Privacy Policy

This Privacy Policy explains how Narraid collects, uses, shares and protects personal data when you create an account or use the Narraid mobile application and related services (“Narraid” or the “Service”).

We believe that workplace learning should be useful without requiring unnecessary collection of personal information. Narraid therefore aims to collect only the information required to operate the Service, provide relevant learning content, measure learning engagement and maintain a secure platform.

1. Who We Are

Narraid is operated by:

Room for Design Schiphol B.V., trading as Narraid
Registered in the Netherlands
Chamber of Commerce number: 64749746

For the personal data for which Narraid determines the purposes and means of processing, Room for Design Schiphol B.V. is the data controller.

Privacy enquiries can be sent to:

our contact form at narraid.com/contact

2. Narraid and Your Employer

If you use Narraid in connection with your employer, retailer or another organisation (“your Organisation”), your account may be linked to that Organisation.

It is important that you understand the resulting privacy relationship.

Narraid as controller

Narraid generally acts as the data controller for information required to:

• create and administer your Narraid account;

• operate and secure the Narraid platform;

• provide the app and its functionality;

• communicate with you about the Service; and

• understand and improve the operation of Narraid.

Your Organisation and learning information

Where your Organisation assigns or provides learning through Narraid and accesses your individual learning records, your Organisation may itself be a data controller for its use of that information.

Depending on the contractual arrangement with your Organisation, Narraid may process some learning information on your Organisation’s behalf.

Your Organisation is responsible for ensuring that its own use of employee learning information complies with applicable employment and data-protection laws.

Questions about how your employer uses your Narraid learning information should therefore also be directed to your employer.

3. Personal Data We Collect

Depending on how you use Narraid, we may process the following categories of information.

A. Account information

When you create an account, we collect information such as:

• your name;

• your email address;

• account authentication information;

• your preferred language;

• your employer or associated organisation; and

• your associated store location, where applicable.

Narraid does not currently collect your job role or job function as part of your standard user profile.

Narraid does not use social-login services to create your account.

B. Learning and activity information

When you use Narraid, we collect information necessary to provide and measure the learning experience, including:

• episodes and playlists you access;

• episodes you start;

• listening progress;

• episode completion;

• quiz participation;

• quiz answers or results where applicable;

• completion status;

• timestamps associated with learning activity; and

• related engagement information within the app.

This information may be linked to your Narraid account.

C. App and technical information

When you use the Service, certain technical information may be processed automatically to operate, troubleshoot and secure the app.

This may include:

• device type;

• operating system;

• app version;

• IP address;

• login and access timestamps;

• technical logs;

• error or diagnostic information; and

• other information required to maintain the operation and security of the Service.

We do not collect your device’s precise GPS location as part of the standard Narraid learning experience.

A store location associated with your account is organisational information and is not obtained by continuously tracking the physical location of your device.

D. Notification information

If you enable push notifications, we may process:

• your notification preferences; and

• a device or push-notification token required to deliver the notification.

Your operating-system provider may also process information necessary to deliver notifications.

You can disable push notifications through your device settings.

E. Communications with Narraid

If you contact us, we may process your:

• name;

• email address;

• message;

• support request; and

• related correspondence.

We use this information to respond to you and provide support.

4. Information We Do Not Intentionally Collect

Narraid is not designed to collect sensitive personal information about users.

We do not ask users to provide information concerning matters such as health, religion, political opinions, ethnicity, sexual orientation or other special categories of personal data as part of the standard Narraid account or learning experience.

Please do not provide such information unless it is genuinely necessary and specifically requested for a lawful purpose.

Narraid also does not currently use app-user information for behavioural advertising.

5. Why We Use Personal Data

We use personal data for the following purposes.

Providing your Narraid account and Service

We process account, profile and usage information to:

• register and authenticate you;

• maintain your account;

• deliver relevant content;

• remember learning progress;

• provide quizzes and learning features;

• provide offline and resume functionality;

• operate your personal learning library; and

• otherwise deliver the Narraid Service.

For users in the European Economic Area (“EEA”), this processing is generally necessary to provide the Service you have requested and/or is based on our legitimate interest in operating the Narraid platform.

Connecting you with your Organisation

We process your organisational association and learning activity so that the appropriate content can be made available and, where applicable, so your employer or Organisation can understand participation and learning progress.

Depending on the circumstances, this processing may be:

• necessary to provide the Narraid Service;

• based on Narraid’s or your Organisation’s legitimate interests in providing and administering workplace learning; or

• carried out by Narraid on behalf of your Organisation under a data-processing arrangement.

Operating and improving Narraid

We may analyse usage patterns to understand how the Service is performing, identify technical issues and improve the user experience.

Where possible, we use aggregated information for this purpose.

For EEA users, this processing is generally based on our legitimate interest in developing and improving the Service.

Security and abuse prevention

We process account and technical information where necessary to:

• protect accounts;

• detect unauthorised access;

• maintain platform security;

• investigate abuse; and

• protect Narraid, our partners and users.

This is based on our legitimate interests in protecting the security and integrity of the Service and, where applicable, compliance with legal obligations.

Service communications

We use your email address for communications relating to your account or the operation of Narraid, including:

• account verification;

• password or authentication communications;

• security information;

• important service announcements; and

• responses to support requests.

We do not currently use app-user email addresses for third-party advertising or general marketing newsletters.

Learning-content notifications

Where enabled, we may use in-app or push notifications to tell you about relevant learning content, such as new episodes or content updates.

You can control push notifications through your device settings.

Legal obligations

We may process or retain information where necessary to comply with applicable law, regulatory obligations, lawful requests or to establish, exercise or defend legal claims.

6. What Your Employer Can See

If your Narraid account is associated with an employer or other participating Organisation, that Organisation may have access through its Narraid dashboard or associated services to information about your individual learning activity.

Depending on the features being used, this may include:

• your name;

• your store location;

• episodes assigned or made available to you;

• episodes started;

• episodes completed;

• listening progress;

• quiz participation;

• quiz scores or results; and

• other individual learning-engagement information.

Your use of Narraid is therefore not anonymous to your employer where your employer has individual dashboard access.

Narraid recommends that participating organisations clearly inform their staff about how learning activity will be used within their organisation.

Narraid does not determine employment consequences based on your learning information.

7. What Brand Partners Can See

Brands may fund, provide or commission learning content made available through Narraid.

Brand partners may receive information concerning how their content is being used.

However, Narraid provides brand partners with aggregated or anonymised statistics rather than identifiable individual employee information.

For example, a brand may receive information about:

• numbers of listeners;

• episode completion rates;

• aggregated quiz results;

• engagement by retailer, market or other group; and

• overall content performance.

Narraid does not provide brand partners with an identifiable individual user’s listening history or quiz results as part of the standard Narraid service.

Where information has been genuinely anonymised so that an individual can no longer reasonably be identified, it is no longer personal data under applicable data-protection law.

8. Technology Service Providers

Narraid uses specialist technology providers to operate the Service.

These currently include:

Microsoft Azure

Narraid uses Microsoft Azure infrastructure and related cloud services to support the operation, hosting and delivery of the Narraid platform.

Supabase

Narraid uses Supabase for technical infrastructure that may include database, authentication, storage and related backend functionality.

These providers may process personal data on Narraid’s behalf where required to provide their services.

We require service providers handling personal data on our behalf to use appropriate safeguards and to process information only for authorised purposes.

We may replace or add technical providers as the Narraid Service develops. Material changes affecting the handling of personal data will be reflected in this Privacy Policy where appropriate.

9. Artificial Intelligence Providers

Narraid uses various artificial-intelligence technologies as part of its content-production processes.

For example, AI models may assist with the creation, localisation or production of learning content.

User personal data and individual user learning information are not provided to these AI content-generation providers as part of Narraid’s content-production process.

The AI systems used to produce learning content therefore operate separately from individual users’ Narraid learning records.

10. Apple and Google

If you download or use Narraid through Apple’s App Store or Google Play, Apple or Google may independently process information relating to your use of their platforms, your device and the download or operation of the app.

Their processing is governed by their own privacy terms.

Apple or Google services may also be involved in technical functionality such as delivering push notifications to your device.

11. Other Circumstances in Which We May Share Information

In addition to the circumstances described above, we may disclose personal data where reasonably necessary:

• to professional advisers such as lawyers, accountants or auditors;

• to technology providers acting on our behalf;

• to comply with a law, court order or legally binding request;

• to protect the security, rights or property of Narraid or others;

• in connection with a corporate restructuring, investment, merger, acquisition or sale, subject to appropriate safeguards; or

• where you have specifically requested or authorised disclosure.

We do not sell Narraid user personal data.

12. International Data Transfers

Narraid is based in the Netherlands and is subject to European data-protection law.

Some technology providers or their sub-processors may operate infrastructure or provide support from countries outside the Netherlands or the EEA.

Where personal data is transferred outside the EEA, we take appropriate steps required by applicable law. Depending on the destination and provider, these may include:

• an adequacy decision of the European Commission;

• approved Standard Contractual Clauses;

• contractual and technical safeguards; or

• another legally recognised transfer mechanism.

You may contact us if you would like further information about safeguards applicable to a particular transfer.

13. How Long We Keep Personal Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected.

The relevant retention period depends on factors including:

• whether your Narraid account remains active;

• whether you remain associated with a participating employer or Organisation;

• the purpose for which the information is used;

• our contractual obligations to participating organisations;

• security and fraud-prevention requirements;

• applicable limitation periods;

• legal and regulatory requirements; and

• whether information has been anonymised.

When an account is deleted, personal data associated with the account will be deleted or anonymised unless continued retention is required or permitted by applicable law.

Information may remain temporarily in secure system backups until those backups are overwritten in the ordinary backup cycle. Such information is not used for ordinary business purposes while awaiting deletion.

Where your employer is independently responsible for particular learning or employment records, deleting your Narraid account may not require your employer to delete information it is independently entitled or required to retain. You should contact your employer about such records.

Aggregated or genuinely anonymised information that can no longer reasonably be associated with you may be retained for statistical, research and service-improvement purposes.

14. Deleting Your Narraid Account

You can initiate deletion of your Narraid account directly from within the Narraid app.

Account deletion is intended to remove the account itself and associated personal data held by Narraid, subject to information we are legally required or otherwise lawfully permitted to retain.

If you experience difficulty deleting your account, you can contact:

our contact form at narraid.com/contact

We may take reasonable steps to verify your identity before acting on a deletion request.

15. Your Data-Protection Rights

If the GDPR or similar data-protection legislation applies to you, you may have rights concerning your personal data.

Depending on the circumstances, these may include the right to:

• obtain information about how your data is processed;

• request access to your personal data;

• correct inaccurate or incomplete information;

• request deletion of personal data;

• request restriction of processing;

• object to processing based on legitimate interests;

• receive certain data in a portable format;

• withdraw consent where processing is based specifically on consent; and

• lodge a complaint with a competent data-protection authority.

These rights are subject to the conditions and exceptions provided by applicable law.

To exercise a right concerning data for which Narraid is controller, contact:

our contact form at narraid.com/contact

Where your request concerns information being processed by your employer for its own employment or training purposes, we may refer you to your employer or coordinate with your employer as appropriate.

16. Dutch Supervisory Authority

Narraid is established in the Netherlands.

You have the right, where applicable, to lodge a complaint with the Autoriteit Persoonsgegevens, the Dutch data-protection supervisory authority.

You may also have the right to contact the competent supervisory authority in the country where you live or work.

We encourage you to contact us first if you have a privacy concern so that we have an opportunity to address it.

17. Automated Decision-Making

Narraid does not currently use individual app-user data to make solely automated decisions that produce legal effects or similarly significant effects for users.

Quizzes, completion tracking, recommendations or content assignments should not be interpreted as automated employment decisions made by Narraid.

An employer may independently use information made available through Narraid as part of its own learning or workforce processes. The employer is responsible for ensuring that such use complies with applicable law.

18. Children and Younger Users

Narraid is designed primarily for workplace learning and is not specifically directed at children.

We do not impose a single worldwide minimum age because age and employment requirements differ between countries.

If applicable law requires parental, guardian or other authorisation for a younger person to use Narraid or for particular processing of their personal data, the Service should only be used where the necessary authorisation or other lawful basis exists.

If we become aware that personal data has been collected or processed in a manner inconsistent with applicable child-privacy requirements, we will take appropriate steps, which may include deletion of the information or account.

19. Security

We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, access, alteration, disclosure or destruction.

Measures may include, where appropriate:

• controlled access to production systems;

• authentication controls;

• encrypted communications;

• access restrictions;

• system monitoring;

• backups; and

• appropriate contractual safeguards with service providers.

No online service can guarantee absolute security. We therefore also encourage users to protect their passwords and devices and to notify us promptly of suspected unauthorised access.

20. No Advertising or Sale of User Data

Narraid does not currently:

• sell app-user personal data;

• provide identifiable learning histories to brand partners;

• use user learning activity for third-party behavioural advertising; or

• provide user personal data to Narraid’s AI content-generation providers.

If these practices materially change in the future, we will update this Privacy Policy and provide any notice or obtain any permission required by law.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

• the Narraid Service;

• the information we process;

• our technology providers;

• legal or regulatory requirements; or

• our business operations.

The current version will always display its “Last updated” date.

Where a change materially affects your privacy rights, we will provide additional notice where required.

Cookies on narraid.com

The narraid.com website does not set cookies. We measure visits with Fathom Analytics, which works without cookies and does not collect personal data or track you across other websites. That is why this site shows no cookie banner.

When you send us a message through the contact form or the support form, or request the white paper, we receive the details you enter by email and use them only to reply to you. Embedded audio is played from our own hosting.

22. Contact Us

For questions, requests or concerns relating to this Privacy Policy or Narraid’s processing of your personal data, contact:

Room for Design Schiphol B.V., trading as Narraid
Registered in the Netherlands
Chamber of Commerce: 64749746

Email: narraid@narraid.com