WEBSITE PRIVACY POLICY

Introduction

Autobrains Technologies Ltd., including any subsidiaries thereof (“us“, “we” or “Company“), respects the privacy of its users (each, a “User” or “you“) and is committed to protect the privacy of Users who access, visit, or engage with its website, available at https://autobrains.ai/ (the “Website“).

This privacy policy (“Privacy Policy“) will help you understand what types of information Company collects through its Website, how the Company uses it, and what choices you have. We encourage you to read this Privacy Policy carefully and use it to make informed decisions. For your convenience, our automated vehicles privacy policy is available here.

This Privacy Policy is integrated into and forms part of Company’s Terms and Conditions and is incorporated therewith by reference.

Collection and Storage of Your Personal Information

We collect and use the following types of information about you:

Non-personal Information

Non-personal Information is non-identifiable information that, when taken alone, cannot be used to identify you. As such, we are not aware of the identity of the user from which the Non-personal Information was collected.

We may anonymize or de-identify the information collected by the Website or via other means so that the information cannot, on its own, personally identify you. We also collect aggregate user data regarding your use and activity on our Website. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose.

For the avoidance of doubt, if we combine Personal Information with Non-personal Information (e.g., analytics data), the combined information will be treated as Personal Information as long as it remains combined.

Personal Information

Personal Information is information that identifies an individual or that may, with reasonable effort, identify an individual. We gather the following types of Personal Information:

Name, email address, phone number, and other contact information: When you send us an email or contact us via the Website, we collect the Personal Information you provide us. This may include your name, email address and any other information you choose to provide.
Voluntary information: We collect Personal Information that Users provide us voluntarily. For example, when they respond to communications from us, or when they share additional information through their use of the Website, including by applying for a job through the Website.
Cookies and Other Tracking Technologies: We may use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Website. See more under the “Tracking Technologies” section in this Privacy Policy.

We also use a tool called “Google Analytics” to collect information about your use of the Website. Google Analytics collects information such as how often users access the Website, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Website and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Device information: We collect from our Users specific types of connection details and information with regard to their device, software or hardware that may identify them, such as online identifiers, device unique identifiers (e.g. UDID, MAC address), IP address and geolocation.

How We Use Personal Information?

In addition to the purposes listed herein, the Personal Information we collect is used for the following purposes:

Provision of the service: We will use the Personal Information you provide us for the provision and improvement of our services.
Protecting our interests: We may use your Personal Information when we believe it is necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of the Company, its Users, customers and/or partners.
Enforcing of policies: We may use your Personal Information in order to enforce our policies, including but not limited to our Terms and Conditions.
Compliance with legal and regulatory requirements: We may use your Personal Information to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
Process for other purposes for which we obtain your consent.

With Whom Do We Share The Personal Information We Collect?

We work with other companies who help us run our business (“Service Providers”). These companies provide services to help us store information (such as cloud storage companies), deliver customer support, process payments, monitor and analyze the performance of our Services, manage and contact our existing customers as well as sales leads, provide marketing support, provide fraud prevention services, and otherwise operate and improve our services. These Service Providers may only process Personal Information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations.

Specifically, we do not permit our Service Providers to use any Personal Information we share with them for their own purposes or for any other purpose except in connection with the services they provide to us.

In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:

With our affiliated group companies;
With our resellers and other partners who may help us distribute the Services to Users;
In the event of a merger, sale, business combination, change in control, or reorganization of all our part of our business;
When we are required to disclose Personal Information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our service agreement, or as otherwise required to comply with our legal obligations; or
as you may otherwise consent from time to time.

Third-parties who we may share your Personal Information with will be required to meet our standards on processing information and security. The Personal Information we provide them will only be provided in connection with the performance of their function.

Why We Use Your Personal Information

Please note that our legal basis for collecting and using your Personal Information will depend on the Personal Information collected and the specific context in which we collect it. We normally collect Personal Information from you only where: (a) we have your consent to do so, (b) where we need your Personal Information to perform a contract with you (e.g., to deliver the service you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such Personal Information under applicable laws.

In some cases, we may need the Personal Information to protect your vital interests or those of another person.

Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.

Tracking Technologies

When you visit or access our Website, we use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies“). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our service, improve our Website’s performance, perform analytics, and customize your experience.

There are various ways in which you can manage and control your Tracking Technologies settings. For example, you can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). However, please note that certain features of the Website may not work properly or effectively if you delete or disable cookies.

Marketing

We may use your Personal Information, such as your full name, email address, etc., ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our services.

At any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to the contact details listed below.

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

Your Rights

Certain jurisdictions provide individuals with certain statutory rights to their Personal Information. You may have the right to certain actions to your Personal Information such as:

To receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with certain supplementary information.
To receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
To request rectification of your Personal Information that is in our control.
To request erasure of your Personal Information.
To object to the processing of Personal Information by us.
To request to restrict processing of your Personal Information by us.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Information, you can contact us at the contact details available below.

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with applicable laws, you can file a complaint to the applicable data protection authority.

For How Long Do We Retain the Personal Information We Collect?

We retain the information we collect (including any Personal Information which may inadvertently be collected) for as long as needed to achieve the purpose for which it was collected, namely to develop and operate the Website and our services, and where applicable, to comply with our legal obligations or the achieve any other purpose of collection described herein.

Retention periods will be determined taking into account the type of the Personal Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Personal Information at the earliest reasonable time.

International Transfer (for EEA and UK residents)

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA or UK.

In these instances, we will transfer your Personal Information only to such countries as approved by the European Commission or the UK Information Commissioner Office as providing adequate level of data protection, or enter into agreements ensuring an adequate level of data protection and which include legally approved data transfer mechanisms (such as the EU Standard Contractual Clauses and/or the UK Data Transfer Addendum).

How Do We Safeguard Your Personal Information?

We take great care in implementing and maintaining the security of the Website and of your Personal Information. We employ industry standard procedures to ensure the confidentiality, integrity, and availability of our Users’ data, safety of your Personal Information, and prevent unauthorized use of any such information.

However, we cannot guarantee that hackers or unauthorized personnel will not gain access to Personal Information despite our efforts. You should note that by using our Website, your Personal Information will be transferred through third party infrastructures which are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

If you feel that your privacy was treated not in accordance with this Privacy Policy, please contact us directly through the contact details available below.

Minors

We do not knowingly collect or solicit Personal Information from anyone under the age of majority (as determined under the applicable laws where the individual resides; “Age of Majority”). By accessing, using or interacting with our Website, you certify to us that you are not under the Age of Majority. In the event that we learn that we have collected through the Website Personal Information from an individual under the Age of Majority without verification of parental consent, we will delete that information upon discovery.

Links to Third Party Sites

The Website may contain links to other sites that are not under the Company’s control. These websites have their own policies regarding privacy. You are encouraged to review those policies before visiting such websites. The Company has no responsibility for linked websites, and it provides these links solely for the convenience and information of its Website’s visitors.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. All other changes to this Privacy Policy are effective as of the stated “Last Revised” date.

Contact Us

Autobrains Technologies Ltd. is the controller of Personal Information under the General Data Protection Regulation (EU) Regulation 2016/679 (“GDPR“).

If you have any questions about this Privacy Policy or if you would like to exercise any of the rights mentioned herein with respect to your Personal Information, please contact us at:

Autobrains AI Technologies GmbH

Pasteurstraße 18, 10407 Berlin, Germany

Email: privacy@autobrains.ai

California and Virginia Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) (“CCPA“); the California Privacy Rights Act (“CPRA“); and Virginia Consumers Data Protection Act of 2021 (“VCDPA“, collectively: “State Laws“)

What information we process

In the preceding 12 months, we have collected, and or disclosed the following categories of Personal Information (as this term is defined under State Laws):

Category of Personal Information Collected	Personal Information Collected	Categories of recipients to whom Personal Information was disclosed
Identifiers	Full name, email address, IP address, MAC, UDID	Service Providers
Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))	Name, telephone number	Service Providers
Internet or Other Electronic Network Activity Information	Cookie and similar online identifiers, information on a consumer’s interaction with the Website	Service Providers
Geolocation Data (non-precise)	Physical location or movements	Service Providers

In the past 12 months, we have not collected Sensitive Personal Information (as this term is defined under State Laws) about you.

Sources of Personal Information

In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

Consumer directly.

Purposes for collection and disclosure of Personal Information

Our purposes for collecting Personal Information can be found above, under the section “How we use Personal Information”. Our purposes for disclosing Personal Information to third parties can be found above, under the section “With whom do we share the personal information we collect?”.

Sale and Share of Personal Information

We do not “sell” or “share” (as these terms are defined under State Laws) any Personal Information.

User rights under State Laws

State Laws provide consumers with specific rights regarding their Personal Information. This section describes the rights you may have under these laws and explains how to exercise those rights.

Access to Personal Information

You may request that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable.

You also have the right to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.

Deletion Requests

You may have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.

Right to Correction

You have the right to request that we rectify inaccurate information about you.

Right to Opt-Out of Selling or Sharing of Personal Information

You have the right to opt out of “selling” or “sharing” your Personal Information or from using your Personal Information for automated decision making and profiling.

We do not sell, share, or use your Personal Information for any of the abovementioned purposes.

Right to data portability

You may have the right to obtain your Personal Information in a portable and readily usable format.

Right to non-discrimination

You have the right to be free from any discrimination for exercising your rights under State Laws. Should you exercise any of your rights under State Laws, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances, for example where you have requested or consented to our services that use your Personal Information to provide the service, we may not be able to provide a service if you choose to delete your Personal Information.

Right to Limit Use of Sensitive Personal Information

We do not engage in uses or disclosures of Personal Information that would trigger the right to limit use of Sensitive Personal Information under State Laws.

Exercising Your Rights

You can exercise your rights by submitting a verifiable consumer request to our physical address (as written below in the “Contact Us” section) or to our email address: privacy@autobrains.ai.

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:

Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative thereof.
Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you are a Virginia resident, you have the right to appeal a rejection to your request. The appeal request shall be submitted through our Data Privacy Officer’s email address: privacy@autobrains.ai or by sending a mail to our physical address specified in the Contact Us section.

If your appeal is denied, you may lodge a complaint with the Virginia Attorney General through the contact information available here: https://www.oag.state.va.us/contact-us/contact-info or file the complaint at: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

Designating Agents

If you are a California resident, you can designate an authorized agent to make a request under the CCPA and CPRA on your behalf if:

The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA and CPRA.

Last revised: December 2022