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EFFECTIVE DATE : 28/11/2023

Privacy Policy for Butly.AI
by AZ Group FZCO

At Butly.AI by AZ Group FZCO (“Butly.AI”, “we”, “us”), we consider the privacy and security of personal data to be extremely important.

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We process personal data for our own purposes and under instructions of our customers who use Butly.AI service (“Service”), upload and keep certain information in it. In the second case, we strictly adhere to customers’ instructions and do not use data for any other purposes than providing the Service (see details in Data Processing Addendum).

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In this Privacy Policy, we describe how we process personal data of the following data subjects for our own purposes:

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  • our customers, their end users, and representatives,

  • website users,

  • newsletter subscribers,

  • potential customers,

  • our counterparties and their representatives.

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It covers information collected in the Service, on our website www.az-group.io or other websites administered by Butly.AI where this Privacy Policy is placed (the “Site”), in our Mobile apps, and in other sources.

If you have any questions or suggestions concerning our privacy practices, please email us at hello@az-group.io. Please also send us an email if you would like to request data access or deletion, or to exercise other rights as a data subject.

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Table of Contents

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  1. How We Collect Personal Data

  2. What Types of Personal Data We Process

  3. For Which Purposes We Use Personal Data

  4. How We Share Personal Data

  5. Your Data Protection Rights & Choices

  6. For How Long We Retain Personal Data

  7. Data Transfers

  8. Personal Data Transferred from the EEA, the UK, or Switzerland to the United States

  9. Children's Information

  10. Security

  11. Legal Basis for Processing Your Personal Data (EEA Visitors/Customers Only)

  12. Changes to Our Privacy Policy

  13. How to Contact Us

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1. How We Collect Personal Data

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What personal data we collect depends largely on the interaction that takes place between you and Butly.AI, most of which can be categorized under the following:

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When you use Butly.AI Service. When you use Butly.AI Service, we store all the content you provide, including information related to you as a customer or an end user of the Service. We gather this information from you directly when you enter it, or from integrations that you linked to the Service. When you ask us to sign a Data Processing Addendum (DPA) or other documents, we also receive data about you and your representatives.

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In some cases, we can receive information from third parties, e.g., from a payment service provider on whether your payment was successful.

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When you send us emails or message us. When we receive emails or messages from you in the chat, we can store the content of such emails, attachments as well as your contact details.

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When you submit forms on the Site or participate in our events. When you complete forms on the Site (contact us, subscription, demo request, event registration, etc.) we collect your contact details and information you complete in the form. If we arrange joint events together with our partners, we can receive information from our partners.

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When you use the Site. When you use the Site, we collect certain information, as described in more detail below that may, alone or in combination with other information, constitute personal data (e.g., cookie files).

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When you join our communities. When you join our Facebook and other groups, we can see data in your profile and process comments you posted in our groups. However, we don’t gather that information or copy it into our systems, but rather just have access to it.

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2. What Types of Personal Data We Process

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We collect and process the following personal data:

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Customer Account Details: To create or update your account and provide the Service, we collect information about you, as a customer or end-user of the Service, from you and third-party integrations. This includes ID, name, email, status, linked pages and accounts, products in use, location, etc.

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Financial Information: To process your payments for the Service subscription, we need your credit card details (last four digits of the card number), account details, and payment information.

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Contact Details and Business Data: We receive information about our customers and potential customers for cooperation and communication purposes. This includes full name, title, company, email, or other contact details as may be necessary.

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Requests, Messages, and Submitted Forms Details: We receive and process your messages, support requests, emails, and information you share with us via online forms or social media accounts. This includes the content of such communications as well as your contact details if any.

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Usage Data, Logs, and Other Technical Data: When you interact with the Service, metadata and log files are collected automatically. This may include the Internet Protocol (IP) address, your browser type and settings, the date and time you used the Service, information about browser configuration plugins, language preferences, and more.

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Email Performance Data: To track engagement and performance metrics of our newsletters, we can use a ‘clear image’ (gif) in email communications. Much of this data is aggregated.

Website Cookies and Similar Technologies: We use cookie technology on the Site. See details in our Cookie Statement.

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Customer Content: As you use our Service, you may import into our system personal data you have collected from your users, customers, prospective customers, social media, and messaging platform contacts (collectively “Subscribers”) or other individuals. We process this data only on your behalf as our customer. We have no direct relationship with your Subscribers or any person other than you, and you are responsible for ensuring you have the appropriate permission and legal basis for us to collect and process information about those individuals.

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3. For Which Purposes We Use Personal Data

 

We collect and process your personal data for the following purposes:

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To Operate the Service: We use data to enter into the agreement with you as a customer and operate, maintain and administer your account in the Service, as well as to communicate with you regarding the account and to respond to Service-related requests, questions, and feedback.

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To Provide the Service: We process Customer Content information on your behalf as a customer (see details in Data Processing Addendum).

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To Communicate and Inform About the Service: If you request information from us, register for the Service, complete a form or feedback on a Site, or participate in our surveys, promotions, or events, we may send you Butly.AI-related marketing communications if permitted by law.

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To Comply with Law: We use your personal data as necessary to comply with applicable laws, legal processes, or audits, and to respond to subpoenas or requests from government authorities.

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For Compliance and Safety: We use your personal data as we believe necessary or appropriate to enforce the terms and conditions that govern the Service, protect our rights, privacy, safety, or property, and to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

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4. How We Share Personal Data

 

We do not sell your data to third parties for commercial or advertising purposes. We share your data as described in this Privacy Policy or upon obtaining your consent for such data sharing.

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We disclose personal data to third parties under the following circumstances:

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Service Providers: We employ third-party companies and individuals to help us with performance of certain activities and use third-party software to process data.

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Professional Advisors: We may disclose your personal data to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services they render to us.

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Third-party Applications and Integrations: For the provision of the Service, we receive and share data with integrations and apps linked by customers, as well as applications developed through the “Butly.AI Developer Program”.

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Business Transfers: In the event of a corporate sale, merger, reorganization, dissolution, or similar event, personal data may be part of the transferred assets.

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Compliance with Laws and Law Enforcement: Butly.AI may disclose information about you to government or law enforcement officials or private parties as required by law.

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Corporate Affiliates: We may share personal data with our corporate affiliates.

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5. Your Data Protection Rights & Choices

 

You have the following rights:

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If you wish to access your personal data that Butly.AI collects, you can do so at any time by contacting us. You can also contact us to update, correct or delete information in your account. If you are in the European Economic Area (“EEA”), the UK, or Switzerland, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data where it is technically possible. Similarly, if you are in the EEA, the UK, or Switzerland, and we have collected and processed your personal data under your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on other lawful processing grounds. You have the right to complain to a data protection authority about our collection and use of your personal data. You may submit your request by sending an email to hello@az-group.io. We will respond to all requests in accordance with applicable data protection laws.

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Access to Data Controlled by our Customers. We don’t have any direct relationships with customers’ Subscribers, i.e., the individuals whose personal data is stored by our customers the Service. An individual who seeks access, or who seeks to correct, amend, or delete personal data processed in the Service by our customers should direct their request to the customer directly.

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6. For How Long We Retain Personal Data

 

We will retain and process personal data until you terminate the Agreement with us as set forth under the Terms of Service.

We may also store some data during a retention period required by law or timeframe necessary to resolve disputes, prevent abuse, and enforce our agreements.

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7. Data Transfers

 

Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, including in the U.S and UAE.

By accepting the terms of this Privacy Policy, you acknowledge and agree to the transfer to and processing of personal data on servers located outside of the country where you reside and our collection and use of your personal data as described herein and in accordance with the data protection laws of the countries in which we have facilities or in which we engage service providers, which may be different and may be less protective than those in your country.

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8. Personal Data Transferred from the EA, the UK or Switzerland to the United States

 

Butly.AI operates in countries outside the EEA, the UK, and Switzerland, such as the U.S. or UAE, and may utilize data processors and sub-processors located in third countries.

If you are located in the EEA, the UK, or Switzerland, this means that we may transfer personal data outside of your country. Such transfers are made using appropriate safeguards and supplementary measures. We enter into the EU Standard Contractual Clauses for data transfers with our customers, who use the Service.

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9. Children's Information

 

We believe it is important to provide added protection for children online. We encourage parents and guardians to spend time online with their children to observe, participate in and/or monitor, and guide their online activity. The Site and/or the Service are not intended for use by anyone under the age of 18, nor does Butly.AI knowingly collect or solicit personal data from anyone under the age of 18.

If you are under 18, you may not attempt to register for the Service or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we confirm that we have collected personal data from someone under the age of 18 without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child under 18 and believe that we might have any information from or about such a child, please contact us. We do not sell any Personal Data of our customers, including those aged between 13 to 18.

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10. Security

 

Safeguarding Your Information

We take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal data.  See the list of measures in Annex 2 of the Data Processing Addendum.

Despite these efforts to store personal data collected on and through the Site and/or the Service and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of personal data during its transmission or its storage in our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.

The credit card processing vendor we work with uses security measures to protect your information both during the transaction and after it is complete.

If you have any questions about the security of your personal data, you may contact us by email hello@az-group.io.

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Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our system that materially affects you or your Subscribers, then we will notify you as soon as possible and later report the action we took in response.

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11. Legal Basis for Processing Your Personal Data (EEA Visitors/Customers Only)

 

If you are a person located in the EEA or  the UK our legal basis for collecting and using the personal data described above will depend on the purpose of processing and personal data concerned:

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  • We process data to perform a contract with you on use of the Service (Art. 6(1)(b) of the GDPR or UK GDPR);

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  • We also process data based on our legitimate interest (Art. 6(1)(f) of the GDPR or UK GDPR) in the following cases:

    • to communicate with you and inform about our Service;

    • to comply with the law we are subject to;

    • to conduct events and communicate with you;

    • to negotiate, enter and perform agreements;

    • for compliance and safety.

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  • We process some types of cookie files based on your consent (Art. 6(1)(a) of the GDPR or UK GDPR). See more details in Cookie Statement.

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If we ask you to provide personal data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data). Similarly, if we collect and use your personal data in reliance on our legitimate business interests, we will make clear to you at the relevant time what those legitimate business interests are.

You are not obliged to provide your personal data to us. However, if we need personal data in order to enter and perform the contract with you and you do not provide this data, we may not be able to perform the contract we have or are trying to enter into with you.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, you may contact us by email at hello@az-group.io.

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12. Changes to Our Privacy Policy

 

We may need to change this Privacy Policy from time to time to reflect legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you before its entry into force, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by data protection laws applicable to us.

You can see when this Privacy Policy was last updated by checking the “EFFECTIVE DATE” displayed at the top of this Privacy Policy. The new Privacy Policy will apply to all current and past users of the website and will replace any prior notices that are inconsistent with it.

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13. How to Contact Us

 

If you require any more information or have any questions about our privacy policy, please feel free to contact us by email at hello@az-group.io.

For EEA data subjects, you can contact the representative by email: hello@az-group.io.

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