Introduction

Privacy Policy. Protecting your privacy is very important to us. We have therefore prepared this privacy policy (the “Policy“) for you. Please read it carefully. This Policy complies with Regulation (EU) 2016/679 of the European Parliament and of the Council on the General Data Protection Regulation (“GDPR”) and provides you with information on what personal data we process about you, why and how we handle it, and how long we will keep it.

Who does it apply to? This Policy applies to you if you are a natural person who uses our website http://www.pinocchat.com (the “Website“).

Who are we? We are a controller of your personal data. A controller is generally a person who determines the purpose of collection and decides how the personal data will be processed. The controller of your personal data is PINOCCHAT s.r.o., Company ID: 199 99 810, with its registered office at Rybná 716/24, 110 00 Praha 1, the Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague under reference C 395360 (“we / us”).

What do we do? We provide an AI tool which enables you to interact with your own data in a smarter way. For the purpose of this Policy, we will call it “Pinocchat AI”. You can find more information on how Pinocchat AI works here on our Website.

Why do we process your personal data? In a nutshell, we process your personal data for one of the following reasons:

• Communication. When you use our contact form on the Website or contact us in another way (e-mail, phone) we need your personal data to be able to get back to you.
• Chatbot. We have set up a chatbot on our Website (the “Chatbot”). By clicking on “Try Me!” or on an icon located in the lower right part of the Website, you can activate it and write into it. As we do not know what messages and information you may send to the chatbot, it is possible that some of these information you sent us may be personal data.
• Newsletter. If you want to receive up-to-date information about us and Pinocchat AI, you can grant us consent to receive newsletters.

Contact details. You can contact us at any time using these details:

e-mail: contact@pinocchat.com

What personal data do we process and for what reasons?

We may process your personal data for several reasons. You will find important information about the personal data processing on our part in this part of the Policy.

Firstly, what personal data may we process about you?

• Basic identification data. This data is used to enable us to identify you, for example, when you communicate with us through a contract form or the Chatbot. This may include, for example, your name or business name, date of birth, identification number, and registered or residential address.
• Contact details. We use these so that we can contact you. This includes mainly telephone number and email address.
• Information from our communications. In this case, this mainly includes other information provided in contact forms, e-mail messages or the Chatbot.

This personal data is processed by us in the following way:

What is the legal basis for the processing?	Why do we process your personal data?	How long do we process it?	What personal data do we process?
TAKING STEPS PRIOR TO ENTERING INTO A CONTRACT Our Chatbot is a showcase of what services we can provide to you and how Pinocchat AI works. After the showcase, you may want to enter into a contract with us. ALONG WITH OUR LEGITIMATE INTEREST We have legitimate interest to show you how Pinocchat AI works and what services we may be able to provide you with.	As we already mentioned, we can process your personal data so that we can showcase you our Chatbot and the services we may offer you.	For the period of 1 year after you inserted your personal data into the Chatbot	As we do not know for which purpose you will try the Chatbot, we cannot tell exactly what personal data you may put into it. It may be all of the categories mentioned above or even some other personal data you provide us via the Chatbot.
LEGITIMATE INTEREST We process your personal data because it is in our legitimate interest.	So that we can respond to your questions and queries from the contact form or an e-mail message.	For the period of 1 year after we receive your question or query.	Basic identification data (your name) Contact details (your e-mail address) Information from our communications (other information included in the contact form or an e-mail message)
CONSENT We process the personal data based on a consent you gave us.	So that we can send you our newsletters.	For however long you give us your consent, usually for three years. You can withdraw your consent at any time, for example by sending us an e-mail or by clicking on “Unsubscribe” or other text in our newsletters. However, even if you withdraw your consent or if it expires, this does not mean that we have to delete all your data that we have processed on the basis of your consent. We may continue to work with those data where another legal reason allows us to do so. If you withdraw your consent, this does not affect the lawfulness of the processing of your personal data prior to the withdrawal.	Personal data mentioned in the consent form, generally your contact details (e-mail).

If you gave us the consent to send you newsletters, we may send these to you for 3 years, unless you unsubscribe sooner. You can do so by clicking directly in the newsletter or by sending an email to contact@pinocchat.com.

Pinocchat AI is aimed at commercial customers, who may want to use AI in the business setting. We understand that certain degree of information confidentiality is needed.

Therefore, we never use the data entered into the Chatbot to improve Pinocchat AI. This includes not only personal data but all data. We only process this data temporarily to enable you to try the Chatbot so that you get responses to your questions and queries. However, your data entered into the Pinocchat AI is not saved and further processed anywhere else.

We may sometimes aggregate or de-identify your personal data so that it may no longer be used to identify you and use such information to analyse the effectiveness of our services, to improve and add features to our services, to conduct research and for other similar purposes. 

We also use cookies and may process some personal data in that regard. You can find more information about cookies in our Cookie Policy.

We implement commercially reasonable technical, administrative and organizational measures to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration or destruction. However, as no data transmission is always 100% safe and error free, we encourage you to take care in deciding what personal data you share with us.

We always try to process as little personal data as possible. If you want to ask us a question, receive newsletters or try our Chatbot, we may need some of your personal data. This generally includes your basic identification data and contact details. If you do not wish to provide us with your personal data, do not use our Website.

We may transfer your personal data to other parties, mainly to ensure that we can operate effectively. However, we transfer a very limited amount of data – mainly data derived from cookies or your e-mail address when you subscribe to our newsletter. As mentioned earlier, we never transfer your personal data entered into the Chatbot.

Our service providers become the processors of your personal data. However, they are only entitled to process your personal data to the extent that we have agreed with them. We also enter into agreements with such processors to ensure that your personal data is processed lawfully.

Specifically, we transfer your personal data to the following entities:

• partners who ensure that our newsletters are sent;
• partners who help us analyze our website as well as your visits and behavior on our website (through cookies), such as Google Analytics;
• partners who provide us with necessary technical background so that we can provide our services to you (cloud and other IT services).

We may also make your personal data available to our employees and contractors who provide certain services to us which are related to the processing of personal data mentioned above.

We may also transfer your personal data to public authorities if it is in our interest to do so or if they ask us to do so.

We may also transfer your personal data to entities located outside of the European Union. If we do so, we do it in the most limited extent possible. We will take all the necessary steps to ensure that your personal data is processed safely and in accordance with law.

You have the following rights concerning the processing of personal data:

• You may ask us to tell you what personal data we process about you and, if you ask us to do so, we must also give you access to it.
• You may ask us to correct incorrect data or complete incomplete data.
• We are also obliged to erase your personal data (‘right to be forgotten’) or restrict its processing under certain conditions if you ask us to do so.
• If you believe that your personal data is being unlawfully processed, you have the option of lodging a complaint with the data protection authority. In the Czech Republic, where we reside, you can contact Office for Personal Data Protection, https://uoou.gov.cz/en, Pplk. Sochora 27, 170 00 Praha 7, the Czech Republic.
• In addition, you also have the right to object if we are processing your personal data based on our legitimate interests. This objection can be made by sending an email to our contact address or contact@pinocchat.com. We will then investigate it within one month of receipt at the latest.

We will not process your personal data using automated individual processing that would have legal effects on you as a data subject or affect you in a similarly significant way.

This Policy is effective as of 15.12.2023.