Privacy Policy

Seekr Technologies (“Seekr”, “the Company”, “we,” “us,” or “our”) is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information.

Scope

This Privacy Policy describes the processing of information provided or collected on the site(s) and/or application(s) where this Privacy Policy is posted. This Privacy Policy applies to all users of our service. We follow this Privacy Policy in accordance with applicable law in the places where we operate and process personal information.

The personal information we collect is covered by this Privacy Policy. Please note that our site(s) and/or application(s) may contain links to other sites not owned or controlled by us, and therefore, we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the Privacy Policy of other sites that may collect your personal information.

We may provide you additional privacy notices at the point of collection of your personal information, such as within a specific application, service, or form. These notices supplement this Privacy Policy and will govern to the extent of any conflict for the specific collection to which they apply.

Data Controller and Data Processor

A “data controller” is the entity that decides why and how personal data is processed. A “data processor” processes personal data only on behalf of, and under the instructions of, a data controller.

We collect and process your personal information and may act as either a data controller or a data processor depending on the service we provide. For certain services, we act as a data controller of the information that you provide to us, meaning we are responsible for deciding why and how personal data is processed. For other services, we act solely as a data processor, processing personal data on behalf of and in accordance with the instructions of a third-party data controller.

When we act as a data controller. We are the data controller for personal data we collect for our own purposes, including information collected through our websites, marketing and sales activities, events, and business communications. This Privacy Policy describes how we handle that data.

When we act as a data processor. When organizations use Seekr’s products and services, they may submit or collect personal data through our platform. We process that data solely on our customers’ documented instructions as a data processor, in accordance with our Data Processing Agreement. Our customer (not Seekr) is the data controller of that data, and the customer’s Privacy Policy governs its use. If you interact with an organization that uses Seekr’s products and wish to exercise rights over personal data they control, please contact that organization directly; we will assist the organization in responding to your request as required by applicable law.

Joint Controllership

In select circumstances, we may act as joint controllers with other parties for the processing of your personal data. This means that we jointly determine the purposes and means of processing your personal data.

When we act as joint controllers, we will enter into a joint controllership agreement with the other parties involved, outlining our respective responsibilities for complying with data protection laws and regulations.

Our responsibilities as a joint controller include (but are not limited to):

• Ensuring that your rights as a data subject are respected and fulfilled in accordance with applicable data protection laws and regulations.
• Providing transparent information about the processing of your personal data, including the purposes for which it is processed and the legal basis for processing.
• Implementing appropriate technical and organizational measures to ensure the security and confidentiality of your personal data.

Information We Collect

Personal Information

We may collect and process personal information about you, such as name, email address, phone number, online identifiers (i.e., ip address, device id, cookie identifiers, etc.), location data, and financial information (i.e., tax records, account number, routing number, and etc.).

Automatically Collected Information

We may also collect certain information automatically when you visit our website or use our services, such as your IP address, browser type, and usage data.

Information from Other Sources

We may receive personal data about you from other sources to supplement data already collected. This may include publicly available data or data provided by third parties. We may combine this data with the data we already have. We will handle this data in accordance with this Privacy Policy and the purposes outlined when the data was collected. We will notify you if there are any material changes to the way we intend to use this data. Please note that we are not responsible for the accuracy of the data provided by third parties or any consequences arising from the use of such data.

Lawful Bases for Processing

This Privacy Policy is a notice describing our information practices. It is not a request for your consent, and your use of our services is not treated as consent to the processing of your personal data. Where we rely on consent as our lawful basis, we will ask for it separately by means of a clear affirmative action, and you may withdraw it at any time as described in the “Withdraw Consent” section below. Seekr operates in dual roles depending on the service provided:

• For services we act as a data controller, we determine the purposes and means of processing your personal data. We process your personal data in these contexts under the lawful bases described in the “How We Use Your Information” section of this Privacy Policy, such as the performance of a contract, legitimate interests, compliance with legal obligations, or consent where we have obtained it.
• For services we act as a data processor on behalf of our clients who serve as the data controllers, we process your personal data solely based on their documented instructions and in accordance with our contractual obligations and applicable data protection laws.

We strive to ensure that our privacy practices remain transparent and understandable.

We encourage you to read this Privacy Policy in full. Where a processing activity depends on your consent, we will not carry out that activity unless and until you have given that consent, and declining or withdrawing consent will not affect your access to services that do not depend on it. If you have questions about any part of this policy, please contact us using the details in the “Contact Us” section below.

Special Categories of Personal Data

Specific protocols are necessary for the processing of ‘special categories of personal data’, because collecting these details is more likely to interfere with fundamental rights or open individuals to discrimination. These include personal data revealing:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data
• Health-related data
• Sexual orientation or data concerning a natural person’s sex life

The Company does not currently process special categories of personal data. Should this change, we will update this Privacy Policy and, where required by law, obtain your explicit consent prior to processing.

How We Use Your Information

We collect information you provide for the following purposes:

• Service Delivery: We use your personal information to provide you with the products or services you have requested. This may include processing your payment, shipping products to your address, or providing access to our online services. The lawful basis for this processing is typically the performance of a contract because we need to process your data to fulfill our contractual obligations to you.
• Communication: We may use your contact information to communicate with you. This includes sending transactional emails and service updates, and responding to your inquiries or requests. We may also use your contact information for marketing purposes, such as sending newsletters or promotional offers, if you have provided your consent or if we have a legitimate interest in doing so. The lawful basis for processing personal information for communication is legitimate interests and, when applicable, consent if you have provided it.
• Account Management: We use your personal information to manage your account, including account setup, verification, and maintenance. This ensures the security and functionality of your account on our platform. The lawful basis for this processing is typically the performance of a contract to maintain your account.
• Customer Support: Your information allows us to provide customer support when you have questions or encounter issues with our products or services. This may include troubleshooting, resolving complaints, and addressing your concerns. This processing is based on the legitimate interests to assist you in using our services effectively.
• Improvement of Services: We analyze your data to understand how our services are used and to make improvements. This includes enhancing the user experience, developing new features, and optimizing the performance and security of our products. This processing is also based on legitimate interests to improve and maintain the quality of our services.
• Legal Compliance: We may process your personal information to comply with our legal obligations, such as tax reporting, responding to legal requests, or assisting law enforcement agencies when required by law. This processing is necessary to fulfill legal obligations.
• Contractual Obligations: If you are a client or business partner, we may use your personal information to fulfill our contractual obligations, including managing contracts, invoicing, and providing support as agreed upon in our business relationship. The lawful basis for this processing is the performance of a contract.
• Fraud Prevention and Security: We use your information to protect against fraud, unauthorized access, and other security risks. This may include monitoring account activities and implementing security measures. The lawful basis for this processing is legitimate interests to ensure the security and integrity of our services.
• Aggregated and Anonymized Data: We may aggregate and anonymize your data to create statistical or research reports that do not personally identify you. This information may be used for business analysis, marketing, and sharing with partners or clients. The lawful basis for processing aggregated and anonymized data is legitimate interests and the fact that this data is no longer considered personal information.
• Other Purposes: In addition to the purposes listed above, we may use your personal information for other legitimate purposes, provided that they are compatible with the original reasons for which your data was collected. For these other purposes, we will rely on legitimate interests or other lawful bases as required by applicable laws.

Data Sharing

We do not sell your personal information. We share personal information only as described below. Please note that when your personal information is shared with an authorized third party, the information received by that third party is controlled by that company and, therefore, becomes subject to that company’s Privacy Policy.

We may share your personal information with the following categories of recipients:

• Service Providers: We may share your personal information with third-party service providers who assist us in delivering our products and services. We will only share the necessary data to fulfill their specific tasks and will have contracts or agreements in place to ensure they process your data securely. The lawful basis for sharing data with service providers is typically the necessity for the performance of a contract or, in some cases, legitimate interests, provided that these interests are not overridden by your data protection rights.
• Business Partners and Affiliates: In some cases, we may share personal information with our business partners and affiliates, but only when it is necessary for the performance of a contract, the provision of services, or as part of a legitimate business interest. For example, we may share data with a partner organization involved in co-branded events or services. Sharing data with business partners and affiliates may be necessary for the performance of a contract or based on legitimate interests, especially when these partnerships are essential for delivering integrated or co-branded services.
• Legal Authorities: We may be required to share personal information with legal authorities, regulatory bodies, or law enforcement agencies when necessary to comply with legal obligations or respond to valid requests for information, as permitted by the law. The lawful basis for sharing with legal authorities is the necessity to comply with a legal obligation.
• Protection of Rights and Safety: We may disclose personal information where we believe it is necessary to protect the rights, property, life, health, security, or safety of Seekr, our users, or third parties. The lawful basis for this disclosure is our legitimate interests, or vital interests where the disclosure is necessary to protect someone’s life.
• Merger or Acquisition: In the event of a merger, acquisition, or sale of all or part of our business, the sharing of personal information with the acquiring entity or parties involved in the transaction may be based on legitimate interests, as it’s necessary for the legitimate interests pursued by us or the acquiring entity. We will ensure that your data remains protected and used in accordance with this Privacy Policy.
• Publicly Available Information: We may share personal information that is publicly available, such as information from public records or online sources. However, we will do so only when it is relevant to the purposes for which your data was collected and used. Sharing publicly available personal information is typically based on legitimate interests, as it is in the legitimate interests of our business to use publicly available data for relevant purposes.
• With Your Consent: We may share your personal information with third parties if you have provided your explicit consent for such sharing. We will always request your consent before sharing your data for specific purposes. If you have provided explicit consent for sharing your personal information with specific third parties, the lawful basis for sharing is your consent.
• Other Legitimate Business Interests: In certain cases, we may share personal information with other parties for legitimate business interests. The sharing of this personal information may be based on legitimate interests. We will always ensure that such sharing is conducted in accordance with applicable data protection laws and respect your rights.

Data Transfers

As a global organization, we may transfer your personal data to countries outside the European Union (EU) or the European Economic Area (EEA). Such transfers may be necessary for the purposes outlined in this Privacy Policy, including providing you with requested products or services, communicating with you, and conducting our business operations effectively.

When we transfer your personal data to countries outside the EU/EEA, we will ensure adequate safeguards are in place to protect your personal data as required by applicable data protection laws and regulations. These safeguards may include (but are not limited to)

• Standard Contractual Clauses: We may use standard contractual clauses approved by the European Commission or other relevant data protection authorities to ensure the protection of your personal data during transfer.
• Data Protection Agreements: We may enter into agreements with recipients of your personal data outside the EU/EEA, imposing obligations on them to protect your personal data to the same standards required in the EU/EEA.
• Certification Mechanisms: We may rely on certification mechanisms such as the EU-U.S. Data Privacy Framework (DPF), where applicable, to ensure that third-party recipients of your personal data provide an adequate level of protection.

We rely on the safeguards described above when transferring your personal data outside the EU/EEA. Where personal data is transferred from the United Kingdom, we apply equivalent safeguards under the UK GDPR, including the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, as applicable.

If you have any questions or concerns regarding the transfer of your personal data outside of the EU/EEA or the safeguards we have implemented, please contact us using the contact details provided at the end of this Privacy Policy.

Data Subject Rights

As a data subject, we will provide you with the following rights:

Right to Access

You have the right to request access to your personal data that is processed. This means you can request information about what personal data is being held about you, and how such data is being used.

Right to Rectification

You can request the correction or updating of your personal data if it is inaccurate or incomplete. You, as the data subject and/or any third parties to whom the data has been disclosed, will be notified upon completion of the rectification process.

Right to Erasure (Right to Be Forgotten)

You can request the deletion of your personal data under certain circumstances. This right is not absolute and can be exercised if the data is no longer necessary, you withdraw consent, or the data processing is unlawful. You, as the data subject and/or any third parties to whom the data has been disclosed, will be notified upon deletion of such data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data under specific circumstances. This means the way your data is used will be limited, but not deleted entirely. This right might be exercised when you contest the accuracy of the data, the processing is unlawful, or you need the data for legal claims.

Right to Data Portability

You can request a copy of your personal data in a structured, commonly used, machine-readable format, or you can ask that it be transmitted directly to another data controller where technically feasible. This right is applicable when processing is based on consent or the performance of a contract.

Right to Object

You have the right to object to the processing of your personal data, including processing based on legitimate interests or for direct marketing purposes. We will stop processing your data for such purposes unless we can demonstrate compelling, legitimate grounds that override your interests, rights, and freedoms.

Automated Decision-Making and Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal or significant effects on you. You may request human intervention in the decision-making process. We will inform you when such decisions are made, provide you with the opportunity to express your point of view, and ensure there are human interventions available.

Withdraw Consent

If we process your personal data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or the place of an alleged infringement, if you believe that the processing of your personal data violates applicable data protection law. A listing of EU supervisory authorities is available on the European Data Protection Board’s website.

Any requests submitted by data subjects will be assessed for validity before being processed, including confirming the identity of the data subject. How these rights are fulfilled depends on the service you are using and our role in providing that service:

• For services where we act as a data controller, you may exercise the rights outlined above directly with us.
• For services where we act as a data processor on behalf of a third-party data controller, we do not have the authority to act independently on such requests. In those cases, we will promptly forward any data subject requests to the respective data controller for review and response.

To submit a request to exercise any of the rights described above, please use our Privacy Rights Request Portal. Submitting a request through this portal helps us verify your identity and route your request efficiently.

Data Security

We implement and maintain reasonable and appropriate technical and electronic safeguards to protect the security of your personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction.

While we implement these security measures to protect your data, it is important to understand that no online platform can guarantee absolute security. Therefore, we encourage you to take necessary, best-practice security precautions such as strong, unique passwords and being cautious with the sharing of login credentials.

In the event of a data breach or security incident, we will take immediate action to isolate and resolve the incident based on our incident response resolution procedures, notify relevant authorities, and inform affected data subjects in compliance with applicable data protection laws.

Data Retention and Disposal

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal or contractual 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 unauthorized 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, as well as applicable legal requirements.

Upon expiration of the applicable retention period, we will securely delete or anonymize your personal data in accordance with applicable laws and regulations.

Cookies and Tracking Technology

We may use “cookies” (or similar tracking technology) on our website. Cookies are text files that our web server may place on your hard disk to store your preferences. When you visit our website, you will be presented with a cookie banner or pop-up requesting your consent to use non-essential cookies. You have the right to accept or decline the use of such cookies. Your consent can be managed and changed anytime through your device or browser settings.

Cookies, by themselves, do not provide us with any personal information unless you explicitly choose and consent to provide this information to us. Once you choose and consent to provide personal information, however, this information may be linked to the data stored in the cookie. If you choose to turn off the collection of cookies through your device or browser, certain features of our service may not function properly without the aid of cookies.

Our website may also incorporate third-party cookies and tracking technologies. These technologies are subject to the privacy policies and practices of the respective third parties. We encourage you to review the privacy policies of these third parties for information on how they collect and use your personal data.

We use both session ID technology and tracking technology. Session ID technologies make it easier for you to navigate our website and expire when you close your browser. Tracking technologies help us understand how you use our website and enhance your visitor experience.

Please note that if you choose to turn off the collection of cookies through your device or browser, this may invalidate other opt-outs that rely on cookies to function, in addition to affecting certain features of our service. Please also note that our website is not designed to respond to “Do Not Track” signals received from browsers.

We may also use third-party tools to collect and analyze company-level information about visitors to our website, such as the name of the organization visiting our website, pages viewed, and general interaction data. This information is used to improve our services and understand user behavior, and does not include personal information about individuals.

In addition to the cookies described above, we may also use analytics tools that do not use cookies or other persistent identifiers and do not track visitors across sessions, days, or devices. These tools rely on temporary, randomized values that are reset periodically and produce only aggregated statistics, such as total visits, page views, and traffic sources. Because this processing does not identify or make identifiable any individual, it does not involve the processing of personal data, and no cookie consent is required for its use.

Social Features and Third-Party Platforms

Certain features of our site or application may permit you to initiate interactions between our services and other platforms, such as social networks operated by unaffiliated parties (“Social Features”). For example, you may follow us on social media. Any content you provide through Social Features will be considered public and is governed by the privacy policy of the company providing them.

If you interact with us through Social Features, we may have access to information about you from the social media platform. If you mention us, or comment about or in response to us, on another platform, that platform may allow us to publish your post on our site or application. We may also receive information about you when that information is accessible through another user’s social media connections. You should review the terms, policies, and settings of these platforms to learn more about their data practices and to adjust your settings as needed.

Children

We do not knowingly collect any information from minors. In situations where personal data from anyone under the age of 16 is needed for data processing activities, we will obtain authorization from an appropriate parent or guardian. If such authorization is unable to be obtained, data processing activities for that data subject will be terminated. In the event that we discover that a minor under the age of 16 has provided personal information to us, we will make efforts to delete the information ASAP. Our responsibilities related to the above differ based on the service you are using:

• For services where we act as a data controller, if we need to process personal data from a child under 16, we will seek verifiable consent from a parent or legal guardian before collecting or using such data. If parental authorization cannot be obtained, we will terminate the processing activity and delete the data as soon as possible. If we discover that a child under 16 has provided us with personal information without appropriate consent, we will take immediate steps to remove such data.
• For services where we act as a data processor on behalf of a third-party data controller, we do not make independent decisions regarding the collection or use of children’s data. In such cases, we rely on the data controller to ensure compliance with applicable children’s data protection requirements. Any concerns related to a child’s personal data collected should be directed to the relevant data controller.

If you believe your child may have accessed our services or if you wish to request the removal of your child’s personal data, please contact us at DPO@seekr.com. If we are acting as a data processor, we will refer your request to the appropriate data controller.

European Data Protection Rights

If the processing of your personal data is subject to European Union (EU) data protection law, you have certain rights with respect to that data. Please refer to the section “Data Subject Rights” above for a listing of these rights.

Additionally, our processing of your personal data is based on specific legal bases as defined in EU data protection law. Please refer to the section “How We Use Your Information” above for a listing of these legal bases.

Location of Personal Information

Our service is hosted in the United States and the United Kingdom. Personal information collected with the service is stored in those countries. If you are visiting our site or using our service, please be aware that you are transferring personal data to those locations.

EU Representative

If you are located in the European Economic Area (EEA), our designated EU Representative for data protection inquiries is:

EU Representation contact details

Postal Address: The DPO Centre Europe Ltd, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2

Phone number: +353 1 631 9460

Email: eurep@seekr.com

UK Representation contact details

Postal Address: The DPO Centre Ltd, 50 Liverpool Street, London, EC2M 7PY, UK

Phone number: +44 (0) 203 797 6340

Email: ukrep@seekr.com

If you have any questions regarding your personal data, you may contact our EU Representative at the details provided above.

Updates to this Privacy Policy

We periodically review this Privacy Policy and may make updates to reflect changes in our practices, for legal reasons, or to meet new regulatory requirements.

When we make changes, we will revise the Effective Date at the top of this Privacy Policy and, where the changes are material, provide notice through our website or by contacting you directly before those changes take effect. If a material change would apply to personal data we have already collected in a manner that is not compatible with the notice given at the time of collection, we will obtain your consent by means of a clear affirmative action before applying the change to that data, where required by applicable law. Your continued use of our services does not by itself constitute consent to any new or expanded processing of your personal data.

Contact Us

If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy, please contact us at privacy@seekr.com. For specific requests relating to your rights as a data subject, including the rights noted in section “Data Subject Rights” noted above or any other data protection matters, please contact our Data Protection Officer (DPO) directly at DPO@seekr.com.