Privacy Policy

Effective Date: 20-06-2025
Last Updated: 25-09-2025

1. Introduction

Welcome to AmberWillo (“we,” “our,” or “us”). We provide a SaaS platform for public speaking exposure and the Confidently mobile application (collectively, the “Services”). We are operated by PageOne AI B.V., a company registered in the Netherlands. This Privacy Policy explains how we collect, use, and safeguard your personal information when you visit our website at amberwillo.com or use the Confidently mobile app. Please read this privacy policy carefully. By using our services, you agree to the collection and use of information in accordance with this policy.

Our Contact Information:

- Company: PageOne AI B.V.
- Address: Dennenlaan 4, 9471PH Zuidlaren, Netherlands
- Email: [email protected]

2. Information We Collect

Personal Information You Provide

When you register for an account or use our services, we may collect:

Account Information: Name, email address, password
Profile Information: Professional bio, speaking topics, experience level, areas of expertise
Communication Data: Messages you send us through support, feedback forms, or other communications
Payment Information: Billing details and payment method information (processed securely through third-party payment processors)

Information We Collect Automatically

When you visit our website or use our services, we automatically collect:

Technical Information: IP address, browser type and version, operating system, device type
Usage Information: Pages visited, time spent on pages, click-through rates, features used
Log Data: Server logs including access times, pages viewed, and other diagnostic data
Cookies and Tracking Data: Information collected through cookies and similar technologies (see our Cookie Policy below)

Information from Third Parties

We may receive information about you from:

Social media platforms if you connect your account
Third-party authentication services
Public databases and professional networks (for speaker verification purposes)

3. AmberWillo – How We Use Your Information

We use your personal information for the following purposes:

Service Provision

Create and manage your user account
Provide access to our public speaking platform
Match speakers with speaking opportunities
Facilitate communication between speakers and event organizers
Process payments and manage billing

Communication

Send you service-related notifications and updates
Respond to your inquiries and provide customer support
Send marketing communications (with your consent)
Notify you about new features, opportunities, or changes to our services

Platform Improvement

Analyze usage patterns to improve our services
Conduct research and development
Troubleshoot technical issues
Ensure security and prevent fraud

Legal Compliance

Comply with applicable laws and regulations
Protect our rights and interests
Respond to legal requests

4. Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data based on:

Contract Performance: To provide our services and fulfill our obligations to you
Legitimate Interests: To improve our services, ensure security, and conduct business operations
Consent: For marketing communications and certain cookies (where required)
Legal Obligation: To comply with applicable laws and regulations

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

With Your Consent

Public profile information visible to other platform users (as configured in your privacy settings)
Speaker information shared with event organizers when you apply for speaking opportunities

Service Providers

We share information with trusted third-party service providers who assist us in:

Web hosting and cloud storage
Payment processing
Email delivery and marketing automation
Analytics and performance monitoring
Customer support tools

Legal Requirements

We may disclose your information when required to:

Comply with applicable laws, regulations, or legal processes
Protect the rights, property, or safety of AmberWillo, our users, or others
Prevent fraud or security threats

Business Transfers

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

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of data in transit and at rest
Regular security assessments and updates
Access controls and employee training
Secure development practices

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as necessary to:

Provide our services to you
Comply with legal obligations
Resolve disputes and enforce agreements
Fulfill the purposes outlined in this privacy policy

When you delete your account, we will delete or anonymize your personal information within 30 days, except where we are required to retain it for legal purposes.

8. International Data Transfers

As we serve users globally, your personal information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for international transfers, including:

Standard Contractual Clauses approved by the European Commission
Adequacy decisions by relevant authorities
Other lawful transfer mechanisms as required by applicable law

9. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

Access and Portability

Request access to your personal information
Request a copy of your data in a structured, machine-readable format

Correction and Deletion

Correct inaccurate or incomplete information
Request deletion of your personal information (subject to certain exceptions)

Restriction and Objection

Restrict the processing of your information in certain circumstances
Object to processing based on legitimate interests
Opt-out of marketing communications at any time

Consent Withdrawal

Withdraw consent for processing based on consent (without affecting past processing)

To exercise these rights, please contact us at [email protected]. We will respond to your request within 30 days (or as required by applicable law).

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our platform. Cookies are small data files stored on your device.

Types of Cookies We Use

Essential Cookies: Necessary for the website to function properly
Performance Cookies: Help us understand how visitors interact with our website
Functionality Cookies: Enable enhanced features and personalization
Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness

Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our services.

11. Children’s Privacy

AmberWillo is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information.

12. Confidently App – Face Data and Personal Information

Face Data Collection: The Confidently app uses the device’s camera and TrueDepth sensors (via ARKit) to analyze facial movements and expressions in real-time.
Use of Face Data: This data is used to provide real-time coaching feedback and calculate performance metrics (e.g., confidence and positivity).
Storage and Sharing: Video recordings are stored locally on your device to allow you to review your practice sessions. We do not store raw face data or video files on Amberwillo servers, nor do we share them with third parties.
Retention and Deletion: The app retains up to 20 of your most recent practice recordings locally on your device. You can manually delete any recording at any time within the app. Once the 20-recording limit is reached, the oldest recording is automatically deleted to make room for new sessions.
User Choice: Users may optionally provide Gender and Date of Birth. This information is used exclusively to tailor the AI coaching experience (such as adjusting speech-pace targets for different age groups) and is not shared with third parties.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

Posting the updated policy on our website
Sending an email notification to registered users
Providing notice through our platform

Your continued use of our services after the effective date of the updated Privacy Policy constitutes acceptance of the changes.

14. Third-Party Links and Services

Our platform may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you access through our platform.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Email: [email protected]
Address: PageOne AI B.V., Dennenlaan 4, 9471PH Zuidlaren, Netherlands

For GDPR-related inquiries, you also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

This Privacy Policy is designed to be transparent about our data practices while ensuring compliance with applicable privacy laws, including GDPR. We are committed to protecting your privacy and handling your personal information responsibly.