1. Introduction
Welcome to ainigma.tech or “the Website” which is owned by Ainigma Technologies (“Ainigma”). This particular notice describes Ainigma’s privacy policy related to the services provided at https://ainigma.tech (the “Services”).
Ainigma complies with the General Data Protection Regulation (“GDPR” that entered into force on 25 May 2018. Focusing on data privacy, GDPR is the new EU legal framework for the protection of personal data.
We are confident that our existing practices provide a strong foundation upon which we build our GDPR compliance activities.
Ainigma respects and values your privacy. This policy is intended to give you confidence in the privacy and security of any personal information that is entrusted to Ainigma.
You are informed that by using or visiting the Website, you acknowledge and accept this Privacy Policy.
This Privacy Policy is applicable to all users and visitors. This Privacy Policy governs your use of the Website.
2. Who we are
The Website is operated by Ainigma Technologies “Ainigma”, which is based in Belgium. This Privacy Policy applies solely to this Website or any sub domain or Services owned by Ainigma, and not to other websites of other providers linked to this Webite, which are not owned by Ainigma. Further information about Ainigma is available at: https://ainigma.tech under the “About” tab.
3. Definitions
| Term | Definition |
| GDPR | The General Data Protection Regulation (2016/679) became applicable on the 25th of May 2018. It is directly applicable at national level and harmonizes data protection laws across the EU. It replaces the current 1995 Data Protection Directive (Directive 95/46/EC). The GDPR applies to Data Controllers and Data Processors established in the EU and becomes applicable to Data Controllers or processors offering goods or services to the EU or monitoring the behaviour of individuals in the EU. |
| Personal Data | Personal data means any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. |
| Data Controller | Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. |
| Data Processor | Data Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. |
| Subprocessor | Subprocessor means any processor as defined in Article 4(8) of the GDPR;”{any} natural or legal person, public authority, agency or other body which processes personal data “on behalf of the Processor (including any affiliate of the Processor). |
| Anonymisation of Personal Data | Anonymisation of Personal Data is defined as the process to strip sufficient elements such that the Data Subject can no longer be identified by the Data Controller using data they process or have access to. It’s irreversible: if it can be reversed, it is not anonymised. |
| Processing | Processing has the meaning given to it in Article 4(2) of the GDPR: “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such us collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.” |
| Transfer | Transfer means to disclose or otherwise make Personal Data available to a third party (including to any affiliate or Subprocessor), either by physical movement of the Personal Data to such third party or by enabling access to the Personal Data by other means. |
| Encryption | In computing, encryption is the method by which plaintext or any other type of data is converted from a readable form to an encoded version that can only be decoded by another entity if they have access to a decryption key. Encryption is one of the most important methods for providing data security, especially for end-to-end protection of data transmitted across networks. |
4. Types of personal data collected by the Website
When you use the Website, Ainigma may ask for and collect personal information about you and your organization (business). Ainigma may collect your personal information including non-public information which will assist Ainigma identify you. This information includes:
- Name
- Surname
- Title
- Position
- Institution/Organization
- Address (street, number, city, postal code, country)
- Telephone number
We also collect Personal Information when you contact us, such as for customer service purposes.
All the aforementioned information you submit through your registration process or at any other phase within the Website are given by you voluntarily and with your consent.
5. How we use your personal data
From the first time of visiting the Website, specific information will be stored anonymized in a protocol filesystem. This information will be completely stored anonymized i.e. Operating system (Linux, Windows, Mac OS etc.), browser (Chrome, Safari etc.), browser settings, additional information such as date and time of accessing the website and domain name of your internet service provider. This information is stored anonymized for logging/auditing purposes, the extraction of statistics regarding the performance or our service and to improve its user interface, contents and functionalities. No correlation between the identified and anonymized information is applied.
6. Why we use and collect your personal data
Ainigma uses and collects your personal data in order:
- To provide its requested services (e.g enable you to register for an account with an online service offered by Ainigma, provide you with the products, services and transactional communications requested by you or your company and for related activities, such as customer service, product service and support, account management, training, reporting and to provide other services related to your company’s account).
- To offer to its users personalized content.
- To process and respond to user feedback and inquiries.
- For administration and improvement of the services and the Website.
- To inform the users about new features, events and services with user consent or provide information about the Site.
- For fraud prevention and, where necessary, to safeguard legitimate interests of Ainigma or a third party or to prevent threats to state or public safety or to prosecute crimes, provided this does not conflict with the data subject’s legitimate interest.
- For other purposes, as long as those purposes were clearly disclosed to the data subject when the information was collected.
- To enforce the Terms of Use, i.e., to contact its users about a breach of the Terms of Use or to initiate a legal complaint.
7. Legal basis for Processing, including Legitimate Interests
Any personal information transmitted to the Website is used solely for the stated purposes when the information was transferred and any of the uses described in this Privacy Policy document. The data will not be used for any other purpose without the express consent provided. However, Ainigma may disclose personal information if it is required by law and/or
- To fulfill a contract with you or with your company (including providing support and services);
- For closely-related purposes, such as payment processing, account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance; and
- With your consent (or provided you have not objected, as may be applicable), to respond to requests for information and to provide you with marketing communications.
We may also process your Personal Data for the purposes of our legitimate interests, without prejudice to your rights and freedoms. In particular, we may process your Personal Information as needed to:
- Provided you have not objected, send you our marketing material;
- Protect you, Ainigma or others from threats (such as security threats or fraud);
- Comply with the laws that are applicable to us around the world,
- Enable or conduct our business, such as for quality control, analytics, consolidated reporting, and product development;
- Understand and improve our business or customer relationships generally.
8. Who we share your data with
User personal information will be transferred to affiliated companies and service providers (sub-processors) of Ainigma contracted with Ainigma, such as IT providers, to perform their contractual obligations. In case third parties have access to personal data of users, Ainigma shall apply legal, technical and organizational measures and regular monitoring regarding such parties’ compliance with the relevant data protection regulations and with this Privacy Policy.
We may disclose Personal Information, where permitted by law, where required to affect the sale or transfer of business assets, enforce our rights, including Terms of Use, protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. Also, we shall disclose Personal data in any case required by law, including law enforcement agencies and courts.
Please note that we may anonymize and/or aggregate your Personal Data to disclose information that is not personally identifiable. For example, we may publish reports that contain aggregated and statistical data. These reports shall not contain any information that would enable the recipient to contact, locate or identify you.
9. Cookies policy
Browser Cookies serve a functional purpose and improve the Website user experience. Ainigma uses browser cookies for statistical purposes to establish, for instance, whether a user visited the Website, and to help Ainigma identify Website features which may have great interest for its users. Cookies may enhance online experience by saving user preferences while visiting a particular website so that there is no need to reset them each time a user visits the Website. However, cookies do not store any personal information. Most browsers automatically accept cookies and provide options to reject cookies or to issue a warning before cookies are saved. You can decline any Browser cookie through your browser, however without Browser cookies you may not be able to use properly the Website. Check your browser’s cookies options in order to learn more about the status of your cookies option.
For more information about the cookies we use in our Website, please see our Cookies Policy.
10. Your rights
Your principal rights under data protection law are:
(a)the right to access;
(b)the right to rectification;
(c)the right to erasure;
(d)the right to restrict processing;
(e)the right to object to processing;
(f)the right to data portability;
(g)the right to complain to a supervisory authority; and
(h)the right to withdraw consent.
Rights and Freedoms of the Data Subject are not absolute, the request of the Data Subject requires the investigation of applicable regulations and laws. If the exercise of the Rights and Freedoms of the Data Subject is denied, the documented reasoning shall be made available for the Data Subject. Denial may only take place after authorisation of the Data Protection Officer (DPO) (see contact information below).
When responding to Subject Access Requests, no fees or charge can be applied to the Data Subjects under the GDPR, unless manifestly unfounded or excessive. It is key that identity verification takes place before any activity.
All communication with the Data Subject will take place in concise, transparent, intelligible and easily accessible form, using clear and plain language explaining any medical or technical terms. Where Ainigma declines to exercise the specific right, we shall inform the Data Subjecy of the reasons and the possibility to lodge a complaint with a Supervisory Authority and seek judicial remedy.
In case the company has transferred personal data to any other parties (Data Sub-Processors), Ainigma shall inform these Data Sub-Processors when the Data Subjects request to amend, restrict processing and erase their personal data.
11. International transfers
Your personal data may be transferred to, stored at or processed in other countries, which may not have equivalent privacy or data protection laws. However, regardless of where your personal data is transferred, we will protect it in accordance with this Privacy Policy and the applicable law. Personal information transfers from the European Economic Area (EEA) and other countries with data transfer restrictions shall be authorized by approved model contracts or other appropriate means.
12. Data retention
We shall retain your Personal Data for as long as required for the purposes set forth above and for any additional period that may be required or permitted by law. In case of an external private business agreement with you, Ainigma may retain your personal Data for a period defined in the private agreement. You may request that we delete your Personal Data by contacting customer support or our DPO. Unless we have a compelling interest in retaining your information, it shall be deleted within 30 days of your request.
13. Data Security
Ainigma has taken required, where applicable, or reasonable technical and operational precautions in order to protect personal information stored in Ainigma filesystems from unauthorized access, misuse or loss. Ainigma security procedures are monitored regularly and updated in line with technological progress.
No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Ainigma to intercept or access transmissions or private communications unlawfully. While Ainigma strives to secure personal information, neither Ainigma nor its collaborating service providers can ensure or warrant the security of any information transferred to us via Internet. Any such transfer shall occur at your own risk.
If you believe that Ainigma has not handled your personal information properly, you may also contact Ainigma’s Customer care service or our DPO at: info@ainigma.tech.
14. Contact information
You may contact us directly concerning any data security issue at info@ainigma.tech. Our Data Protection Officer and our legal department will assist you. In order to contact our Data Protection Officer directly, please contact us at dr@ainigma.tech so that we may provide you with the contact details.
15. Privacy policy changes
Ainigma may revise this Privacy Policy at any time as it integrates new features, or modify the way in which it manages information, or due to amendments to the law that may subsequently affect its Services. In case of such change, Ainigma shall will publish the changes on the Website and update the last updated date of this Privacy Policy. Any revised Privacy Policy shall apply both to personal information already collected at the time of the changeand to any personal information created or received after the change takes effect. You should periodically review this Privacy Policy, to see whether there have been any changes to policies that may affect you.
If you have any questions concerning this Privacy Policy, please contact us at info@ainigma.tech.
