u00a0Last updated: August 5th, 2026This Privacy Policy describes the policies and procedures of MIDGENIE AI LABS PRIVATE LIMITED (u201cCompanyu201d, u201cWeu201d, u201cUsu201d, u201cOuru201d) on the collection, use, storage, and disclosure of Your information when You use mple.ai (the u201cServiceu201d), and explains Your rights under the Digital Personal Data Protection Act, 2023 (u201cDPDP Actu201d) and other applicable law.By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. Where the DPDP Act or another applicable law requires Your explicit consent for a specific purpose, We will seek that consent separately before processing.Note on variable data collection: mple.ai is deployed differently across client organizations. Depending on how Your organization has configured the Service, some data categories described below (such as email address, phone number, or audio/video recordings) may not be collected for You at all. Where a data category does not apply to Your account, the corresponding provision in this Policy simply does not apply to You. Wherever this Policy refers to a data type or use u201cwhere applicable,u201d it means that data type is collected and used only if Your organizationu2019s configuration and Your role require it.1. Interpretation and Definitions1.1 InterpretationWords with the initial letter capitalized have meanings defined below. These definitions apply regardless of whether they appear in singular or plural.1.2 DefinitionsAccount: means a unique account created for You, or on Your behalf by Your organization, to access the Service or parts of the Service.Company: refers to MIDGENIE AI LABS PRIVATE LIMITED,u00a0The Gateway by Wadhwa, Hira Nagar, Mulund West, Mumbai, Maharashtra 400080, India.Consent Manager: has the meaning given under the DPDP Act, where applicable to the processing in question.Cookies: are small files placed on Your computer, mobile device, or other device by a website, containing details of Your browsing history among other uses.Country: refers to India.Data Fiduciary: means the entity that determines the purpose and means of processing Personal Data. For purposes of this Policy, the Company acts as Data Fiduciary. Where the Service is provided to You through Your employer or another organization, that organization may separately act as a Data Fiduciary or joint Data Fiduciary in respect of data it instructs Us to process.Data Principal: means the individual to whom the Personal Data relates (u201cYouu201d).Device: means any device that can access the Service, such as a computer, mobile phone, or tablet.Personal Data: means any data about an individual who is identifiable by or in relation to such data, as defined under the DPDP Act.Service: refers to mple.ai, accessible from https://mple.ai, owned and operated by MIDGENIE AI LABS PRIVATE LIMITED.Service Provider: means any natural or legal person who processes data on behalf of the Company.Usage Data: refers to data collected automatically, either generated by use of the Service or from the Service infrastructure itself.You: means the individual accessing or using the Service, or the organization on behalf of which such individual is accessing or using the Service, as applicable.2. Data We Collect2.1 Personal DataDepending on how Your organization has configured the Service and the features You use, We may collect some or all of the following:Email address (where applicable)First name and last namePhone number (where applicable)Organization-issued identifier (such as an employee ID or single sign-on identifier), where Your organization provisions access this way instead of by email or phoneAudio and video recordings, for users of practice, roleplay, or assessment features (where applicable)Where Your organization does not collect email address, phone number, or audio/video recordings for Your role, We will identify and authenticate You using the organization-issued identifier or other mechanism Your organization has configured, and the provisions of this Policy specific to email, phone, or recordings will not apply to You.2.2 Audio and Video Recordings (Where Applicable)For users of features that involve practice, roleplay, sales-training exercises, or assessment activities, and only where Your organization has enabled such features for Your account, We may collect:Audio recordings of Your voice and speechVideo recordings of Your practice sessions and roleplay interactionsScreenshots or session metadata related to Your training activitiesPurpose of collection:Deliver personalized AI coaching and feedbackEvaluate performance and skill developmentImprove the accuracy and relevance of the ServiceMaintain quality and conduct internal compliance reviewsModel Training Exclusion: Your audio and video recordings are never used to train, fine-tune, or improve the Companyu2019s AI models without Your explicit, separate consent. Recordings are used only for the purposes You agreed to when recording began.2.3 Usage DataUsage Data is collected automatically and may include Your Deviceu2019s IP address, browser type and version, pages visited, time and date of visit, time spent on pages, device identifiers, and other diagnostic data. When accessed via mobile device, We may also collect device type, unique device ID, IP address, operating system, browser type, and other diagnostic data.2.4 Tracking Technologies and CookiesWe use Cookies (browser and Flash) and web beacons to monitor activity and store information. Cookies may be session-based or persistent. You may refuse cookies through Your browser settings, though some parts of the Service may not function properly as a result. We use cookies for essential site functionality, remembering login preferences, and analytics/performance tracking.3. How We Use Your DataWe use Your Personal Data to:Provide and maintain the ServiceCreate and manage Your Account, including generating initial account credentials where Your organization provisions access on Your behalfFulfil contractual obligations to Your organizationContact You, where We hold Your email address or phone number, with service updates, training reminders, account notices, or support communicationsOffer information about services similar to ones previously used or inquired about, unless You opt outManage customer support requestsConduct business transactions such as mergers, acquisitions, or asset transfers, subject to confidentiality obligationsPerform data analysis to improve the ServiceWhere We do not hold an email address or phone number for You, We will not contact You directly by those channels; communications will instead be routed through Your organizationu2019s administrator, where applicable.4. Account Credentials4.1 CreationDepending on Your organizationu2019s setup, Your Account and initial login credentials may be created by You directly, or generated by the Company and provisioned to You through Your organizationu2019s designated administrator.4.2 Sharing of CredentialsWhere credentials are generated on Your behalf, they are shared only with Your organizationu2019s designated administrator for the limited purpose of account setup and provisioning, and are transmitted through secure channels. We do not share Your credentials with any other third party.4.3 Your Ability to Change CredentialsYou may change Your password and update Your account credentials at any time through Your Account settings. Where Your organization manages authentication centrally (for example, through single sign-on), credential changes may instead be governed by Your organizationu2019s own identity management policies.5. Consent for Audio and Video Recordings5.1 Consent for Audio and Video Recordings (Where Applicable)Where the Service involves audio or video recording, We will obtain Your explicit, informed consent before collection begins. At the point of recording, You will:Receive clear notification that recording is about to beginBe informed of what will be recorded (audio, video, or both) and whyHave the opportunity to decline recording without penalty to Your access to the non-recording features of the ServiceBe provided with information about storage duration and access scope (see Section 6)You may withdraw consent to future recordings at any time through Your Account settings. Recordings already collected under prior consent will continue to be handled per the retention and access policies in this Policy.6. Retention of Your Personal DataWe retain Personal Data only as long as needed for the purposes outlined in this Policy and to comply with legal obligations.Usage Data is generally retained for a shorter period, unless required for security, improvement purposes, or a longer period is legally mandated.6.1 Audio and Video Recordings (Where Applicable)Duration of active training: throughout Your engagement with a training module or roleplay scenario, for AI coaching and feedback purposes.Performance history: up to 12 months after training completion, for progress review and skill assessment archival.Legal compliance: longer periods only where required by applicable law or regulation.You may request deletion of Your recordings at any time by contacting the Grievance Officer (Section 9). Deletion requests will be completed within 30 days, unless a legal hold applies.6.2 Storage Location and SecurityPersonal Data, including audio and video recordings where applicable, is stored on secure cloud servers in India, with encryption in transit and at rest. Access is restricted to authorized personnel and is logged for audit purposes.6.3 Access ScopeYou can access Your own recordings and performance data, where applicable, via Your Account.Your assigned manager or team lead, where Your organization has granted them visibility, can view performance summaries and insights, but not raw recordings by default.Company engineering and support staff may access recordings only for troubleshooting, quality assurance, or legal compliance, subject to access controls and audit logging.Recordings are never shared with third-party AI model providers, data brokers, or partners, except where legally required.7. Your Rights as a Data PrincipalConsistent with the DPDP Act, You have the following rights:Right to be informed and give consent: Before We collect any Personal Data, We will clearly explain what We need, why, and how it will be used, and We will only collect it with Your explicit consent where required. For audio/video recordings, You will receive explicit notice and the opportunity to decline before recording begins.Right to access Your data: You may request access to the Personal Data We hold about You, including Your recordings where applicable, to review and verify its accuracy and completeness.Right to correction and erasure: If You find errors or missing information in Your data, You may request correction. You may also request erasure of Personal Data that is no longer necessary for the purpose it was collected, subject to our legal retention obligations.Right to grievance redressal: You may raise a grievance regarding the processing of Your Personal Data with Our Grievance Officer (Section 9), who will respond within the timelines prescribed under the DPDP Act.Right to nominate: You may nominate another individual to exercise Your rights under the DPDP Act in the event of Your death or incapacity, by writing to the Grievance Officer.Right to withdraw consent: You may withdraw consent for Us to process Your Personal Data at any time. On withdrawal, We will stop processing Your data for the purpose originally agreed upon, unless continued processing is required by law. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.To exercise any of these rights, contact Our Grievance Officer using the details in Section 9.u00a08. Grievance OfficerIn accordance with the DPDP Act, We have appointed a Grievance Officer to address Your concerns regarding Personal Data processing.Name: Riddhesh Hitesh GanatraEmail: dpo@mple.aiWe will acknowledge and respond to grievances within the timelines prescribed under the DPDP Act and its rules.9. Children’s PrivacyThe Service is not intended for individuals under the age of 18, in line with the DPDP Actu2019s treatment of children. We do not knowingly collect Personal Data from children. If You are a parent or guardian and believe Your child has provided Us with Personal Data, please contact the Grievance Officer immediately, and We will take steps to delete such data.10. Links to Other WebsitesThe Service may contain links to external sites not operated by Us. We are not responsible for the content or privacy practices of any linked site, and this Policy does not extend to them.11. Changes to This Privacy PolicyWe may update this Privacy Policy from time to time. We will notify You of material changes by email (where We hold one for You), through the Service, or through Your organizationu2019s administrator, and will update the u201cLast updatedu201d date above. You are encouraged to review this Policy periodically.12. Contact UsFor any questions about this Privacy Policy, contact:MIDGENIE AI LABS PRIVATE LIMITEDThe Gateway by Wadhwa, Hira Nagar, Mulund West, Mumbai, Maharashtra 400080, IndiaMumbai, Maharashtra 400081, IndiaEmail: dpo@mple.ai