Privacy Policy
Last updated: July 2026 · Empathia Learn Technologies Inc., Ontario, Canada
The short version: Empathia Learn is a training simulation. It stores no patient health information, learner records are stored in Canada and encrypted (simulation text is processed by our AI provider — see §3), coordinators never see a learner's words, and training data is never used for discipline or employment decisions — a commitment we also make contractually.
1. What we collect
- Account information: a learner's name, email, and cohort, provided by your service or program at onboarding.
- Practice metadata: which scenarios were started and completed, which call types were covered, and whether a reflection was completed.
- Conversation content: the words a learner types in a scenario are used to run the simulation and the learner's own reflection. They are never shown to coordinators, employers, or educators.
2. What we never collect
Scenarios are fictional simulations. No patient health information (PHI) ever enters the platform. We do not collect real patient data, call records, or clinical documentation, and learners are instructed never to enter details of real calls or real patients.
3. Data residency, processing, and subprocessors
Learner records — accounts, participation, reflections — are stored in Canada and encrypted in transit and at rest. Access is restricted to authorized Empathia Learn personnel with an operational need.
Processing is a separate question, and we answer it plainly. To generate a simulated patient's reply, the words a learner types in a scenario are sent to our AI model provider, Anthropic (PBC), and may be processed on infrastructure outside Canada. That text is a fictional training conversation containing no patient health information. It is sent for the sole purpose of producing the next line of the simulation, is not used to train any model, and is not retained by us beyond the learner's own record.
Our subprocessors are Anthropic (model inference), Supabase (database), and Netlify (hosting and serverless functions). We will provide the current list, with processing locations and data-protection terms, to any reviewer on request.
4. Privacy-law alignment
Because the platform holds no personal health information, Empathia Learn does not act as a health information custodian under Ontario's Personal Health Information Protection Act (PHIPA) or equivalent legislation elsewhere. Our data-handling practices are nonetheless designed to align with PHIPA's principles, with the equivalent health-privacy laws of each province or jurisdiction we operate in, and with the privacy obligations of the services and programs we work with. Documentation for privacy and security reviewers — architecture, retention, and subprocessors — is available on request.
5. No use in discipline
Training data exists for training and program evaluation only. It is never used in discipline, performance management, or employment decisions, and we contractually refuse to provide it for those purposes.
6. What coordinators see
Coordinators and faculty see participation and coverage: that a learner practiced, which call types they covered, and whether reflections were completed. They never see conversation content or any judgment of how a learner performed.
7. Retention and deletion
Learner data is retained for the duration of your license and deleted or returned at the end of the engagement, per your agreement. Learners and institutions may request deletion at any time by writing to us.
8. Contact
Questions about this policy or a privacy review: privacy@empathialearn.com. We reply personally, usually within two business days.