Privacy Policy

Last updated: June 26, 2026

This Privacy Policy explains how Being Essential Consulting SA, owner of the Sophian micro-learning product ("Sophian," "we," "us," or "our") collects, uses, and protects personal information when you use the Sophian micro-learning platform, our websites, and our mobile applications available on the App Store and Google Play (together, the "Services").

Sophian is a business-to-business service. It is provided exclusively to organizations and their workforce and is not offered, marketed, or made available to individual consumers. Sophian provides bite-sized, in-the-flow-of-work learning experiences, including content provided in partnership with Harvard Business Impact.

Your employer or organization ("Customer") provides the Services to you and acts as the controller of the personal data processed through the Services, while Sophian acts as a processor on the Customer's behalf under a data processing agreement. Your organization's own privacy notice also applies and, for questions about how your organization uses your data, you should contact your organization directly.

1. Scope

This policy applies to personal information we process about Authorized Users (such as learners and account administrators) of our organizational Customers, business contacts at prospective customers, and visitors to our websites. The Services are not available to individual consumers, and we do not knowingly create accounts for individuals outside of an organizational Customer relationship. This policy does not apply to third-party products or services that we do not control, even if they link to or from the Services.

2. Information we collect

Information you or your organization provide

• Account and profile details such as name, work email address, job title, organization, and language preference.
• Information submitted within the Services, such as responses to quizzes and interactive exercises, notes, and feedback.
• Communications you send to us, including support requests and survey responses.

Information collected automatically

• Usage and learning-progress data, such as modules viewed, completion status, time spent, and engagement metrics.
• Device and technical data, such as device type, operating system, app version, IP address, and approximate location derived from IP.
• Log data and identifiers collected through cookies and similar technologies (see Cookies & tracking).

Information from third parties

• Provisioning and authentication data from your organization's identity provider or single sign-on (SSO) system.
• Limited information from service providers that help us operate, secure, and analyze the Services.

3. How we use information

We use personal information to:

• Provide, maintain, and personalize the Services, including delivering adaptive learning paths and tracking progress.
• Authenticate users, administer accounts, and provide customer support.
• Generate aggregated insights and reporting for your organization on engagement and learning outcomes.
• Improve, develop, and secure the Services, including troubleshooting and analytics.
• Communicate with you about updates, security notices, and (where permitted) relevant offerings.
• Comply with legal obligations and enforce our agreements.

4. Legal bases for processing

Where applicable law (such as the GDPR) requires a legal basis, we rely on one or more of the following: performance of a contract; our legitimate interests in operating and improving the Services; your consent (which you may withdraw); and compliance with legal obligations. Where Sophian acts as a processor, we process personal data according to our Customer's instructions under a data processing agreement.

5. How we share information

• With your organization. Account administrators of the Customer may access account, usage, and progress information associated with their organization.
• Service providers. We share information with vendors who host, support, secure, and analyze the Services under contractual confidentiality and data-protection obligations.
• Content partners. Limited data may be shared as necessary to deliver licensed learning content, such as content from Harvard Business Impact.
• Legal and safety. We may disclose information to comply with law, enforce our terms, or protect the rights, safety, and security of users and the public.
• Business transfers. Information may be transferred as part of a merger, acquisition, financing, or sale of assets, subject to this policy.

We do not sell personal information.

6. Cookies & tracking technologies

We use cookies and similar technologies to keep you signed in, remember preferences, measure performance, and understand how the Services are used. You can control non-essential cookies through your browser settings and, where offered, our cookie banner. Disabling certain cookies may affect functionality.

7. Data retention

We retain personal information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Retention periods are also governed by our agreement with your organization. When information is no longer required, we delete or anonymize it.

8. Security

We maintain administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, or misuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. International data transfers

We may process and store information in countries other than where you are located. Where we transfer personal data across borders, we use appropriate safeguards such as standard contractual clauses or other lawful transfer mechanisms. Data is hosted and stored in the EU.

10. Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, or object to the processing of your personal information, to data portability, and to withdraw consent. Because your organization may control your data, please direct requests to your administrator; we will support our Customers in responding. You may also contact us using the details below. You have the right to lodge a complaint with your local data protection authority.

11. Children's privacy

The Services are intended for use by organizations and their workforce and are not directed to children. We do not knowingly collect personal information from individuals under 18 years old. If you believe a child has provided us information, please contact us so we can take appropriate action.

12. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version with a revised "Last updated" date and, where appropriate, provide additional notice. Your continued use of the Services after an update indicates acceptance of the revised policy.

13. Contact us

If you have questions about this Privacy Policy or our data practices, contact us at:

Being Essential Consulting SA
Leoforos Vouliagmenis 23, 16675, Glyfada
Athens, Greece
Email: privacy@sophian.co