Privacy Policy

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows you to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google
• Github

If you decide to register through or otherwise grant us access to a Third-Party Social Media Service, we may collect personal data that is already associated with your Third-Party Social Media Service's account, such as your name, your email address, your activities or your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. The technologies we use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Privacy Policies website article.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

  Type: Session Cookies

  Administered by: Us

  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Processing of Lead Data (When We Act as a Data Processor)

When our Customers embed the EasyFindAi chatbot on their websites, we collect and process "Lead Data" solely on behalf of and under the instruction of our Customers, who are the Data Controllers for this information.

Types of Lead Data Collected

Lead Data typically includes:

• Full Name
• Email Address

These fields are currently fixed by the Service.

Purpose of Processing

We process Lead Data solely for the purposes defined by our Customers, which typically include:

• Responding to inquiries from website visitors
• Managing requests for product demonstrations or information
• Enabling customer follow-up for sales or support purposes

Storage and Access of Lead Data

Lead Data is stored securely within the European Union (specifically in Frankfurt, Germany). Our Customers access their Lead Data via their secure EasyFindAi dashboard.

Retention of Lead Data

Lead Data is retained until the Customer deletes it via their EasyFindAi dashboard or until the Customer's account is terminated, whichever comes first.

Customer Responsibilities

As the Data Controller for Lead Data, our Customers are responsible for:

• Ensuring they have a lawful basis (such as valid consent or legitimate interest) for collecting Lead Data through the chatbot
• Providing necessary transparency information (e.g., in their own privacy policy) to end-users about the data collection
• Responding to data subject rights requests from end-users regarding their personal data
• Ensuring their use of the Lead Data complies with applicable data protection laws

Data Processing Agreement

The processing of Lead Data by EasyFindAi as a Data Processor on behalf of our Customers is governed by a separate Data Processing Agreement (DPA). This DPA outlines our respective responsibilities and ensures that appropriate data protection safeguards are in place.

Use of Your Personal Data (When We Act as a Data Controller)

The following applies when we act as a Data Controller for personal data collected directly from our website visitors and registered customer accounts:

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

Customer Account Data and Website Visitor Data (As a Controller)

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Lead Data (As a Processor)

Lead Data (As a Processor) When acting as a Data Processor, we retain Lead Data only as long as instructed by our Customers (the Data Controllers). Lead Data is deleted when:

• The Customer deletes a specific lead via their EasyFindAi dashboard.
• The Customer terminates their account with EasyFindAi (resulting in the deletion of all associated Lead Data).
• The Customer provides a specific instruction for deletion (subject to the terms of the DPA).

We do not retain Lead Data beyond these deletion triggers, unless retention is specifically required by applicable law.

Transfer of Your Personal Data

Customer Account Data and Website Visitor Data (As a Controller)

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the Åland Islands and choose to provide information to us, please note that we transfer the data, including Personal Data, to the Åland Islands and process it there.

Lead Data (As a Processor)

Lead Data processed on behalf of our Customers is stored primarily in the European Union (specifically in Frankfurt, Germany).

International Data Transfers

We may utilize sub-processors who process data globally. Any transfers of personal data outside the EU/EEA rely on appropriate safeguards such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions issued by the European Commission, establishing that a particular country ensures an adequate level of protection
• Binding Corporate Rules, where applicable

Where we utilize sub-processors outside the EU/EEA, we ensure appropriate safeguards, such as Standard Contractual Clauses (SCCs) or adequacy decisions, are in place to protect your data

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Your Rights

Under data protection laws, you have rights in relation to your personal data. The availability of these rights and the ways to exercise them may depend on our legal basis for processing and the jurisdiction in which you reside.

Your Rights for Customer Account Data and Website Visitor Data (Where We Act as Controller)

You have the right to:

• Access your personal data (right to know whether we are processing your data and receive copies)
• Rectification of inaccurate or incomplete personal data
• Erasure ("right to be forgotten") in certain circumstances
• Restrict processing in certain circumstances
• Data portability (receiving a copy of your data in a commonly used format)
• Object to processing (particularly for direct marketing purposes)

You may update, amend, or delete your information at any time by signing in to your Account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us directly to request access to, correct, or delete any personal information that you have provided to us.

To exercise these rights in relation to data for which we are the Data Controller, please contact us at anton@easyfindai.com.

Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

Your Rights for Lead Data (Where We Act as Processor)

For personal data (Lead Data) that we process on behalf of our Customers through the chatbot, we are not the Data Controller. If you shared your information with a chatbot on a Customer's website and wish to exercise your rights regarding that data:

• You should direct your request to the Customer (the company whose website you were using)
• The Customer, as the Data Controller, is responsible for responding to your request
• EasyFindAi will provide reasonable assistance to our Customers to help them respond to such requests, as outlined in our Data Processing Agreement

If you are unsure about who to contact regarding Lead Data collected through a chatbot, you may contact us at anton@easyfindai.com, and we will direct your inquiry appropriately.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of your Personal Data is important to us. We implement and maintain appropriate technical and organizational measures to protect your data, including:

• Encryption of data in transit (TLS/HTTPS) to protect data as it travels across the internet
• Encryption of data at rest to protect stored information
• Secure authentication and access controls (via Clerk) to protect access to customer accounts and Lead Data within the dashboard
• Regular security assessments and updates
• Employee training on data protection and security practices
• Restricted access to personal data on a need-to-know basis
• Secure and monitored infrastructure hosted with reputable cloud providers

Despite our best efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

In the event of a data breach that affects your Personal Data, we will notify you and the relevant supervisory authorities as required by applicable law.

Sub-processors

EasyFindAi engages certain third-party service providers to assist in providing our Service. These "sub-processors" may have access to personal data to help us provide our Service. We use the following categories of sub-processors:

• Cloud Infrastructure/Hosting: Vercel (hosting our front-end application) and Amazon Web Services (AWS, for various infrastructure needs)

• Database Provider: PlanetScale (for secure storage of data including Lead Data)

• Authentication Service: Clerk (used for securing access to Customer accounts; does not process Lead Data)

• Email Service Provider: Used for communicating with our Customers regarding their accounts and service updates

All our sub-processors are engaged under data processing agreements that require appropriate data protection measures in line with applicable data protection laws. We regularly review the security and compliance posture of our sub-processors.

If you are a Customer and require more specific information about our sub-processors for compliance purposes, please contact us at anton@easyfindai.com.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, your rights, or our data practices, you can contact us:

• By email: anton@easyfindai.com
• By mail: DocumentFlow Ab, Örnvägen 22, AX-22150 Jomala, Åland Islands

For specific inquiries about Lead Data for which we are a Data Processor, please contact the organization that collected your data through their chatbot.