Summary
This Privacy policy (the “Policy”) sets out the way in which Celito Tech (“Celito”, “we” “our” or “us”) and its subsidiaries and affiliates are committed to safeguarding the privacy of the data you submit to us through our product Celito AI (the “Services”).
This Privacy Policy describes how Celito collects, uses, shares, and secures the Personal Data you provide. It also describes your choices regarding use, access, and correction of your personal information. Celito’s use of information collected through our services is limited to the purpose of providing the Services.
Type of Data We Collect
To provide you with the Services, we collect your Personal Data. In simple terms, personal data is information that identifies you as an individual, including your name, email address, home or business address and telephone number (“Personal Data”).
We collect Personal Data which you provide to us, including when you register for an account. In addition, we collect information about your use of the Services. We will also collect other information necessary for us to process your Personal Information for the purposes set out in this Policy.
Typically we collect the following data:
Person Data You Provide Directly to Us. When you use the Services or register for a Services account with Celito, or when interacting with the Services, responding to surveys, requesting information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Account Creation. We may collect Personal Data from you to create a Services account, such as your name, job title, email address, phone number, username, information, and other Personal Data requested at the time which you register for an account with either the Services.
Use of the Services. When you access or otherwise use the Services, we may collect Personal Data from you.
Communications with Us. We may collect Personal Data from you such as email address, phone number, or mailing address when you choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us. As a job applicant, we may also collect your resume and cover letter.
Automatic Data Collection. We may collect certain Personal Data automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, MAC address, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the data and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
How We use Your Personal Data; Legal Basis
Personal Data submitted to us through the Services, may be used and processed for the following specified purposes:
Usage Data:
Purpose of Processing: keep our Services secure, diagnose and prevent service or technology problems affecting our Services; prevent fraud; better understand the types of visitors who browse or use our Services in order to improve it; safeguard that the users of our Services comply with the Terms of Use.
Correspondence Data:
Purpose of Processing: to enable us to respond to enquiries or complaints you may have about our Services.
Research and Development:
Purpose of Processing: use Personal Data alone or in the aggregate with information obtained from other sources, to help us deliver our existing Services optimally, better understand and serve the users of the Services, conduct research on customer demographics, interests and behavior; and develop new Services. This research may be compiled and analyzed alone or on an aggregate basis, and Celito may share the aggregate data with its current affiliates and vendors for lawful purposes
Sharing Content with Friends or Colleagues:
Purpose of Processing: offer various tools and functionalities that allow you to share content and collaborate with others. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request but will not be collected or otherwise used by Celito or any other third-parties for any other purpose.
Other Uses. We may use Personal Data for which we have a legitimate interest, such as direct marketing, individual or market research, fraud prevention, disclosure to our affiliated organizations, and network and information security. We may also use your Personal Data where such use is necessary to provide the Services, to comply with our legal obligations, protect a vital interest or for any other purpose disclosed to you at the time you provide Personal Data or with your consent.
Third-Party Websites
The Services may include hyperlinks to, and details of, third party websites.
We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Information We Share
We will disclose your Personal Data:
- to the extent that we are required to do so by law or by public and/or government authorities;
- in connection with any ongoing or prospective legal proceedings and to comply with legal process;
- in so far as it is reasonably necessary, for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or to establish, exercise or defend our legal rights whether in court proceedings or in an administrative or out-of-court procedure (including providing information to others for the purposes of fraud prevention and reducing credit risk);
- to enforce our Terms of Use;
- to allow us to pursue available remedies or limit the damages which we may sustain and
We may also disclose your Personal Data:
- with our business partners for our and their internal business purposes or to provide you with a product or service that you have requested.
- In the event of a merger, sale or other asset transfer, in any manner consistent with the Privacy Policy then in effect.
International Data Transfer
As an international group of companies, we have offices and people around the world and more predominantly in the United States of America and India.
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use and process the information in accordance with this Policy.
Personal Data may be transferred outside the country in which it was collected and/ or processed, for legitimate business activities in accordance with applicable law. In addition, to the extent permissible by applicable law, the Company may store and/ or process Personal Data in facilities operated by Third Parties on behalf of the Company outside the country in which the Personal Data was collected and/ or processed.
Your Rights
You have several rights in relation to the Personal Data you have shared with us. These are in line with the applicable legislation and can be summarized as follows:
Right to Access:
You have the right to request access your Personal Data that we hold including the right to be informed about the purpose of the processing and the recipients of your Personal Data. Provided the rights of others are not affected, we will supply to you a copy of your Personal Data that we hold but in doing so we may ask you to verify your identity.
Right to Rectification:
You have the right to have any inaccurate Personal Data rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed.
Right to Erasure:
Under some circumstances, you have the right to the erasure of your Personal Data without undue delay. Those circumstances can come about when:
- your Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed;
- you withdraw consent in circumstances where you had previously provided it;
- you object to the processing under certain rules of applicable data protection law;
- the processing is for direct marketing purposes;
- your Personal Data was unlawfully processed.
The right to erasure is not absolute and exclusions include circumstances where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; and/ or for the establishment, exercise or defense of legal claims.
Right to Restrict Processing:
Under certain circumstances, you have the right to restrict the processing of your Personal Data. Examples of such circumstances include cases where you contest the accuracy of your Personal Data or our need to have access to your Personal Data for the declared processing purposes. If and when processing has been restricted on this basis, we may continue to store your Personal Data but we cannot otherwise process it:
Right to Object to Processing:
If we have been processing your Personal Data on certain legal basis (such as legitimate interest) you have the right to object to such processing in certain circumstances. On the submission of such objection and unless we can demonstrate compelling legitimate grounds for the continuance of the processing which override your interests or if the processing is for the establishment, exercise or defence of legal claims, we shall seize the processing.
Right to Data Portability:
If the processing is carried and by automated means AND the legal basis for our processing of your personal data is:
- consent; or
- performance of a contract to which you are party or
- preparatory work at your request prior to entering into a contract;
- you have the right to receive your personal data from us in a structured, commonly used and machine-readable format, unless it would adversely affect the rights and freedoms of others.
Right to Lodge a Complaint to a Supervisory Authority;
If you consider that our processing of your Personal Data infringes applicable data protection legislation, you have a legal right to lodge a complaint with the Bulgarian, Cyprus or other Supervisory Authority.
Right to Withdraw Consent:
To the extent that the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us via [data.privacy@celitotech.com].
Security
The security of your Personal Data is very important to us. We will take reasonable, technical and organizational precautions to prevent the loss, unauthorized access, disclosure, destruction, misuse or alteration of your Personal Data. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information that we collect. All the Personal Information that you provide us is stored in a secure computing environment protected to prevent unauthorized access. We control access so that only people who need to access the Personal Data can. All staff are provided security training and are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs.
Changes to Privacy Policy
This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.
Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, and review it periodically. If you continue to use the Services made available to you after such changes have been made, you as a result of this provide your consent to the changes.
Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, we will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be valid immediately when it is published (or upon notice as applicable).