ASKEL.AI OÜ PRIVACY NOTICE

Last updated: December 2024

This Privacy Notice describes how Askel.ai OÜ processes the personal data of representatives of its business partners and customers, business partners who are natural persons, and individuals who visit our website at www.askel.ai (“you”). The Privacy Notice also describes the privacy rights available to you.

• CONTROLLER OF PERSONAL DATA

The controller of your personal data is Askel.ai OÜ (“Askel.ai”, “we”). Askel.ai is responsible for ensuring that your personal data is processed in accordance with this Privacy Notice and applicable personal data protection laws, in particular with the General Data Processing Regulation (EU) 2016/679 (“GDPR”).

Contact details of the controller:

Askel.ai OÜ

Estonian registry code: 16902242

Address: Almare tee 5, Vääna-Jõesuu, 76909 Harku, Estonia

E-mail: [email protected] 

• WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?

1. 1. Data we process about our business partners and their representatives

If you are (a) our current or prospective business partner as a natural person or (b) a representative of our current or potential business partner or customer or (c) a user authorised on behalf of our customer to use our services, we primarily collect your personal data directly from you when you order services from us or when we order goods or services from you, or when you otherwise communicate with us. We may also receive your personal data from legal persons with whom we have a contractual relationship or through the use of cookies and similar technologies in accordance with section 4 of the Privacy Notice. To the extent permitted by applicable law, we may also collect your personal data from third parties, such as online databases, government authorities etc.

Due to our contractual and statutory rights and obligations related to our business relationship, we may process the following personal data about you:

• General personal data, such as your name and the language of communication;
• Contact details, such as your e-mail address and phone number. 
• In case you are representative of a legal person, data about your employer and your position, as well as information on your authorisation (right of representation);
• Details of your Google account that you use to access our services and software, including your name, e-mail address and photo (if included to your Google account).
• Information related to our contractual relationship, such as data on inquiries and responses, feedback on our business activity, data on invoicing and transactions (including information on completed sales, fees payable and tax liabilities), details of the contract concluded between the business partner and us;
• Data about the use of our services and software, such as analytics and log data associated with the user.
• Data related to a breach of the contract, such as nature and time of the breach;
• Data about our marketing activities towards you, such as information about the undertaken marketing activities (e-mails, calls, meetings).

We may also collect other personal data about you that you voluntarily provide to us in the course of our contractual relationship. You can provide us with other personal data if you wish, but this is not required for the purposes related to our contractual relationship.

1. Data we process about the visitors of our website

If you are a visitor of our website, we collect your personal data (a) through the use of cookies and similar technologies in accordance with section 4 of the Privacy Notice, and (b) directly from you when you schedule a meeting with us or subscribe to our newsletter through our website. 

Through the use of cookies and similar technologies, we collect information about your IP address, used devices, usage of our website, navigation, analytics and log data associated with the use and engagement with our website.

When you schedule a demo of our services through our website, we will collect and process your name, email and information you wish to disclose about your company and operations.

When you subscribe to our newsletter, we collect and process your email address that you provide to us.

• PURPOSE AND LEGAL BASIS OF DATA PROCESSING

• Purposes and legal bases for processing the personal data of our business partners and their representatives

We may process the personal data of our contractual and business partners’ representatives for the following purposes and on the following legal bases:

1. Establishing relationships with potential business partners and customers, including by contacting leads or target customers via phone, e-mail or otherwise, and marketing our products services. For these purposes, the legal basis for the processing of your personal data is our legitimate interest in business development (Article 6(1)(f) of the GDPR).
2. Management of business relationships and offering services to our customers. For these purposes, the legal basis for the processing of your personal data is usually our legitimate interest in maintaining business relationships and providing our services to our customers (Article 6(1)(f) of the GDPR). Where we have a business relationship directly with you as a natural person, the legal basis for processing your personal data for this purpose is the necessity to perform our obligations under the contract entered into with you (Article 6(1)(b) of the GDPR).
3. Managing and responding to customer inquiries and support requests. For this purpose, the legal basis for the processing of your personal data is our legitimate interest in maintaining a high level of customer service (Article 6(1)(f) of the GDPR) or taking steps at your request prior to entering into a contract with you (Article 6(1)(b) of the GDPR).
4. Improving and developing our service, including for security purposes. For these purposes, the legal basis for the processing of your personal data is our legitimate interest in enhancing the functioning of our services, conducting analytics, improving access to content that Askel.ai publishes, and ensuring the technical availability and security of our services (Article 6(1)(f) of the GDPR). Where we use cookies for these purposes, we ask for your consent for the placement of optional cookies in accordance with section 4 of this Privacy Notice.
5. Establishing, exercising and defending any potential legal claims. Where the processing of your personal data is necessary for taking action on legal claims or for compliance, regulatory and investigative purposes, the legal basis for the processing of your personal data is our legitimate interest in establishing, exercising and defending legal claims (Article 6(1)(f) of the GDPR).
6. Complying with our legal obligations deriving from applicable law. For these purposes, the legal basis for the processing of your personal data is the respective legal provision obliging us to process the relevant data (in accordance with Article 6(1)(c) of the GDPR). Such legal obligations may derive, for example, from accounting and tax laws.

• Purposes and legal bases for processing the personal data visitors of our website

We may process the personal data of the visitors of our website for the following purposes and on the following legal bases:

1. Improving and developing our website, including for security purposes. For these purposes, the legal basis for the processing of your personal data is our legitimate interest in enhancing the functioning of our website, conducting analytics, improving access to content that Askel.ai publishes, and ensuring the technical availability and security of our website and services (Article 6(1)(f) of the GDPR). Where we use cookies for these purposes, we ask for your consent for the placement of optional cookies in accordance with section 4 of this Privacy Notice.
2. Scheduling meetings with you. Our website enables you to book a demo of our services. When you book a demo with us, the legal basis for the processing of your personal data is our legitimate interest in business development (Article 6(1)(f) of the GDPR) or taking steps at your request prior to entering into a contract with you (Article 6(1)(b) of the GDPR).
3. Sending newsletters. You can subscribe to our newsletter through our website. When you do so, we process your personal data based on your consent (Article 6(1)(a) of the GDPR). You can withdraw your consent at any time by clicking the “unsubscribe” button in our newsletter.

• COOKIES

We may use web cookies and other similar technologies (hereinafter “Cookies”) on our websites and in our customer application. Cookies are small bits of information that are placed on your device. For instances, Cookies enable us to remember information about your activities and preferences on our website to make the use and navigation more efficient and user-friendly by providing you a more customised experience when you use our website or our application. These Cookies are divided into essential and optional Cookies. 

Essential Cookies are necessary to make our website work and function properly. As these Cookies are strictly necessary for the functioning of our website, and your consent is not required for their use according to applicable law and therefore they cannot be turned off. We use these Cookies based on our legitimate interest to keep our website functional.

Optional Cookies are placed on your device only if you give your consent for this. Optional cookies are not strictly necessary for the functioning of the website, but for instance, they enable us to analyse the performance and design of our website (e.g., they enable us to see which sections of our website are the most popular, how much time is spent by users on each section, etc.). For such analytics, we may use third party cookies such as (without limitation) Google Analytics. Optional Cookies also enable us to record data about your actions on the browser (tracking Cookies). Such cookies may also be used for targeted marketing. We use such optional Cookies only if you give us your consent to place and use these Cookies.

Please note that the Cookies are divided into two categories with different storage times on your device. Temporary session cookies are set per each use session and stored on your device until you close your device or browser. Persistent cookies are stored on your device after you have finished browsing until they expire or are deleted.

If you want to remove or block optional Cookies described herein, you can update your browser settings. Please be aware that the rejecting of Cookies may affect your user experience on our website.

• RECIPIENTS OF YOUR PERSONAL DATA

We may disclose your personal data to the following third parties:

• if permitted or required by applicable law, we submit your data to tax authorities and other authorities;
• if our trusted service providers (such as IT-service providers, payroll and accounting service providers, etc) provide services to us in accordance with our instructions, we may disclose your personal data to our service providers. In these cases, we will control and remain responsible for the use of your personal data at all times;
• statistical browsing data may be accessible to our partners, who provide us with tools for analytics; 
• in connection with our merger, takeover or sale of all or part of our business as well as raising capital and investments, we may disclose your personal data to our investors, acquirers, legal advisors, tax advisors, auditors, etc;
• if we, in good faith, believe that disclosure of relevant data is necessary to protect your rights, to ensure safety, to investigate fraud or other offences or if the disclosures are necessary for the establishment, exercise and defence of legal claims. In such cases, the recipients may include law enforcement agencies, other public authorities, legal advisors and courts;
• banks and other financial service providers;
• internal and external auditors.

We make every effort to keep your personal data safe and always require a high level of security and confidentiality from our employees and partners.

Askel.ai may transfer personal data outside of the European Economic Area from time to time. If we do so, we take all measures to ensure that transfers outside the European Economic Area are adequately protected as required by applicable law. With respect to transfers to countries not providing an adequate level of data protection, Askel.ai bases the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to receive more information about data transfers and the safeguards that we apply to them, please contact us at the contact details provided above in Section 1.

• RETENTION OF PERSONAL DATA

We process and retain your personal data for as long as necessary to achieve the specific purposes described in this Privacy Notice, including to comply with legal requirements applicable to us.

Most of your personal data will be retained until the end of the relevant contractual relationship. Certain personal data may be retained after the end of the contractual relationship if required or permitted by applicable law. For example, we retain the accounting source documents (e.g., copies of invoices) for 7 years from the end of the relevant financial year when a business transaction was recorded, as required by applicable law.

In some cases, personal data may be retained for a longer period if storage of personal data is required in order to protect our or any third parties’ legitimate interests, e.g. in case of a legal dispute.

We will delete or anonymise your personal data when processing is no longer necessary for intended purposes.

• YOUR RIGHTS

Subject to the restrictions and conditions set out in law, you have the following rights as a data subject:

• to request access to your personal data;
• to request rectification of your personal data;
• to request erasure of your personal data; 
• to request the porting of your data from us to another controller where the processing is based on your consent or the contract concluded with you;
• to request restriction of processing of your personal data;
• to object to the processing of your personal data, for example, when we process your personal data for marketing purposes, you always have the right to object to such processing;
• to withdraw your consent where the processing is based on your consent.

If you think there is a problem with the way we are handling your personal data, you have a right to lodge a complaint to your national data protection authority in the EU/EEA, or seek judicial remedy. In Estonia, the competent supervisory authority is the Estonian Data Protection Inspectorate. You can find contact details of the Estonian Data Protection Inspectorate here: www.aki.ee. However, we encourage you to first contact us with any concerns that you may have, although you have no obligation to do so.

• SECURITY MEASURES

We use reasonable security measures (including physical, electronic and administrative) to protect your personal data from loss, destruction, misuse and unauthorised access or disclosure. For example, we only grant access to your personal data to authorised employees and contractors who need it to perform their duties.

Please note that while we take reasonable steps to protect the security of your personal information, no system completely eliminates all potential security risks.

• UPDATES

From time to time, we may update this Privacy Notice in order to adapt it to any updates that might arise. In such a case, we will notify you via the e-mail that you have communicated us. This Privacy Notice was last updated as of the “Last updated” date shown above.