Privacy Policy

Version 1.1

Last Updated 21.10.2021

Welcome to our website blackthorn.ai (the “Site”). The Site provides some information about our services and business activity and is created for information purposes. The Site is owned and operated by BLACKTHORN AI LTD (“we,” “Company”).

We will be transparent with you about why and how we collect data.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY. BY ACCESSING OR USING OUR SITE, YOU SIGNIFY YOUR UNDERSTANDING OF THE TERMS SET OUT HEREIN.

We are committed to respect and protect the privacy of the Personal Data we obtain from you through the Site and we have created this Privacy Policy to inform you about how we collect, use and share your Personal Data, and about our privacy practices in general.

Our Site uses cookies and similar technologies. For more information please see the Cookies section below.

We are always ready to address your questions and concerns regarding this Policy and our privacy practices. If you would like to contact customer service, please contact us at the email address at the end of this Policy.

We continually strive to find new ways to enhance your experience with the Site and we may modify this Privacy Policy from time to time to reflect changes in our privacy practices. You are encouraged to review this Privacy Policy periodically and to check the “Last Updated” date at the top of the Privacy Policy for the most recent version. If we make changes to this Privacy Policy, we will notify you here and in our sole discretion, via notice through the Site or email.

Data Processor

BLACKTHORN AI LTD

Kemp House, 160 City Road, London,

United Kingdom, EC1V 2NX

Company No: 13335565

Data Processing

The Personal Data we gather from you helps us communicate with you, suggest relevant information and marketing materials, perform our contract with you and comply with applicable laws, and learn about your visit to the Site. We use this information to improve the Site, to better tailor the features, performance and support of our products and services, to answer your requests, questions and concerns, and to offer you additional information and opportunities. Thus, we use your Personal Data for business purposes.

“Personal Data” is any information that allows us (or others) to identify a person and would include (for example) your name, username, address, email address, IP address or phone number, location, image, as well as other non-public information that is associated with or directly linked to such information.

Non-personal “Usage Data” is anonymous data about your use of the Site that is tied to your computer and/or device through which you use the Site.

Personal Data that We Collect

We only collect and use your Personal Data when we have a legitimate reason for doing so. In which instance, we only collect Personal Data that is reasonably necessary to provide our services to you.

The company collects information about you, including information that directly or indirectly identifies you. The Company also collects information about how you use the Site. There are also several opportunities for you to share information about yourself and your activities with Company. Some examples are listed below.

Usage information. We collect information about your online behavior when you use the Site using cookies and third-party services as described below.

Contact information. If you choose to provide us with your contact information (name, email address, phone, etc.), for example by emailing us or submitting the contact form, we will use this to respond to support requests, information newsletter and advertisements.

Use across our services. We may combine information we collect from you with information obtained from other users, third parties and information derived from any other subscription, product or service we provide.

Technical information. We collect technical information from the devices and browsers you use to access the Company. This information is used to analyze trends, protect, and secure Company. The information collected includes network information; including operating system, browser, IP addresses, location, timestamps, log files, etc.

Use of the Personal and Usage Data that We Collect

We use, process, and store your Personal Data as necessary to perform our contract with you and for our legitimate business interests, including:

  • To help us provide and administer our Site, provide personalized user features and access, conduct research, develop new features, and improve the features, algorithms, and usability of our Site.
  • To communicate with you about your use of our Site, product announcements, and software updates, as well as respond to your requests for assistance, support, etc.
  • To show and/or send you direct marketing emails and special offers about the Company, from which you can unsubscribe at any time.
  • To calculate aggregate statistics on the number of unique devices using our Site, and to detect and prevent fraud and misuse of those.

Usage Data may be used by us for administrative, analytical, research, optimization, security and other purposes. Specifically, we may use your Usage Data to help us learn more about your activities, personalize content, compile statistics, respond to customer service inquiries, provide security and otherwise enhance your experience. Usage Data may also be used to help us provide you with advertising that better suits your interests.

Geolocation information will be used to determine the jurisdiction in which you’re located so we can determine what set of laws or restrictions apply to you.

Your device ID may be used to track your usage of our Site so that we can better understand your preferences and tendencies which will help us best personalize your experience and provide you with offers and notifications that are tailored to you.

Service Providers

We may employ third party companies and individuals to facilitate our Site (“Service Providers”), provide services on our behalf, perform service-related services or assist us in analysing how our Site is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Site.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Behavioral Remarketing

The Company uses remarketing services to advertise on third party websites to you after you visit our Site. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Site.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Data Storage and Retention

Information submitted to the Company will be transferred to, processed, and stored in the United Kingdom and other countries. When you use the Site on your computing device, the user content you save will be stored locally on that device and synced with our servers. If you post or transfer any information to or through our Site, you are agreeing to such information, including Personal Data and user content, being hosted and accessed in the United Kingdom. Please note that the laws of the United Kingdom may be different from the privacy laws applicable to the place where you reside.

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations.

Transfer of Data

The Personal Data we collect is stored and/or processed in the UK, or where we or our partners, affiliates, contractors and third-party providers maintain facilities.

The countries to which we store, process, or transfer your Personal Data may not have the same data protection laws as the country in which you initially provided the information. If we transfer your Personal Data to third parties in other countries: (i) we will perform those transfers under the requirements of applicable law; and (ii) we will protect the transferred Personal Data under this Privacy Policy.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Disclosure of the Personal Data

We may transfer your Personal and Usage Data to our affiliated entities, contractors, third-party services providers but such information shall continue to be governed by this Privacy Policy.

Except as otherwise stated in this Privacy Policy, we do not trade, rent, or share your Personal Data with third parties and we will not disclose financial information that is part of your Personal Data unless you ask us to do so.

We may share your Personal Data with third parties to provide us with the products and services. These third parties are required not to use your Personal Data other than to provide the products and services requested by the Company and are bound by confidentiality agreements about their use of such information.

You expressly consent to the sharing of your Personal Data with our contractors and third-party service providers to provide products, services and interest-based advertising to you. You can also opt-out by clicking “Opt-out” or “Unsubscribe” in our email communications with you.

Usage Data in aggregated, anonymous form may be shared with third parties who assist us with our internal operations such as administration, analytics, research, and optimization.

If another company acquires our company or our assets, that company will possess the Personal Data collected by us and it will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Regardless of any choices you make regarding your Personal Data (as described below), we may disclose your Personal Data if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on the Company; (b) to protect and defend the rights or property of the Company, our users and/or others; (c) lawful requests by public authorities, including to meet national security or law enforcement requirements; (d) take action against illegal activity, suspected abuse; (e) unauthorized use of the Site.

Subject to your privacy settings, your information and content may be publicly accessible (if you post comments or other publications on the Site).

Your Privacy Rights

By providing Personal Data to us, you understand we will collect, hold, use, and disclose your Personal Data under this Privacy Policy. You do not have to provide Personal Data to us, however, if you do not, it may affect your use of our Site offered on or through it.

If we receive Personal Data about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing Personal Data about somebody else, you represent and warrant that you have such person’s consent to provide the Personal Data to us.

If you have previously agreed to us using your Personal Data for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Upon request, the Company will provide you with information about whether we hold any of your Personal Data. You may access, correct, or request deletion of your Personal Data by contacting us at home@blackthorn.ai. We will respond to your request within a reasonable timeframe.

Please note, this right is subject to certain exceptions, including if we need to comply with a legal obligation or complete a transaction for which we collected the information.

The Company acknowledges that you have the right to access your Personal Data.

We will not discriminate against you for exercising any of your rights over your Personal Data. Unless your Personal Data is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this Privacy Policy, or opt-out using the opt-out facilities provided in the communication.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the client support at home@blackthorn.ai. If requested to remove data, we will respond within a reasonable timeframe.

You have the right to access information held about you. You also have the right to ask us to update and correct any out-of-date or incorrect personally identifiable information that we hold about you free of charge.

Please note that we will try to verify your identity via the email address or other information such as the phone number that is associated with your request before deleting your Personal Data. If another person makes this request on your behalf, please note that we will verify your identity and require them to prove that they have your written authorization to request on your behalf.

Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

The GDPR distinguishes between organizations that process Personal Data for their purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). Our Company located at the address provided in our Contact Us section is a Data Controller concerning the Personal Data you provide to us.

Legal Bases for Processing Your Personal Data

We will only collect and use your Personal Data when we have a legal right to do so. In which case, we will collect and use your Personal Data lawfully, fairly, and in a transparent manner. If we seek your consent to process your Personal Data, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your Personal Data for that specific purpose.

Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

Consent From You

Where you give us consent to collect and use your Personal Data for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however, this will not affect any use of your information that has already taken place. You may consent to provide your email address to receive marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or to take preparatory steps before we enter into a contract or transaction with you. For example, if you contact us with an enquiry, we may require Personal Data such as your name and contact details to respond.

Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Compliance with Law

In some cases, we may have a legal obligation to use or keep your Personal Data. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further inquiries about how we retain Personal Data to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of Personal Data from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Your Rights and Controlling Your Personal Data

Restrict: You have the right to request that we restrict the processing of your Personal Data if (i) you are concerned about the accuracy of your Personal Data; (ii) you believe your Personal Data has been unlawfully processed; (iii) you need us to maintain the Personal Data solely for a legal claim; or (iv) we are in the process of considering your objection to processing based on legitimate interests.

Objecting to processing: You have the right to object to the processing of your Personal Data that is based on your legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, to proceed with the processing of your Personal Data.

Data portability: You may have the right to request a copy of the Personal Data we hold about you. Where possible, we will provide this information in CSV format or another easily readable machine format. You may also have the right to request that we transfer this Personal Data to a third party.

Deletion: You may have a right to request that we delete the Personal Data we hold about you at any time, and we will take reasonable steps to delete your Personal Data from our current records. If you ask us to delete your Personal Data, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you send us a request to terminate or delete your Personal Data, we will delete your Personal Data within 30 days of approving your request. Please be aware that search engines and similar third parties may still retain copies of your Personal Data that has been made public at least once, like certain contact information and public comments, even after you have deleted the information from our services.

Additional Disclosures for California Compliance (US)

Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes.

To make such a request, please contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of Personal Data we revealed to other organizations for their marketing purposes in the last calendar year, along with their names and addresses. Not all Personal Data shared in this way is covered by Section 1798.83 of the California Civil Code.

Cookies

Our Site uses cookies. If you have agreed, in addition to mandatory and performance cookies that ensure the functioning and aggregated statistics of the Site, other cookies for analytical and marketing purposes may be placed on your computer or another device from which you access our webpage.

This Cookie Policy describes what types of cookies we use on our Site and for what purposes.

What are Cookies?

Cookies are small text files created by the website, downloaded to and stored on any internet-enabled device, such as your computer, smartphone or tablet—when you visit our homepage. The browser you’re on uses the cookies to forward information back to the website at each subsequent visit for the website to recognize the user and to remember the user’s choices (for example, login information, language preferences and other settings). This can make your next visit easier and the site more useful to you.

What Types of Cookies Do We Use and for What Purposes Do We Use Them?

We use different types of cookies to run our Site.

The cookies indicated below may be stored in your browser.

Mandatory and performance cookies. These cookies are necessary for the website to function and will be placed on your device once you access the website. Most of these cookies are set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. These cookies provide convenient and complete use of our Site, and they help users efficiently use the website and make it personalized. These cookies identify the user’s device insofar, so we would be able to see how many times our Site is visited, but do not collect any additional personally identifiable information. You can set your browser to block or alert you about these cookies, but some parts of the site will then not work. These cookies do not store any personally identifiable information and are stored on the user’s device until the end of the session or permanently.

Analytical cookies. These cookies collect information about how users interact with our Site, for example, to determine which sections are most frequently visited and which services are most often used. The collected information is used for analytical purposes to understand the interests of our visitors and how to make the Site more user-friendly. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance. For analytical purposes, we may use third-party cookies. These cookies are stored on the user’s device for as long as set by the third-party cookie provider (ranging from 1 day to permanently).

Marketing and targeting cookies. These cookies collect information about how users interact with our Site, for example, to determine which sections are most frequently visited and which services are most often used. Before you agree to the use of all cookies, we will only collect anonymous data regarding the access of the Site. The collected information is used for analytical purposes to understand the interests of our users and how to make the webpage more user-friendly. For analytical purposes, we may use third-party cookies. These cookies are stored permanently on the user’s device.

Third-party cookies. Our Site uses third-party services, for example, for analytics services so we would know what is popular in our Site and what is not, thus making the website more usable. You can learn more about these cookies and their privacy policy by visiting the websites of respective third parties. All information processed from third-party cookies is processed by the respective service providers. At any point in time, you have the right to opt out from data processing by third-party cookies.

For example, we may use Google Analytics cookies to help measure how users interact with our Site content. These cookies collect information about your interaction with the Site, such as unique visits, returning visits, length of the session, actions carried in the webpage, and others.

Managing Cookies

We strive to give you choices about how your Personal Data is used. We do not sell, trade, or otherwise transfer the information we collect from you to unaffiliated third parties. We do, however, share the information we collect from you with trusted third parties who assist us in operating our Site, conducting our business, or provided that those parties agree to keep your information confidential and secure.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact on the usability of many websites.

If you block cookies, you will not be able to use all the features on our Site.

For more information please visit http://www.aboutcookies.org

Our Policy on “Do Not Track” Signals

We honor Do Not Track signals and do not track plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Minors

While the Site may be visited by children, we do not knowingly collect or use any Personal Data from children under the age of 13 and hereby specifically prohibit any user under the age of 13 from providing us with any Personal Data. If you are a parent of a child under 13 years of age and you believe your child has provided us with Personal Data, please contact us at home@blackthorn.ai and we will delete the information from our IT systems.

We may collect a device ID or other persistent identifier linked to the device or computer that may be used by a child to use our Site. The data collected will be anonymous and not tied to any Personal Data. In addition, this data will be used solely for internal purposes such as personalization of content, security, and contextual (not behavioral) advertising.

Security

It is entirely your choice whether or not you provide Personal Data to us. We and/or our third-party partners have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, maintain data security and correctly use the Personal Data collected through the Site. We take or obligate applicable third parties to take reasonable precautions to protect our customers’ Personal Data against loss, misuse, unauthorized disclosure, alteration, and destruction.

However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. We cannot ensure or warrant the security of any information you transmit to us by email and you do so at your own risk.

If there is a breach of security involving your Personal Data from our Site, we will inform you immediately and take commercially reasonable steps to rectify such breach.

If you believe your Personal Data is being improperly used by us or any third party, please immediately notify us via email at home@blackthorn.ai.

External Sources

Our Site may link to external sites beyond our control. This Privacy Policy covers only the way we treat the Personal Data and Usage Data we collect on our Site. By accessing any external sites, you are agreeing to the privacy policies of those sites.

Please note that the external sites may have different policies for the collection, use and disclosure of your Personal Data. We have no control over and are not responsible for the privacy practices of such third parties. Therefore, you are encouraged to review the privacy policies of all third-party websites or apps. Without limiting anything in the following section, we are not liable in any way for the actions, inactions or policies of any external websites or apps.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: home@blackthorn.ai

or send us a mail:

BLACKTHORN AI LTD, Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX