The information and data you may provide, or which may otherwise be collected through the Websites, in the context of your use of expert.ai’s services, such as the registration to the Natural Language API developer platform provided on the website https://developer.expert.ai/or to expert.ai’s community, the use of the NL Platform (“Platform”) or the use of our analysis & classification tool provided on the website https://try.expert.ai/, the request to have further information on our products and services, etc. (hereinafter, the “Services”) as defined in the Purpose of processing Section, will be used by expert.ai in compliance with the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.
- Data Controller
- Data Protection Officer
- Personal Data processed
a. Name, contact details and other Personal Data
b. Job applications. Special Categories of Personal Data
c. Third party Personal Data provided voluntarily by the user
d. Publicly available online data
e. Browsing data
- Purpose of the processing
- Legal bases, data controllership and mandatory/discretionary nature of the processing
- Recipients of Personal Data
- Transfers of Personal Data
- Retention of Personal Data
- Data subjects’ rights
- Additional information regarding local processing, where applicable, and privacy law
1. Data Controller
The Data Controller of your personal data is expert.ai S.p.A., registered office in Rovereto (38068 – Trento, Italy), Via Fortunato Zeni, No. 8, VAT No. 02608970360 (hereinafter the “Company”), as well as each company of the expert.ai Group that processes personal data under the circumstances specified below (each individually the “Relevant Company” and jointly with the Company, “expert.ai”).
Expert System Enterprise Corp., with registered office in 6110 Executive Boulevard, Suite 690, Rockville (U.S.A.), MD 20852.
Expert System Iberia S.l.u., with registered office in Calle Poeta Joan Margall, 3-5, escalera izquierda, planta 1ª, derecha, 28020, Madrid, Espana.
Expert System France S.a., with registered office in 15 – 17, rue Traversiere, 75012 Paris, France.
Expert System Deutschland Gmbh., with registered office in Weinbergsweg 3c, 61348 Bad Homburg v. d. Höhe.
Expert System Cogito Ltd., with registered office in Unit 203, Second Floor China House 401 Edgware Road, NW2 6GY, London – United Kingdom.
Expert System Canada – Semantic T. Inc., with registered office in 900-2001 av.McGill College Montréal (Québec) H3A1G1 – Canada.
2. Data Protection Officer
It is possible to contact the expert.ai Group Data Protection Officer (“DPO”) by writing to: [email protected].
3. Personal Data processed
As a result of browsing the Sites and/or the Services, we inform you that the Company and/or the Relevant Company of the expert.ai Group will process your Personal Data, which may consist – also depending on your decisions on how to use the Services – of an identifier such as your name, an identification number, an online identifier (hereinafter just “Personal Data”), either because you voluntarily provide it (e.g. when you fill out an online form or when you decide to register with Natural Language API or the expert.ai community and create your profile) or simply by analyzing your behavior on the Sites.
Please note that payments for the services provided by the Natural Language API are made through a third-party platform (depending on the country in which you are located, e.g. PayPal or others), which operates as an independent data controller and does not allow expert.ai to access your payment information, such as credit card number or other data that you must provide to complete the purchase. Expert.ai will, however, use your billing information, which will be requested at the time of purchase, for any relevant tax and accounting obligations and to send you the invoice relative to your purchase.
Personal Data which may be processed through the Websites are as follows:
a. Name, contact details and other Personal Data
In some sections of the Websites (e.g. Contact Us, Resources, Newsletter, online training programs, community’s profile settings, Natural Language API registration form, etc.), you may be asked to enter information such as your name, surname, telephone number, email address, job title, company you work for, etc.
b. Job applications. Special Categories of Personal Data
By sending your application and your CV from the “Careers” section on www.expert.ai, you authorize the Company and/or the expert.ai Group’s Relevant Company to process your Personal Data. Expert.ai asks that you do not disclose Personal Data which may fall under the category of Personal Data referred to in Article 9 of the Regulation – i.e. “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”, unless you consider this to be strictly necessary, and to provide your consent if you decide to share them by authorization to be included in the CV. The processing of such Personal Data may be permitted as it is based on the release of your consent according to the applicable rules on personal data protection. Expert.ai asks that you do not disclose any such types of Personal Data unless you consider this to be strictly necessary. In any case, expert.ai would stress the importance of providing your explicit consent to process this sort of Personal Data, if you decide to share it, nonetheless.
c. Third party Personal Data provided voluntarily by the user.
As mentioned above, in some parts of the Sites (such as, for example, in the Contact Us section found at expert.ai, in the comment sections found under topics created by members of the expert.ai community, or when you enter text or type in a URL within the analysis and classification tool) you may enter text messages or information that may contain Personal Data of other people.
With respect to such hypotheses, you stand as autonomous data controller, assuming all the obligations and responsibilities of the law. In this sense, it confers on the point the widest indemnity with respect to any dispute, claim, request for compensation for damages from processing, etc. that may be received by expert.ai from third parties whose Personal Data have been processed through its use of the functions of the Sites in violation of the applicable data protection regulations. In any event, should it provide or otherwise process Personal Data of third parties in its use of the Sites, it warrants as of now – assuming all related liability – that such particular instance of processing is based on the consent of such third party concerned or on another appropriate legal basis legitimizing the processing of such information.
d. Publicly available online data
As part of the presentation and promotion activities (“Demo”) of its semantic analysis platform, the Company may also process documents and information publicly available online that may contain Personal Data (e.g. in newspaper articles, magazines, etc.). Such processing is based on the legitimate interest of the Company to demonstrate the correct functioning and capabilities of the Demo(s) and is carried out for the time strictly necessary to achieve the aforementioned purpose. For further information you can write to: [email protected].
e. Browsing Data
The computer systems and software procedures used to operate the Sites acquire, in the course of their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. While expert.ai does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Websites, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. Data could be used to ascertain liability in case of hypothetical computer crimes against the Sites, the Platform or third parties: except for this eventuality, at present, data on web contacts do not persist for more than seven days.
4. Purpose of the processing
The Company (and/or, where relevant, the expert.ai Group’s Relevant Company) intends to use your Personal Data, collected through the Websites, for the following purposes.
To provide Services you request, such as the download of the materials shared on the Websites (e.g. in the “Resources” section on www.expert.ai), subscribing to events, the online training programs and/or expert.ai’s community, providing you access to the Natural Language API you request, using the Platform or our analysis & classification tool, responding to a request sent to addresses you may find on the Websites (“Provision of the Service“).
To analyze the CV and to contact the candidates who submit their applications through the addresses you may find in the “Careers” section on www.expert.ai (“Recruitment“).
To carry out direct marketing activities via e-mail for services similar to those you have subscribed to through the Websites, unless you objected to such processing initially or in subsequent communications (“Soft Opt-In“).
To analyze your preferences, habits, interests, and consumption choices expressed through the use of the Websites and the services offered, and, where appropriate, by using non-essential cookies, in order to send you material and commercial communications and personalized promotions on the services offered by expert.ai (“Personalization”).
To fulfil the legal obligations which required the Company and/or the expert.ai Group’s Relevant Company to collect and/or further process certain types of Personal Data (“Compliance“).
To prevent or identify any fraudulent conduct by using the Websites in order to allow the Company and/or the expert.ai Group’s Relevant Company for legal defense (“Abuse/Fraud”).
To verify information relevant to the use of the Platform in order to ensure the security of the services we provide (“Security”).
To carry out statistical analysis without the possibility of identifying the user (“Statistics”).
To disclose, where a subscription to the expert.ai online training programs occurs, Personal Data (name, surname, company role, and – if applicable – LinkedIn account) of the contractual representative or another contact point of the partners of expert.ai on expert.ai social media accounts, in order to promote the certification obtained (“Disclosure“).
5. Legal basis data controllership and mandatory/discretionary nature of the processing
The legal bases the Company (and/or, where relevant, the expert.ai Group’s Relevant Company) to process your Personal Data, in accordance with the purposes set out in the Purpose of Processing Section above, are as follows:
Provision of the Service: the processing for this purpose is carried out by the Company in its capacity as autonomous data controller. Such processing is necessary to provide the Service and for the performance of the contract. The provision of your Personal Data for this purpose is optional, however, failure to provide them would imply the inability to initiate the requested Services provided through the Websites or to respond to requests.
Recruitment: the processing for this purpose is necessary for the Company (or, where appropriate, the expert.ai Group’s Relevant Company) to be able to consider your application and, therefore, it is necessary in order to start the selection process. The provision of your Personal Data is optional, but any failure to provide it would make it impossible to evaluate your profile. If you decide to provide special categories of Personal Data (e.g. data concerning health, religious beliefs, etc.), the Company (or, where appropriate, the expert.ai Group’s Relevant Company) may require your specific consent which, in this case, may be inserted at the bottom of your application. In this regard, we would like to remind you not to provide such type of information unless strictly necessary and that in the absence of your giving your consent to the processing of special categories of Personal Data related to you, if you provide such type of data, your application cannot be considered.
Soft Opt-In: the processing for this purpose is carried out by the Company in its capacity as autonomous data controller. Such processing is based on the interest of the Company to send marketing communications by email regarding products and services similar to those requested through the Websites. You may interrupt the receipt of these communications, without any consequence for you (with the exception of the failure to receive such further communications from the Company) using the link at the bottom of each of these emails.
For Personalization purposes, where applicable in relation to the geographical area of reference, the Relevant Company acting as Joint Controller is: Expert System Iberia S.l.u. (for Spain), Expert System France S.a. (for France), Expert System Deutschland Gmbh (for Germany), Expert System Cogito Ltd. (for the United Kingdom), Expert System Canada – Semantic T. Inc. (for Canada).
- Compliance: the processing for this purpose is carried out by the Company (or, where appropriate, the expert.ai Group’s Relevant Company) in its capacity as autonomous data controller and is necessary in order to fulfil any legal obligations. When you provide Personal Data, they must indeed be processed according to the applicable regulations, which could entail their retention and disclosure to the Authorities for accounting, tax, or other obligations.
- Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activity or abuse in the use of the Websites and therefore allow the Company or the expert.ai Group’s Relevant Company, in its capacity as autonomous data controller, to defend in court.
- Security: the processing for this purpose is carried out by the Company in its capacity as autonomous data controller and it is based on the legitimate interest of the Company.
- Statistics: it is specified that such processing is not performed on Personal Data and therefore can be freely carried out by expert.ai.
6. Recipients of Personal Data
Your Personal Data may be shared with the subjects mentioned below (collectively “Recipients”):
- subjects typically acting as data processors, namely: persons, companies or professional firms providing the Company (or, where appropriate, the expert.ai Group’s Relevant Company) with advice and consulting in accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
- subjects to engage with in order to provide the Services (for instance hosting providers or email platform providers);
- persons authorized to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
- persons authorized by the Company (or, where appropriate, the expert.ai Group’s Relevant Company) to process the Personal Data required for carrying out activities strictly related to the provision of the Services, who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality, for example the Company and/or expert.ai Group’s Relevant Company employees;
- public entities, bodies, or authorities to disclose your Personal Data to in accordance with Compliance, Abuse/Fraud purposes or under the orders of the authorities.
7. Transfers of Personal Data
Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. Expert.ai ensures that your Personal Data are processed by these Recipients in accordance with the applicable rules on data protection. Indeed, transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. Further information is available from expert.ai by writing to the following email address: [email protected].
8. Retention of Personal Data
Personal Data processed for Provision of the Service purposes will be kept by the Company for the period deemed strictly necessary to fulfil such purposes. In any case, as these Personal Data are processed for the provision of the Services, the Company will retain them for a longer period of time, particularly as may be necessary under applicable law to protect the Company’s interests against possible claims relating to the Services.
Personal Data processed for Recruitment purposes will be kept by the Company and/or expert.ai Group’s Relevant Company for 24 months and they may be used to contact you for any future job opportunities at expert.ai.
Personal Data processed for Marketing and Personalization purposes will be kept by the Joint Controllers until you withdraw your consent or until you object to the processing (where applicable). Once the consent has been withdrawn, the Joint Controllers will no longer use your Personal Data for such purposes, but they may retain them in any case, in particular if it may be deemed necessary in order to protect the interests of the Joint Controllers from potential complaints based on such processing.
Similarly, Personal Data processed for the purpose of Disclosure will be retained by the Company until you withdraw your consent or until you object to the processing (where applicable). Once the consent has been withdrawn, the Company will no longer use your Personal Data for such purposes, but may still retain it, in particular if it may be deemed necessary in order to protect the interests of the Joint Controllers from potential complaints based on such processing.
Personal Data processed for Soft Opt-in purposes will be kept by the Company until you object to the processing for such purpose.
Personal Data processed for the Compliance purpose will be retained by the Company or by expert.ai Group’s Relevant Company for the period provided for by specific legal obligations or applicable law.
Personal Data processed to prevent Abuse/Fraud and for the Security purpose will be retained by the Company (or, if appropriate, by expert.ai Group’s Relevant Company) for the time deemed strictly necessary for the aforementioned purposes, and thus until it is bound to keep them so as to protect himself in court to communicate such data to the competent Authorities.
9. Data subjects’ rights
Under Article 15 et seq. of the Regulation, you, as a data subject, are entitled to request at any time, to the Company or, where appropriate, to the expert.ai Group’s Relevant Company, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing, pursuant to Article 21 of the Regulation. You are also entitled to request the restriction of the processing of your Personal Data in the cases set out in Article 18 of the Regulation, as well as to obtain the Personal Data you have provided in a structured, commonly used, and machine-readable format, in the cases set out in Article 20 of the Regulation. You may interrupt the reception of Soft Opt-in, by using the appropriate link you may find at the bottom of each e-mail you receive. Requests should be made in writing to: [email protected] or to the work address of the Company (or the expert.ai Group’s Relevant Company) listed above.
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through these Websites violates applicable law.
11. Additional information regarding local processing, where applicable, and privacy law