Privacy Policy
Last updated: 18 September 2026
Who we are
ORCA IQ is a call coaching platform for recruitment firms, operated by Orca Recruiter Systems Limited, a company registered in England and Wales, company number 17259799, registered office 11 Penfolds Place, Arundel, England, BN18 9SA. "We", "us" and "our" mean that company. Train with Orca is our training brand and this policy covers it too.
You can reach us about anything in this policy at privacy@trainwithorca.com.
The short version
Recruitment firms use ORCA IQ to review and coach their consultants' phone calls. That means we handle recordings and transcripts of real calls, which contain information about people who are not our users and have never dealt with us directly, usually job candidates. We think that deserves to be said first rather than buried, so this policy is written in plain English and says what actually happens.
Two different relationships
If you are a candidate or a contact on a recorded call, the recruitment firm that called you decides why that call was recorded and what happens to it. They are the data controller. We process it on their instructions. If you want your data removed, the fastest route is to ask the recruitment firm you spoke to. You can also come to us and we will act on it together with them.
If you use ORCA IQ at work, your employer is the controller of your employment data and we process it for them. Separately, we are the controller of a small amount of information about how you use the product, which we collect to run and improve it.
If you visit our website, we are the controller.
What we hold
From recorded calls
The audio recording, a transcript of what was said, the phone number, the name and, where known, the company and email address of the person called, the identity of the consultant who made the call, and the coaching assessment we generate from it.
From people who use the platform
Name, work email address and login credentials, which company and team you belong to, and your activity: calls made, scores, coaching assigned, videos watched.
From product analytics
Deliberately minimal. An anonymous identifier, your company, your role, which screens you open and when. No names, no email addresses, no call content and no screen recording. Web addresses are stripped of anything variable before they are sent, so a page about a named person is recorded as the shape of the page and not the person.
From our website
Standard server logs and, if you contact us, whatever you send.
What we use it for, and our lawful basis
| What | Why | Lawful basis |
|---|---|---|
| Recording, transcribing and scoring calls | It is the service the client bought | We process on the client's instructions. The client decides its own lawful basis, typically its legitimate interests in training and quality |
| Running your account and logging you in | To provide the service | Contract |
| Product analytics | To know whether the product works and where people get stuck | Legitimate interests |
| Security, fraud prevention, service alerts | To keep it working and safe | Legitimate interests |
| Marketing emails | Only if you asked for them | Consent |
Automated assessment, and what it does not decide
Calls are scored automatically by AI against a coaching framework. The score is a coaching tool for a human manager, not an automated decision about anyone's employment. It does not by itself hire, fire, promote, discipline or rank anyone, and a manager sees the call and the reasoning alongside the number.
We score what was said, from the transcript. We do not analyse the sound of a person's voice: not tone, pitch, pace or emotion. That is a deliberate line.
If you are assessed by ORCA IQ and want to understand or challenge a score, ask your employer first, since they hold the context. We will support them, and you can contact us directly.
We do not train AI on your calls
We do not use client call recordings or transcripts to train AI models.
Who we share it with
We do not sell personal data and we do not share it for advertising.
We use third parties to run the service: hosting, AI scoring, transcription, telephony, login, email and analytics. Where we transcribe a phone call's audio ourselves, we use a transcription service in the EU by default. Clients can ask us for the current list of these suppliers at any time.
Some of these suppliers are in the United States, including the AI services that generate coaching assessments. That means call transcripts can leave the UK and the EU. Where they do, we rely on the safeguards in our agreements with those suppliers: standard contractual clauses with the UK addendum, or the supplier's certification under the Data Privacy Framework where it has one. Call recordings are stored in Western Europe and our product analytics are hosted in the EU.
We will also disclose data where the law requires it.
How long we keep it
A consultant's development over time is the point of the product, so we keep a client's calls, transcripts and scores for as long as that client's account is active. Our copy of a recording is kept separately from the phone system's copy, so that coaching history is not lost when a phone provider clears its own archive.
When a client's contract ends, we delete that client's call data within 90 days, unless the client asks us to delete it sooner or the law requires us to keep something for longer.
Any individual can ask for their data to be deleted at any time, and a client can instruct us to delete specific calls or people at any time. Deleting a call removes the recording as well as the transcript and the score.
Your rights
You can ask us for a copy of what we hold about you, to correct it, to delete it, to restrict or object to how we use it, and to receive it in a portable form. You can complain to the Information Commissioner's Office in the UK, or to the data protection authority where you live, though we would rather you came to us first.
In practice: if your data reached us through a recruitment firm, ask them first. They hold the context and the relationship. We will act on a request whether it arrives through a client or directly.
We respond within one month.
Cookies and similar technologies
We do not use advertising cookies or third-party tracking. The platform stores a small amount of information in your browser to keep you logged in. Our product analytics use your browser's local storage rather than cookies, record page views including the login page, and create no profile of anyone who has not logged in.
Children
ORCA IQ is a workplace tool and is not intended for anyone under 18.
Changes
We will post changes here and, where they matter, tell clients directly.
Contact
privacy@trainwithorca.com, or write to Orca Recruiter Systems Limited, 11 Penfolds Place, Arundel, England, BN18 9SA.