Nytro.ai Privacy Policy

Last updated March 6, 2025

ABOUT NYTRO.AI

Nytro.ai is an AI-powered software application designed to help sales and customer teams practice conversations and receive coaching based on real-world sales scenarios. Our application leverages artificial intelligence to simulate realistic sales interactions, provide instant feedback, and enhance team performance through personalized coaching and insights. Nytro.ai is owned and operated by Nytro.ai Inc., a MarketStar company located in the United States in Ogden, Utah.
We respect your privacy and take safeguarding personal data seriously. Please read the following to understand the privacy practices of Nytro.ai. This Privacy Policy applies to all Personal Data processed by Nytro.ai Inc. (“Nytro”, “we”, “us”, and “our”).

WHAT IS PERSONAL DATA

“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Under specific laws, Personal Data may include any information relating to a household.

PERSONAL DATA WE PROCESS

We operate as both a Data Controller, where we determine the means of data processing for our own business needs, and a Data Processor, where we process data on behalf of our business customers.

The categories of data subjects for whom we process Personal Data are:


As Data Controller:
  • Customer Representatives
  • Representatives of Prospective Customers
  • Web Users


As Data Processor:
  • Customer Representatives
  • End Users
  • Customer Content


The categories of Personal Data we process are:


As Data Controller:
  1. Business contact information e.g., first name, last name, title, email address, phone number
  2. Business administration information e.g., company data, contract signatory
  3. Other data related to the specific Customer relationship.

As Data Processor:
  1. Business contact information e.g., first name, last name, email address
  2. Audio recordings e.g., audio and accompanying text out from practice exercises
  3. Video recordings (optional) e.g., uploaded or recorded videos from practice exercises
  4. Usage analysis e.g., metrics, evaluations, reports
  5. Personal Data input as Customer Content e.g., name, company

Please note End Users determine whether the data of real individuals or pseudo data is input as Customer Content for use in practice exercises.

The examples of Personal Data processed include: name, email address, voice recordings and video recordings.

The main source of Personal Data is the data collected directly from our Customers including data of their End Users and Customer Content. Where Nytro prospects for new Customers, it uses direct marketing, social media, lead generation platforms, and open-source means to identify contact information about Representatives of Prospective Customers.

The legal basis for processing Personal Data is: (1) necessity to perform contracts; (2) legitimate interest as a provider of Nytro.ai; or (3) regulatory requirements. In addition Nytro relies upon consent as the legal basis for processing Personal Data for login access, use of cookies, and related targeted advertising.

Personal Data we do NOT actively collect or process: We do not actively collect or otherwise process the Personal Data of minors, data related to criminal convictions and offenses, or special categories of data i.e. revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, or genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Please note our employees are provided a separate privacy notice.

We do not separately sell Personal Data. We do not process, sell or share the data of minors.

Technical data: We process technical information and navigational information when you visit our website, which is found at https://www.nytro.ai/. Technical information includes IP address, geographical location, device ID and related information and browser type. Navigational information includes pages viewed, selection made and length of visit. Our primary goal in processing this information from you is to provide access to features on the site and help us improve our website and market Nytro.ai.

Cookies and Similar Tracking Technologies

We (and the third-party service providers working on our behalf) use various technologies to collect Personal Data. This may include saving cookies to your device. For information on what cookies are, which ones we use, why we use them, and how you can manage their use, see our Cookie Policy.

PURPOSES FOR PROCESSING PERSONAL DATA

Nytro processes Personal Data to (1) operate its website and (2) operate the Nytro.ai application; and (3) operate its business.

  1. Nytro.ai Website
    Nytro processes Personal Data as a Data Controller in operating its website. This includes capturing inquiries, serving up content, identifying browsers, ensuring optimal user experience, and analyzing website traffic.
  2. Nytro.ai Application
    Nytro processes the following data for Nytro.ai as a Data Processor.
    • Access Nytro.ai. This requires collection of basic Personal Data including a user’s name, email and an optional profile picture. The Personal Data is collected via our SSO integration. Nytro.ai’s functionality and analysis are user-based, and the login information is required to enable data access limitations relevant to a specific user.
    • Data used for Creation of Practice Exercises. Nytro.ai is designed to provide a personalized, context-driven sales practice and coaching experience. Customers input their own data for use in practice exercises. This flexibility allows customization so that practice exercises align with business needs. This data is separated and limited for use by the Customer who input the data.
    • Data Generated from Practice Exercises. Nytro.ai generates audio and text files from the practice exercises. Customers have an option to upload video recordings. The audio and text files are analyzed to provide insights on the user’s performance. Evaluation data is generated that includes performance metrics and evaluation reports. These evaluation reports are used by managers to assess users in their progress and provide effective coaching.
    • Interaction with AI-models. AI-models are engaged to process data specific to each Customer to preserve the integrity of the results and restrict data use. We do not use Customer data for training our AI models. We use Customer data, including company information exclusively to contextual input via advanced prompt engineering techniques. This approach enables near real-time, context-specific experience while using the Nytro product, and the data is not repurposed for training Nytro.ai or Provider AI-models. The data remains isolated within each customer account and is not repurposed for AI training, advertising, or any other external applications.
  3. Business Operations
    Nytro processes Personal Data as a Data Controller in order to operate its business. This includes interacting with Customers, administering contracts, seeking new market opportunities, and meeting our legal obligations. We may use your Personal Data to comply with applicable laws, exercise legal rights, and meet tax and other regulatory requirements. We may also use your Personal Data for internal purposes, including auditing, data analysis, system troubleshooting, and research. In these cases, we base our processing on legitimate interests in performing the activities of the organization.

Where we directly collect Personal Data and you choose not to provide it, we may not be able to respond to your enquiries.

SHARING OF PERSONAL DATA

We do not sell your Personal Data! Data sharing is limited to the following categories of recipients:

  1. Customer Representatives and End Users. The main purpose of data sharing is for the Customer to manage access to the application and analyze the results of the AI-leveraged training and coaching.
  2. Third-Party Providers. We share Personal Data with third-party providers for their processing in performing functions on our behalf including Provider AI-models, hosting services and security monitoring. Third-party providers are technically and contractually restricted from further use of the data. Data transfers comply with this Privacy Policy and applicable laws.
  3. Social Media Links. Nytro’s website connects to social media platforms, including LinkedIn, X and Meta. For information on the privacy practices of these social media platforms, we encourage you to read their privacy policy before clicking on any link from Nytro’s website.
  4. Affiliates. Nytro operates as part of the MarketStar group of entities and may share your Personal Data with Nytro affiliates where resources are assigned to work on Nytro.ai.
  5. Subcontractors. Nytro may engage subcontractors to perform specific services for certain specialty work.
  6. Regulatory Bodies, Public Authorities and Law Enforcement. We may access and disclose your Personal Data to regulatory bodies if we have a good-faith belief that doing so is required under regulation. This may include submitting Personal Data required by tax authorities. We may disclose your Personal Data in response to lawful requests by public authorities or law enforcement, including to meet national security or law enforcement requirements.
  7. Other Disclosures. We may also disclose your Personal Data to exercise or defend legal rights; to take precautions against liability; to protect the rights, property, or safety of the resource, of any individual, or of the general public; to maintain and protect the security and integrity of our services or infrastructure; to protect ourselves and our services from fraudulent, abusive, or unlawful uses; or to investigate and defend ourselves against third-party claims or allegations. Disclosures may be made to courts of law, attorneys and law enforcement or other relevant third parties to meet these purposes.

In cases of onward transfer of Personal Data to third parties of data of EU individuals received, Nytro remains liable.

STORAGE OF PERSONAL DATA

Personal Data is stored on servers located in the United States of America. In the event that Personal Data is transferred outside of the United States of America, we will ensure that adequate protections are implemented to comply with the GDPR, such as Standard Contractual Clauses.

DATA SECURITY

Nytro uses technical and organizational measures to protect the Personal Data that we store, transmit, or otherwise process, against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. Nytro adheres to best business practices related to security, including the following:

  • We implement unique authentication for production databases and accounts, limit access to authorized personnel, and have established access control procedures.
  • Our systems use encrypted data storage and transmission, intrusion detection systems, and network segmentation to prevent unauthorized access.
  • We uphold organizational security through comprehensive data management policies, background checks, confidentiality agreements, and regular security training.
  • Furthermore, we conduct vulnerability assessments and penetration testing and have incident response and disaster recovery plans in place, aligning with industry best practices to ensure high standards of security and data protection.

We regularly consider appropriate new security technologies and methods as we maintain and develop our software and systems. We ensure that all employees and contractors complete mandatory annual privacy and security training.

RETENTION OF PERSONAL DATA

Nytro maintains an internal data retention policy and schedule that determines how long data is stored. Nytro Customers can determine End User access to Nytro.ai. These End Users are required to submit their name and email to establish login credentials. Nytro.ai captures Personal Data in the form of audio to analyze quality of work and provide information that accelerates onboarding and skill-building. Personal Data is retained as follows:

  • End user login data is controlled by the Customer who determined end user access. Customers can delete the access at any time. Otherwise, this data is deleted by Nytro within 30 days of termination of services.
  • Audio and video data is stored for the duration of the contract and deleted within 30 days of termination of services.
  • Customer Content input into the application and analysis reports are stored for the duration of the contract and deleted within 30 days of termination of services.

Where Nytro collects Personal Data for its own purposes, it retains the Personal Data for a reasonable time period, which varies depending on the purpose. For example, data collected on Representatives of Prospective Customers is retained for a maximum of 3 years while data incorporated into executed contracts is stored for 10 years following the termination of the contract.
Where regulations require data retention, Nytro will store those records per the applicable regulation. We regularly audit our databases and archive information to ensure that Personal Data is only stored and archived in alignment with our retention policy.

PERSONAL DATA RIGHTS

Nytro invites anyone with questions about individual privacy rights, our Privacy Policy or privacy practices to contact us. For marketing emails, an unsubscribe option is provided at the end of each email communication. You may also request that we limit the use and disclosure of your personal data using the contact methods provided below.

Depending on where you reside, there may be certain rights that you can exercise regarding your Personal Data. We have listed key privacy rights below:

Residents of the European Economic Area (“EEA”)

  • Access: The right to obtain confirmation as to whether or not your Personal Data is being processed, and to obtain access to specific information about the processing.
  • Rectification: The right to obtain rectification of inaccurate Personal Data and the right to have incomplete Personal Data completed.
  • Erasure: The right to obtain erasure of Personal Data, subject to certain GDPR requirements.
  • Restriction of Processing: The right to obtain restriction of processing of Personal Data where (a) accuracy is contested and being verified, (b) processing is unlawful, (c) data is not needed but for processing but is required for legal claims, or (d) following an objection to processing where legitimate grounds for processing are being verified.
  • Data Portability: The right to receive Personal Data and transmit to another controller
  • Object: The right to object to direct marketing; the right to object on grounds of particular situation
  • Automated individual decision-making, including profiling: The right not to be subject to a decision based solely on automated decision-making, including profiling; a right to appeal.

Individuals also have the right to lodge a complaint about the processing of their Personal Data with their local data protection authority or with the Irish Data Protection Commission at:
Online Form:
Email: dpo@dataprotection.ie
Postal (EU):
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2, D02 RD28, Ireland

Residents of California

  • Right to know what personal information is being collected
  • Right of access
  • Right to know what personal information is sold or shared and to whom
  • Right to opt out of sale or sharing of personal information
  • Right to delete personal information
  • Right to correct inaccurate personal information
  • Right to limit use and disclosure of sensitive personal information
  • Right of no retaliation following opt out or exercise of other rights

AMENDMENTS

We may modify this Privacy Policy from time to time, with the current version indicated by the effective date at the top of this document. The current version of the Privacy Policy will govern our use of your Personal Data and will always be published at https://www.nytro.ai.

CONTACT INFORMATION

Inquiries may be made through any of the following means:
Email: privacy@nytro.ai
Address:
Nytro.ai
2475 Washington Blvd,
Ogden, UT 84401, USA