DATA PRIVACY POLICY

The company under the name “PALO DIGITAL TECHNOLOGIES LIMITED LIABILITY COMPANY“, seated in Athens Greece, 9 Chavriou Street, with no. G.E.MI. 115334437000, hereinafter referred to as the “Company”, created the website www.palowise.ai, hereinafter referred to as the “Website” with the following services Palowise Platform, Palowise Analytics, Email Alerting, Mamalytics, Palowise Trends and Influencers Evaluation & Analysis, hereinafter referred to as the “Services”.

Purpose

The protection of your information is important to us. This information Privacy Policy aims to explain how we collect, store, use and disclose your personal information whenever you use the Website and Services or interact with the Company.

The information Controller

The information Controller is the Company.

General principles

The Company understands your concerns regarding the confidentiality of your personal information. Below we describe how we acquire and use this information and outline your rights. Please read this carefully so that the process is as fair, transparent and secure as possible.

The following principles are central to how we process your personal information.

Transparency and fairness: When we collect and process your personal information, we inform you as to who collects and receives these data and the reasons for this. When required by law, we always seek your prior consent (e.g. before collecting any sensitive information or sending any direct marketing materials). We never use your personal information for purposes that are incompatible with the purposes outlined here.

Legitimacy: The Company does not collect or process personal information without a lawful reason. We use your personal information only for appropriate business purposes, e.g. to provide services, perform accurate invoicing, profiling to better serve customers and comply with our legal obligations.

Minimization: We only collect personal information strictly necessary for data processing, as set out in this document. We collect sensitive information only where relevant. We take all reasonable measures to ensure that your personal data is accurate, complete and up to date.

Privacy: We endeavor to ensure privacy when implementing personal processing. To this end, we also carry out privacy impact assessments to ensure that our safeguards are appropriate and that your information is protected.

How long do we keep your personal information?

We retain your personal information only as long as you enjoy a business relationship with the Company or the term applicable under local law since our last contact, or as required to comply with the Company’s legal obligations under Greek Law.

In case of litigation, we may keep your personal information until the end of such legal action, including any potential periods for appeal. We will then either delete or archive it according to the law in force.

In any event, your personal information will not be kept in a form that allows you to be identified for any longer than necessary by the Company for achieving the purposes for which it was collected or processed or according to the relevant laws in force.

How do we ensure the security and integrity of your personal information?

We protect your data through technical and organizational security measures (including education and training of relevant personnel) against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

Only those teams and employees who need to know your information within our Company can access it. We make sure to implement administration rights and policies within our Company and we take all measures to ensure that employees, advisers / analysts and service providers keep your files confidential.

How can you express your preferences on the use of your personal information?

To exercise the set out in the following section at any time, please contact the Company at the email: [email protected], sending a relevant request.

The request must be sent with a Responsible Statement bearing the certified authentic signature for identification purposes.

Withdrawal. In cases where you have given your prior consent for your information to be processed, you can withdraw that consent at any moment.

Access. You can request access to your personal information we maintain about you. If you make such a request, we will provide you with all the information on the purposes of processing, categories of data processed, categories of recipients, data retention period, your rights to rectify, delete or restrict the data accessed (if applicable), etc.

Portability. You can also obtain a copy of any personal information we hold about you in our records in a format compatible and structure to allow you to exercise your right to data portability.

Restriction. You can request a restriction in the following cases:

for a period enabling the Company to verify the accuracy of your personal data in the event you contest the accuracy of your personal information,
if the processing is unlawful and you wish to restrict your personal information rather than deleting it,
if you wish the Company to keep your personal information, because you need it for your defense in the context of legal claims,
if you have objected to the processing, but the Company needs to check whether it has legitimate grounds for such processing which may override your rights.

Rectification / Erasure. You may also request that we correct, amend, erase, any information which is incomplete, out of date or inaccurate.

You can request the deletion of your personal information in the following cases:

if your personal information is no longer necessary for the purpose of processing;
if you have withdrawn your consent for data processing based exclusively on such consent;
if you object to the data processing;
if the personal information must be erased to comply with a legal obligation applicable to the Company.

Objection. You can also object to the processing of your personal information at any time when used for marketing purposes or profiling to send you targeted advertising or to object to the sharing of your data with third parties.

Complaint. You also have the right to lodge a complaint with the competent supervisory authority.

You can also provide your instructions regarding the storage, deletion or disclosure of your personal information after your death. These instructions may be general or specific.

Am I required to provide Personal Data?

As a general principle, your granting of any consent and your provision of any personal data hereunder for processing based on the data subject consent is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide personal data. However, there are circumstances in which the Company cannot take action without certain personal data, for example because this personal data is required to process your inquiries, your orders or provide you with access to an offering or newsletter or the execution of contractual obligations or obligations imposed by law. In these cases, it will unfortunately not be possible for the Company to provide you with what you request without the relevant personal data.

Please refer to the “How do we use your personal information?” section below for details on data processing purposes and legal grounds of such processing.

Conditions concerning your personal data

What activities and people are concerned by data collection?

This policy applies to all sources of data collected and processed by the Company in the context of its activities, the use of the Website, the Services, as well as all other offline processing activities. Also to all operations necessary for implementing this activities and in general necessary to the operation of our Company such as supply of goods and services, hiring and employing people and associates, etc

We may collect and process your personal information if you are among the following categories: contact person of corporate customers, partners, traders, potential customers, employees, associates of the Company, etc.

How do we use your personal information?

The Company uses your personal information to offer you better services.

Therefore, the Company may use your personal information in the following cases:

When necessary for contractual purposes

On a general level, to manage the commercial relationship with you and your company, respond to estimate requests, open customer accounts, fulfill your orders for services and for related activities, manage events, send you communications related to your contract, respond to your inquiries and requests for verifications, provide customer service, account management, support and related training of our personnel involved in such activities, and to provide other services related to your account.

When it is necessary because there is a legitimate interest for the processing by the Company

to report to clients on customer satisfaction survey results
to implement customers’ selection, creditworthiness control, credit scoring to clients.
The Customer Identification process, to comply with laws and regulations pertaining to prevention and prohibition of money laundering and terrorist financing.

With your informed knowledge and consent

We may also invite you to participate in marketing events, games or quizzes through our mobile applications and/or websites.

Cookies: We may collect information through cookies to provide us with an enhanced experience and improve your browsing experience notably to store your preferences and parameters to save you time, (such as languages preferences), enable log in, fight against fraud, and analyze the performance of our website and services.

For more information, please consult the Cookies Policy available at https://palowise.ai/

Profiling: To improve our understanding of your interests and concerns: we may use your personal information to improve our Website and Services, to customize your experience with us and to tailor our marketing activities to fit your needs and interests. We believe that it is also in our interest to better serve you and respond to your needs, when required under regulatory obligations.

When necessary to comply with a legal obligation of the Company

We use your personal information to maintain business records for legal, administrative and audit purposes imposed by Greek law. We also use information to meet legal, insurance and processing requirements.

What type of personal information do we collect?

We collect the following types of personal information:

Identification and contact information, such as your name, last name, city, phone/mobile number, or email address.
Professional information, such as your job title or professional address.
Financial/Credit information, such as your Credit Acceptance Date or contract information or PO.

We collect your personal information either directly from you (e.g. if you create an account or make a purchase), or passively (e.g. when using tracking tools such as browser cookies), or indirectly (from our partners) or from your employer.

Who do we share your personal information with?

We understand that you do not want us to provide your personal information directly to third parties for their own marketing purposes without your consent. However, occasionally we need to use partners or processors to provide you with the requested services and a better experience, for the purposes described above. We therefore limit our sharing of your personal information on a need-to-know basis as follows:

with internal business departments such as sales, customer care/quality department, marketing, IT services, support and maintenance.
with our service providers, such as data hosting service providers, call centers, data administrators, located in Greece or within the European Economic Area and instructed to only use your personal information in accordance with our instructions.
To unaffiliated marketing partners, but only if you have given us your consent.
When required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the countries where we operate.

Please note that we may also use and disclose personal information about you that is not personally identifiable i.e. personal information in an aggregate form that no longer identifies you.

How is your personal information transmitted?

We may also transfer your personal information to the service providers involved in the provision of call center services, data hosting, maintenance and support services or the provision of any other tool used for the processing of our customers or prospects personal information. When we transfer your information, we protect and provide adequate protection for the transfer of your personal information to recipients in those countries by entering into data transfer agreements based on the European Commission standards clauses with such data recipients.

How long do we keep your personal information?

We retain your personal information collected for the purposes and under the conditions described above for a duration limited to what is strictly necessary.

How can you contact us or the supervisory authority to lodge a complaint?

If you have any questions, complaints, or comments regarding this Data Privacy Policy or our information collection practices, please contact us by writing, or sending an email to: [email protected]

You can also lodge a complaint with the Supervisory Authority of the country where you are located if you have any concern about the conditions of processing of your personal information by the Company.

What happens when we change this Data Privacy Policy?

Our Data Privacy Policy may change from time to time to reflect changes in the way we processing your personal information. However, these changes will remain fully compliant with applicable law. We encourage you to periodically review this page for the latest information on our privacy practices.