Privacy Policy
1. Definitions
1.1. Data Controller (We, Us, Our)
Alice AI ApS as an entity processing your personal data.
Alice acts as a data
controller for the processing of your personal data in the following situations:
● when you visit our website (cookies and similar tracking technologies),
●
when you Create an account for our User Service and use our User
Service,
● when you communicate with us,
● when you are subject to direct marketing,
● if you visit our social media platforms (Facebook, Instagram, Twitter), and
● when you represent a supplier, vendor or other third party.
Below, you can read more about the various purposes of our processing of your personal data in the different situations. You can also see which data we process, what the legal basis for our processing is, for how long we store the personal data and who we share it with.
1.2. Data subject
You as a user of our website or Customer of our Platform
1.3. Processor
Means companies processing personal data on behalf of Us.
1.4. Website
Means our website at alice.tech and other sites and apps we operate.
1.5. Platform
The online contract drafting and management system provided by us
1.6. Services
Services and solutions delivered by us to you.
2. General
Who processes the data?
Your data is processed by us, Alice AI
ApS, a company registered in Denmark with CVR number 44597144.
How to contact us?
You may contact us by sending an email to support@alice.tech
3. When, why, what, and for how long we process your data
For more information on our use of cookies on our website, please visit our cookie policy
3.1. When you visit our website
When you visit our website, we use cookies and similar tracking technologies to
collect data about your visits,
including e.g. your navigation on the website
or in the app, the type of browser or device you use and your IP
address. These
data may contain personal data.
For the website, we collect the data in
order to ensure a stable, secure and user-friendly experience on our
website,
as well as to keep statistics about our website visitors. In some cases, data is
processed in order to
target marketing based on the web browser behavior.
The legal bases for our processing are:
● for necessary (technical) cookies on the website: article 6(1)(f) of the GDPR, as
we are pursuing our legitimate interest in ensuring functionality and security of
our website, and
● for other cookies and similar technologies on the website:
article 6(1)(a) of the GDPR, as you have given your consent to e.g., targeted
marketing.
We disclose information about your use of the website to any third-party service
providers that you have allowed to place cookies and/or similar tracking
technologies when you use the website or apps. If you have given your consent, such
third parties include:
Facebook Ireland Limited – see privacy notice here.
Google LLC – see privacy notice here.
Personal data contained in cookies will be deleted in accordance with
the lifetime/period for each specific cookie. Read more about our cookies, including
their lifetime and the specific third-party providers (i.e. the recipients), in our
Cookie Policy. You can read more about the processing of your personal data at the
third-party provider's own privacy notices (see links above).
3.2. When you create an account for our Platform
When you create an account to access our Platform, you will be asked to enter your
name, selected
educational information, contact information, email address and
a password chosen by you. We collect such
information from you in order to
provide you access to our Platform and to make sure that your access account is
secured by your own individual password. In addition, we will have access to
information regarding your geographical location.
With regard to users
with a paid subscription to our Platform (including those starting on a free trial
basis,
where offered), we will also be collecting payment information in order
to provide you access to your
subscription. However, as Alice cooperates with
third party payment service providers who operate
independently in systems
separated from Alice, no complete payment data, such as complete credit card
numbers, will be stored by Alice.
Further, where the option is
available, you may choose to provide us with additional information about your age,
gender, university, level of ambition, courses etc. We collect such additional
information from you in order to provide the best possible customized user
experience and learning journey. However, such information is not required and fully
optional.
In addition, we will have access to information regarding how
you engage with our Platform, including what
content you have interacted with.
This includes processing technical data (such as unique platform ID, device
IP
address). We collect such information from you in order to improve your use of our
Platform, including to
make suggestions for improved learning and to analyze
engagement with our Platform.
Personal data processed: i) in order to
deliver our Platform, including personal data that you choose to provide us with in
order to receive our Platform is based on article 6(1)(b) of the GDPR, as the
information is necessary for the performance of a contract with you.
Personal data processed in order to analyze your use of our Platform and measure
the success of campaigns
is based on article 6(1)(f) of the GDPR, as we are
pursuing our legitimate interests in operating and developing our Platform.
If you use a discount code provided through a collaboration between us and a
commercial partner, and that
code is subject to specific eligibility criteria,
we may share your name and email address with the relevant
partner to verify
your eligibility. For example, this may apply if the discount requires you to be a
member of the
partner’s organization or service. This processing is carried out
pursuant to Article 6(1)(b) of the GDPR.
We only keep your data for as
long as they are of relevance to us and we have a legitimate purpose for keeping
them. Your data will therefore be deleted in accordance with applicable data
protection legislation and as a general rule your data will be deleted 5 years after
the end of the financial year in which you choose to unsubscribe from our Platform,
in order to facilitate any decision by you to restore your subscription. This length
of time is chosen as this is the most common length of a full university degree in
Denmark, and we want students to be able to subscribe and unsubscribe to our
Platform throughout their education (e.g., during summer break) without losing all
previous data, as this is part of the value proposition of the Platform (e.g.,
tracking learning progression).
In specific situations, we may defer
from our general retention periods (in case of e.g. complaints, objections or other
specific situations).
We disclose personal data included in our account
records to the relevant public authorities, including the tax and customs
authorities, in connection with our statutory bookkeeping etc.
Further,
we disclose your personal data to the service providers for the online payments
company that we use (Stripe). Finally, we make your personal data available to our
group companies and processors who e.g. host, develop and support our IT systems and
provide analytics services connected to our Platform. Please see below regarding
transfer of your personal data to third countries.
3.3. When you upload material to our Platform
When you upload learning materials to our platform, we read the content of the
material and share it with one of the providers of an LLM listed in section 5
(OpenAI, Google, Mistral & Anthropic). Which one the material is
sent to
depends on a variety of factors such as the type of material, model status and
capacity and cost. The
material is subject to the terms of use and privacy of
the providers listed in Section 5. None of the providers
store the input data
nor train their models based on it. Please refer to our Terms of Use, regarding the
required
ownership rights of the material that you upload.
We only
keep your data for as long as they are of relevance to us and we have a legitimate
purpose for keeping them. Your data will therefore be deleted in accordance with
applicable data protection legislation and as a general rule your data will be
deleted 5 years after the end of the financial year in which you choose to
unsubscribe from our Platform, in order to facilitate any decision by you to restore
your subscription.
Before uploading material to the platform, we
recommend that you ensure that the material does not contain
any sensitive
personal information.
3.4. When you use the AI-chat function on our platform
When you use the chat-function on our Platform we store the conversation in order to
improve your user
experience and to improve our Platform. Your messages are
sent to one of our providers of LLM services for
processing, but are not stored
with them nor used for training purposes. See the terms of use and privacy of
our processors in Section 5.
3.5. When you communicate with us
When you communicate with us (e.g., via email) your communication will contain
personal data, e.g., your
contact details (including name and email address)
and other personal data you may provide us with.
We process these
personal data for the purpose of managing and answering your inquiries. The legal
basis for the processing is article 6(1)(f) of the GDPR, as we are pursuing our
legitimate interests in managing general inquiries.
We only keep your
data for as long as they are of relevance to us and we have a legitimate purpose for
keeping them. Your data will therefore be deleted in accordance with applicable data
protection legislation. Personal data pertaining to our general communication with
you (such as email inquiries) will be deleted 5 years after the end of the financial
year where your last inquiry has been handled/concluded.
In specific
situations, we may defer from our general retention periods (in case of e.g.
complaints, objections or other specific situations).
3.6. When you are subject to direct marketing
When you subscribe to the newsletter about or User Service or other marketing
communications (e.g. for news / offers regarding an upcoming launch of new features
to our Services), we register your name, email address and, in the case of users of
our User Service, any preferences you may have given (e.g., education). The latter
involves that we, based on your profile, including your geographical location and
the preferred content, are able to better target our marketing. Further, we process
these personal data for the purpose of being able to send you targeted
communications.
The legal basis for our processing is the consent you
have given in accordance with section 10 of the Danish Marketing Practices Act
(markedsføringsloven).
We stress that you at any time have the right to
object to our processing of your personal data concerning marketing, including our
profiling related to such direct marketing. Further, you have the right to withdraw
your consent at any time. See our contact information below under "Contact
details".
Personal data pertaining to our distribution of marketing
communications will be deleted 2 years after our last marketing communication has
been distributed, unless you have withdrawn your consent (i.e., unsubscribed) before
such time.
We make your personal data available to our group companies
and processors who e.g. host, develop and support our IT systems. Please see below
regarding transfer of your personal data to third countries.
3.7. When you visit our Social Media platforms (e.g., Facebook, Instagram, LinkedIn, TikTok, YouTube)
If you visit our account on platforms at, e.g., Facebook, Instagram, Twitter,
Youtube or TikTok we may process the personal data that you have available to us via
the specific settings, your reactions on content, including likes and comments, and
any sharing of our content etc.
We process these personal data for the
purpose of managing our social media platforms and communicating with you through
these platforms. The legal basis for the processing is article 6(1)(f) of the GDPR,
as we are pursuing the above-mentioned legitimate interests.
We only
keep your data for as long as they are of relevance to us, and we have a legitimate
purpose for
keeping them. Your data will therefore be deleted in accordance
with applicable data protection legislation.
Personal data pertaining to our
social media platforms, that we are in control of, will be deleted 5 years after the
end of the financial year in which such personal data was collected.
Please note that when using our social media platforms, the provider (such as
e.g., Facebook) will also process your personal data for its own purposes, including
for targeted marketing purposes. You may find further information on these
processing activities at the provider's own privacy notices
3.8. When our customer service accesses your account for troubleshooting
To give you great support and keep your account safe, our customer service may
sometimes log in to your account. This happens in two situations:
(a)
When you ask for help. If you report an issue, we may access your account to look
into it and fix it for you. When you contact us, we confirm your identity using the
email address linked to your account.
(b) To protect you. Without you
asking first, we may access your account when it is needed to handle a security
concern, such as suspected unauthorized access, or to fix a technical problem
affecting your account, where accessing it is necessary to resolve the issue. We do
not access your account on our own initiative in any other situations.
In
both cases, we only do what is needed to resolve the issue, and we do not use your
uploaded materials or AI-chat history (see sections 3.3 and 3.4) for anything else.
The legal basis for this processing is article 6(1)(f) of the GDPR: we have
a legitimate interest in supporting you and in keeping your account and our Platform
secure and functional. You can object to this processing at any time (see section
6).
4. How we keep your data safe
We have taken reasonable organizational, technical, and administrative measures to protect your personal data. We further describe here how we ensure that you are personal data is retained in a safe and secure manner.
● We encrypt the data whenever appropriate
● We use logging of access and use
of the personal data when relevant
● We retain appropriate backups of the
personal data
● We regularly test, assess, and evaluate our privacy measures
We do our utmost to ensure the safety and security of data transmission, but as the internet is not a 100% secure environment, we kindly ask you to take appropriate precautions. For example, if you send us an unencrypted email, we advise you not to send any confidential or sensitive information, as we are unable to guarantee confidentiality.
5. Processors
We use Processors to help us deliver our services to you, for example, to provide
the hosting environment for our product, send out newsletters, and help us run our
website, etc.
We make sure that there is an agreement in place regarding
how our processors handle the data on our behalf. We’ll also ensure that they imply
appropriate security measures. You can find the agreements (called “Data Processing
Agreements” or “Data Processing Addendum”) in the list below:
Stripe
Google
Mailchimp
OneSignal
OpenAI
Mistral
Google Gemini
Anthropic
Digital Ocean
GitHub
Slack
AWS
In the event that we are involved in a bankruptcy, merger,
acquisition, or reorganisation, the data may be transferred as part of that
transaction.
5.1. Transfer of your personal data to third countries
We transfer your personal data to countries outside the EU and EEA, when making data
available to our processors in various third countries.
The basis for
such transfer is either:
the Commission Decision of 4 June 2021 on
standard contractual clauses for the transfer of personal data to third countries
pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council
(“SCCs”), or
an EU Commission adequacy decision based on article 45 of
the GDPR (“Adequacy Decision”).
If you want additional information about our transfer of personal data outside
the EU and EEA, including a copy of the relevant security measures, etc., you may
make a request for such additional information by contacting us (see contact
information below).
6. Your Rights
As a Data Subject you have a number of rights and this section describes the rights and how to exercise them:
A. Access the data: You have the right to ask us for copies of your personal
data
B. Erasure: You can ask us to erase your personal
information in certain
circumstances
C.
Restrict processing: You have the right to ask us to restrict the processing of
your information
D. Data portability: You have the right to receive the data in a
structured,
commonly used and machine-readable format
E. Rectification: You may ask us to rectify information that is inaccurate
F. Consent withdrawal: If processing is based on your consent, you have the right
to withdraw
consent at any time.
G. Object processing: You have a right to object
to the processing of your personal
data
H. Assistance and information: You have the right to contact us and request more
information about how we
process your personal data
7. Complaint to a supervisory authority
If you want to lodge a complaint with a supervisory authority about our processing
of your personal data, you can do so by contacting the Danish Data Protection Agency
via their website, www.datatilsynet.dk.
You can read more about your
rights in the Danish Data Protection Agency's guidelines on data subjects'
rights, which is available at www.datatilsynet.dk (in Danish).
Please
contact us if you wish to exercise your rights. The relevant contact details are
stated below.
8. Contact details
If you have any questions about how we process personal data, please contact us.
Alice AI ApS
Højbro Plads 10,
1200 København K, Denmark
Company
registration number (CVR): 44597144
E-mail: support@alice.tech