Privacy Policy

I. INTRODUCTION

1. When you visit our website: https://siana.ai/ (the Website) or use any of our Services (described in Terms of Service), we (SIANA) may collect and use some of your personal data or personal data of your representatives, proxies or employees, if they act in behalf of you (Personal Data).

2. We want to provide you with the highest standards, therefore the protection of privacy is particularly important to us.

3. We make every effort to ensure that the processing of Personal Data respects the privacy of persons whose data is processed and care for the security of the processed data.

4. We have taken appropriate measures provided for by law to ensure the security of Personal Data, we apply technical and organisational measures ensuring the protection of Personal Data, appropriate to the threats and categories of data protected, in particular we protect Personal Data against unauthorised disclosure removal, change, loss, damage or destruction.

5. You are not legally required to provide us with your Personal Data, but without it we might not be able to provide you with the full range of the Services, or the best experience while using the Website.

6. All capitalised terms have the meaning given to them in this Privacy Notice or in the Terms of Service.

7. Please read our Privacy Notice, which explains the principles and scope of the data we process. You will also find here all information about your rights and our obligations.

II. DATA WE PROCESS

1. We process your Personal Data that you provide to us when you visit the Website or use the Services, express an interest in obtaining information about us or our Services or otherwise when you contact us. The Personal Data we process depends on the context of your interactions with us and the Services, but usually they include:

1) data needed to register with our Services: name, surname, job title, e-mail address, work telephone number, information about your company;

2) data related to payments for our Services;

3) information received from you during contact with us;

4) data related to the use of our Website: IP address, information about your general location (city and country);

2. We also process data about the use of the Website or our Service and the characteristics and activities of Users, which are Non-Personal Data. They include:

1) technical information such as the Website visit, browser used and display settings, operating system, device type, session start and end time, referring URL, time zone, network connection type (e.g. Wi-Fi, cellular) and information about cookies. We do not use such data to identify an individual, but to better understand how our users normally use our Website and our Services;

2) data collected by sensors in our Devices that you use on the basis of Terms of Service;

3) information about your mobile device, push notifications when you use our Application, such as mobile device ID, model and manufacturer, operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider, mobile operator, IP address or proxy server.

3. If we combine Personal Data with Non-Personal Data, the combined data will be treated as Personal Data.

III. PURPOSES OF DATA PROCESSING AND LEGAL GROUNDS

1. We process Personal Data for following purposes:

1) provision of Services - i.e. for performance of the Agreement that we have concluded on the basis of the Terms of Service and for the provision of electronic services on the Website - the legal basis for the processing of Personal Data is the necessity of processing to perform the contract - Article 6 (1) (b) of the GDPR;

2) contact with our Customers, Users and all data subject who are interested in our Website or Services - the legal basis for processing is the legitimate interest of SIANA - Article 6 (1) (f) of the GDPR;

3) analytical and statistical purposes, including the improvement of the functionalities of the Website, Platform and Application, analysing the Users' activity on the Website and in our Services, as well as their preferences in in order to improve the functionalities used - the legal basis for processing is SIANA’s legitimate interest - Article 6 (1) (f) of the GDPR;

4) in case of any dispute - to establish and pursue claims or defend against them - the legal basis for processing is the legitimate interest of the SIANA - Article 6 (1) (f) of the GDPR;

5) to fulfil the statutory obligations incumbent on SIANA, resulting in particular from tax and accounting regulations - the legal basis for processing is the legal obligation - Article 6 (1) (c) of the GDPR;

6) sending to our Customers and Users information about products, services and new features and/or information about changes to our terms and conditions or direct marketing purposes - in this case, the legal basis for processing is also the legitimate interest pursued by the SIANA or by a third party (our business partners) - Article 6 (1) (f) of the GDPR;

7) technical and administrative purposes, including the purposes of ensuring the security of the our ICT systems and managing these systems - in this respect, the legal basis for processing is the SIANA's legitimate interest - Article 6 (1) (f) of the GDPR.

IV. DATA RECIPIENTS

1. The recipients of Personal Data are persons authorised by SIANA to process Personal Data in behalf of SIANA, processors, such as service providers - IT, Internet, cloud, accounting, legal, insurance, courier, marketing and similar, payment operators, social plug-in providers as well as administrative bodies public or judicial authorities, if we are required to provide these data on the basis of legal provisions.

2. Your Personal Data, including data that you provide as part of browsing the Website or using our Services, including data collected through cookies, may be made available to trusted third parties based on your consent.

V. DATA TRANSFER

In a situation where trusted third parties to whom we transfer Personal Data are based outside the EEA, the transfer of Personal Data will be made in accordance with the principles expressed in the GDPR. In particular, it may take place:

1) to countries for which the European Commission has issued decisions on the adequacy of Personal Data protection (https://ec.europa.eu/info/law/law-topic/dataprotection/international-dimension-data-protection/adequacy-decisions_en) without any additional requirements;

to other countries, primarily on the basis of Standard Contractual Clauses with the use of additional security (technical and legal) or Binding Corporate Rules.

VI. DATA RETENTION

1. Personal Data is processed for the time necessary to perform the Agreement regarding the use of the Services, as well as for the duration of the legal obligation or implementation of SIANA's legitimate interests for the duration of the interests, including the time necessary to assert or defend against any claims. In other words, we will only process Personal Data for as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required by law.

2. At the end of the retention period, we will delete or anonymise the Personal Data or, if this is not possible (in case the Personal Data has been stored in backup archives), we will securely store Personal Data and isolate it from any further processing until deletion.

VII. USERS RIGHTS

1. On the basis of the GDPR, you have the rights that you can exercise by applying to the SIANA:

1) the right to information, i.e. to know what Personal Data is collected about you, why, who is collecting data, how long it will be kept, how you can file a complaint, and with whom will we share the data;

2) the right to access to your Personal Data, i.e. to know what data we process;

3) the right to rectification your Personal Data, i.e. to update any inaccurate or incomplete data we have on you;

4) the right to be forgotten (the right to erasure), i.e. to ask for your Personal Data to be deleted in cases indicated in GDPR;

5) the right to restrict processing, i.e. to limit the way we use your Personal Data;

6) the right to data portability, i.e. to obtain your Personal Data in a structured, commonly used, and machine-readable format;

7) the right to object to processing according to Article 21 of GDPR (in certain situations and it will depend on the purpose of processing and the lawful base for processing).

2. You have also the right to lodge a complaint with the supervisory body. Danish Data Protection Authority is Datatilsynet, e-mail: dt@datatilsynet.dk

VIII. COOKIES AND OTHER TRACKING TECHNOLOGIES

1. We use cookies on the Website and the Platform.

2. The Website may use two basic types of cookies:

1) session files - these are temporary files that are stored on your device until you leave the Website or Platform;

2) permanent - these are files stored on your device by the cookies specified in the parameters or until you delete them.

3. The Website and the Platform may use all or some of the following types of cookies:

1) "necessary", which enable the use of the Website or Platform,

2) "performance", which enable the collection of information on how to use the Website or Platform;

3) "functional", which enable you to keep the settings selected and personalise the your interface, e.g. through the language, font size, appearance of the Website or Platform;

4) "advertising", which make it possible to provide you with advertising content more tailored to your interests.

4. Currently we use the following types of cookies: […] [here the table listing all currently used cookies should be displayed automatically by state for the day like cookie declaration by Cookiebot on https://www.cookiebot.com/en/cookie-declaration/].

5. You at any time change the settings for cookies. These settings can be changed in particular in such a way as to block the automatic handling of cookies in the web browser settings, or to inform about their every posting in your device. If the access of cookies to your device is restricted or disabled, the use of the Website or Platform may be difficult and may disable some of the functionalities that require cookies. Detailed information on the possibilities and methods of handling cookies is available in your browser or device settings.

6. We may also use social plugins, i.e. tools enabling connection with popular social networks. These plugins enable your browser to download content from the plug-in provider and provide this provider with data about you, including your Personal Data:

1) Facebook Ireland Ltd. - "Like" and "Share" plug-ins, which allow you to refer to Facebook, and a plug-in linking directly to Instagram. By clicking one of the aforementioned plugins, the you log into Facebook or Instagram, respectively, which have separate privacy protection rules. You can read them by going to the link: https://www.facebook.com/policy.php;

2) LinkedIn Ireland Unlimited Company - there is a plug-in that allows you to refer to the LinkedIn portal and share a post on it. By clicking such a plug-in, you log into LinkedIn, which has separate privacy protection rules available at: https://www.linkedin.com/legal/privacypolicy; 3) Google Ireland Limited - the Website may contain embedded videos from the YouTube. You can read the privacy protection rules on YouTube by clicking on the links: https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/ and https://policies.google.com/privacy

7. As part of the Website or the Platform, there may be some links to other websites. Such websites operate independently of SIANA and are not supervised by us in any way These websites may have their own privacy policies and regulations, which we recommend to read.

IX. DATA CONTROLLER AND CONTACT DETAILS

1. Data controller of Personal Data is SIANA - the company under the name of Siana ApS, based in Denmark, Aabogade 15, 8200 Aarhus N, DK-40312161, www.siana.ai.

2. In order to exercise your rights under the GDPR as described in this Privacy Notice, or if you have any questions, concerns or comments related to this Privacy Notice, do not hesitate to contact us by e-mail: privacy@siana.ai.