Policy

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Welcome to Relata’s Privacy Notice (the “Privacy Notice”).

Relata (collectively referred to as “Relata”, “we“, “us” or “our” in this Privacy Notice) respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you when:

• you visit our website at www.relata.ai(regardless of where you visit it from) (“Site”);
• you are in contact with us, whether by email, voice or video calls or any other means of communication (“Correspondence”)
• you access our web app (“App”); and
• we provide you with our interaction tracking software/services (“Services”).

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The following are categories of individuals to whom this Privacy Notice applies:

• User: means any person accessing our Site or in Correspondence with us.
• Client: means any individual, business or organisation, including any of their employees, agents or contractors, using the Services/App.

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We reserve the right to change this Privacy Notice as may be necessary from time to time by changing it on the Site or by emailing you.

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1. Important information and who we are

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Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how we collect and process your personal data through your use of the Services, Site, App or from Correspondence.

The Site, App and Services are not intended for children and we do not knowingly collect data relating to children.

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Controller

For the purposes of data protection and in relation to the provision of our Services or App to you as a Client, you are the controller and we are the processor. When we use personal data in relation to the development of our software we are the controller. We are also the controller where we process any personal data from your use of theSite or from Correspondence.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this PrivacyNotice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights set out below. You can contact the data privacy manager by using the contact details set out below.

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Contact details

Our full details are:

Company name: FeedStock Limited (UKCompany Number: 09604780)

Name of data privacy manager: Lucas Wurfbain

Email addresses: privacy@relata.ai

Postal address: 7 Savoy Court, London, WC2R 0EX, United Kingdom

Telephone number: 020 3633 1840

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You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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Changes to the Privacy Notice and your duty to inform us of changes

This version was last updated on 21st March 2023.

It is important that the person all data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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Third-party links

Our Site 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 Notice of every website you visit.

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Third Party Processors

‍Our carefully selected partners and service providers may process personal information about you on our behalf as described below:Digital Marketing Service ProvidersWe periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

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2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed(anonymous data). We may check the details you provide with fraud prevention agencies and share your information with them if we suspect fraud. It is important that you don’t provide false, inaccurate information or in person at another individual.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes title, first name, last name and job title.
• Contact Data includes billing address or registered company address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of Services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and  location, browser plug-in types and versions, operating system and     platform and other technology on the devices you use to access the Site     and App or for Correspondence.
• Profile Data includes your unique account  reference number, actions made by you on the App or Site, preferences, feedback, survey responses and other Correspondence.
• Usage Data includes information about how you  use our Site, App and Services and interactions tracked through our Services.
• Marketing and Communications Data includes  your preferences in receiving marketing from us, and your communication  preferences.

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We also collect, use and shareAggregated Data such as statistical or demographic data for any purpose.Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature or the number of Service types that are purchased. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We do not knowingly or intentionally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexlife, sexual orientation, political opinions, trade union membership,information about your health and genetic and biometric data) nor any information about criminal convictions and offences.  However in the event that we do collect such data we do not use this data in any of our software output or Services.

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If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with theServices). In this case, we may have to cancel delivery of the Services you have with us but we will notify you if this is the case at the time.

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3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact by filling in forms, providing documentation or by corresponding with us by post, phone, email or otherwise. This includes  personal data you provide when you:
      use our App and Services;
      create an account for our App or otherwise;
      enter into Correspondence with us, for example, to report a problem with the Site, App or Services, or for other purposes;
      request marketing to be sent to you; or
      give us some feedback.

• Automated technologies or interactions. As you interact with our Site, we may automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• When you are in Correspondence with us then we may record video/voice calls for training and monitoring purposes.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
      analytics providers based in the UK or the EU, including Google Analytics and Lead Forensics; and
      search information providers.
• Contact and Transaction Data from providers of technical, payment and delivery services.

• Identity and Contact Data from the Client or from lead generation providers, including Lusha.

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4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

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Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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Purposes for which we will use your personal data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

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Purpose/Activity

To register you as a new Client

Type of data

• Identity
• Contact

Lawful basis for processing including basis of legitimate interest

 Performance of a contract with you

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Purpose/Activity

To provide the Services to you including:

• Manage payments, fees and charges
• Collect and recover money owed to us

Type of data

• Identity
• Contact
• Transaction
• Profile
• Technical

Lawful basis for processing including basis of legitimate interest

• Performance of a contract with you
• Necessary for our legitimate interests (to ensure payments are made correctly)
• Necessary for the legitimate interests of others (preventing fraud)

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Purpose/Activity

To manage our relationship with you which may include:

• Notify you about changes to our terms, Privacy     Notice or Services
• Ask you to leave a review or take a survey

Type of data

• Identity
• Contact
• Transaction
• Profile
• Marketing and Communications

Lawful basis for processing including basis of legitimate interest

• Performance of a contract with you
• Necessary to comply with a legal obligation
• Necessary for our legitimate interests (to  keep our records updated, study how users use our Services and to improve     our Services into the future)

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Purpose/Activity

To administer and protect our business, the Site, App and Services (including troubleshooting, data analysis,testing, system maintenance, product development, support, reporting and hosting of data and debugging)

Type of data

• Identity
• Contact
• Technical
• Usage

Lawful basis for processing including basis of legitimate interest

• Necessary for our legitimate interests (for     running our business, improving our software, the provision of     administration and IT services, network security, to prevent fraud in the     context of a business reorganisation or group restructuring exercise)
• Necessary to comply with our legal obligations

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Purpose/Activity

To deliver relevant Services and Appand Site content and advertisements to you and measure or understand theireffectiveness

Type of data

• Identity
• Contact
• Profile
• Usage
• Marketing and Communications
• Technical

Lawful basis for processing includingbasis of legitimate interest

Necessary for our legitimateinterests (to study how users use our Site, App and Services, to develop them,to grow our business and to inform our marketing strategy)

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Purpose/Activity

To use data analytics or other meansto improve our Site, App, Services, marketing, client relationships andexperiences

Type of data

• Identity
• Contact
• Technical
• Usage
• Profile
• Marketing and Communications

Lawful basis for processing includingbasis of legitimate interest

Necessary for our legitimateinterests (to define types of users for our Services/App, to keep our Siteupdated and relevant, to develop our business, for training and monitoringpurposes and to inform and deliver our marketing strategy)

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Purpose/Activity

To make suggestions andrecommendations to you about Services or events that may be of interest to you

Type of data

• Identity
• Contact
• Technical
• Usage
• Profile
• Marketing and Communications

Lawful basis for processing includingbasis of legitimate interest

Necessary for our legitimateinterests (to develop our software and grow our business)

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Marketing

We strive to provide you with choicesregarding certain personal data uses, particularly around marketing andadvertising.

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Promotional offers from us

We may use your Identity, Contact,Technical, Usage and Profile Data to form a view on what we think you may wantor need, or what may be of interest to you. This is how we decide whichServices and offers may be relevant for you and send to you through ourmarketing messages.

You will receive marketing messagesfrom us if you have requested information from us or purchased Services from usand you have not opted out of receiving that marketing.

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Opting out

You can ask us to stop sending youmarketing messages at any time by contacting us (unsubscribe@relata.ai)or unsubscribing from our marketing list.

Where you opt out of receiving thesemarketing messages, this will not apply to personal data provided to us as aresult of a Service use, warranty registration, Service experience or othertransactions.

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Cookies

A cookie is a small file of lettersand numbers that we store on your browser or the hard drive of your computer ifyou agree. Cookies contain information that is transferred to your computer’shard drive.

We only use the following cookies:

• Strictly necessary cookies. These are cookies     that are required for the operation of our Site and App. They include, for     example, cookies that enable you to log into secure areas of our App.
• Analytical/performance cookies. They allow us     to recognise and count the number of visitors and to see how visitors move     around our Site or how they use our App. This helps us to improve the way     our Site and App work, for example, by ensuring that users are finding     what they are looking for easily on the Site.

For further details on the cookies weuse, please see below:

Cookie name: _ga*

Type of cookie: Google Analytics

Purpose of cookie: Usability trackingused by Relata

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Cookie name: _hj*

Type of cookie: HotJar Analytics

Purpose of cookie: Usability trackingused by Relata

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Cookie name:  _hs*

Type of cookie: HubSpot

Purpose of cookie: Providingfunctionality to our demo sign up experience.

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Cookie name:  li_*

Type of cookie: LinkedIn

Purpose of cookie: Providing insightinto our business traffic.

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Cookie name: sessionid, csrftoken

Type of cookie: Functional cookies

Purpose of cookie: Providing corefunctionality to the product such as session control.

You can set your browser to refuseall or some browser cookies, or to alert you when websites set or accesscookies. If you disable or refuse cookies, please note that some parts of theSite or App may become inaccessible or not function properly. You can findfurther information about cookies, and how to set or access cookies, by goingto www.aboutcookies.org/default.aspx.

Please note that third parties(including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

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Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Client or other Users as applicable.
• Service providers who provide, for example, payment, software, hosting, marketing, IT or system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.‍

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6. International transfers

We may transfer, store and/or use your personal information outside of the UK and the European Economic Area (the“EEA”) and the laws of some of these destination countries may not offer the same standard of protection for personal information as countries within the UK and EEA.  It may also be processed by staff operating outside the UK andEEA who work for us or for one of our suppliers.

We currently transfer data to the following countries outside of the UK and EEA: United States of America.

We may update this list from time to time and any changes will be communicated to you via an update to this PrivacyNotice.

Transfers to our third-party service providers are to enable them to use and store your personal information on our behalf. We will, however, put in place appropriate security procedures in order to protect your personal information. We also ensure that, where your information is transferred to any country outside the UK and EEA, this is done using suitable safeguards where necessary. You can request further details by contacting us (see section 1).

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7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

As evidence of our approach to data security, FeedStock is ISO 27001 certified.

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8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you)for research or statistical purposes in which case we may use this information indefinitely without further notice to you.‍

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9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

• Access to information: You have the right to request a copy of the information Relata holds about you.
• Ensuring accuracy of information: Relata wants to make sure that your personal information is accurate and up-to-date. You may ask Relata to correct or complete information that is inaccurate or incomplete.
• Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require Relata to delete personal information held about you.
• Ability to restrict processing: You may also have the right to require Relata to restrict Relata’s use of your personal  information in certain circumstances. This may apply, for example, where you have notified Relata that the information Relata holds about you is incorrect and you would like Relata to stop using such information until Relata has verified that it is accurate.
• Right to data portability: You may have the right to receive personal data Relata holds about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
• Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body, including ICO as listed above.
• Preventing direct marketing: Relata does not sell your personal data. From time to time, Relata may send emails  containing information about new features and other news about us. This is considered direct marketing. Relata will always inform you if Relata intends to use your personal data or if Relata intends to disclose your information to any third party for such purposes.
• Objecting to other uses of your information: You may also have the right to object to Relata’s use of your information in other circumstances. In particular, where you have consented to Relata’s use of your personal data, you have the right to withdraw such consent at any time.

If you would like further information on how you can exercise these rights, please email us at privacy@relata.ai.

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No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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Time limit to respond

We try to respond to all legitimate requests within one month.Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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