Your privacy is one of our fundamental commitments, and therefore, we take utmost care to process your personal data in accordance with the principles set forth in the applicable legislation.
VATIS TECH S.R.L., having its headquarters at STR. LUCIAN PRICOP, NR.50, Vădăstrița, Olt, tax code 43155475, registered with the Trade Registry under no. J28/696/2021 ("VATIS TECH", "us") processes, as data controller, your personal data („Personal Data”). The purpose of this privacy policy („Policy”) is to explain how your Personal Data is processed by VATIS TECH.
1. CATEGORIES OF PERSONAL DATA, PROCESSING PURPOSES AND LEGAL GROUNDS
A. SECTION APPLICABLE TO USERS
If you use our Brewbrand platform available at https://app.brewbrand.ai (“Platform”) to generate LinkedIn posts (“User”), this Section A applies to you. Please also check Section B, which applies to visitors to https://www.brewbrand.ai and Users of the Platform.
Creating and managing the User account
Personal Data: first name, last name, e-mail address, user account ID, LinkedIn profile URL.
The LinkedIn profile indicated by the User must be public, as the service relies on publicly available profile information and posts. If the profile is private or the relevant content is not publicly accessible, the service cannot retrieve the information needed to generate personalised content.
Purpose of processing: Creating and managing the User account.
Legal ground: Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6, para. 1, let. b of GDPR).
Generating LinkedIn posts
Personal Data: LinkedIn profile URL, personal data contained in publicly available LinkedIn posts and in the ideas or other content provided by the User.
The service uses publicly accessible User's LinkedIn posts to analyse the User’s communication style and generate content based on the ideas provided. The AI services used are configured so that the data transmitted is not used to train the providers’ models.
Purpose of processing: Generating personalised LinkedIn posts.
Legal ground: Performance of a contract to which the data subject is party (art. 6, para. 1, let. b of GDPR).
Payments and invoicing
Personal Data: first name, last name, e-mail address, billing address, purchased services, payment amount and transaction information, to the extent received or retained by us.
Payments are processed through a third party payment processor. Payment card details are provided directly to the payment processor and are not accessed or stored by VATIS TECH.
Purpose of processing: Managing subscription payments and issuing invoices for the purchased services.
Legal ground: For managing subscription payments: performance of a contract to which the data subject is party (art. 6, para. 1, let. b of GDPR). For invoicing: compliance with the Company’s legal obligations in relation to taxation and accounting (art. 6, para. 1, let. c of GDPR).
Dispute resolution
Personal Data: first name, last name, e-mail address and other Personal Data necessary for the resolution of the dispute, contained in relevant correspondence or supporting documents.
Purpose of processing: Establishing, exercising or defending legal claims.
Legal ground: Legitimate interest of the Company (art. 6, para. 1, let. f of GDPR): the Company’s legitimate interest in protecting its rights and interests in disputes arising from or relating to the conclusion or performance of the contract, including proceedings before courts or other competent authorities.
B. SECTION APPLICABLE TO VISITORS AND USERS
This Section B applies to you if you are a visitor to our Platform or you if are a User.
Browsing Data
Computer systems and software procedures used for the operation of the Platform generally acquire some Personal Data (so-called "log files"), the transmission of which is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified persons, but due to its nature, can, through processing and integration with certain data held by third parties, allow the identification of visitors / users.
Such information includes IP addresses, the time of the request, the method used to send the request to the server, the size of the file obtained in reply, other parameters related to the visitor’s / user's operating system. Insofar such information leads to the identification of a user, the provisions of this Policy become applicable.
Purpose of processing: We use this data for the sole purpose of obtaining anonymous statistical information concerning the use of the Platform and to check its correct operation
Legal ground: Our legitimate interest in the improvement of our Platform and in managing the server capacities, and in the bug-free preservation of our Platform (art. 6 para. 1, let. f GDPR);
Compliance with our legal duties concerning the security aspects of our systems, including without limitation those resulting from the Vatis Tech obligation to take appropriate technical and organizational measures for the processing of Personal Data (art. 6 para. 1, let. c GDPR)
Communication with the visitor / User
Personal Data: first name, last name, e-mail address.
Purpose of processing: Communication with the visitor / User in relation to their requests / claims
Legal ground: Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6, para. 1, let. b of GDPR)
Marketing (Newsletter, promotions, offers, marketing communications)
Personal Data: first name, last name, e-mail address.
Purpose of processing: Sending marketing messages in order to advertise the Company's services
Legal ground: Data subject's consent (art. 6, para. 1, let. a of GDPR)
2. PROVIDING YOUR PERSONAL DATA
You may refuse to provide certain Personal Data but in such a case you may not be able to benefit from certain services specific to the relationship described in this Policy.
3. ABOUT LEGAL GROUNDS
The legal ground for processing the personal data differs depending on the specific situation and the Personal Data processed.
When we process your Personal Data based on your consent, we will seek your free, informed, specific and unequivocal consent for the respective processing. By expressing your consent, you will agree that we may collect, use, disclose, process and transfer Personal Data in accordance with this Policy.
4. AUTOMATED INDIVIDUAL DECISION-MAKING
Your Personal Data shall not be processed in order to be subject to decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, pursuant art. 22 para. (1) of GDPR.
5. PROCESSING DURATION
We keep your Personal Data only for as long as necessary for the purpose for which it was collected. When that period ends, we delete it or anonymise it so that it can no longer be linked to you.
Data related to creating, authenticating and managing your User account is kept for as long as your account is active. The same applies to the data we use to generate LinkedIn posts for you.
Invoicing and tax data is kept for 5 years, unless the law requires a different period.
When you send us feedback, we keep it until we have analysed it. When you contact us as a visitor or User, we keep the data from that communication until your request has been resolved.
In certain circumstances, we may keep your Personal Data for longer, but only as far as necessary. For example, we may do so to keep an accurate record of our relationship with you in case of a complaint, or where we reasonably believe that legal proceedings may arise.
6. TRANSFER OF PERSONAL DATA
We may transfer Personal Data, to the necessary extent, to the following categories of recipients: IT services suppliers (including authentication, hosting, database, workflow and AI service providers), e-mail services suppliers, payment services providers, accountants, marketing services suppliers, public authorities.
These recipients may be located in the European Union, the European Economic Area or third countries, including the United States. Transfers are carried out on the basis of an applicable adequacy decision or appropriate safeguards, such as the standard contractual clauses issued by the European Commission. For transfers to US organisations participating in the EU–US Data Privacy Framework, we may rely on Commission Implementing Decision (EU) 2023/1795, where the recipient’s certification is active and covers the relevant data. You may request information about recipients in third countries and a copy of the applicable safeguards at the contact address below.
7. SECURITY OF PERSONAL DATA
The security of your Personal Data is important for us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption of Personal Data, storage on secure environments. However, despite our efforts, we cannot always guarantee the effectiveness of the security measures implemented, and therefore we cannot guarantee the security of Personal Data at any time.
8. RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA
Access right: You have the right to obtain from us confirmation that your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, the source of Personal Data, if we transfer the Personal Data abroad and how we protect it, your rights, the right to lodge a complaint before the supervisory authority.
Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, we will immediately correct your Personal Data.
Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent on which the processing is based according and where there is no other legal ground for the processing; (iii) the Personal Data have been unlawfully processed; (iv) you exercise the right to object to the processing. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. There are also other circumstances in which we are not obliged to comply with this request for the deletion of Personal Data. Users can also delete their account directly from their profile. Data required to comply with legal obligations or for legal claims may be retained as described above.
Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) you contest the accuracy of the Personal Data, for a period enabling us to verify the accuracy of the Personal Data; (ii) the processing is unlawful and then you oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) we no longer need the Personal Data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; (iv) you have objected to processing, pending the verification whether our legitimate grounds override yours. However, we can continue to process your Personal Data (i) when you consent; (ii) for the establishment, exercise or defence of legal claims or (iii) for the protection of the rights of another natural or legal person.
Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically, and you have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.
Right to opposition: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest, you have the right to object to the processing of your Personal Data by us. We will stop such processing unless we demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims. You also have the right to object to the processing of your Personal Data for marketing purposes.
Withdrawal of consent: Insofar you consented to the processing of your Personal Data, you can at all times withdraw your consent, without affecting the lawfulness of processing based on consent before its withdrawal.
Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.
Right to lodge a complaint with the supervisory authority: You have the right to lodge a complaint with The National Supervisory Authority for Personal Data Processing (“DPA”) in relation to any breach of your rights regarding the processing of your Personal Data. The contact details of the DPA are: 28-30 Gheorghe Magheru Boulevard, District 1, Postal Code 010336, Bucharest, Romania; e-mail: anspdcp@dataprotection.ro.
To learn more about the manner in which you may exercise the aforementioned rights, please contact us at the e-mail below.
9. CONTACT
If you have any questions or concerns about this Policy or its implementation, you may contact us at: adrian@vatis.tech.