Privacy Policy
Last updated: February 2025
Thanks for using Valence and for checking out our Privacy Policy.
We understand the importance of protecting personal information. For this reason, we strive to have business procedures and safeguards in place to protect personal information under our control.
Application and Scope
This Privacy Policy (“Policy“) is intended to establish responsible and transparent practices for the management of personal information and satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities and obligations of Get Pegasus Inc. (here forth known as “Valence“, “we” or “our“) in respect of any personal information collected, accessed or processed by Valence in the course of its business operations.
This Policy also governs personal information collected about Users (“you” or “your“) during the use of the Valence website(s), Valence Tools Platform, and/or other related applications or services (collectively the “Service“). This Policy explains how we use and disclose personal information collected from people who use the Service.
Your organization, as the administrator of your access to Valence, determines the lawful basis for processing your personal information. In most cases, this is based on the organization’s legitimate interests or contractual obligations in providing you with access to the Service. As an end user, your account and associated data are provisioned and managed by your organization. If you have any questions about how your personal information is being handled or the lawful basis for processing, please contact your organization’s administrator.
What information do we collect and how is that information collected?
We collect information relating to you and your use of the Service from a variety of sources. Some of this information is collected directly from you and some of this information is collected from your interaction with the Service, or from third-parties.
In some cases, Valence acts as a data controller, and in other cases, as a data processor. This depends on the type of data collected and its purpose. For example:
As a controller: We manage contact and billing information to provide customer support and improve our services.
As a processor: We process user-provided data (e.g., survey responses, AI recommendations) solely on behalf of our customers in accordance with their instructions.
Information We Process as a Processor
Valence acts as a processor when handling information on behalf of your organization. This includes:
Account Registration Data: Your organization may provide information such as your name, email address, and other details to register an account for you on the platform. Valence processes this information to enable your access to the Service as instructed by your organization.
Support Data: When your organization submits support requests on your behalf, Valence processes the information provided (e.g., contact details, issue descriptions) to resolve those requests in line with your organization’s instructions.
Exercise Data: Valence collects and stores data related to exercises, and AI-powered coaching recommendations. This data is processed to provide the platform’s functionality. While your organization may have initiated the creation of these surveys or exercises, Valence determines how the data is processed within the platform (e.g., to generate recommendations or benchmarks).
AI Coach (Nadia) Data: Valence collects the contents of chats that users have with the AI Coach and use that to provide context to drive the ongoing conversation as well as to inform certain attributes used to customize the coaching. These attributes are transparently shown to you in the platform and may be edited by you at any time.
Information We Collect and Control as a Controller
Valence acts as a controller for data it collects to operate and improve the platform. This includes:
Survey Data: Valence collects and stores data related to surveys. This data is processed to provide, maintain, and improve the platform’s functionality. Valence uses this data to improve the program.
Contact Information for Direct Communication: If you contact us directly (e.g., via our website, sales inquiries, or customer support), Valence collects and uses your information for communication purposes and to improve our Service.
Information We Collect Automatically
We collect certain data automatically during use of the Service, regardless of role:
Cookies: As described previously, we use cookies to manage sessions, store preferences, and improve platform performance.
Log Data: Valence and its service providers may collect technical details like IP addresses, browser types, and interaction data to monitor platform performance and debug issues.
Third-Party Services: We use tools such as Google Analytics to understand usage patterns and enhance the Service.
Onward Transfer of Information
Valence remains responsible for the personal information it processes and transfers to third parties acting as its agents. Third parties are contractually obligated to handle information consistent with this Privacy Policy and applicable laws. Valence retains liability for unauthorized processing by its agents unless it can demonstrate it was not responsible for the violation.
How do we use the information we collect?
When providing our Service, we only process personal information in accordance with this Policy, our Terms of Use and applicable laws. Valence generally uses personal information from or about our Users for the following purposes:
- to create, establish, and administer a User’s account, to respond to a User’s inquiries related to its account, and to contact a User about the Service or account-related matters;
- to provide services, including to provide Users with access to use of the Valence Tools Platform and customer support;
- to measure and analyze Users behavior in order to, among others, monitor, maintain, and improve our Service or features and to create new services or features;
- to personalize or customize the experience when using the Service;
- to meet legal and regulatory requirements and to allow Valence to meet contractual requirements relating to the services provided to the User; and
- to provide Users with offers for additional Valence products and services that we offer, that we believe may be of interest to the User. As a User you will always have control over the type and frequency of the emails you receive, and you can opt out by following the instructions in the message. Your personal information will not be passed on to third-party services for their own direct marketing purposes.
Valence may also use information provided by Users to create de-identified data aggregated for benchmarking or to improve our Service.
Unless required or authorized by law, Valence will not use User's personal information for any other or new purpose without obtaining prior consent.
Artificial Intelligence
Our AI-enabled coaching tool uses artificial intelligence to provide coaching recommendations that are based on user-provided information. The tool analyzes information provided by users, and then proposes new topics to discuss and makes recommendations about next steps. The outputs from the service are based on information given explicitly from the user, as well as information inferred from the conversation, and past conversations, if applicable.
The information processed by our models includes name, seniority and other information provided by users, and we process data using AI to provide, maintain, develop, and improve our products and services and to fulfill our agreements. We do not use your data to train our model or any underlying models. We share the information with our service providers that support the service, but they do not use it to train their underlying models. Information shared with our service providers may be transferred internationally as described below.
Please note that the output of our AI-enabled services may not always be 100% accurate, and it must be reviewed for accuracy and appropriateness for your use case, including using human review where appropriate.
For more information about your rights and how to exercise those rights (including how to withdraw your consent or opt-out of automated decision-making where applicable), please review the “What are your rights to your personal information?” section of this Policy.
Data Processed on Behalf of Your Organization: If your account has been provisioned by your organization, Valence processes your data on behalf of your organization. Any requests to exercise rights such as opting out of processing or correcting inaccuracies in your data should be directed to your organization, which acts as the data controller. Please contact your organization’s administrator for assistance.
Data Controlled by Valence: For data that Valence collects and controls directly (e.g., marketing communications, support inquiries), you may exercise your rights by contacting us at privacy@valence.co. If you notice that the output of our services contains factually inaccurate information about you and would like us to correct it, you may submit a correction request via the same email. However, due to the technical complexity of our models, we may not be able to correct inaccuracies in all cases. You may also request that we remove your personal data from our outputs by contacting us.
Who has access to your chats and personal information?
Your information will never be sold. Ever.
To provide our Service, we work with third-party providers. In some instances, we process your information using these third-party services and tools to operate and improve our platform. We only share the minimal amount of information required to perform these services, as described in this Policy. Examples include hosting services, email providers, system monitoring tools, and analytics platforms. These providers are contractually obligated to handle your information securely and only for the purposes specified by Valence.
Disclosure to Third Parties
When Valence Acts as a Controller: If Valence determines the purpose and means of processing your personal information (e.g., sales, marketing, or support data), we will notify you before disclosing your information to third parties unless disclosure is required by law or essential to providing the Service. All third parties receiving such data must adhere to this Privacy Policy and applicable laws.
When Valence Acts as a Processor: If your organization uses Valence to provide services to you as a platform user, Valence processes your data on behalf of your organization. In these cases, your organization controls access to your data and any notifications regarding disclosures to third parties will be handled by your organization.
Valence does not provide an in-app method for your organization to access the contents of your chats. The chat data may be requested by or shared back to your organization in cases such as: imminent risk of harm to any person, illegal activities, valid legal orders like court subpoenas, or in support of internal investigations at your organization. In these cases, we comply with valid legal and contractual requests. For questions about how your data is shared, accessed or managed, please contact your organization’s administrator.
Legal or Necessary Disclosures
In certain situations, we may disclose your personal information, such as:
- To comply with legal obligations, including subpoenas, court orders, or requests from law enforcement or other government authorities.
- To enforce our terms of service or protect the rights, safety, or property of Valence, its staff, or others.
- To prevent fraud or illegal activity.
We may also share aggregated, de-identified data with third parties for research, benchmarking, or product improvement purposes. This data cannot be used to identify individuals.
How do we secure the information we collect?
No method of electronic transmission or storage is 100% secure, and we cannot ensure or warrant the absolute security of any information you transmit or store in the Service. But the security of your information is of paramount important to us. Valence uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information, once we receive it. We continuously and regularly back up your data to help prevent data loss and aid in data recovery. We strive to protect your data by encrypting it in transmission using industry standard protocols, and implementing access restrictions on our services to secure our network and servers. We protect your password by one-way encrypting it with salt so even we don’t know it.
In the event that personally identifiable information is compromised as a result of a breach of security, Valence will promptly notify those persons whose personally identifiable information has been compromised or as otherwise required by applicable law.
How long do you retain my information?
When Valence Acts as a Processor: For data processed on behalf of your organization (e.g., platform data such as surveys or exercises), we retain the information for the duration of our contract with your organization. Retention policies for this data, including deletion requests or access rights, are determined by your organization. If you have questions or would like to access or delete data related to your use of the platform, please contact your organization’s administrator.
When Valence Acts as a Controller: For data we collect and control directly (e.g., contact details for marketing, support, or other communications), we retain this information indefinitely unless:
- You request its deletion.
- Retention is no longer necessary to fulfill the purposes for which it was collected.
- Legal, regulatory, or contractual obligations require otherwise.
What are your rights to your personal information?
Rights Related to Processor Data: If your organization uses Valence to provide services to you, any requests to access, rectify, delete, or restrict processing of your information must be directed to your organization’s administrator. Valence processes this data under the direction of your organization and cannot fulfill these requests directly.
Rights Related to Controller Data: For personal data that Valence collects and controls directly, you may:
- Access or request rectification of your information.
- Request deletion of your data.
- Restrict or object to processing activities.
- Withdraw consent, where applicable (e.g., for marketing communications).
Depending on the specifics of your request, to exercise these rights, please contact either your administrator or us at privacy@valence.co.
We will address your request promptly and in accordance with applicable laws.
Complaints and Disputes
If you are dissatisfied with how Valence processes your personal information, you may:
Lodge a complaint with the data protection authority (DPA) in your jurisdiction.
In certain circumstances, invoke binding arbitration to resolve disputes.
For questions or concerns, contact us at:
Valence
privacy@valence.co
733 3rd Ave ℅ Eisner Amper
New York, NY 10017
European Privacy Rights
Privacy Rights for the EU, EEA, Switzerland, and the UK
If you are located in the European Union (EU), European Economic Area (EEA), Switzerland, or the United Kingdom (UK), this section provides details about how we process your personal data and your rights under the General Data Protection Regulation (GDPR) and equivalent laws.
Privacy Rights for the EU, EEA, Switzerland, and the UK
You have the following rights concerning your personal data, subject to certain limitations:
Transparency and Right to Information: This Privacy Policy explains how we collect, use, and share your personal information. For additional questions, you can contact us at privacy@valence.co.
Right of Access, Rectification, Erasure, Restriction, and Portability:
When Valence Acts as a Processor: If your organization uses Valence to provide services, Valence processes your personal data on behalf of your organization. To exercise your GDPR rights (e.g., access, rectification, or erasure), you must contact your organization, which is the data controller. Valence will assist your organization in responding to such requests.
When Valence Acts as a Controller: For data Valence collects and controls directly (e.g., marketing or support inquiries), you can request access, rectification, erasure, restriction, or portability by contacting us at privacy@valence.co.
Right to Object: You may object to the processing of your personal data for certain purposes, including direct marketing, at any time.
If Valence is acting as a processor, contact your organization to exercise this right.
If Valence is acting as a controller, email privacy@valence.co.
Right Not to Be Subject to Automated Decisions: Valence does not make automated decisions using your personal data that negatively impact you without your explicit consent or another lawful basis.
Right to Lodge a Complaint: If you believe your privacy rights under GDPR or equivalent laws have been infringed, you can lodge a complaint with a supervisory authority in the EU, EEA, Switzerland, or UK. Contact details for these authorities are available at https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.
Legal Basis for Processing
The legal basis for processing your personal data depends on the context:
When Valence Acts as a Processor: Your organization determines the lawful basis for processing (e.g., performance of a contract, legitimate interests) and provides this information to you. Valence processes your data strictly per the organization’s instructions.
When Valence Acts as a Controller:
Contractual Necessity: To fulfill agreements with you or your organization (e.g., providing the Service, responding to inquiries).
Legitimate Interests: For purposes such as improving our services, ensuring security, or engaging in direct marketing (where not overridden by your rights).
Consent: For specific activities like sending marketing communications or using certain cookies. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Legal Obligations: To comply with laws or protect vital interests.
If you have questions about the legal basis for processing your data, contact us at privacy@valence.co
International Transfer of Data
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Sites or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, including without limitation the United States of America, Canada, Ireland, and the United Kingdom, which may have different data protection rules than those of your country of residence or the country in which you were located when you initially provided the information in question.
Cookies
Additional information regarding your Personal Information:
Data transfer
We are committed to ensuring that all transfers of your personal information are and will be in compliance with the required international data transfer standards. Information we collect is transferred and stored in servers in the United States or Ireland. Valence engineers may access this data for support, product development, and quality assurance. Whenever we transfer your information, we take steps to protect it. We rely on Standard Contractual Clauses (SCCs) or other appropriate safeguards where applicable. Our full list of subprocessors for the platform can be found here.
Data Use and Employer Policies
Valence provides its Service to organizations, which act as the data controllers for all information processed through the platform. As a data processor, Valence processes information solely under the instructions of your organization.
Your organization determines how data, including chat interactions, is monitored, managed, and used. This may include policies on responding to specific scenarios such as self-harm or harm to others. Valence does not independently monitor, act upon, or notify individuals about these scenarios unless explicitly instructed by your organization.
For details on how your organization handles data and responds to such situations, please refer to your organization’s policies or contact your administrator.
Children’s Privacy
Protecting the privacy of young children is especially important. Our Service is not directed to persons under the age of 16. Valence does not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register with the Service. If we become aware that we have collected personal information from a child under the age of 16 without verification of parental consent, we take steps to remove that information. If you believe that we might have any information from or about a child under 16, please contact us at privacy@valence.co
Changes to this Privacy Policy
We may revise and update this Policy from time to time as required to keep current with rules and regulations, new technologies, standards and customer concerns. The most current version will always be posted on our website. If a revision, in our sole discretion, is material we will notify you (for example via email to the email address associated with your account). Other changes may be posted to our Privacy Policy page, so please check those pages regularly. By continuing to access or use the Service after revisions become effective, you agree to be bound by the revised Policy. If you do not agree to the new Policy, please stop using the Service.
Contact Us
If you have questions, concerns or complaints about how your information is handled or compliance with this Privacy Policy or relevant privacy laws, please contact us at privacy@valence.co
Valence
privacy@valence.co
733 3rd Ave ℅ Eisner Amper
New York NY 10017
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