Privacy Policy

INTRODUCTION

1.1 Important information and who we are

Welcome to Oblivious Software Limited’s Privacy and Data Protection Policy (“Privacy Policy”).

At Oblivious Software Limited (“we”, “us”, or “our”) we are committed to protecting and  respecting your privacy and Personal Data in compliance with the General Data Protection  Regulation (“GDPR”) laws.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy  will tell you about your privacy rights, how the law protects you, and inform our employees  and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

  • Customers
  • Business contacts
  • Users

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data  processed at any time by us.

1.2 Who is Your Data Controller and Data Protection Officer

Oblivious Software Limited is your Data Controller and responsible for your Personal Data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing  questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy,  including any requests to exercise your legal rights surrounding your Personal Data please  contact the DPO at hello@oblivious.ai or postal address: 6 JAMES' TERRACE, Malahide, Co Dublin, K36Y972, Ireland.

You have the right to make a complaint at any time to your local Data Protection Authority. We would, however, appreciate the chance to deal with your concerns before you approach the DPA so  please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with  your data on our behalf (known as “Processors”). Therefore, the responsibilities described  below may be assigned to an individual, or may be taken to apply to the organisation as a  whole. The Data Controller and our Processors have the following responsibilities:

  • Ensure that all processing of Personal Data is governed by one of the legal bases laid  out in the GDPR (see 2.2 below for more information on those bases);
  • Ensure that Processors authorised to process Personal Data have committed   themselves to confidentiality or are under an appropriate statutory obligation of  confidentiality;
  • Implement appropriate technical and organisational measures to ensure a level of  security appropriate to the risk associated with the processing of Personal Data;
  • Obtain the prior specific or general authorisation of the Controller before engaging  another Processor;
  • Assist the Controller in the fulfilment of the Controller's obligation to respond to  requests for exercising the data subject's rights;
  • Make available to the Controller all information necessary to demonstrate compliance  with the obligations laid down in the GDPR and allow for and contribute to audits,  including inspections, conducted by the Controller or another auditor mandated by the  Controller;
  • Maintain a record of all categories of processing activities carried out on behalf of a Controller;
  • Cooperate, on request, with the supervisory authority in the performance of its tasks;
  • Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
  • Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
  • Designate a data protection officer where required by the GDPR, publish their details  and communicate them to the supervisory authority; and
  • Support the data protection officer in performing their tasks by providing resources  necessary to carry out those tasks and access to Personal Data and processing  operations, and to maintain their expert knowledge;

LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

Personal Data” means any information about an individual from which that person can be  identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

  • Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
  • Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
  • Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
  • Usage Data: information about how you use our website, products and services.

We also collect Aggregated Data for page visits related analytics such as but not restricted to country of visitor, how a search engine was used to access our website link, duration for which the page was visited. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will  not directly or indirectly reveal your identity. However, if we combine or connect Aggregated  Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand  and serve you and others. For example, we may conduct research on your demographics and  usage. Although this aggregated data may be based in part on Personal Data, it does not  identify you personally. We may share this type of anonymous data with others, including  service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details  about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,  political opinions, trade union membership, information about your health, and genetic and  biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing  of Personal Data. The main avenues we rely on are:

Consent”: Certain situations allow us to collect your Personal Data, such as when you  tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to  a service.

Contractual Obligations”: We may require certain information from you in order to  fulfil our contractual obligations and provide you with the promised service.

Legal Compliance”: We’re required by law to collect and process certain types of data,  such as fraudulent activity or other illegal actions.

Legitimate Interest”: We might need to collect certain information from you to be able  to meet our legitimate interests - this covers aspects that can be reasonably expected as  part of running our business, that will not have a material impact on your rights,

freedom or interests. Examples could be your address, so that we know where to  deliver something to, or your name, so that we have a record of who to contact moving  forwards.

HOW IS YOUR PERSONAL DATA COLLECTED

3.1 Direct Interactions

You may give us your identity and contact data by filling in forms or by corresponding with us by phone, email or otherwise. This includes Personal Data you provide when you:

  • Inquire about or purchase our products or services and go on to use them
  • Speak to our support team
  • Request marketing to be sent to you
  • Give us feedback or contact us

3.2 Automated Technologies or Interactions

As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies. Please see the Cookie Declaration  for more information.

3.3 Third-parties or Publicly Available Sources


We will receive Personal Data about you from various third parties including:

  • Analytics providers such as Google and other third parties
  • Advertising networks such as LinkedIn and Google

HOW WE USE YOUR PERSONAL DATA

4.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table  containing the different types of Personal Data we collect and the lawful basis for processing  that data. Please refer to section 2.2 for more information on the lawful basis listed in the  table below.

Examples provided in the table below are indicative in nature and the purposes for which we  use your data may be broader than described but we will never process your data without a  legal basis for doing so and it is for a related purpose. For further inquiries please contact our  Data Protection Officer.



ActivityType of dataLawful basis for processing data
To use data analytics to improve the Website, products, services, marketing, customer relationshipsUsage Data(a) Legitimate Interest - To keep our website updated and relevant, to define types of customers for our products and services and develop our business
When you sign up to join our early access programContact Data
Marketing and Communications
(a) Consent - We ask for your email to be able to get back in touch with you about our early access program. (b) Necessary for our legitimate interest in order to grow our business and inform about our marketing strategy.

4.2 Marketing and Content Updates

You will receive marketing and new content communications from us unless you specifically  request that you would not like to receive these communications. From time to time we may  make suggestions and recommendations to you about goods or services that may be of  interest to you.

4.3 Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we  reasonably consider that we need to use it for another reason and that reason is compatible  with the original purpose. If you wish to get an explanation as to how the processing for the  new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will  explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in  compliance with the above rules, where this is required or permitted by law.

YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

5.1 How Does Oblivious Software Limited Protect Customers' Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate  disclosure. Any Personal Data collected by us is only accessible by a limited number of  employees who have special access rights to such systems and are bound by obligations of  confidentiality. If and when we use subcontractors to store your data, we will not relinquish  control of your Personal Data or expose it to security risks that would not have arisen had the  data remained in our possession. However, unfortunately no transmission of data over the  internet is guaranteed to be completely secure. It may be possible for third parties not under  the control of Oblivious Software Limited to intercept or access transmissions or private  communications unlawfully. While we strive to protect your Personal Data, we cannot ensure  or warrant the security of any Personal Data you transmit to us. Any such transmission is done  at your own risk. If you believe that your interaction with us is no longer secure, please contact  us.

5.2 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by You can ask us to stop  sending you marketing messages at any time by writing to us at hello@oblivious.ai.

Where you opt out of receiving these marketing messages, we will continue to retain other  Personal Data provided to us as a result of interactions with us not related to your marketing  preferences.

5.3 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other  rights). However, if your request is clearly unfounded, we could refuse to comply with your  request.

We may need to request specific information from you to help us confirm your identity and  ensure you have the right to access your Personal Data (or to exercise any of your other  rights). This is a security measure to ensure that Personal Data is not disclosed to any person  who has no right to receive it. We may also contact you to ask you for further information in  relation to your request to speed up our response.

YOUR DATA AND THIRD PARTIES

6.1 Will We Share Your Data With Third Parties?

We may also share Personal Data with interested parties in the event that Oblivious Software  Limited anticipates a change in control or the acquisition of all or part of our business or  assets or with interested parties in connection with the licensing of our technology.

If Oblivious Software Limited is sold or makes a sale or transfer, we may, in our sole discretion,  transfer, sell or assign your Personal Data to a third party as part of or in connection with that  transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the  further use of your Personal Data. In all other situations your data will still remain protected in  accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy.

HOW LONG WILL WE RETAIN YOUR DATA FOR?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we  collected it for. We may retain your Personal Data for a longer period than usual in the event of a  complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship  with you.

INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions outside  the US where Oblivious Software Limited has facilities. We are currently storing data in the EU and so,  by using Oblivious Software Limited, you are permitting and consenting to the transfer of information,  including Personal Data, outside of the US.

NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 2 July 2021. By using Oblivious Software Limited, you consent to the collection and use of  data by us as set out in this Privacy Policy. Continued access or use of Oblivious Software Limited will  constitute your express acceptance of any modifications to this Privacy Policy.

INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in  this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to  not respond to emails, even if they relate to a legitimate subject matter for which we have provided  an email address. As a matter of common sense, you are more likely to get a reply if your request or  question is polite, reasonable and there is no relatively obvious other way to deal with or answer your  concern or question (e.g. FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of Oblivious Software Limited, waive rights or make  representations (whether contractual or otherwise). If anything contained in an email from a Oblivious  Software Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Oblivious  Software Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Oblivious Software Limited legal department.