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Palantrix helps organisations prepare their people for high value business conversations. This page explains how we handle personal data and how we approach our obligations under GDPR and the EU AI Act. What Palantrix is, and what it is not Palantrix is a preparation and practice tool. It does not make or automate decisions about people. It does not screen candidates, rank employees, or produce output intended to inform decisions about pay, promotion or continued employment. Feedback on a practice conversation is generated for the person who took part in it. Practice attempts are private to that person unless they choose to share one. Transparency Anyone interacting with Palantrix is told, before the interaction begins, that they are speaking with an AI system. This applies to practice conversations, Team Chemistry questions, and follow-up messages in Slack or Microsoft Teams. This meets the transparency obligations set out in Article 50 of the EU AI Act. Data about your team Team members answer a short set of questions that produce trait indicators, which combine into your organisation’s Team Chemistry signature. Before anyone starts, they are told what is collected, what it is used for and who can see the results. Team Chemistry describes the team as a whole and is used to calibrate feedback, not to assess individuals. Data about your customers Client Digital Twins are built from information your organisation already holds about people at your customer organisations, either through your CRM or entered directly. Those individuals are data subjects with rights under GDPR. Your organisation remains the controller of that data. Palantrix processes it on your instructions under our Data Processing Agreement.
Two things follow from this, and they matter:Client Digital Twins hold observations of business interactions, not inferred assessments of individuals. Our guidance throughout the product is to record what happened in a conversation rather than impressions of the person.We record the source and date of each field, so you can respond to access requests and know where information came from.
Human oversight Palantrix produces feedback, not decisions. Nothing the platform generates is intended to be acted on without a person reading it and forming their own view. Where feedback is shared with a manager, it is shared by the employee who chose to share it. Where your data is held Palantrix is hosted in Ireland on Amazon Web Services. Customer data is not used to train foundation models. Our current sub-processor list is available on request. Documentation The following are available on request: our Data Processing Agreement, records of processing activities, sub-processor list, and our assessment against the EU AI Act. Contact [dpo@palantrix.com] and we will send them on. Changes to this page We update this page as the platform and the regulatory position develop. Material changes are noted in the Changelog.