Polityka prywatności

1Scope of this policy

Sereda.ai OÜ (“we”, “us”, “our”, “Company”, “Sereda.ai“) is committed to protecting your privacy. On this page, you can learn what information about you we collect while you interact with Sereda.ai and how we process the personal data you provide us with.

This Policy is intended to help you understand:

• why we collect your personal data;
• how we collect, use, and store your personal data;
• which rights relating to your personal data you have;
• how you can exercise the rights relating to your personal data;
• how we use cookies and other tracking technologies;
• how we share and disclose your personal data.

This Privacy Policy (“Policy”) applies between you and Sereda.ai. It describes how we handle the data you provide us with through our website https://sereda.ai (“Website”) and web application Sereda.ai (“Platform”), including via contact forms, when you interact with us via our email address support@sereda.ai, or on our social media sites, including but not limited to, LinkedIn, Facebook, and Instagram (“Social media accounts”), during video or phone calls or otherwise provide us with information about yourself.

When processing your personal data, Sereda.ai can play different roles under the GDPR and other applicable laws and regulations. Depending on the factual circumstances of the processing, we may act as a data controller or data processor under the GDPR.

You can be a Website Visitor, Demo Requester, Client, or Client’s Employee or Contractor:

• You are a Website Visitor when you merely browse our Website and provide us with your data through cookies and other tracking technologies or contact us via email or Social media accounts;
• You are a Demo Requester when you fill in the Request a Demo form available on the Website and request a demo of our services;
• You are a Client when you purchase our services and maintain an account on the Platform, contact us via email, contact forms available on our Website, or our Social media accounts for assistance and/or to leave feedback, share personal data during video or phone calls, or otherwise provide us with personal data when you use our services or when your testimonials published on our Website;
• You are a Client’s Employee or Contractor when our Client provides your personal data while using our services, and we process your personal data as a data processor on behalf of our Client.

2Interpretation and definitions

We use the following definitions in this Policy:

“GDPR” means the General Data Protection Regulation (Regulation (EU) 2016/679).

“CCPA, as amended” means the California Consumer Privacy Act as amended with the California Privacy Rights Act.

“data controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and how any personal data is processed.

“data processor” means the natural or legal person who processes personal data on behalf of the data controller.

“data subject” means a person who can be identified, directly or indirectly, by details like their name, identification number, location, online identifier, or factors related to their physical, physiological, genetic, mental, economic, cultural or social identity.

“personal data” means any information relating to the data subject and helping identify the data subject (directly or indirectly), such as a name, last name, email, location, etc.

“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3Types of personal data we collect

We collect and process information about you in accordance with this Policy. We may collect your personal data through the Website (including contact forms) and Platform, email, Social media accounts, during video or phone calls, or via other ways of communication.

We collect the following types of information about you in connection with our Website and services: Website Visitor Data, Demo Requester Data, Client Data, and Client’s Employee or Contractor Data, which relate to Website Visitors, Demo Requesters, Clients, and Client’s Employees or Contractors, respectively. In particular, we collect the following:

Website Visitor, Demo Requester, and Client Data:

(a) Contact Information. When you contact us via email, Social media accounts or share your personal data during video or phone calls, we may collect your personal data. This information may include your first name, last name, email, and any other details you provide to us.

(b) Communication Information. We may collect certain information during our communications with you, such as the content of emails, messages, or video/phone conversations. This can include a brief summary of the discussion, key details relevant to our interaction, or, with your consent, a recording of the call.

(c) Cookies Information. We may use cookies and other tracking technologies on our Website to function correctly, for analytics, marketing activities, remembering your preferences, and for other purposes. Such use may involve the transmission of information from us to you and from you to a third-party website or us. To learn more regarding our use of cookies, please, read the ‘Use of cookies’ section of this Privacy Policy and our Cookies Policy.

(d) Automatically Collected Information. When you access the Website, we may collect certain information about your device automatically. We may use this information for technical administration of our Website, analytics, research and development, monitoring and improving our Website.

(e) Demo Request Information. When you fill in the Request a Demo form, we may collect your name and surname, position, phone number, email, your company name, and the number of employees in your company.

(f) Payment Information. We can collect financial details or banking information in conjunction with other information needed for invoicing and bookkeeping purposes, such as your full name, email, phone number, company name, job title, and other transactional details to obtain payment from your company.

(g) Registration Information. We may collect and process your information when you register and maintain an account on our Platform. This information may include your full name, position, phone number, email, your company name, information about team members (their emails, names and surnames, positions), etc.

(h) Connected Accounts Information. When you connect other services to your account on our Platform, we may collect and process some data regarding the connected Social media account (Telegram, Viber, WhatsApp, Slack) to send you notifications regarding our services.

(i) AI Functionality Information. We can process some data when you use our AI functionality  (the input text content, generated text content, and information about the Client which uses the functionality).

(j) Testimonials. We may publish the Client’s testimonials with feedback regarding the use of our services. Such testimonials may include the full name, job title, company name, and text of testimonial.

Client’s Employee or Contractor Data:

(k) Client’s Employee or Contractor Information. We can have access to data provided by our Client for the performance of services to our Client by us. In this case, the exact categories of personal data and the respective legal basis for processing are determined by the Client.

We use the personal data we collect and process only for the purposes listed in this Policy. We may share personal data with third parties solely for the purposes listed herein.

4Grounds for processing

We collect and process your personal data in accordance with the provisions of the GDPR and other applicable laws and regulations.

Under the GDPR there is an exclusive list of lawful bases, allowing us to process your personal data. During personal data processing, we rely only on four of them, namely:

Article 6.1(a): consent

We collect the information you choose to give us, and we process it under your consent. You may withdraw your consent to the processing of your personal data at any time.

You may withdraw your consent to the processing of your personal data by emailing us at support@sereda.ai or contacting us in any other way convenient for you.

Article 6.1(b): performance of a contract

When you provide us with personal data via available options on our Platform, this can be considered a request to form a contract or perform a contract between you and us. However, we may ask you for clear consent in case of doubt.

Article 6.1(c): legal obligation

We process your personal data to fulfil our legal obligations, such as complying with tax or regulatory requirements. If you request to exercise your rights under the GDPR, we may ask you for some personal data for verification purposes to identify you and comply with the applicable law.

Article 6.1(f): legitimate interest

We process your personal data for the purposes of our legitimate interests, such as:

• preventing fraud,
• ensuring the security of our Platform, and
• providing you with a seamless user experience.

We only collect and use the strictly necessary data to achieve these purposes, provided that your fundamental rights and freedoms are not overridden.

5How we use your data

When acting as a data controller, we use your personal data for the purposes listed in the table below, where we also detail the types of personal data processed, legal bases we rely on to do so, third parties with whom we may share your personal data and information on the source of such data:

We can also process personal data as a data processor, at the request and pursuant to the instructions given by our Client as a data controller or by the respective data controller if our Client acts as a data processor. We describe the situation when we act as a data processor and process personal data on behalf of the Client in the table below:

6Use of cookies

When you visit our Website, we automatically gather certain information through cookies. These cookies, for example, can help us understand your interactions with our Website, enhance your browsing experience, improve our Website and services, and conduct marketing activities. To learn more about the types of cookies we use and how you can customize your cookie preferences, please review our detailed Cookies Policy.

7Data retention

We keep personal data for as long as needed to fulfil the purposes outlined in this Policy.

We store Cookies Information for the period specified in our Cookies Policy.

We store Demo Request Information for the entire period when you use our demo subscription and for 90 days after its expiration, unless you upgrade to a paid subscription for continued use of the service. If a project is moved to a free plan, the company reserves the right to delete all data without additional notice.

We store Registration Information for the entire period when you use our services and for 90 days after the termination of your account on the Platform or after you stop paying the subscription fee.

We store Payment Information for the entire period when you use our services and for 90 days after the termination of your account on the Platform or after you stop paying for the services.

As a data processor, we process Client’s Employee or Contractor Information for the period established by the Client as the data controller in the data controller’s instructions.

We may not delete or anonymise your data if we are compelled to keep it under the GDPR and other applicable laws and regulations.

Notwithstanding any of the aforementioned periods of data storage, you may request to delete your personal data by emailing us at support@sereda.ai or contacting us in another convenient way.

8Security and integrity of the data

We have implemented appropriate organisational, technical, administrative, and physical security measures designed to protect your personal data from unauthorised access, disclosure, use, and modification. We regularly review our security procedures and policies to consider appropriate new technology and methods.

9Sharing your data with other entities

We may share your personal data with other entities in accordance with the provisions specified hereafter.

Sharing personal data with joint controllers

We act as the joint controller when cooperating with Meta Platforms Ireland Limited, namely when we use Meta Pixel. For this personal data processing case, we are the party to Meta’s Controller Addendum.

In particular, Meta Platforms Ireland Limited and we act as joint controllers with regard to:

• marketing and statistical data collected by Meta and shared with us via Meta Pixel; and
• emails of the clients we can provide Meta with to customize the advertising of our services.

When we act as a joint controller for a particular processing of personal data, a data subject may exercise their rights under the GDPR and other applicable laws and regulations in respect of and against both joint controllers.

Sharing personal data with other controllers

Google LLC and we act as independent controllers of personal data across Google LLC’s digital marketing services, such as Google Ads and Google Tag Manager. You may read Google LLC’s Privacy Policy here.

Sharing data with data processors

There are many features necessary to provide you with our services that we cannot complete ourselves; thus, we seek help from third parties. We may grant some service providers access to your personal data, in whole or part, to provide the necessary services.

Therefore, we may share and disclose your personal data to other data processors, namely, to:

• Google Analytics (Google Ireland Limited, Ireland): for Website analytics purposes. You may read its Privacy Policy here.
• Google Cloud Platform (Google Ireland Limited, Ireland): for managing and storing data. You may read its Privacy Notice here.
• Google LookerStudio (Google Ireland Limited, Ireland): for financial reporting and accounting analysis purposes.  You may read its Privacy Policy here.
• Jira (Atlassian Corporation, Australia): for workflow organization and team collaboration purposes. You may read its Privacy Statement here.
• Merit Software (Datastart (Wales) Ltd., UK): for invoicing, accounting, and bookkeeping purposes. You may read its Privacy Policy here.
• OpenAl (OpenAI OpCo, LLC, USA): for AI-driven automation and content generation purposes. You may read its Privacy Statement here.
• Anthropic (Anthropic PBC, USA): to provide artificial intelligence-based functionality. You may read its Privacy Statement here.
• QuickBooks (Intuit Inc., USA): for invoicing, accounting, and bookkeeping purposes. You may read its Privacy Statement here.
• Ringostat (Netpeak LTD, UK): for customer relationship management purposes. You may read its Privacy Policy here.
• SendPulse (SendPulse Inc., USA): for marketing purposes. You may read its Privacy Statement here.
• Resend (Plus Five Five, Inc., USA): for sending transactional emails, including registration, account login, and service notifications. You may read its Privacy Statement here.
• Postmark (ActiveCampaign, Inc., USA): for sending transactional emails and ensuring delivery of service communications. You may read its Privacy Statement here.
• Slack (Slack Technologies, LLC, USA): for workflow organization and team collaboration purposes. You may read its Privacy Policy here.
• Stripe (Stripe, Inc., USA): for financial transactions and accounting purposes. You may read its Privacy Statement here.
• Tableau (Tableau Software LLC (Tableau), USA): for Website analytics purposes. You may read its Privacy Statement here.
• Wise (Wise Payments Limited, UK): for financial transactions and accounting purposes. You may read its Privacy Statement here.

As part of our business operations, we may engage various specialists who may receive your personal data, including technical, sales, legal, and marketing professionals, to provide you with better client service. Collectively, these specialists are referred to in this Policy as Contractors.

10International data transfers

We may transfer your personal data to countries outside the European Union (EU) and the European Economic Area (EEA) that are not deemed to provide an adequate level of data protection under Article 45 of GDPR (adequacy decision).

In such cases, we will ensure that appropriate safeguards are implemented in accordance with the GDPR to protect your personal data, in particular, the standard contractual clauses adopted by the European Commission. Where possible, we always enter into Data Processing Agreements (DPAs) and Non-Disclosure Agreements (NDAs) with these third parties to ensure that your personal data is adequately protected.

We put supplementary technical and organisational measures in place when transferring data outside the EU and the EEA. e.g. prior assessment of the service supplier’s reliability and personal data protection practices, encryption of the transferred personal data, prompt reacting to any threats to confidentiality, integrity, and availability of the personal data, conducting transfer impact assessments (TIA) when necessary, etc.

11Links to third-party websites or services

This Policy applies only to this Website and services. We strongly recommend you review the privacy documents of any websites you may reach by following the hyperlinks presented on our Website. We have no control over the content and data practices of other websites and are not responsible for their actions.

12Social media accounts

We manage the Company's official pages on various social media sites, including LinkedIn, Facebook, and Instagram. We can collect information about you when you interact with us via our Social media accounts by following our official pages, posting comments, or reacting to our content.

When you contact us via our Social media accounts for assistance or leave us feedback regarding the provision of services, we can collect this information for further communication purposes. You can find a detailed description of the personal data that we may collect from you above in the “HOW WE USE YOUR DATA” section of this Policy.

Please note that depending on the social media platform, additional processing operations may be conducted by the operators of these platforms. We recommend always checking social media platforms' privacy policies and rules regarding the collection of your personal data.

13Data subject age

Our Website and services are intended for general audiences and are not directed to children under the age of 18. By submitting your personal data to us, you acknowledge that you have reached the age of 18, and under the laws of your country of residence, you have all rights to provide us with your personal data for processing.

Under the GDPR, we do not knowingly collect any personal data from children under the age of 16 (or a lower age if provided by EU member state law, provided that such lower age is not below 13 years).

We do not knowingly collect any personal information from children under the age of 13 without seeking any required parental approval in accordance with applicable legal and regulatory obligations, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”).

If we learn we have collected or received personal data from a child, we will delete that information. If you have any reason to believe that a child has provided their personal data to us, please contact us at support@sereda.ai.

14Rights under the GDPR

You may exercise the following rights by submitting a data subject request at support@sereda.ai.

Please note that we may need to confirm your identity to process your requests to exercise your rights under the GDPR. Thus, we may not be able to satisfy your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to your request.

15Information for California residents: rights under the CCPA and the CPRA

This section applies to the processing of the personal information of California residents.

Under the California Consumer Privacy Act (the “CCPA”) and the California Privacy Rights Act (the “CPRA”, “CCPA, as amended”), California residents have certain rights regarding the collection, use, and sharing of their personal information.

We may collect various categories of personal information when you use and/or access our Platform, including information you provide when you want to receive our services, provide us with any additional information, and automatically collect data (regarding your interactions with our Platform). In particular, depending on actual circumstances, we may collect the following categories of personal information specified in the CCPA, as amended when you access our Platform:

• Category A – Identifiers;
• Category B – Personal information categories listed in the Cal. Civ. Code § 1798.80(e);
• Category C – Protected classification characteristics under California or federal law;
• Category D – Commercial information;
• Category F – Internet or other similar network activity;
• Category G – Geolocation data;
• Category I – Professional or employment-related information;
• Category K – Inferences drawn from any of the information identified above to give you a more personalized web experience (i.e., this may involve the use of cookies in accordance with our Cookies Policy).

You can find a detailed description of the personal information that we may collect from you above in the “TYPES OF PERSONAL DATA WE COLLECT” section of this Policy. The purposes of the collection and/or use of personal information are stated in the “HOW WE USE YOUR DATA” section of this Policy. Note that in the “SHARING YOUR DATA WITH OTHER ENTITIES” section of this Policy, you can review the categories of third parties with whom we may share your personal information. The terms used within those sections of this Policy are taken from the GDPR in consideration of the definitions established in the CCPA, as amended.

If you are a California resident, to the extent provided for by the CCPA, as amended, and subject to applicable exception, you have the following rights in relation to the personal information we have about you:

You can exercise your rights under the CCPA, as amended, by sending us an email by any other means of communication convenient for you, including those listed in the “HOW TO CONTACT US” section of this Policy.

Please note that we may need to confirm your identity to process your requests to exercise your rights under the CCPA, as amended. Thus, we may not be able to satisfy your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to your request. You may exercise the following rights by submitting your request at support@sereda.ai.

16Complaints

We encourage you to reach out to us initially with any concerns you may have regarding the processing of your personal data. You may use the following email to address your inquiries: support@sereda.ai.

You have the right to lodge a complaint about our use of your personal data with a data protection authority. For more information, please contact your national data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us. You can find a full list of EU supervisory authorities through this link.

17Amendments to the policy

We may periodically update this Policy to reflect new updates, technologies, legal requirements, or for other reasons. Any changes will be communicated by posting an updated version of the Privacy Policy on our Website.

We encourage you to review this Policy periodically. If possible, we always give advance notice of upcoming changes by indicating when the new version of the Privacy Policy will take effect. If you continue to use our Website or otherwise provide us with your personal data after the new version of the Privacy Policy goes into effect, we assume that you agree to the changes.

18How to contact us

If you have a question related to this Privacy Policy, our processing activities, or your data subject rights under the GDPR, CCPA, as amended and other applicable laws, you can contact us using the following details: