Privacy Policy

This policy explains what Learnly Ventures Inc, trading as Inyoke, does with personal information. Section 1 matters most: we handle two different kinds of data, under two different roles, and which one applies determines who you should contact about your rights.

1. Two roles, two kinds of data

We are a controller for information about our own customers and prospects — the agencies who buy Inyoke, the individuals who administer and use their accounts, and visitors to our website. We decide how that information is used, and this policy governs it.

We are a processorfor the data our customers load into or generate inside the platform — their leads, contacts, call recordings, transcripts and messages. We hold that on our customers’ behalf and act on their instructions. We do not decide what it is used for.

If you were called or texted by an agency using Inyoke and you want your information accessed, corrected or deleted, the agency is the right party to ask — they control that record, not us. If you contact us, we will refer you to them, or pass the request on where we can identify the account. Our processor commitments are in the Data Processing Addendum.

2. What we collect as a controller

• Account and contact information — name, business email, telephone number, employer, role, and the credentials used to sign in.
• Billing information — plan, seat count, and transaction records. Card details are handled by our payment provider; we do not store full card numbers.
• Professional information that you supply during onboarding, such as producer licence numbers and the states you are licensed in, which the platform uses to scope what a user may work.
• Usage and device data — pages and features used, timestamps, IP address, browser and device type, and diagnostic logs. We use this to operate, secure and improve the Services.
• Support communications — the content of messages you send us.

3. What we process on our customers’ behalf

On our customers’ instructions, the platform stores and processes: lead and contact records, including names, telephone numbers, addresses and information relevant to insurance products; call metadata and, where the customer enables it, call audio; transcripts and AI-generated summaries of that audio; SMS message content and delivery status; notes, dispositions, quotes and policy records; and the audit trail of dial and messaging attempts.

Depending on the customer, that data may include information a consumer would consider sensitive. We handle it as confidential, we do not use it for our own purposes, and we do not sell it. What is collected and why is determined by the customer.

4. How we use information

• To provide, maintain, secure and support the Services.
• To authenticate users, enforce access controls and prevent abuse and fraud.
• To bill, and to manage subscriptions and seats.
• To monitor reliability and diagnose faults, including telephony quality and delivery failures.
• To communicate with you about your account, service changes, security matters and support requests.
• To send marketing about our own products where permitted, always with an unsubscribe option.
• To comply with law and to respond to lawful requests, and to establish or defend claims.

Where the GDPR or UK GDPR applies to our controller processing, we rely on: performance of a contract; our legitimate interests in operating and securing the Services and in modest direct marketing to business contacts; consent where required; and compliance with legal obligations.

5. Cookies and analytics

Our website and application use cookies and similar technologies that are strictly necessary to sign you in and keep your session secure, together with limited performance measurement. Your theme preference is stored locally in your browser and is never sent to us. You can control cookies through your browser; blocking strictly necessary cookies will prevent sign-in from working. We do not use cross-site advertising cookies.

6. Sharing and sub-processors

We do not sell personal information, and we do not share it for cross-context behavioural advertising. We disclose it only to:

• Service providers and sub-processors who help us run the platform, bound by contract to confidentiality and to using the data only as instructed. These currently cover application hosting, database hosting, telephony and messaging carriers, AI inference for transcription-adjacent and reply-classification features, spreadsheet synchronisation where a customer enables it, insurance quoting, and subscription billing. How we engage them, and how to request the current list, is set out in the Data Processing Addendum.
• Our customers, where the information relates to their account or their data.
• Authorities, where we are legally required to disclose. We will tell the affected customer unless legally prohibited.
• An acquirer, in a merger, financing or sale of assets, subject to this policy continuing to apply.

7. Automated processing and AI features

The platform includes features that apply machine learning to customer content: transcription of recorded calls, summarisation of those transcripts, detection of answering machines during dialling, and classification of inbound SMS replies so they can be routed.

• We do not train shared or general-purpose models on Customer Data. Models are used to produce output for the customer whose data was submitted.
• Speech recognition for transcription runs on infrastructure we operate, rather than being sent to a third-party transcription service.
• Reply classification and assistant features call third-party model providers. Those providers act as sub-processors, are contractually restricted from training on the content, and are engaged under the DPA.
• These features assist people; they do not make decisions producing legal or similarly significant effects about a consumer without human involvement.

8. Call recording

Call recording is a customer-controlled feature. The customer decides whether it is enabled, what disclosures are given, and how long recordings are kept. We store recordings and their transcripts on the customer’s behalf and make them available within their account. Consent and notice obligations for recording rest with the customer, as set out in the Terms of Service.

9. Retention

We keep controller data for as long as your account is active and afterwards as needed for legitimate business purposes — resolving disputes, meeting legal, tax and audit obligations, and enforcing agreements. Customer Data is retained per the customer’s configuration and the DPA; on termination we make it available for export for 30 days and then delete it in the ordinary course, subject to backup cycles and legal holds.

10. Security

We use administrative, technical and organisational measures appropriate to the risk, including encryption in transit, encryption at rest for stored credentials and provider secrets, role-based access control enforced down to the field, tenant isolation between agencies enforced in the data layer, audit logging of privileged and compliance-relevant actions, and access on a least-privilege basis. No system is perfectly secure, and we cannot guarantee absolute security. Measures are described further in Annex II of the DPA.

11. International transfers

We are established in the United States and process data there. Where we receive personal data from the European Economic Area, the United Kingdom or Switzerland, transfers are made under the European Commission’s Standard Contractual Clauses together with any additional measures required, as set out in the DPA.

12. Your rights

Depending on where you live you may have the right to access, correct, delete or receive a portable copy of your personal information, to object to or restrict certain processing, to withdraw consent, and to appeal a refusal. Residents of California and other US states with comprehensive privacy laws additionally have the right not to be discriminated against for exercising these rights.

We do not sell personal information and do not share it for cross-context behavioural advertising, including that of anyone under 16.

To exercise rights over information we control, contact support@inyoke.com. We will verify your identity before acting and respond within the period the applicable law requires. If your request concerns data an agency holds about you in their CRM, see section 1 — the agency is the controller and the right party to ask. If you are in the EEA or UK you may also complain to your supervisory authority.

13. Children

The Services are for business use and are not directed to children. We do not knowingly collect personal information from anyone under 16 as a controller. If you believe a child’s information has reached us, contact us and we will delete it.

14. Changes

We may update this policy. Material changes will be notified by email or in the product before they take effect, and the date at the foot of this page will change. Continued use after the effective date constitutes acceptance.

15. Contact

Learnly Ventures Inc (DBA Inyoke)
251 Little Falls Drive
Wilmington, DE 19808
United States
support@inyoke.com