European Economic Area Privacy Policy

Last Updated: Feb 23, 20255
Unless otherwise expressly stated, capitalized terms in these Disclosures have the same meaning as defined in the Privacy Policy.

Scope of Disclosures »

These Additional European Economic Area (EEA) Privacy Disclosures supplement the information contained in our Privacy Notice. In addition, these Disclosures apply only to our processing of your personal data where you are based in the EEA. AlphaPrism, Inc. is the data controller responsible for the collection and use of such personal data.

Personal Data Disclosures »

When we use the term “personal data” in these Disclosures, we mean any information relating to an identified or identifiable natural person .

Legal Bases for Processing »

We rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:
CATEGORY OF PERSONAL DATAHOW WE USE THE PERSONAL DATALEGAL BASES FOR PROCESSING
Contact Information, including your full name, email address, phone number and state and country of residence.We use this information to communicate with you or the customer you represent, including sending service-related communications.Where you are the customer, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Where you are not the customer, the processing is necessary for our legitimate interests and those of our customers, namely administering our services.
We use this information to provide our services to you or the customer you represent.Where you are the customer, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Where you are not the customer, the processing is necessary for our legitimate interests and those of our customers, namely administering our services.
We use this information to deliver marketing communications and advertisements.We will only process your personal information in this way to the extent that you have given us consent to do so.
Professional Information, including your title, company name, professional background and the nature of your relationship with us.We use this information to provide our services to you or the customer you represent.Where you are the customer, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Where you are not the customer, the processing is necessary for our legitimate interests and those of our customers, namely administering our services.
We use this information to tailor content provided to you or the customer through the services, including notifications and marketing communications.The processing is necessary for our legitimate interests, namely to tailor our service to the user.
We use this information to conduct research and analytics on service usage and activity trends.The processing is necessary for our legitimate interests, namely to inform the development of new features of the services and the improvement of the services generally.
Service Information, including product or service interests and orders.We use this information to communicate with you or the customer you represent, including sending service-related communications.Where you are the customer, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Where you are not the customer, the processing is necessary for our legitimate interests and those of our customers, namely administering our services.
We use this information to tailor content provided to you or the customer through the services, including notifications and marketing communications.The processing is necessary for our legitimate interests, namely to tailor our service to the user.
We use this information to conduct research and analytics on service usage and activity trends.The processing is necessary for our legitimate interests, namely to inform the development of new features of the services and the improvement of the services generally.
Inquiry Information, such as the content of your email, text or chat with us and, where applicable, your voice from calls with us.We use this information to communicate with you or the customer you represent, including to respond to your inquiries.Where you are the customer, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Where you are not the customer, the processing is necessary for our legitimate interests and those of our customers, namely administering our services.
We use this information to tailor content provided to you or the customer through the services, including notifications and marketing communications.The processing is necessary for our legitimate interests, namely to tailor our service to the user.
We use this information to optimize customer experience with our services.The processing is necessary for our legitimate interests, namely to optimize our service for the user.
We use this information to diagnose errors and problems with existing service.The processing is necessary for our legitimate interests, namely to ensure our services are operating as intended.
Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.We use this information to provide our services to you or the customer you represent.Where you are the customer, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Where you are not the customer, the processing is necessary for our legitimate interests and those of our customers, namely administering our services.
We use this information to tailor content provided to you or the customer through the services, including notifications and marketing communications.The processing is necessary for our legitimate interests, namely to tailor our service to the user.
We use this information to optimize customer experience with our services.The processing is necessary for our legitimate interests, namely to optimize our service for the user.
We use this information to diagnose errors and problems with existing service.The processing is necessary for our legitimate interests, namely to ensure our services are operating as intended.
We use this information to conduct research and analytics on service usage and activity trends.The processing is necessary for our legitimate interests, namely to inform the development of new features of the services and the improvement of the services generally.
Analytics Data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and object you view, click or otherwise interact with (also known as “Click-stream Data”).We use this information to provide our services to you or the customer you represent.Where you are the customer, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Where you are not the customer, the processing is necessary for our legitimate interests and those of our customers, namely administering our services.
We use this information to tailor content provided to you or the customer through the services, including notifications and marketing communications.The processing is necessary for our legitimate interests, namely to tailor our service to the user.
We use this information to optimize customer experience with our services.The processing is necessary for our legitimate interests, namely to optimize our service for the user.
We use this information to diagnose errors and problems with existing service.The processing is necessary for our legitimate interests, namely to ensure our services are operating as intended.
We use this information to conduct research and analytics on service usage and activity trends.The processing is necessary for our legitimate interests, namely to inform the development of new features of the services and the improvement of the services generally.
Location Data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device.We may use approximate or more precise location to ensure content made available to you through our services is relevant to the location in which you are using your device.The processing is necessary for our legitimate interest, namely to tailor our service to the user and to improve our service generally.
We use this information to conduct research and analytics on service usage and activity trends.The processing is necessary for our legitimate interests, namely to inform the development of new features of the services and the improvement of the services generally.
All Personal Data Set Out AboveWe use all the personal information we collect to provide our services to you or the customer you represent, to communicate with you, to monitor and improve our services and business, to conduct research and analytics relating to our services, and to help us develop and test new products and services.The processing is necessary for our legitimate interests, namely to administer and improve our services.
We use all the personal information we collect to facilitate our internal business operations that are put in place for compliance with our contractual obligations.Where you are the customer, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Where you are not the customer, processing is necessary for our legitimate interests and those of our customers, namely administering our services.
We use all the personal information we collect to otherwise exercise or comply with legal obligations and rights.Where required by law, processing is necessary for compliance with a legal obligation to which we are subject.
Where not required by law, the processing is necessary for our legitimate interests, namely the exercise of our legal rights or to take steps to further compliance with our legal obligations.
You are not required to provide personal data to us, but we do rely on your personal data to provide certain of our services and products. For example, we need your personal data to facilitate and deliver an order that you request. If you choose not to provide us with your personal data, we may not be able to provide you with a service or product you request.

Data Retention »

We retain personal data about you for as long as is necessary for the purposes set out in these Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.
The criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data:
LEGITIMATE INTERESTSDESCRIPTION
ConsentWhere we are processing personal data based on your consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain circumstances, to have certain of your data erased (please see the Your Privacy Rights section below).
ContractWhere we are processing personal data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Legal ObligationWhere we are processing personal data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfil the legal obligation.
Legal ClaimWe may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.
In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.

International Data Transfers »

We may transfer personal data about you among us and to our subsidiaries or affiliates, as well as to the categories of third parties identified in the Our Disclosure of Personal Information section of the Privacy Policy. Personal data may be transferred to, stored and processed in a country other than the one in which it was collected, including, but not limited to, the United States. The country to which personal data is transferred may not provide the same level of protection for personal data as the country from which it was transferred.
We may transfer personal data about you outside the EEA and when we do so, we rely on appropriate or suitable safeguards recognized under the GDPR including adequacy decisions and standard contractual clauses.

Adequacy Decisions »

We may transfer personal data about you to countries that the European Commission has deemed to adequately safeguard personal data.

Standard Contractual Clauses »

The European Commission has adopted Standard Contractual Clauses, which provide safeguards for personal data transferred outside of the EEA. We may use these Standard Contractual Clauses when transferring personal data from a country in the EEA to a country outside the EEA that has not been deemed to adequately safeguard personal data. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.

Your Privacy Rights »

You have the following rights in relation to your personal data (subject to certain limitations at law):
ACCESSTHE RIGHT TO ACCESS AND OBTAIN A COPY OF PERSONAL DATA ABOUT YOU
RectificationThe right to correct or update any personal data about you that is inaccurate or incomplete.
RectificationThe right to correct or update any personal data about you that is inaccurate or incomplete.
RestrictionThe right to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
ErasureThe right to request the deletion or erasure of personal data about you without undue delay if the continued processing of that personal information is not justified.
PortabilityThe right to obtain a copy of personal data about you in an easily accessible format and the right to transmit that personal data to another controller.
ObjectionYou also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our products or services to you, or otherwise engage with you going forward.

Right to Withdraw Consent »

Where we rely on your consent for processing of your personal data, you also have the right to withdraw your consent to such processing, subject to certain limitations at law.
You may withdraw your consent by emailing us at legal@alphaprism.ai

Submitting Requests »

To submit a request, please contact us as set forth in the Contact Us section below. We may need to verify your identity before processing your request, which may require us to obtain additional personal data from you. In certain circumstances, we may decline a request to exercise the rights described above.

Right to Lodge a Complaint »

If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority).

Updates to These Disclosures »

We may update these Disclosures from time to time. When we make changes to these Disclosures, we will change the “Last Updated” date at the beginning of these Disclosures. If we make material changes to these Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us »

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to legal@alphaprism.ai.
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