Privacy Policy

Effective as of October 7, 2026.

California Notice at Collection/State Privacy Rights Notice: See the State privacy rights notice section below for important information about your rights under applicable state privacy laws.

Gigatic LLC ("Gigatic," "we", "us" or "our") provides modern artificial intelligence ("AI") services for small and medium-sized businesses in the United States and Latin America, including AI automation, custom AI chatbots (including chatbots that operate on WhatsApp), AI integrations, AI content systems, analytics and AI consulting, and builds professional websites and online stores for small businesses. This Privacy Policy describes how Gigatic processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website at https://gigatic.com, our WhatsApp and other messaging channels, and our social media pages) as well as our marketing activities and other activities described in this Privacy Policy (collectively, the "Service").

NOTICE TO EUROPEAN USERS: Please see the Notice to European users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe", and "European" should be understood accordingly) below.

Your use of the Service is also governed by our Terms of Service. For information about cookies and similar technologies, see our Cookie Notice.

Personal information we collect

Information you provide to us

Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, email address, phone number (including your WhatsApp number), company or business name, professional title, and billing address. We collect this information when you fill in the contact form on our website, email us, message us on WhatsApp, or reach us through a social media advertisement (for example, a click-to-WhatsApp advertisement on Meta platforms).
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat or messaging features (such as WhatsApp or website chat), social media, email, or otherwise. This includes the content of your messages, voice notes and any attachments you send us.
Transactional data, such as information relating to or needed to complete your orders for our services, including the services you purchased, invoices, order numbers and transaction history.
Payment data needed to complete transactions. Payments are processed by a third-party, PCI-compliant payment processor. We do not store your full payment card number; we receive only limited information about the transaction (such as the last four digits of the card, the card type, the billing name and the payment status).
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Client business content and input data, such as product catalogs, photos, images, logos, prices, menus, business descriptions, opening hours, documents, messages, prompts and other content or information that you provide to us or make available through the Service so that we can build or operate your website, online store, chatbot or other deliverable, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources

We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

Public sources, such as government agencies, public records, business directories and listings, social media platforms, and other publicly available sources.
Social media and advertising platforms. When you contact us through an advertisement or page on a social media platform (for example, a click-to-WhatsApp advertisement on Meta platforms), the platform may provide us with information such as your name, phone number, profile information and the advertisement or campaign you responded to, as made available to us based on your settings on that platform.
Partners, such as marketing partners, referral partners and parties with whom we jointly offer products or services.
Customers. Our business customers may provide us with personal information about their personnel, customers or contacts so that we can build or operate their website, online store or chatbot on their behalf.
Service providers that provide services on our behalf or help us operate the Service or our business.
Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

Automatic data collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data, such as your interactions with our email, text, WhatsApp or other communications (e.g., whether you open and/or forward emails). We may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking & other technologies section below.

Data about others. You may share with us the contact details of other people (for example, colleagues at your business, or your own customers whose information we need in order to build or operate your website, store or chatbot). Please do not refer someone to us or share their contact details with us unless you have their permission to do so and, where you are a business customer, unless you have the legal right to share that information with us.

Tracking & other technologies

Cookies and other technologies. Some of our automatic data collection is facilitated by cookies and other technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

Chat and other artificial intelligence ("AI") technologies. We use chat and messaging technologies (such as WhatsApp and website chat features) and generative AI platforms provided by third-party service providers, which employ software code (and, on our website, cookies) to operate the chat, messaging and input features that you can use to communicate with us and to input your prompts, content and other data through the Service. These providers and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats or within inputs to facilitate the provision of the Service and for the purposes described in this Privacy Policy. We contractually require these providers to maintain appropriate data protection safeguards and prohibit them from using your data for generalized AI model training.

For information concerning your choices with respect to the use of tracking technologies, see the "Your choices" section of our Cookie Notice.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations

We may use your personal information to:

provide the Service, including to design, build, host, maintain and operate the websites, online stores, chatbots, automations, integrations, content systems, analytics and consulting deliverables that you engage us to provide;
enable security features of the Service;
establish and maintain your client record or user profile on the Service;
provide chat and messaging functionality, including AI-powered chat and WhatsApp features;
process your payments and manage billing, invoicing and collections;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
provide support for the Service, and respond to your requests, questions and feedback.

Service personalization

This may include using your personal information to:

understand your needs and interests;
personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate webpages.

Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For more information on analytics, see our Cookie Notice.

Marketing

Direct marketing. We may send you direct marketing communications (for example, by email or WhatsApp) and may personalize these messages based on your needs and interests. You may opt out of our marketing communications as described in the Opt-out of communications section below.

No interest-based advertising. We do not use your personal information to serve you interest-based or targeted advertising, and we do not share your personal information with third-party advertising companies for that purpose. We may advertise our own services on third-party platforms (such as social media platforms); any information those platforms collect about you when you see or interact with our advertisements is governed by their own privacy policies.

Compliance and protection

We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events

We may share certain personal information in the context of actual or prospective corporate events. For more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data

We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you, and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including analyzing and improving the Service and promoting our business. We do not use your personal information, or the content you provide to us, to train generalized AI models.

Further uses

In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).

Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business, such as hosting, information technology, customer support, AI providers (such as providers of chat functionality and other providers of generative AI and large language model technologies, which we contractually restrict from using your data to train generalized AI models), messaging platforms (such as the WhatsApp Business platform), email delivery, marketing, and website analytics.
Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our third-party, PCI-compliant payment processor, which may use your payment data in accordance with its own privacy policy. We do not store your full payment card number.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, for example when you ask us to integrate your website, store or chatbot with a third-party service (such as a messaging platform, payment service, booking system or CRM).
Partners. Third parties with whom we partner, including parties with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Gigatic, financing of Gigatic, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Gigatic as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Content that you ask us to publish on your website, online store, chatbot or other deliverable (such as your business name, address, contact details, product catalogs, photos and prices) is, by design, visible to the public. Messages you exchange with us privately are not made public. Information made public in this way can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states and Europe can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. Otherwise, you may ask us to review or update your information by contacting us at [email protected].

Opt-out of communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. You may opt out of marketing messages sent by WhatsApp or text message by replying "STOP" to the message or by contacting us. Please note that if you choose to opt out of marketing-related communications, you may continue to receive service-related and other non-marketing communications.

Cookies and other technologies. For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Notice.

Blocking images/clear GIFs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit https://allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to contact or connect with us through a social media account, WhatsApp or another third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content or close your account. If you wish to request deletion of content you have provided to us, or to close your account or client relationship with us, please contact us at [email protected]. Please note that content you have asked us to publish on your website, online store or chatbot may remain visible until the deliverable is updated or taken down, and that we may retain certain information as described in the Retention section.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Websites, online stores and chatbots that we build for our business customers are operated by those customers. Those customers are responsible for their own privacy practices and for providing their own privacy notices to their visitors and customers; this Privacy Policy does not apply to those properties unless they link to it.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the important information provided in the Notice to European users section about transfer of personal information outside of Europe.

Children

The Service is intended for businesses and for adults acting on behalf of a business. The Service is not intended for use by anyone under 18 years of age, and we do not knowingly collect personal information from children. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy related right that may be available to you, please contact us via one of the methods listed below.

Email: [email protected]
Mail: Gigatic LLC, Wyoming, United States

State privacy rights notice

Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the "State Privacy Laws").

This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. To confirm your identity, we will match the information you provide in your request against the information we hold about you (such as the name, email address or phone number you used when you contacted us or purchased our services), and we may send a confirmation message to that email address or phone number before acting on your request.

For purposes of this section, the term "Personal Information" has the meaning given to "personal data", "personal information" or other similar terms and "Sensitive Personal Information" has the meaning given to "sensitive personal information," "sensitive data", or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws. In some cases, we may provide a different privacy notice to certain categories of residents of these states, in which case that notice will apply instead of this section.

Your privacy rights

The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you.
Appeal. You can appeal our denial of any request validly submitted.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out.
- Targeted advertising. We do not process your Personal Information for targeted advertising purposes.
- Profiling/automated decision-making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.
- Sales of personal data. We do not sell your Personal Information within the meaning of State Privacy Laws.
Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.
Sensitive Personal Information. We do not intentionally collect or process Sensitive Personal Information.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your right to opt-out of the "sale" or "sharing" of your Personal Information

We do not sell your Personal Information for money, and we do not "share" your Personal Information with third parties for cross-context behavioral or targeted advertising within the meaning of the State Privacy Laws. Accordingly, there is currently no sale or sharing to opt out of. If our practices change, we will update this Privacy Policy and provide a means to opt out before engaging in any such activity. You may nonetheless submit an opt-out request at any time via email to [email protected] or by broadcasting the Global Privacy Control ("GPC") signal. We honor GPC signals as valid opt-out requests for the sale or sharing of Personal Information, as required by applicable law. When we detect a GPC signal from your browser, we will treat it as a request to opt out of the sale or sharing of your Personal Information. For more information about GPC, visit https://globalprivacycontrol.org.

Exercising other state privacy rights

You may submit requests to exercise any of the other state privacy rights listed above via email to [email protected]. Please include "Privacy Request" in the subject line and tell us which right you wish to exercise and the state in which you reside.

Verification of identity; authorized agents

We may need to verify your identity in order to process your information/know, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Information practices

The following describes our practices currently and during the past 12 months:

Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described above in this Privacy Policy.
Retention. The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
Deidentification. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Personal information that we collect, use and disclose

We have summarized the Personal Information we collect, the purposes for which we collect it and the third parties to whom we may disclose it by reference below to both the categories defined in the Personal information we collect section of this Privacy Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). This chart describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, chats or messages, may contain other categories of personal information not described below. We do not sell or share any of the categories of Personal Information listed below.

Personal Information ("PI") we collect	CCPA statutory category	Purposes	Categories of third parties to whom we "disclose" PI for a business purpose	Categories of third parties to whom we "sell" or "share" PI
Contact data	Identifiers; personal information categories listed in Cal. Civ. Code §1798.80(e); commercial information	Service delivery and operations; service personalization; service improvement and analytics; direct marketing; compliance and protection; corporate events	Affiliates; service providers (including hosting, IT, customer support, AI, messaging, email delivery, marketing and analytics providers); payment processors; professional advisors; authorities and others; business transferees	None
Communications data	Identifiers; personal information categories listed in Cal. Civ. Code §1798.80(e); audio, electronic, visual or similar information; internet or other electronic network activity information	Service delivery and operations; service personalization; service improvement and analytics; direct marketing; compliance and protection; corporate events	Affiliates; service providers (including AI and messaging providers); professional advisors; authorities and others; business transferees	None
Transactional data	Commercial information; identifiers	Service delivery and operations; service improvement and analytics; compliance and protection; corporate events	Affiliates; service providers; payment processors; professional advisors; authorities and others; business transferees	None
Payment data	Personal information categories listed in Cal. Civ. Code §1798.80(e); commercial information	Service delivery and operations (processing payments); compliance and protection	Payment processors; professional advisors; authorities and others	None
Marketing data	Identifiers; commercial information; inferences drawn from the above	Direct marketing; service personalization; service improvement and analytics	Affiliates; service providers (including email delivery and marketing providers); business transferees	None
Client business content and input data	Personal information categories listed in Cal. Civ. Code §1798.80(e); audio, electronic, visual or similar information; commercial information	Service delivery and operations (building and operating your website, online store, chatbot or other deliverable); service improvement and analytics; compliance and protection	Affiliates; service providers (including hosting and AI providers); third parties designated by you; the public (only for content you ask us to publish); professional advisors; authorities and others; business transferees	None
Device data, online activity data and communication interaction data	Identifiers; internet or other electronic network activity information; general (non-precise) geolocation data	Service delivery and operations; security; service personalization; service improvement and analytics; compliance and protection	Affiliates; service providers (including hosting, analytics and messaging providers); professional advisors; authorities and others; business transferees	None

Additional information for California residents

Shine the Light law. Under California's Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to [email protected]. In your request, you must include the statement "Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Additional information for Nevada residents

Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email [email protected].

Contact us

If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.

Notice to European users

General

Where this Notice to European users applies. The information provided in this "Notice to European users" section applies only to individuals in the United Kingdom and the European Economic Area (i.e., "Europe" as defined at the top of this Privacy Policy).

Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" (as defined in the GDPR), i.e., information about individuals from which they are either directly identified or can be identified.

Controller. Gigatic LLC is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU General Data Protection Regulation (Regulation (EU) 2016/679) and the so-called "UK GDPR" (as and where applicable, the "GDPR")). See the How to contact us section above for our contact details.

Processing on behalf of our business customers. Where we process personal information about the customers, contacts or personnel of a business customer in order to build or operate that customer's website, online store or chatbot, we generally do so as a processor acting on the instructions of that customer, who is the controller of that personal information. If you have questions about how such a customer handles your personal information, please contact that customer directly.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity").
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation ("Compliance with Law").
Where we have your specific consent to carry out the processing for the Purpose in question ("Consent").

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information. For more information on these Purposes and the data types involved, see How we use your personal information.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Contact data; communications data; transactional data; payment data; client business content and input data; device data	Contractual Necessity.
Security	Contact data; device data; online activity data	Compliance with Law. Legitimate Interests: we have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks.
Service personalization, improvement and analytics	Contact data; device data; online activity data; communication interaction data	Legitimate Interests: we have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences. Consent, in respect of any optional cookies used for this purpose.
Direct marketing	Contact data; communications data; transactional data; marketing data; communication interaction data	Legitimate Interests: we have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Compliance and protection	Contact data; communications data; transactional data; device data; any and all other data types relevant in the circumstances	Compliance with Law. Legitimate Interests: where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Data sharing in the context of corporate events	Any and all data types relevant in the circumstances	Legitimate Interests: we and any relevant third parties have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate, and, where relevant, to continue to operate, all or relevant part(s) of our operations). However, we would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate.
Research and development; to create aggregated, de-identified and/or anonymized data	Any and all data types relevant in the circumstances	Legitimate Interests: we have a legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Services operate as intended.
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for Compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No sensitive personal information. We ask that you not provide us with any sensitive personal information (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) on or through the Service, or otherwise to us. If you provide us with any sensitive personal information when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through the Service.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling which produces legal or similarly significant effects.

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests. You also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising these rights. You may submit these requests by email to [email protected] or to our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information). If we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your right to lodge a complaint with your supervisory authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area, the contact information for the data protection regulator in your place of residence can be found here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
For users in the UK, the contact information for the UK data protection regulator is below:
The Information Commissioner's Office
Water Lane, Wycliffe House
Wilmslow, Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk

Data processing outside Europe

We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

It is important to note that the U.S. is not the subject of an "adequacy decision" under the GDPR. Basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
Transfers to territories without an adequacy decision. We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above). However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe. For example, we rely on the standard contractual clauses approved by the European Commission (and, for transfers from the UK, the UK International Data Transfer Agreement or Addendum) for transfers of personal information to the U.S.; or
- in limited circumstances, we may rely on an exception, or "derogation", which permits us to transfer your personal information to such country despite the absence of an "adequacy decision" or "appropriate safeguards". For example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at [email protected].