PRIVACY POLICY

LAST UPDATED: 9 October 2024

This privacy policy (“Privacy Policy”) is designed to advise You about how we collect, use, and protect personal data You provide when using our software, websites, and services provided through them (together “Service”).

Please read this Privacy Policy before using the Service.

By using the Service, You represent and warrant to us that (i) You have read, understand, and agree to this Privacy Policy, and (ii) You are over 18 years of age. If You do not agree or cannot make this promise, You must not use the Service.

GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

EEA” includes all member states of the European Union and the European Economic Area.

Process” with respect to personal data includes collecting, storing, and disclosing it to others.

Capitalized terms not defined in this Privacy Policy have the meaning given under the Terms of Use available at: https://posex.ai/tos.html.

1.              Categories of personal data we collect

We collect personal data that (1) You give us voluntarily by filling in an application to use the Service, as well as (2) information that is collected automatically.

1.1.          Personal data provided by You

You provide Your personal data when filing the application to use the Service on our website. The categories of data we ask You to provide are:

(a)            contact information, such as Your e-mail, login and password;

(b)            content, including photos and other information;

(c)            feedback and correspondence, such as information You provide when You report a problem with the Service, receive customer support, or otherwise correspond with us.

1.2.          Data collected automatically

When You visit a website, You disclose certain information, such as Your IP address and the time of Your visit. This site, like many other sites, records this basic information about visits to our site. In particular, we collect the following data:

(a)            data about how You found us. We collect data about Your referring app or URL (the app or place on the Web where You were when You tapped on our ad).

(b)            device and location data. We collect data from Your device. Examples of such data include language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

(c)            usage data. We record how You interact with the Service and our Software. For example, we log Your taps on certain areas of the interface, the features, and the content You interact with. We also record the ads on our website with which You interact (and the Internet links to which those adds lead). We also analyze Your actions when using the software (e.g., we can track Your clicks on UI elements).

(d)            cookies. We may collect information using “cookies.”

Cookies are small data files stored on the hard drive of Your computer or mobile device by a website. We may use both session cookies (which expire once You close Your web browser) and persistent cookies (which stay on Your computer or mobile device until You delete them) to provide You with a more personal and interactive experience on our site.

We use three broad categories of cookies: (1) first-party cookies, served directly by us to Your computer or mobile device, which we use to recognize Your computer or mobile device when it revisits our website; (2) third-party cookies, which are served by service providers on our website, and can be used by such service providers to recognize Your computer or mobile device when it visits other websites; and (3) necessary cookies, which are necessary for our website operations to work properly, required to navigate and use key functions throughout the website and cannot be switched off in our systems..

The abovementioned categories of data are collectively referred to as “Personal Data”.

2.              Sensitive Personal Data

We do not collect any special categories of personal data as defined by Article 9 of the GDPR or other sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).

Please do not send us or disclose any sensitive personal data through the Service or otherwise to us.

If You send or disclose sensitive personal data to us when You use the Service, You must consent to our processing and use of such sensitive personal data under this Privacy Policy. If You do not consent to our processing and use of such sensitive personal data, You must not submit such sensitive personal data through the Service or do not give access to it.

3.              Purposes for which we process Your Personal Data

The Personal Data we collect is used for the following purposes:

3.1.          to improve, develop, and provide our products and Services

We process Your Personal Data to enhance the functionality of our products and Services, ensuring they are relevant and useful to You and others. This includes the development of new features and services.

3.2.          to develop and train AI models

We process Your Personal Data to help develop and train AI models that power our Services, enabling us to provide personalized and automated experiences that better meet Your needs.

3.3.          to gain insights using AI, automated systems, and inferences

We process Your Personal Data to generate insights through the use of AI, automated systems, and inferences. These insights help us personalize Your experience and improve our Services to be more relevant and useful to You.

3.4.          to provide You with customer support

We process Your Personal Data to promptly address all Your concerns regarding the use of the Service, provide additional information about Subscriptions, etc.

3.5.          to communicate with You regarding Your use of the Service

We process Your Personal Data to inform You about the terms of use of the Service, subscription options, etc. We also communicate with You via our communications channels to provide You with technical and other support. We can also send You reminders regarding the expiration of Your subscription.

3.6.          to customize Your content

We process Your Personal Data to adjust the content of the Service and provide content tailored specifically to Your needs.

3.7.          for the marketing purposes

We process Your personal data for our marketing campaigns. We may add Your email address to our marketing list, provided we receive consent or otherwise establish the legal basis for sending You marketing communications. As a result, You will receive information about our Service, such as, special offers. If You do not want to receive marketing emails from us, You can unsubscribe by following the instructions in the footer of the marketing emails or by contacting us at info@posex.ai.

3.8.          to enforce Terms

We use personal data to enforce our agreements and contractual commitments.

3.9.          to research and analyze Your use of Service

We process Your Personal Data to understand our business better, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service. We also use data for statistical analysis purposes to test and improve our offers.

To analyze how visitors use the Service, we use Google Analytics, a web analysis program of Google, and other analytical services.

3.10.       to comply with legal obligations

We may process, use, or share Your data due to legal requirements, particularly if a law enforcement agency requests Your data by available lawful means.

4.              Legal bases for collecting Your Personal Data (applies only to EEA-based users)

We process Your personal data, in particular, under the following legal bases:

(a)            Your consent. We rely on this legal basis to send You marketing communications.

(b)            for our legitimate interests. We rely on legitimate interests:

      To communicate with You regarding Your use of our Service.

      To research and analyze Your use of the Service. Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and can provide You with a better experience (for example, to make the use of the software more accessible and more enjoyable or to introduce and test new features).

      To send You marketing communications. The legitimate interest we rely on for this processing is our interest in promoting our Service in a measured and appropriate way.

      To enforce our Terms and to prevent and combat fraud. Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Service, and non-compliance with our Terms.

(c)            to perform our contract with You. Under this legal basis, we:

      provide our Service;

      customize Your experience;

      provide You with customer support; and

      communicate with You regarding Your use of our Service.

(d)            to comply with legal obligations.

5.              Who has access to Personal Data

Access to Your Personal Data may be provided to third parties who provide technical support for the operation of our website. We share information with third parties that help us operate, provide, improve, and customize our Service.

5.1.          service providers

We share personal data with third parties that we retain to provide services or perform business functions on our behalf based on our instructions. In particular, we may share Your personal information with the following types of service providers:

(a)            email services providers (GMail).

These third parties may use Your information only as directed by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing Your information for any other purpose.

5.2.          law enforcement agencies and other public authorities

We may use and disclose Personal Data to enforce our Terms, to protect our rights, privacy, safety, or property, and/or that of our affiliates, You, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

5.3.          third parties as part of a merger or acquisition

We may buy or sell assets or business offerings as we develop our business. Customers’ information is generally one of the transferred business assets in these transactions. We may also share such information with any affiliated entity (e.g., parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or the unlikely event of bankruptcy.

5.4.          professional advisors

We may disclose Your personal information to professional advisors and our contractors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

6.              How You can exercise Your Personal Data rights

You have the following rights regarding Your Personal Data:

6.1.          Accessing / reviewing / updating / correcting Your personal data. You have the right to review, edit, or change the personal data that You had previously provided to us in the profile section. Please send us a data access request if You would like to receive a copy of the data we process.

6.2.          Delete. You may also ask us to delete Your Personal Data, and we will honor Your request to the extent possible. In some instances, we may be legally required to keep Your Personal Data.

6.3.          Restrict. You may ask to stop or limit the processing of all or part of Your Personal Data.

Additional information for EEA-based users. If You are based in the EEA, You have the following rights in addition to the above:

(i)              The right to submit a complaint to the supervisory authority. We encourage You to contact us directly so that we can address all Your concerns. Nevertheless, You have the right to submit a complaint to a competent data protection supervisory authority, in particular in the EU Member State where You reside, work, or where the alleged infringement has occurred.

(ii)             The right to data portability. If You wish to receive Your personal data in a machine-readable format, You can request a copy of Your personal data as described above.

6.4.          Opt-out. You may ask us to stop sending You direct marketing communications. We may continue to send emails that relate to the Service provision and are not marketing-related.

6.5.          Object. Object to our reliance on our legitimate interests as the basis of processing Your Personal Data.

You can exercise the above-mentioned right and submit Your requests by emailing us at the address indicated in clause 11. We may request specific information to help us confirm Your identity and process Your request. Applicable law may require or permit us to decline Your request. If we decline Your request, we will tell You why subject to legal restrictions.

7.              International data transfers

We may transfer Personal Data to countries other than the country where the data was originally collected to provide the Service provided for in the Terms and for purposes indicated in this Privacy Policy. We deploy special safeguards if these countries do not have the same data protection laws as the country where You initially provided the information.

8.              Changes to this Privacy Policy

We may amend and modify our Privacy Policy from time to time. If our Privacy Policy or procedures change, we will immediately post those changes to our website. By continuing to access or use the Service after those changes become effective, You agree to be bound by the revised Privacy Policy.

9.              Data retention

We will retain Your personal data for as long as it is reasonably necessary for achieving the purposes specified in this Privacy Policy, which includes but is not limited to the period during which You are using the Service. We will also retain and use Your personal data to comply with our legal obligations.

10.           Contact details

You may contact us at any time for details regarding this Privacy Policy. For any questions concerning Your personal data or the exercise of Your privacy rights, please contact us at info@posex.ai.