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Personal Data Processing Policy

Personal data processing principles

Grove Tech AI s.r.o., with registered office at Varšavská 715/36, 120 00 Praha 1 - Vinohrady, ID No.: 21707146 (hereinafter also "we"), supplies services related to the development and implementation of artificial intelligence (hereinafter also "AI Services").

The provision of AI Services may involve the processing of personal data in which we act as data controllers. In this information document, we would like to inform you how we process personal data, on what legal basis, for how long we process personal data and what your rights are.

We also process personal data as data processors for our customers with whom you are employed or have another relationship. In this case, we enter into a processing agreement and it is the customer's responsibility to inform you of how they handle your personal data.

A. CONTENTS

In this document, you will learn the following information in turn:

  • Our commitment to data protection (Part B);

  • the personal data we process, including examples of the data we process (Part C);

  • the purposes of the processing of personal data, as well as the legal bases and periods of processing (Part D);

  • sharing of personal data (Part E);

  • Your rights in the processing of data and how to exercise them (Part F);

  • the possibility to lodge a complaint (Part G); and

  • amendments to this document (Part H).

B. OUR COMMITMENT TO DATA PROTECTION

We are committed to the security of the data we process. In order to prevent unauthorised access or disclosure of data, to ensure the accuracy of data and the proper processing of such data, we have taken a number of technical and organisational measures to ensure the protection of the personal data we process.

C. PERSONAL DATA PROCESSED

Personal data will be processed when providing AI Services and arranging mutual cooperation. For ease of reference, we have divided the following document into the different categories of personal data that we, as controllers, will process:

  • Identification data, which is your name and surname, or the name and identification of the company you represent. These are used to identify you as a contact person when we communicate together or when we enter into a contractual relationship.

  • Contact details, which are your email address and telephone number. This data is used to ensure that we can communicate with each other.

  • Information obtained from the contact form, i.e. information related to the message you leave us in the contact form on the Platform.

  • Billing data, which is payment information, bank account number, responsible party information and other personal data that we process for the purpose of billing for our services.

  • Contractual data, which is information about the course of service provision, such as the agreed date of service provision (AI development and implementation), other information obtained in the course of service provision, such as technical consultation or strategic planning.

  • Client portal user account data and related service data, which is user account data, logs from the client portal, reports and other information exchanged in the course of service provision and other activities.

  • Communication Data, which is the information you provide in the contact form on the Site, the content of an email, or other information we exchange in our communications with each other.

  • Data from reviews, i.e. your identification, identification of the company where you work, the text of the review, which we use on the site in the relevant tab(s) for the purpose of presenting our major projects and clients.

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D. PURPOSES OF PROCESSING PERSONAL DATA

In the first part of this section, we describe the processing of your data related to the provision of our products and services. In the second part we further describe the processing related to the use of our website.

Processing of personal data in connection with the provision of our services

D.1 Provision of AI Services and related information

We primarily process personal data to provide you with services related to the development and implementation of AI services and to deal with you as a customer. This processing includes the use of personal data for the purposes of sending you a quotation, entering into a contract and the subsequent provision of the services themselves (communication to arrange dates for the provision of the implementation, dealing with analyses, adjustments), other contractual communication, making the client portal available, dealing with service requests and invoicing for the services provided. As part of this purpose, we also use your personal data for the purposes of pre-contractual negotiations, gathering background information, etc.

For this purpose, we process your Identification Data, Contact Data, Information obtained from the contact form, Billing Data, Data from the contractual relationship, Data from Client Portal user accounts and related service data, Data contained in communications.

We obtain your personal data through the contact form on the website, or by establishing cooperation by telephone or in person when we meet with you.

The legal basis for this processing is the performance of the contract between you and us and the necessity to take action at your request before entering into the contract, or, where you are not directly party to the contract (if you are, for example, an employee of the customer), our legitimate interest in the performance of any contract entered into. The data is processed for the duration of the contract entered into and for the time necessary for the performance of the obligations under such contract, or until the expiry of 3 years from the acquisition of the data if no contract has been entered into (and in the event that there is a subsequent renewal of possible cooperation).

D.2 Protection of our rights and legal interests

In the course of providing the AI Services and performing the mutual contractual relationship, there may also be situations where we will deal with your challenges, claims, etc. Although we do not anticipate it, there may be disagreements or problems within our mutual relationship. In this case, we may process your personal data in order to protect our rights and legal interests. In particular in connection with proceedings before judicial authorities and other public authorities, or in connection with the internal handling of your claims.

For this purpose, we process your Identification Data, Contact Data, Information obtained from the contact form, Billing Data, Data from the contractual relationship, Data from client portal user accounts and related service data, Data contained in communications.

The legal basis for this processing is our legitimate interest in protecting our rights and legal interests.

Personal Data is generally retained for the duration of the statutory limitation period, including any suspension or interruption of that period, but generally no longer than 10 years after the provision or termination of the contract with us. In the event that judicial, administrative or other proceedings are initiated, we process your personal data to the extent necessary for the duration of such proceedings.

D.3 Compliance with legal obligations

We may also process your personal data to comply with our legal obligations, in particular in the areas of accounting and tax. At the same time, we need to be prepared to provide assistance to government authorities if we are required to do so by law.

For this purpose, we process your Identification Data, Contact Data, Billing Data, Contract Data, Client Portal user account data and related service data, Data contained in communications.

The legal basis for this processing is the performance of our legal obligations.

The data is processed for the time period specified by law, for example in the area of taxation for up to 10 years.

D.4 Publication of reviews

We also publish on the website interesting contracts and references in which we have been involved. We do this by mutual agreement with you or the company you work for. The purpose of this processing is to present our important clients and interesting assignments.

For this purpose, we process your Data contained in the awarded reviews.

The legal basis for this processing is our legitimate interest in promoting our services.

The data is processed for as long as the information is published on the website.

D.5 Improving our services

We may process data about how you have found out about us, how the cooperation takes place, so that we can better adapt and subsequently improve our services.

For this purpose, we process your Identification Data, Information obtained from the contact form, Billing Data, Contract Data, Data from Client Portal user accounts and related service data, Data contained in communications.

The legal basis for this processing is our legitimate interest in improving our services and the data is processed for a maximum period of 3 years from the date of collection.

E. SHARING OF PERSONAL DATA

As a data controller, we determine the purposes for which we obtain and process your personal data as set out above, choose the means of processing your data and are responsible for the proper processing of such data.

At the same time, we may share personal data with third parties who help us provide you with artificial intelligence services and our other services. These parties act as our data processors (or recipients). Specifically, these are:

  • Cloud storage and infrastructure providers;

  • providers of service response systems;

  • developers and others who work with us under collaboration agreements and similar arrangements;

  • an external accounting firm;

  • CRM system providers.

In addition to this, we may share your personal data with certain third parties in their capacity as data controllers where we are obliged to do so under applicable legislation (in particular, administrative authorities, police authorities and judicial authorities) in the context of the purpose of "Fulfilling Legal Obligations". Similarly, we may be required to share your data with persons who claim to have been harmed by your conduct.

Where we share your personal data with controllers and processors in third countries (outside the EEA), we only do so where there is a decision by the European Commission that a particular country outside the EEA provides an adequate level of data protection, including where controllers or processors have adopted additional data protection measures such as Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SCCs).

F. YOUR PROCESSING RIGHTS AND THE POSSIBILITY OF EXERCISING THEM

Just as we have rights and obligations when processing your personal data, you have certain rights when processing your personal data as set out in the following paragraphs. You have the right to (i) request access to your personal data; (ii) withdraw your consent; (iii) request the rectification of your personal data; (iv) request the erasure of your personal data; (v) request the restriction of the processing of your personal data; (vi) request the portability of your personal data; (vii) object to the processing of your personal data; or (viii) lodge a complaint with the relevant supervisory authority.

For all issues related to the processing of your personal data, whether it is a question, exercise of rights, sending a complaint to us, etc., you can contact terry@grovetechai.com.

Your request will be processed without undue delay, at most within 1 month. In exceptional cases, in particular due to the complexity of your request, we are entitled to extend this period by a further 2 months. We will, of course, always inform you of any such extension and the reason for it.

You also have the right to lodge a complaint with the supervisory authority as described below.

F.1 Right of access

You have the right to obtain confirmation from us as to whether or not we are processing your personal data.

If we do process your personal data, you also have the right to request access to information about the purpose and scope of the processing, the recipients of the data, the duration of the processing, the right to rectification, erasure, restriction of processing and to object to processing, the right to lodge a complaint with a supervisory authority and the sources of the personal data (this information is already set out in this document).

You can also ask us for a copy of the personal data we process. We provide the first copy free of charge, others may already be subject to a fee. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.

F.2 Right to withdraw consent

You have the right to withdraw your consent to the processing of personal data at any time. However, the withdrawal of consent does not affect the lawfulness of the processing prior to the granting of such consent, nor does it lead to the termination of the processing of personal data that has already been anonymised.

F.3 Right to rectification

You have the right to request us to correct inaccurate personal data concerning you. Depending on the purpose of the processing, you may also have the right to have incomplete personal data completed, including by providing an additional declaration.

F.4 Right to erasure (right to be forgotten)

You have the right to request the erasure of your personal data where:

  • We no longer need your personal data for the purposes for which they were collected or processed;

  • you withdraw the consent on the basis of which the personal data was processed and there is no further reason for processing it:

  • you object to processing and there are no other overriding reasons for processing, or you object to processing for direct marketing purposes;

  • the personal data are processed in breach of the law.

However, you cannot exercise this right if the processing is necessary for compliance with our legal obligations or for the performance of tasks entrusted to us in the public interest or for the establishment, exercise or defence of legal claims.

F.5 Right to restriction of processing

You have the right to request restriction of the processing of your personal data where:

  • you contest the accuracy of your personal data; in this case, you may request the restriction of processing until the accuracy of the personal data has been verified;

  • the processing is in breach of the law and instead of erasure you request restriction of the processing of your personal data;

  • We no longer need your personal data for the purposes for which it was collected or processed, but you require it for the establishment, exercise or defence of legal claims;

  • you have objected to the processing of your personal data; in this case, you may request a restriction of processing pending verification that our legitimate interests prevail.

F.6 Right to portability

You have the right to obtain a copy of your personal data that we process by automated means on the basis of your consent or for the performance of a contract. We will transmit this data in a commonly used and machine-readable format to you or to a controller designated by you, if technically feasible. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.

F.7 Right to object

You have the right to object to the processing of your personal data that we process on the basis of our legitimate interest. We will stop processing your data if there are no other overriding reasons for the processing or if the processing is not necessary for the establishment, exercise or defence of legal claims or if you object to processing for direct marketing purposes.

G. THE RIGHT TO LODGE A COMPLAINT

In addition to exercising your rights with our company, you may also file a complaint with the relevant supervisory authority, which is the Office for Personal Data Protection located at Pplk. Sochora 27, 170 00 Prague 7.

H. CHANGES TO THIS PROCESSING INFORMATION

This document is effective from 08.07.2024. We are entitled to change this processing information from time to time, so please check it regularly. We will post any changes to this document on our website.

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