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Privacy Policy

Last Updated: 15th September 2026

1. Introduction

Jolt Systems ("Company", "we", "our", or "us") operates the Ehem platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. By using Ehem, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Personal Information

We collect information that you provide directly to us, including:

  • Email address (required for account creation and sign-in)
  • Name (first and last name)
  • Organisation and role information
  • Payment information (processed securely through Stripe)

2.2 Learning and Course Data

As you use the platform, we collect and store:

  • Course enrolments, module and step completion, and progress records
  • Quiz and assessment responses, scores, and competency estimates
  • Course material, knowledge-base documents, and other content that providers create or upload

2.3 AI Interaction Data

  • Conversations with the Wingman AI tutor
  • Prompts and instructions submitted to AI authoring features, and the AI-generated responses
  • AI-generated course drafts, lessons, and assessments
  • Roleplay transcripts, learner corrections, and communication-practice evaluations
  • When you choose live voice, microphone audio is transmitted directly from your browser to OpenAI for the practice. Ehem stores the resulting transcript, but not the raw live audio.

2.4 Usage Information

  • Log data (IP address, browser type, device information)
  • Usage statistics and feature interaction data
  • Credit consumption and billing transactions

3. How We Use Your Information

We use the collected information for various purposes:

  • To provide, maintain, and improve our Service
  • To power AI-assisted authoring and the Wingman adaptive tutor
  • To process payments and manage credits and subscriptions
  • To send you one-time sign-in codes and service-related communications
  • To track learner progress and competency and generate reports
  • To monitor usage and prevent fraud or abuse
  • To comply with legal obligations

4. AI and Third-Party Services

4.1 AI Provider Integration

Our AI features are powered by large language models and embedding models provided by third parties, currently Anthropic, Azure OpenAI, and OpenAI. When you interact with AI features, your prompts and the relevant course or knowledge-base content are sent to the provider's API to generate a response. These providers process the data according to their own privacy policies and data usage terms.

In live roleplay, OpenAI processes the microphone stream and generates the counterpart's voice and automatic transcript in real time. Raw live audio is not routed through or retained by Ehem. You can end the connection, review the transcript, correct your own words, or report the scenario before it is used as learning evidence.

4.2 Stripe Payment Processing

Payment transactions are processed through Stripe. We do not store complete card details on our servers. Stripe maintains your payment details according to its own privacy policy.

4.3 Email Delivery

Transactional emails, including sign-in codes and service notifications, are delivered through our email provider (Mailgun). Only the information needed to deliver the message (such as your email address and the message content) is shared for this purpose.

5. Data Sharing and Disclosure

We may share your information in the following situations:

5.1 Service Providers

We share data with third-party service providers (including Anthropic, Azure OpenAI, OpenAI, Stripe, and our email provider) who help us operate our Service, limited to what each provider needs to perform its function.

5.2 Course Providers

When you enrol in or purchase a course, the training-provider organisation that publishes that course receives the enrolment and the associated progress, completion, and assessment data needed to deliver the course and track your competency. That provider handles this data under its own obligations and policies.

5.3 Legal Requirements

We may disclose your information if required by law or in response to valid requests by public authorities.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide services. We may retain certain information as required by law or for legitimate business purposes. Course history and results are retained to provide continuity in learner progress and competency tracking.

Communication-roleplay transcripts and evaluations are retained for 365 days by default, subject to an organisation's configured retention policy. Optional learner recordings are retained for 7 days by default and are queued for immediate deletion when a practice is abandoned. Ehem does not retain raw live-voice audio.

7. Data Security

We implement appropriate technical and organisational security measures to protect your information. However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

8. Your Rights and Choices

You have the following rights regarding your personal information:

  • Access: You can access and review your account information at any time
  • Correction: You can update your personal information through your account settings
  • Deletion: You can request deletion of your account and associated data
  • Export: You can request a copy of your data in a portable format
  • Opt-out: You can opt out of marketing communications (service emails are required)

9. Cookies and Tracking

We use essential session cookies to maintain your sign-in state and operate the Service across the Ehem surfaces. These are always active and cannot be disabled while you use the Service. We do not use advertising cookies and do not sell your data to advertisers. You can disable cookies in your browser settings, but this may affect Service functionality.

10. Children's and Minors' Privacy

Learners using the Service may be under the age of 18. Where a learner is a minor, their organisation administrator or educator is responsible for obtaining appropriate parental or guardian consent before creating the learner's account. We collect only the minimum information necessary to provide the Service to minor learners (name, email, and learning performance data). We do not knowingly collect personal information from minors without oversight by their school or learning organisation. If you believe a minor's information has been collected without appropriate consent, please contact us immediately.

11. International Data Transfers

11.1 Where your data is processed

Ehem is operated by Jolt Systems from Australia. Customer data (account details, course records, progress, and uploaded content) is stored on Microsoft Azure infrastructure. AI features are processed on a per-request basis by Anthropic (United States), Azure OpenAI, and OpenAI; AI prompts and the immediate context required to fulfil them are sent to these providers and processed under their own data-handling terms. Transactional email is delivered through Mailgun.

11.2 Australian customers

Where data is disclosed to overseas recipients (including AI processing in the United States), We take reasonable steps to ensure the recipient handles personal information in a manner consistent with the Australian Privacy Principles, in accordance with APP 8 of the Privacy Act 1988 (Cth). By using the Service, you also acknowledge and consent to your information being transferred to and processed in jurisdictions outside Australia, including the United States.

11.3 Other jurisdictions

For users outside Australia, your information may be transferred to and processed in countries other than your country of residence, which may have different data protection laws. By using our Service, you consent to such transfers and accept that the Service may not be specifically tailored for the law of your jurisdiction. Where local mandatory consumer-protection or privacy law provides rights that cannot be excluded by contract, those rights continue to apply.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of the Service after changes are posted constitutes acceptance of the updated policy.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:

Jolt Systems
Email: privacy@jolt.systems