Legal

Privacy Policy — EchoDepth for Sales

Last updated: 1 March 2026

EchoDepth for Sales is operated by Cavefish, registered in England and Wales (15127122), based at 15 Neptune Court, Vanguard Way, Cardiff CF24 5PJ. This policy explains how we collect, use, and protect your data when you use our platform or contact us.

EchoDepth for Sales is an AI-powered avatar coaching platform that analyses emotional expression during voluntary practice sessions. It is not facial recognition or surveillance technology.

1. Who we are

Cavefish is the data controller for personal data collected through echodepthsales.com. Contact our Data Protection lead at privacy@cavefish.ai.

2. What data we collect

Contact and enquiry data

When you request access or contact us: name, work email, job title, company name, and the content of your message.

Session performance data (platform users)

During coaching sessions, EchoDepth analyses facial micro-expressions and vocal tonality in real-time. Raw video and audio data is not stored. What we retain is aggregated session performance scores — Confidence, Warmth, Authority, Composure — that form your coaching progress record. This data cannot be used to identify or surveil individuals outside of their own coaching context.

Usage and analytics data

Standard anonymised usage data (session frequency, feature engagement) via privacy-first analytics.

3. Legal basis for processing

  • Contract performance — to provide the EchoDepth coaching service to enterprise users.
  • Legitimate interests — to improve the platform and respond to enquiries.
  • Consent (Article 6(1)(a) + Article 9(2)(a) UK GDPR) — for session analysis where explicitly provided at onboarding. Withdrawable at any time without affecting prior processing.
  • Legal obligation — where required by law.

4. How we use your data

  • To deliver coaching sessions and progress reports to the individual rep.
  • To provide team-level aggregated analytics to enterprise sales leaders (no individual identification without consent).
  • To respond to sales enquiries and access requests.
  • To improve the EchoDepth platform.
  • We never sell your data to third parties or use it for advertising.

5. Session data principles

EchoDepth is a coaching tool, not a surveillance system. Session performance data:

  • Is accessible to the individual rep by default.
  • Is only shared with managers/administrators where explicit organisational consent is established in the enterprise agreement.
  • Is not used to make automated decisions about employment or performance reviews without human involvement.
  • Can be deleted on request within 30 days.

6. Data residency and transfers

All data is processed and stored within the United Kingdom as standard. No personal data is transferred outside the UK without a lawful transfer mechanism under UK GDPR. Enterprise clients may request specific data residency commitments in their service agreement.

7. Your rights under UK GDPR

You have the right to access, correct, delete, restrict, or port your personal data, and to object to processing. Email privacy@cavefish.ai. We will respond within 30 days. You may also lodge a complaint with the Information Commissioner's Office (ICO). ICO registration: ZB915633.

8. Data retention

Contact and enquiry data: retained for 24 months from last contact or until deletion is requested. Session performance data: retained for the duration of your enterprise subscription plus 90 days, or until deletion is requested.

9. Cookies

We use essential session cookies and privacy-first analytics only. No advertising cookies, no third-party tracking pixels. You can disable cookies in your browser settings.

10. Changes to this policy

Material changes will be communicated by email to registered users. Continued use after changes constitutes acceptance. Current version always available at echodepthsales.com/privacy/.

Data protection contact

Cavefish · 15 Neptune Court, Vanguard Way, Cardiff CF24 5PJ

Article 9 Position

EchoDepth for Sales analyses facial Action Units during live coaching sessions. During active processing this constitutes processing of biometric-adjacent data under UK GDPR. Our position is that session analysis for voluntary coaching purposes, with explicit consent from the participant at onboarding, satisfies Article 9(2)(a) UK GDPR. No biometric identification profile is created or retained. AU scores are used solely to generate coaching feedback and are not used to identify or re-identify individuals.

Sub-processors

Cavefish uses the following sub-processors in delivery of EchoDepth for Sales:

  • Vercel — hosting and infrastructure (UK/EU data centres)
  • Supabase — database and authentication

Sub-processors are bound by data processing agreements. No video or biometric data is shared with sub-processors beyond what is required for service delivery.

Governance Documents

Legitimate Interests Assessment — LIA-ED-SPORT-001  ·  Data Protection Impact Assessment — DPIA-ED-SPORT-001

privacy@cavefish.ai  ·  ICO reg: ZB915633  ·  ico.org.uk

Data & privacy FAQ

Common questions about your data.

Does EchoDepth store my facial data?

No. EchoDepth analyses emotional expressions in real-time during coaching sessions. It does not store biometric templates, facial images, or identity data. Session analytics are retained only for your coaching feedback and are configurable per your enterprise data retention policy.

Can I delete my session data?

Yes. You can request deletion of all your session data at any time by contacting privacy@cavefish.ai. We process deletion requests within 30 days in accordance with UK GDPR requirements.

Is EchoDepth UK GDPR compliant?

Yes. Cavefish is registered with the UK Information Commissioner's Office (ICO: ZB915633). We process data under UK GDPR and maintain data residency within the UK. Our lawful basis for processing session data is legitimate interest for coaching purposes, with explicit consent obtained at session start.

Is EchoDepth facial recognition or surveillance?

No. EchoDepth is a voluntary coaching tool. It analyses emotional expression patterns during practice sessions to provide feedback. It does not identify individuals, track people across sessions without consent, or share data with third parties for surveillance purposes.