Entrenador.ai — Inteliventa
This Privacy Policy describes how Inteliventa SpA (“Inteliventa”) processes personal data in connection with the provision of Entrenador.ai, an AI-assisted sales training platform. It applies to Users located in the European Economic Area (EEA) and in Switzerland, and is governed by Regulation (EU) 2016/679 (GDPR) and by the Swiss Federal Act on Data Protection (FADP), in force since 1 September 2023. Inteliventa is established in Chile and is subject to the GDPR pursuant to its Article 3(2).
Inteliventa has appointed Andrés Pardo as its representative for Europe for the purposes of Article 27 GDPR and Article 14 FADP. You may contact him, at the address indicated, on any matter relating to the processing of your personal data, without prejudice to your ability to contact Inteliventa SpA directly.
Entrenador.ai is contracted by companies (the “Client”) to train their employees or collaborators (the “Users”). In this context:
The relationship between both parties is governed by a data processing agreement under Article 28 GDPR, covering the subject matter and duration of the processing, staff confidentiality, security measures, the use of sub-processors, assistance to the controller, and deletion or return of the data at the end of the service.
We do not request special categories of data. Users are instructed not to include in their answers any data concerning health, religious or philosophical beliefs, trade union membership, ethnic origin, sex life or sexual orientation, or personal data of third parties.
| Purpose | Determined by | Legal basis |
|---|---|---|
| Delivering the training, transcribing and evaluating the exercises and providing feedback | Client | Performance of the employment contract (Art. 6(1)(b)) or legitimate interest in training the sales team (Art. 6(1)(f)); consent (Art. 6(1)(a)) where the Client chooses it as the basis |
| Producing progress reports, rankings and comparisons for management | Client | Legitimate interest in staff development and quality supervision (Art. 6(1)(f)) |
| Operating, maintaining and securing the platform; preventing abuse | Inteliventa | Own legitimate interest in the security and continuity of the service (Art. 6(1)(f)) |
| Complying with legal obligations and responding to requests from competent authorities | Client / Inteliventa | Compliance with a legal obligation (Art. 6(1)(c)) |
In Switzerland, the processing relies on the principles of lawfulness, good faith, proportionality and purpose limitation set out in Articles 6 and 7 FADP and, where applicable, on consent under Article 6(6) FADP.
Inteliventa does not determine on its own any purposes other than those instructed by the Client, does not commercialize the data, and does not use it to train its own or third-party models.
The platform automatically generates transcriptions, scores, comparisons and feedback on the exercises. Regarding these outputs:
The Client undertakes contractually not to base decisions with legal or similarly significant effects on the User —such as promotions, sanctions, determinative performance appraisals or termination of employment— solely on the automated output, without meaningful human intervention. Every User may request, through the Client, human intervention in the review of their evaluation, express their point of view and contest the result, in accordance with Article 22(3) GDPR and Article 21 FADP.
To provide the service, Entrenador.ai uses artificial intelligence models and other services provided by specialized third parties, with whom only the information necessary for each function is shared. These categories include:
Toward the AI engines, content is transmitted applying dissociation measures, so that it does not include the contact data that directly identifies the User.
In accordance with Article 28(2) and (4) GDPR, Clients grant a general written authorization for the use of sub-processors, receive prior notice of the addition or replacement of any of them, and have a reasonable period to object. The named, up-to-date list of sub-processors is made available to Clients on request at [email protected]. Inteliventa imposes on each sub-processor, by contract, data protection obligations equivalent to those it owes the Client, and remains liable to the Client for their performance.
The service is operated from Chile and part of the processing is carried out by providers located outside the EEA and Switzerland. Direct identification data remains hosted on infrastructure located in Chile.
The European Commission has not adopted an adequacy decision regarding Chile within the meaning of Article 45 GDPR. Transfers of personal data from the EEA are therefore based on the appropriate safeguards of Article 46 GDPR, in particular:
We do not rely on the derogations of Article 49 GDPR as a routine basis for transfers. You may request a copy of the safeguards applied by writing to [email protected].
Inteliventa applies appropriate technical and organizational measures in accordance with Article 32 GDPR and Article 8 FADP, taking into account the state of the art, the costs of implementation and the risks to Users’ rights and freedoms. No system is completely infallible, so Inteliventa cannot guarantee the absolute security of the information against events exceeding such appropriate measures.
If a personal data breach occurs, Inteliventa will notify the Client without undue delay after becoming aware of it, in accordance with Article 33(2) GDPR, providing the information necessary for the controller to meet its own obligation to notify the supervisory authority (Art. 33(1)) and, where the risk is high, the affected Users (Art. 34). In Switzerland, the duty to notify the FDPIC under Article 24 FADP additionally applies.
Data is retained for as long as the service relationship with the Client is in effect. Once that relationship ends, or upon the Client’s express instruction, data is deleted or returned within a maximum period of 90 days, unless there is a legal obligation to retain it.
You can request manual deletion of the data associated with your account on our data deletion page.
Under the GDPR you have the right to request access to your personal data (Art. 15), its rectification (Art. 16) and its erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interest (Art. 21). Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out beforehand (Art. 7(3)). You also have the right not to be subject to decisions based solely on automated processing (Art. 22), on the terms of Section 05.
Under the Swiss FADP you have the right of access (Art. 25), the right to the handing over or transfer of your data (Art. 28), and the rights of rectification and objection recognized by that act.
Since the Client is the data controller, please address your request preferably to the company you carry out the training for. You may also write to us at [email protected]: we will forward your request to the controller within five business days and provide the assistance needed to respond to you, in accordance with Article 28(3)(e) GDPR. The controller must respond within one month, extendable by two further months where the complexity justifies it (Art. 12(3) GDPR).
You may lodge a complaint with the supervisory authority of your Member State of habitual residence, place of work or place of the alleged infringement (Art. 77 GDPR) — in Spain, the Spanish Data Protection Agency, aepd.es — and, if you are in Switzerland, with the Federal Data Protection and Information Commissioner (edoeb.admin.ch). You may also bring judicial proceedings under Articles 79 and 82 GDPR.
The inteliventa.ai website uses strictly necessary cookies for its operation — in particular, the language preference and the submission of contact forms — which do not require consent because they are essential to deliver the service you request.
Analytics cookies — Google Analytics, managed through Google Site Kit — and any other non-essential cookie are only set if you give your prior consent through the cookie notice displayed on your first visit. Until you accept, those cookies remain blocked.
You can withdraw or change your consent at any time from the same cookie notice, and block or delete cookies already stored from your browser settings or through the Google Analytics opt-out add-on available at tools.google.com/dlpage/gaoptout.
Inteliventa provides the service as a data processor and is liable under Article 82 GDPR for damage caused where it has not complied with the obligations of the Regulation specifically directed to processors, or where it has acted outside the Client’s lawful instructions.
It is for the Client, as controller, to determine and demonstrate the legal basis for the processing, to inform its Users in the terms of Articles 13 and 14 GDPR, to handle the exercise of their rights, and to assess the need for a data protection impact assessment under Article 35. Evaluations and content generated by artificial intelligence are indicative and may contain errors.
Nothing in this policy excludes or limits any liability that is mandatory under the GDPR, the FADP or any other applicable law.
Inteliventa may update this policy when changes occur in its providers, the technologies used or applicable regulations. Changes will be published on this page, indicating the date of the last update. Where the change is substantial, Clients will additionally be informed through the agreed contact channels.
For any questions about this policy or about data processing, write to us at [email protected].
This policy is interpreted and applied in accordance with Regulation (EU) 2016/679 and the Swiss Federal Act on Data Protection, depending on the User’s location, without prejudice to the rights granted to you by the mandatory law of your country of residence.
