Privacy Policy

1 BACKGROUND 

Last updated: 8 January 2025 

1.1 This notice (Privacy Notice)tells you how we look after your personal data when you visit our websiteat complianceplay.ai (Website),where you are a prospective customer of our business, or where you are anothertype of business contact, such as a supplier or service provider to ourbusiness. 

1.2 This notice sets out what informationwe collect about you, what we use it for and whom we share it with. It alsoexplains your rights under data protection laws and what to do if you have anyconcerns about your personal data. 

1.3 We may sometimes need to update thisPrivacy Notice to comply with new business practices or legal requirements. Youshould check this Privacy Notice regularly to see whether any changes haveoccurred. 

2 WHO WE ARE AND OTHER IMPORTANTINFORMATION 

2.1 We are Complianceplay.ai registered in Bulgaria(we, us or our). 

2.2 For all visitors to our Website and the use of AI assistant we are the controller of your information(which means we decide what information we collect and how it is used). 

3 CONTACT DETAILS 

3.1 If you have any questions about this Privacy Notice or the way that we use information, please get in touch using the following details: 

Email address: info@complianceplay.ai 

4 THE INFORMATION WE COLLECT ABOUTYOU 

4.1 Personal data means any information which does (or could be used to) identify a living person. We have grouped together the types of personal data that we collect, and where we receive it from, below. 

4.2 Type of personal data: 

Identity Data: your first and   last name or title. 

Contact Data: your email     address, telephone numbers, home address. 

Technical Data: internet  protocol (IP) address, browser type and version, time zone setting and     generic location, browser plug-in types and versions, operating system and     platform on the devices you use to access our systems. 

Usage Data: information about  how you use our systems. 

Location Data: your device location if you log into our systems remotely. 

Feedback: information and responses you provide when completing surveys and questionnaires. 

Marketing and Communication Data: includes  your preferences in receiving marketing from us and our third parties and  your communication preferences. 

5 HOW WE USE YOUR INFORMATION 

5.1 We are required to identify a legal justification(also known as a lawful basis) for collecting and using your personal data. There are six legal justifications which organisations can rely on. The most relevant of these to us are where we use your personal data to: 

fulfil our contract with you; 

comply with a legal obligation that we  have; 

pursue our legitimate interests (our  justifiable business aims) but only if those interests are not outweighed by your other rights and freedoms (e.g. your right to privacy). 

5.2 Below is set out the lawful basis we rely on when we use your personal data. If we intend to use your personal data for a new reason that is not listed below, we will update our Privacy Notice. 

5.2.1 Contract 

• To administrate or perform our contract with you. 

• To process your payment information in connection with any  contract we have with you. 

• To send you updates about the services you have bought (e.g. confirmation of order, arrival time). 

5.2.2 Legal Obligation 

• Recording your preferences (e.g. marketing) to ensure that we comply with data protection laws. 

• Where we send you information to comply with a legal obligation  (e.g. where we send you information about your legal rights). 

• Where we retain information to enable us to bring or defend legal claims. 

5.2.3 Legitimate Interests 

• Where using your information is necessary to pursue our legitimate business interests to: 
      a) improve and optimise our Website and AI Assistant; 
      b) monitor and make improvements to our Website and AI Assistant to enhance security and prevent fraud; 
      c) provide our services to you and ensure the proper functioning of our Website; and 
      d) protect our business and defend ourselves against legal claims. 

• Where we use your information for our legitimate interests, we  have assessed whether such use is necessary and that such use will not infringe on your other rights and freedoms. 

5.3 Where we need to collect your personal data (for example, in order to fulfil a contract we have with you), failure to provide us with your personal data may mean that we are not able to provide you with the services. Where we do not have the information required about you to fulfil an order, we may have to cancel the service ordered. 

6 WHO WE SHARE YOUR INFORMATIONWITH 

6.1 We share (or may share) your personal data with: 

• Our personnel: our employees (or other types of workers) who have contracts containing confidentiality     and data protection obligations. 

• Our supply chain: other organisations that help us provide our goods. We ensure these  organisations only have access to the information required to provide the support we use them and have a contract with them that contains  confidentiality and data protection obligations. 

• Our professional advisers: such as our accountants or legal advisors where we require specialist advice to     help us conduct our business. 

• Any actual or potential buyer of our business. 

6.2 If we were asked to provide personaldata in response to a court order or legal request (e.g. from the police), wewould seek legal advice before disclosing any information and carefullyconsider the impact on your rights when providing a response. 

7 WHERE YOUR INFORMATION IS LOCATED ORTRANSFERRED TO 

7.1 We store your personal data on serversof Microsoft Azure. We have proper mechanisms in place to ensure that transferto that region follows relevant data protection laws. 

7.2 Except as set out above, we will onlytransfer information outside of Europe where we have a valid legal mechanism inplace (to make sure that your personal data is guaranteed a level of protection),regardless of where in the world it is located. 

7.3 If you access our Website whilst abroadthen your personal data may be stored on servers located in the same country asyou or your organisation. 

8 HOW WE KEEP YOUR INFORMATIONSAFE 

8.1 We have implemented security measuresto prevent your personal data from being accidentally or illegally lost, usedor accessed by those who do not have permission. These measures include: 

• Internal IT and network security; 

• Business continuity and disaster recovery processes. 

8.2 If there is an incident which has affected your personal data and we are the controller, we will notify the regulator and keep you informed (where required under data protection law). Where we act as the processor for the affected personal data, we notify the controller and support them with investigating and responding to the incident. 

8.3 If you notice any unusual activity onthe Website, please contact us info@complianceplay.ai

9 HOW LONG WE KEEP YOURINFORMATION 

9.1 Where we act as the controller, we willonly retain your personal data for as long as necessary to fulfil the purposeswe collected it for. 

9.2 To decide how long to keep personaldata (also known as its retention period), we consider the volume, nature, andsensitivity of the personal data, the potential risk of harm to you if anincident were to happen, whether we require the personal data to achieve thepurposes we have identified or whether we can achieve those purposes throughother means (e.g. by using aggregated data instead), and any applicable legalrequirements. 

9.3 We may keep Identity Data, Contact Dataand certain other data (specifically, any exchanges between us by email or anyother means) for up to seven years after the end of our contractualrelationship with you. 

9.4 If you browse our Website, we keeppersonal data collected through our analytics tools for only as long asnecessary to fulfil the purposes we collected it for. 

9.5 If you have asked for information from us or you have subscribed to our mailing list, we keep your details until you ask us to stop contacting you. 

10 YOUR LEGAL RIGHTS 

10.1 You have specific legal rights in relation to your personal data. 

10.2 We can decide not to take any action in relation to a request where we have been unable to confirm your identity(this is one of our security processes to make sure we keep information safe)or if we feel the request is unfounded or excessive. Usually there is no cost for exercising your data protection rights, but we may charge a fee where we decide to proceed with a request that we believe is unfounded or excessive. If this happens, we will always inform you in writing. 

10.3 We will respond to your legal rights request without undue delay, but within one month of us receiving your requestor confirming your identity (whichever is later). We may extend this deadline by two months if your request is complex or we have received multiple requests at once. If we need to extend the deadline, we will let you know and explain why we need the extension. 

10.4 We do not respond directly to requests which relate to personal data for which we act as the processor. In this situation, we forward your request to the relevant controller and await their instruction before we take any action. 

10.5 If you wish to make any of the right requests listed below, you can reach us at info@complianceplay.com. 

10.6 Your rights include: 

• Access: You must be told if your personal data is being used and you can ask for a copy of your     personal data as well as information about how we are using it to make     sure we are abiding by the law. 

• Correction: You can ask us to  correct your personal data if it is inaccurate or incomplete. We might     need to verify the new information before we make any changes. 

• Deletion: You can ask us to delete or remove your personal data if there is no good reason for us to     continue holding it or if you have asked us to stop using it (see below).  If we think there is a good reason to keep the information you have asked     us to delete (e.g. to comply with regulatory requirements), we will let     you know and explain our decision. 

• Restriction: You can ask us to restrict how we use your personal data and temporarily limit the way we     use it. 

• Objection: You can object to  us using your personal data if you want us to stop using it. If we think there is a good reason for us to keep using the information, we will let you know and explain our decision. 

• Portability: You can ask us to  send you or another organisation an electronic copy of your personal data. 

• Complaints: If you are unhappy     with the way we collect and use your personal data, you can complain to     the relevant supervisory body, but we hope that we can respond to your  concerns before it reaches that stage. Please contact us at info@complianceplay.ai. 

11 WHEN WE SEND YOU MARKETINGMESSAGES 

11.1 If you have consented to receivingmarketing messages from us, you can opt out of these at any time. Just let usknow at info@complianceplay.ai. 

11.2 We market to prospective and existingbusiness customers, this is known as Business-to-Business Marketing (B2BMarketing). We may send marketing communications to their staff via workcontact details. If you are a member of staff and do not wish to receive B2BMarketing, please let us know at info@complianceplay.ai 

11.3 Opting out of marketing will not affect our processing of your personal data in relation to any order you have with us and where we are required to use your personal data to fulfil that order or provide you with certain information. 

12.CHILDREN

Our Services are not directed to, or intended for, children under 18.  We do not knowingly collect Personal Data from children under 18. If you have reason to believe that a child under 18has provided Personal Data to us through the Website or AI Assistant, please email us at privacy@openai.com⁠. 

13. CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time. When we do, we will publish an updated version and effective date on this page, unless another type of notice is required by applicable law.

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