Privacy Policy of Emma.ai

Owner and Data Controller

Combine AI Limited, F4, Sutton Yard, 65 Goswell Rd, London EC1V 7EN

Owner contact email: privacy@emma.ai

Types of Data collected

Among the types of Personal Data that Emma.ai collects, by itself or through third parties, there are: Cookies; Usage Data; various types of Data; first name; last name; email address; country; Data communicated while using the service.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Emma.ai.
Unless specified otherwise, all Data requested by Emma.ai is mandatory and failure to provide this Data may make it impossible for Emma.ai to provide its services. In cases where Emma.ai specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Emma.ai or by the owners of third-party services used by Emma.ai serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Emma.ai and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Emma.ai (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Registration and authentication, Infrastructure monitoring, Hosting and backend infrastructure, Data transfer outside the EU, Managing support and contact requests, Displaying content from external platforms, Managing contacts and sending messages, Handling payments, Heat mapping and session recording, Tag Management, Interaction with live chat platforms, Remarketing and behavioral targeting and Platform services and hosting.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics (Google LLC)

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Emma.ai, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

  Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

  Hotjar is an analytics service provided by Hotjar Ltd.
  Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: Malta – Privacy Policy – Opt Out.

  Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)

  Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on Emma.ai. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: Ireland – Privacy Policy.

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on standard contractual clauses (Emma.ai)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
  This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

  Personal Data processed: various types of Data.

  Data transfer to countries that guarantee European standards (Emma.ai)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
  The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.

  Personal Data processed: various types of Data.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of Emma.ai and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Maps widget (Google Inc.)

  Google Maps is a maps visualization service provided by Google Inc. that allows Emma.ai to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

• Handling payments

  Payment processing services enable Emma.ai to process payments by credit card, bank transfer or other means. To ensure greater security, Emma.ai shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  Stripe (Stripe Inc)

  Stripe is a payment service provided by Stripe Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  ChargeBee (ChargeBee Inc.)

  ChargeBee is a payment service provided by ChargeBee Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Heat mapping and session recording

  Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
  Some of these services may record sessions and make them available for later visual playback.

  Hotjar Heat Maps & Recordings (Hotjar Ltd.)

  Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
  Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

  Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Malta – Privacy Policy – Opt Out.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable Emma.ai to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Emma.ai. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Amazon Web Services (AWS) (Amazon Web Services, Inc.)

  Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United Kingdom – Privacy Policy.

  Google Cloud Storage (Google Ireland Limited)

  Google Cloud Storage is a hosting service provided by Google Ireland Limited.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

• Infrastructure monitoring

  This type of service allows Emma.ai to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Emma.ai.

  Airbrake (Airbrake Technologies, Inc.)

  Airbrake is a monitoring service provided by Airbrake Technologies, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Interaction with live chat platforms

  This type of service allows Users to interact with third-party live chat platforms directly from the pages of Emma.ai, for contacting and being contacted by Emma.ai support service.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

  Freshchat Widget (Freshworks, Inc.)

  The Freshchat Widget is a service for interacting with the Freshchat live chat platform provided by Freshworks, Inc.

  Personal Data processed: Cookies; Data communicated while using the service; email address; Usage Data.

  Place of processing: United States – Privacy Policy.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Mailchimp (The Rocket Science Group, LLC.)

  Mailchimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

  Personal Data processed: country; email address; first name; last name.

  Place of processing: United States – Privacy Policy.

  Sendgrid (Sendgrid)

  Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

  Personal Data processed: country; email address; first name; last name.

  Place of processing: United States – Privacy Policy.

• Managing support and contact requests

  This type of service allows Emma.ai to manage support and contact requests received via email or by other means, such as the contact form.
  The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

  Freshdesk (Freshworks, Inc.)

  Freshdesk is a support and contact request management service provided by Freshworks, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Platform services and hosting

  These services have the purpose of hosting and running key components of Emma.ai, therefore allowing the provision of Emma.ai from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
  Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Webflow (Webflow, Inc.)

  Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host Emma.ai. Webflow is highly customizable and can host websites from simple blogs to complex e-commerce platforms.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy – Opt out.

• Registration and authentication

  By registering or authenticating, Users allow Emma.ai to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, Emma.ai will be able to access some Data, stored by these third-party services, for registration or identification purposes.

  Google OAuth (Google Inc.)

  Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Direct registration (Emma.ai)

  The User registers by filling out the registration form and providing the Personal Data directly to Emma.ai.

  Personal Data processed: country; email address; first name; last name.

• Remarketing and behavioral targeting

  This type of service allows Emma.ai and its partners to inform, optimize and serve advertising based on past use of Emma.ai by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
  Some services offer a remarketing option based on email address lists.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

  LinkedIn Website Retargeting (LinkedIn Corporation)

  LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of Emma.ai with the LinkedIn advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on Emma.ai in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Segment (Segment Inc.)

  Segment is a tag management service provided by Segment.io, Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Google Tag Manager (Google Ireland Limited)

  Google Tag Manager is a tag management service provided by Google Ireland Limited.

  Personal Data processed: Usage Data.

  Place of processing: Ireland – Privacy Policy.

Further information about Personal Data

• Automated decision-making

  Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Emma.ai may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Emma.ai adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
  Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
  The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within Emma.ai, Users can check the relevant sections in this document.

  Consequences of automated decision-making processes for Users and rights of Users subjected to it

  As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
  In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing.

  To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

Emma.ai uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Emma.ai or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Emma.ai may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Emma.ai and any third-party services may collect files that record interaction with Emma.ai (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Emma.ai does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Emma.ai and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.