OSTRACON AI PRIVACY POLICY

1. PURPOSE

1.1 We maintain a strong commitment to privacy. The importance of trust is recognized when our services are used and thus client privacy is given top priority, underscoring our technology and business decisions.

1.2 We offer a range of professional consulting services. For clarity, "Services" shall mean the range of professional services provided by us, Ostracon AI, including but not limited to marketing, consulting, public relations, and communication services. We may utilize advanced artificial intelligence (AI) technologies in the provision of these services to ensure optimal efficiency and results. The specific scope and nature of the Services to be provided shall be determined based on the requirements of each individual assignment as mutually agreed upon by our clients (the "Client") and Ostracon AI.

1.3 We go to the best possible extent to protect the data we process, keeping it private and secure. Data we may collect within the scope of our Service is with the purpose of providing best results and personalized experience.

1.4 This privacy policy applies to the collection, use, and disclosure of personal data for provision of the Services, marketing, sales, client engagements, and the operation of our website.

1.5 Depending on the data subject, Ostracon AI acts as the data controller or as the data processor within the meaning of the General Data Protection Regulation (EU 2016/679).

2. DESCRIPTION OF THE CATEGORIES OF DATA SUBJECTS AND CATEGORIES OF PERSONAL DATA

2.1 We collect personal data through different means. The type of data collected depends on the data subject and varies by assignments. Collecting and processing may include, but is not limited, to the following:

(a) basic information, such as name, title, address and the data subject's relation to a company represented and contact details;

(b) information relating to our relationship, such as services and order details, contract information, payment details, billing information;

(c) data generated in connection with website use and analytics tools, e.g. IP addresses, browser information, email marketing engagements and how our websites are used;

(d) data from clients' and their employees' social media profiles, their own sales systems, and CRM databases, including but not limited to profile information, contacted individuals and details of meetings, call recordings and transcripts; and

(e) other data, which is based on your consent and defined in detail on a case-by-case basis.

2.2 We may also collect personal data about our clients' customers and potential customers, including but not limited to data categories mentioned above in section 2.1, to assist our clients in providing personalized and effective services.

2.3 We may combine information available from public sources with the information received from our clients or other relevant third parties to provide more accurate and tailored services.

2.4 We may collect and use for any purpose aggregated data, where individual person is not identified from e.g., statistical data collected in connection with the provision of services.

3. MARKETING AND ANALYTICS

3.1 We act as an independent controller for processing necessary data to provide our consulting services and managing our internal databases.

3.2 Our clients act as independent controllers for providing their own services. We may act as processors regarding the Client's information and thus operate as data processor subject to our client.

3.3 We may market and inform you about Ostracon AI's services. We may combine the data collected about you from publicly available sources, and from our different interactions with you. Further, your personal data may also be used for market research and customer surveys. Processing of personal data is based on our legitimate interest to collect and analyse relevant information to better understand our clients and develop relevant services.

3.4 We utilize various analytics tools to collect and analyse data about the usage of our website and services. These tools help us understand customer behaviour, measure the effectiveness of our marketing campaigns, and improve our services.

3.5 Based on your consent we may store and access information, including personal data, on your device in order to create personalized ads profile and deliver relevant content at the website as well as to measure the effectiveness of the advertising.

4. PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

4.1 We may process your personal data for the performance of an agreement to provide our services to you, improve our services, to comply with our legal obligations, and to provide quality services to our clients. The purposes for which we process personal data are:

(a) marketing and sales of services; (b) verifying the identity and providing services to our clients; (c) managing, pursuing and analysing client relationship; (d) improving Ostracon AI's services; (e) improving and personalizing services and developing new services; and (f) customer support.

4.2 We may process your personal data also for other specific purposes if you have consented to such processing.

5. USE OF COOKIES

5.1 When visiting our website, cookies and other similar technologies ("Cookies") are used to automatically collect information about the visits. Collected information and retention time for each Cookie is detailed in the Cookie banner at our website.

5.2 You can accept or refuse Cookies or change your earlier choices through Cookie banner at our website. You can always disable Cookies or clear your Cookie history from your browser settings.

5.3 Accepting Cookies will enable you to get the best from our website. If you refuse Cookies, some aspects of the website may not work on your device.

6. DATA SHARING AND DISCLOSURES OF PERSONAL DATA

6.1 We may share personal data with third-party service providers, e.g. for analytics services, potential subcontractors and AI tools to assist us in providing our services.

6.2 We may also share personal data related to our clients' customers and potential customers with these service providers when necessary to deliver our services effectively.

6.3 We may disclose your personal data to comply with legal obligations or protect our legal interests.

7. TRANSFER OF PERSONAL DATA OUTSIDE OF THE EU OR EEA

7.1 We reserve the right to transfer personal data outside of the European Union (EU) or European Economic Area (EEA) as some of our partners and service providers are located outside of these regions. In such cases, we will give our best efforts to implement the necessary requirements under the GDPR to safeguard your personal data.

7.2 To provide appropriate protections for international data transfers, our service providers utilize standard contractual clauses approved by the European Commission as stated in Article 46(2) of the GDPR or rely on adequacy decisions in accordance with Article 45(1) of the GDPR.

7.3 By using our services, you acknowledge and consent to the potential transfer of your personal data outside of the EU/EEA.

8. RETENTION OF PERSONAL DATA

8.1 We will retain the personal data of our Clients only for as long as necessary to provide services and as required by law.

8.2 Data retention time is by default the duration of the business relationship with Ostracon AI and 3 years after this.

9. YOUR RIGHTS

9.1 You have certain rights regarding your personal data:

9.2 Right to Access. 9.3 Right to Rectify Personal Data. 9.4 The Right to Object to the Processing. 9.5 The Right to Data Portability. 9.6 The Right to Be Forgotten. 9.7 The Right to Restriction of the Processing. 9.8 The Right to Give and Withdraw Your Consent.

10. DATA SECURITY

10.1 We take appropriate technical and organizational measures to protect your personal data from loss, destruction, unauthorized access, disclosure, or other misuse.

10.2 Personal data is stored in an encrypted database on the servers of third-party cloud service providers.

11. CHANGES TO THE PRIVACY POLICY

11.1 We may update this privacy policy from time to time.

11.2 This privacy policy has last been updated on 18 January 2025.

12. CONTACT US

12.1 Marketing Agency Ostracon AI, business ID: 3461802-8, Bulevardi 21, 00180 Helsinki.

12.2 If you have any questions or concerns, please contact Valtteri Taube at valtteri.taube@ostracon.ai.