a Coaching Session to insult a Coach or Coachee respectively or otherwise display defamatory or inflammatory behavior; or
  • use CoachHub® AIMY™ or the Coaching Services to send other Users marketing messages, chain letters, invitations to participate in pyramid schemes or other types of messages that encourage the recipient to forward content to strangers. Coaches further may not promote or offer any services or contracts not approved in writing by CoachHub.

CoachHub does not monitor the content of Coaching Sessions on or through CoachHub® AIMY™ or Coaching Services. CoachHub has no responsibility for any information created, uploaded, stored, maintained, transmitted, or made accessible on or through CoachHub® AIMY™ or the Coaching Services.

CoachHub may take appropriate measures including without limitation the following measures with regard to you if there are specific indications that such User has violated statutory provisions, third-party rights or these terms:

  • Warning of the respective User.
  • Blocking the respective User’s AIMY account (preliminarily or, in case of repeated or severe violations, permanently). In that case, the Customer does not re-allocate that User’s Coaching License to another User or allocate another Coaching License to that User.

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