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 usedand thus client privacy is given top priority, underscoring our technology andbusiness 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 ourrelationship, such as services and order details, contract information, paymentdetails, billing information;(c) data generated in connectionwith 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 theiremployees’ social media profiles, their own sales systems, and CRM databases,including but not limited to profile information, contacted individuals and detailsof meetings, call recordings and transcripts; and(e) other data, which is based onyour consent and defined in detail on a case-by-case basis.2.2 We may also collect personaldata about our clients' customers and potential customers, including but notlimited to data categories mentioned above in section 2.1, to assist ourclients in providing personalized and effective services.2.3 We may combine informationavailable from public sources with the information received from our clients orother relevant third parties to provide more accurate and tailored services.2.4 We may collect and use for anypurpose aggregated data, where individual person is not identified from e.g.,statistical data collected in connection with the provision of services.3 MARKETING AND ANALYTICS3.1 We act as an independentcontroller for processing necessary data to provide our consulting services andmanaging our internal databases. 3.2 Our clients act as independentcontrollers for providing their own services. We may act as processorsregarding the Client’s information and thus operate as data processor subject toour client.3.3 We may market and inform youabout Ostracon AI’s services. We may combine the data collected about you frompublicly available sources, and from our different interactions with you.Further, your personal data may also be used for market research and customersurveys. Processing of personal data is based on our legitimate interest tocollect and analyse relevant information to better understand our clients anddevelop relevant services.3.4 We utilize various analyticstools to collect and analyse data about the usage of our website and services.These tools help us understand customer behaviour, measure the effectiveness ofour marketing campaigns, and improve our services. The data collected throughthese tools may include information such as your IP address, browser type,operating system, referring URLs, and other usage information.3.5 Based on your consent we maystore and access information, including personal data, on your device in orderto create personalized ads profile and deliver relevant content at the website(e.g. information and ads about Ostracon AI’s services) as well as to measurethe effectiveness of the advertising. Respectively, your personal data may alsobe processed to develop and improve the website, or for developing our own orour partners’ services.4 PURPOSE AND LEGAL BASIS FOR PROCESSINGPERSONAL DATA4.1 We may process your personaldata for the performance of an agreement to provide our services to you,improve our services, to comply with our legal obligations, and to providequality services to our clients. The purposes for which we process personaldata are:(a) marketing and sales ofservices;(b) verifying the identity and providingservices to our clients;(c) managing, pursuing andanalysing client relationship, including customer communication, client accountmanagement, and processing payments;(d) improving Ostracon AI’sservices; (e) improving and personalizingservices and developing new services; and(f) customer support.4.2 We may process your personaldata also for other specific purposes if you have consented to such processing.5 USE OF COOKIES5.1 When visiting our website, cookiesand other similar technologies (“Cookies”) are used to automaticallycollect information about the visits. Collected information and retention timefor each Cookie is detailed in the Cookie banner at our website. It is possiblefor you to accept or refuse the use of the Cookies.5.2 You can accept or refuse Cookiesor change your earlier choices through Cookie banner at our website. You canalways disable Cookies or clear your Cookie history for all visited websitesfrom your browser settings.5.3 Accepting Cookies will enableyou to get the best from our website. If you refuse Cookies, some aspects ofthe website may not work on your device, and you may not be able to access allareas thereof.6 DATA SHARING AND DISCLOSURES OFPERSONAL DATA6.1 We may share personal data withthird-party service providers, e.g. for analytics services, potentialsubcontractors and AI tools to assist us in providing our services. Forexample, names and titles may be extracted from emails using AI-assisted tools,and client email lists may be shared with our service providers to facilitateour operations.6.2 We may also share personal datarelated to our clients' customers and potential customers with these serviceproviders when necessary to deliver our services effectively. This may includecontact information, engagement history, and preferences to supportpersonalized service offerings and enhance client interactions.6.3 We may disclose your personaldata to comply with legal obligations or protect our legal interests.7 TRANSFER OF PERSONAL DATA OUTSIDE OFTHE EU OR EEA7.1 We reserve the right totransfer personal data outside of the European Union (EU) or European EconomicArea (EEA) as some of our partners and service providers are located outside ofthese regions. In such cases, we will give our best efforts to implement thenecessary requirements under the GDPR to safeguard your personal data. However,it's important to recognize that while we aim for comprehensive protection, theultimate compliance by our partners is beyond our direct control.7.2 To provide appropriateprotections for international data transfers, our service providers utilize standardcontractual clauses approved by the European Commission as stated in theArticle 46(2) of the GDPR or rely on adequacy decisions in accordance withArticle 45(1) of the GDPR. Additionally, we implement further technical,organizational, and contractual measures as necessary.7.3 By using our services, youacknowledge and consent to the potential transfer of your personal data outsideof the EU/EEA, and you agree that we will take all reasonable and available stepsto protect your data in compliance with applicable laws and regulations.8 RETENTION OF PERSONAL DATA8.1 We will retain the personaldata of our Clients only for as long as necessary to provide services and asrequired by law. After that, we will securely dispose all personal data.8.2 Data retention time is bydefault the duration of the business relationship with Ostracon AI and 3 years afterthis. The retention period of three years is justified by the long businesscycles inherent in the industry, which require maintaining data to ensurecontinuity and quality of service.9 YOUR RIGHTS9.1 You have certain rightsregarding your personal data:9.2 Right to Access: You have the right to access your personal data that we hold.9.3 Right to Rectify PersonalData: You have the right to request that we correctany inaccurate or incomplete personal data that we hold.9.4 The Right to Object to theProcessing: You have the right to object to theprocessing of your personal data for certain purposes.9.5 The Right to DataPortability: You have the right to receive yourpersonal data in a structured, commonly used, and machine-readable format.9.6 The Right to Be Forgotten: You have the right to request that we erase your personal dataunder certain circumstances.9.7 The Right to Restriction ofthe Processing: You have the right to request thatwe restrict the processing of your personal data under certain circumstances.9.8 The Right to Give andWithdraw Your Consent: You have the right to giveor withdraw your consent for the processing of your personal data.10 DATA SECURITY10.1 We take appropriate technicaland organizational measures to protect your personal data from loss,destruction, unauthorized access, disclosure, or other misuse. These measuresinclude physical, electronic, and procedural safeguards that comply with applicablelegal requirements. We limit access to personal data to those authorizedemployees and service providers who need to know the information in the courseof their duties. They will only process your personal data based on ourinstructions and are subject to a confidentiality obligation.10.2 Personal data is stored in anencrypted database on the servers of third-party cloud service providers. Wemake sure to adhere to best practices for persisting and encrypting data.10.3 Although our good faith effortsto store your data in a secure operating environment that is not available tothe public, please remember that unfortunately no data transmission or storageis 100% risk free. You provide your personal data at your own risk, and wecannot guarantee the absolute security of your data. In the unfortunate case ofa security breach that that endangers your privacy or data we will inform youas well as the relevant authorities, as required by law. We may alsotemporarily shut down services to protect the personal data.11 CHANGES TO THE PRIVACY POLICY11.1 We may update this privacypolicy from time to time. We will notify our Clients of any significant changesby posting a notice on our website or by sending an email.11.2 This privacy policy has lastbeen updated on 18 January 2025.12 CONTACT US12.1 The contact details of thecompany are:Marketing Agency Ostracon AI, business ID: 3461802-8Kellosaarenkatu 4 A 21, 00180 Helsinki.12.2 If you have any questions orconcerns about this privacy policy or our use of your personal data, pleasecontact Valtteri Taube at valtteri.taube@ostracon.ai.