Privacy Policy

www.nissy.ai ("our website") is provided by Cleverbit Software Limited ("we", "our" or "us"). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your "personal data") in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the Data Protection Act (Chapter 586 of the Laws of Malta) (the "Act"), as may be amended or replaced from time to time, and the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR").

This website is not intended for children, and we do not knowingly collect data relating to children.

What this policy applies to

This privacy policy relates to your use of our website only.

Data Protection Officer

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

How to contact us

If you have any questions about this privacy policy or our privacy practices, please contact our DPO:

• Full legal name: Cleverbit Software Limited
• Email: [email protected]
• Postal address: 50, Triq Giorgio Preca, San Gwann, Malta

You have the right to make a complaint at any time to the Office of the Information and Data Protection Commissioner (IDPC) at idpc.org.mt. We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact our DPO at [email protected] in the first instance.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

• Identity data: this is limited to your email address when registering your interest in our products and services, and your first and last name should you contact us by email.
• Usage data: this is limited to information about how you use our website.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offences.

How your personal data is collected

We collect personal data from you:

• Directly, when you enter your information, such as when you register your interest with your email address, and when you contact us via email.
• Indirectly, such as your browsing activity while on our website. We will usually collect information indirectly using the technologies explained in the 'Cookies' section below.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, for example:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see 'How to contact us' above).

What we use your personal data for	Our reasons
Registering your interest in our products and services	For our legitimate interests — to be as efficient as we can so we can deliver the best service to you at the best price.
Customising our website and its content to your particular preferences based on your use of our website	Your consent. See 'Cookies' below. You may withdraw consent at any time by emailing [email protected].
Retaining and evaluating information on your recent visits to our website for analytics purposes, to understand how people use our website so that we can make it more intuitive	Your consent. See 'Cookies' below. You may withdraw consent at any time by emailing [email protected].
Communications not related to marketing, including about changes to our terms or policies, or other important notices	To comply with our legal and regulatory obligations; or for our legitimate interests to be as efficient as we can so we can deliver the best service to you.
Disclosures and activities necessary to comply with legal and regulatory obligations that apply to our business	To comply with our legal and regulatory obligations.
Marketing our services to prospective, existing, and former customers	For our legitimate interests, to promote our business. See 'Marketing' below.

Marketing

We will use your personal data to send you updates (by email) about our products and services, and any new products and services. We have a legitimate interest in using your personal data for marketing purposes. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us at [email protected]; or
• using the 'unsubscribe' link in emails.

We will always treat your personal data with the utmost respect and never share it with other organisations outside our organisation for marketing purposes.

Who we share your personal data with

We share personal data with third parties we use to help us run our business, for example, assistance with email marketing.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Cookies

A cookie is a small text file which is placed onto your device when you use our website. We use cookies on our website. For further information on cookies, our use of cookies, when we will request your consent before placing them, and how to disable them, please see our Cookie Policy.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access

The right to be provided with a copy of your personal data.

Correction

The right to require us to correct any mistakes in your personal data.

Erasure

The right to require us to delete your personal data in certain situations.

Data portability

The right to receive the personal data you provided to us in a structured, commonly used and machine-readable format, and/or to transmit that data to a third party in certain situations.

Object to use

The right to object at any time to your personal data being used for direct marketing (including profiling).

Automated decisions

Where significant decisions are made using your personal data based on solely automated processing with no meaningful human involvement, you have the right to have safeguards in place to protect your rights, freedoms and legitimate interests. We do not make any such decisions based on data collected by our website.

Withdraw consent

If you have given us consent to use your personal data, you have the right to withdraw it easily at any time by contacting us at [email protected]. Note that withdrawal does not affect the lawfulness of our use of your personal data before it was withdrawn.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see 'How to contact us' above). You may also refer to guidance from the IDPC on your rights under the Act and GDPR.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you via email.