Effective as of: 12.12. 2021.

‍

As AI Software d.o.o BEOGRAD-Vračar (“AI Software”, “we,” “our,” or “us”) we take your privacy very seriously and we encourage you to read the content of this document occasionally so that you could be completely informed and could provide your consent for application of this Privacy Policy (“Privacy Policy”) and obtaining, using, and otherwise processing your personal information as presented herein only upon obtaining full knowledge of its content.

This Privacy Policy applies to all persons visiting our websites, using the App and/or any of our other services, and all of App’s related features, functionality, and services, blog, posts, feed, online shop or one of our other products or services now or in the future that reference this Privacy Policy.

This Privacy Policy explains how we collect, use, and disclose your personal information.

Please note: AI Software operates a an online AI-powered image and data analysis engine that enables brand managers to track and report original, counterfeit as well as second-hand goods online under the name Reputeo (“Reputeo“ or “App”) as well as provides other services. This Privacy Policy also applies when you are create a user account with us (“User Account”) and use the App and the services we provide within the App. By accessing our website and our services (including the App) and providing a consent to apply Privacy Policy, you agree that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. By accepting to apply this Privacy Policy, you have provided the consent as a data subject meaning that you have provided us with the legal ground to obtain and process the information as contemplated in this Privacy Policy. In addition, please note that this Privacy Policy may be closely corelated with our Terms and Conditions of Use of Reputeo Tool (for the purposes of this Privacy Policy, such document shall be hereinafter referred to as the “Terms of Service”) and by you accepting Terms of Service, we are entitled to obtain and process your information under this Privacy Policy in order to enforce such agreement or any other agreement between us. By accepting this Privacy Policy, you have agreed that your personal information can be obtained and processed in accordance with this Privacy Policy when our legitimate interests are pursued (as such legitimate interests are provided hereunder, including through providing examples). If you do not agree with this Privacy Policy and do not want to provide the consent for its application, please stop accessing our website and using our services. Even after providing your consent to application of this Privacy Policy, you are entitled to withdraw your consent for application of this Privacy Policy at any time, however in such case you will not be able to continue to access our website and/or use our services to its full extent or to use it at all.

‍

1. Personal Information We Collect

‍

1.1. Data Provided Directly by You:

• Contact and Profile Information. When you access our website and/or use our services or otherwise communicate or interact with us, we may collect information from you that you have provided us, such as your name, username, password, email address, age, date of birth, gender, address, personal preferences, product and service reviews, purchasing habits, desired products, purchasing history, photos and videos that you have posted within the App, and any other personal information that you choose to include, or in other communications with us or using the App, including through your comments and reviews. You acknowledge that if you post a rating and/or review within the App, your rating and/or review may become a public information and may be retained by us. We may combine personal and non-personal information about you collected by us or by our affiliates and we may combine this information with information from external sources. We use this contact and profile information to: (i) create, verify, and personalize our services; (ii) communicate with you directly about our services as well as about any questions, issues, or concerns you or other users of our services may have; (iii) fulfill your order (including any subscription plan you may have with us); and (iv) send you information about our or third party products offered within our services in accordance with your possible preferences.
• Use of our Services and the App. If you use the App or our services to track your activity (including purchase of products or services), we may collect and store this information so that you can review it on the App and track your activity. We may also use this information to calculate further information about your activity so that this can be provided to you as part of the functionality of the App and our services.
• Payment Information. When you make your purchases, you may reveal your financial information (e.g. credit card number, etc.), however we do not collect any financial or billing information from you in relation to such a transaction. Please review the relevant payment processor terms and notices to learn about how your data is used. We keep a record of the purchases you make, the time at which you make those purchases and the amount spent.
• Transaction Information. When you submit purchase order, we collect information, including the purchased products and services, date and time of your transaction, and other information necessary to fulfill the order. We use this transaction information to fulfill your order, detect and prevent fraud, personalize your experience, perform analytics/identify usage trends, and inform you of our advertising and marketing campaigns.
• Communications, Participation and Other Content. We maintain all communications resulting from your interactions with us by email, posts, forum, comments or using our services otherwise. We also record comments and opinions you express, responding to our surveys, entering a sweepstakes, or taking part in promotions we help to run. We use all of the foregoing communications to address your questions, issues, and concerns, and to improve our services. Such communication and interaction may include the content of the message and information about when the message has been sent, as well as the participants of the communication. Please be aware that communication and interaction posted publicly will be accessible by those users and that we are not responsible for the manner in which those users use or disclose such communication and interaction.
• Other Information You Provide. With your previous permission, we may access your photos and/or videos from your mobile device to enable you to share your comments and reviews on our services.

‍

1.2. Personal Information Generated and/or Automatically Collected During Your Use of Our Website, the App and Our Other Services:

• Information About Your Device and Its Software. Information about your device and its software includes your IP address, browser type, internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to identify your browser, mobile device, or your User Account (if any), identifiers of beacons communicated to us, and other similar information. We may use this device and software information to diagnose and fix technology problems, personalize your experience, perform analytics/identify usage trends, and improve our products and services or develop new products.
• Information About the Way You Access and Use Our Services. We collect information regarding your use of our services and any other user generated content that you generate. We also link your subscriber information with your activity on the App across all your devices using your email, password or similar information. We may also use the information about the way you access and use our services and/or the App to determine which of our products and services may be of interest to you, to improve our products and services, to evaluate the success of advertising and marketing campaigns, and to send you marketing communications.
• Analytics Information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends and the demographics of our users in order to improve our services. Please go to the Google Privacy Policy to learn more.
• Location Information. We do not obtain or store your location information while using our website or using our services. In that sense, under no circumstances shall we be liable for claims or for any damages therefrom, arising out of your informed decision to allow other users to see your mobile device location information in any form, including without limitation through posting your photos, while using or interacting with our services.

We typically collect the foregoing information through a variety of technologies, including use of third-party partners or services to assist with this effort. Information we collect automatically about you or your device may be combined with other personal information we collect directly. For information about our and our third-party partners’, please see our “Third-Party Tracking” further below.

We or the third-party partners we use, may use the data collected automatically through mentioned technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the App; (b) provide custom, personalized content and information; (c) provide and monitor the effectiveness of our services; (e) perform analytics and detect usage patterns on our services; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities, and (h) otherwise plan for and enhance our services and for other internal purposes.

‍

1.3. Data From Other Sources:

• Information We Receive from Third-Party Sites or Applications. We may receive personal information about you from third parties and combine that with information we collect through the App or our other services. For example, we may obtain information when you login through a third-party social network or authentication service, such as Google. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, gender or other information. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site. Prior to using any such sign-in service, please review the privacy policies of these social media providers as they may have different policies and practices than us. We do not assume any responsibility for the privacy practices, policies or actions of the operators of these social media websites.
• Information We Receive from Third Parties. From time to time, we may collect information about you from third parties, such as analytics providers. We may also collect information about you that is publicly available. We may receive additional information about you, such as fraud detection information, from third-party partners and combine it with other information that we have about you. We use this information from third parties to create your User Accounts, to contact you, to send you promotional materials or to personalize our services, to protect against bot attacks and account takeovers, and to better understand the demographics and interests of our users.

‍

‍

2. How We Use Your Information

As explained below, we use your information to fulfill and enforce our Terms of Service, to improve and administer our services, and to allow you to use its functionalities. We may also use your information to, among other things, show you suggestions, promote our services and third-party offerings, and customize your experience. We will use your information to:

‍

2.1 Provide Services to You.

We use your personal information to create your User Account, enable you to use the App and our services, as well as to provide you a support in using the App and our services.

‍

2.2 Maintain and Improve Our Services.

We may use your personal information to provide, maintain, improve and develop the App and our services. For example, we may use information about how users of our App search for and find specific products to better understand the best ways to organize and present the content that we offer. Specifically, we may use your personal information in order to (i) provide our services to you, including, without limitation, sending receipts, and tracking and notifying you of payment information; (ii) providing custom and personalized content and information; (iii) to perform analytics, detect activity patterns and otherwise research usage; and (iv) to test and develop new features and functionality and otherwise enhance the App and our services.

‍

2.3 Maintain the Safety, Stability and Security of Our Services and the App.

We may use your personal information to investigate and remedy fraudulent or allegedly fraudulent activity as well as diagnose or fix technology problems.

‍

2.4 Communications with You to Provide Support and Other Important Messages and Notifications.

We may use personal information to communicate important messages and notifications to you and/or to provide you with support and use your data to manage our relationship with you and to improve our services and enhance your experience with us.

‍

2.5 For Promotion Purposes.

We may promote third party products or services that we believe might interest you. Please note that, if you choose to purchase products or services promoted by us, you may be a customer of both us and third parties developing and producing such products or services and that we may share certain information with such third parties in order to fulfil your order and enforce such contract.

‍

2.6 Legal and Regulatory Requirements and Proceedings.

We may use the personal information in connection with legal proceedings and requirements. For example, we may need the personal information to enforce our corporate reporting obligations and our Terms of Service, or to comply with applicable laws.

‍

2.7 Enforce Our Rights.

We may use your personal information to ensure you comply with our Terms of Service and this Privacy Policy and use your personal information to monitor, investigate, prevent and/or mitigate violations of these legal provisions, as well as enforce our agreements with third parties and business partners.

‍

2.8 Other Purposes Disclosed at the Time of Collection.

From time to time, we may use personal information for a specific purpose not contemplated by this Privacy Policy. In such an event, we will specifically disclose that use to you.

‍

‍

3. Sharing of Your Information

We may share your personal information in the instances described below. We encourage you to repeatedly check this part of our Privacy Policy in order to be informed with whom we share your personal information.

We May Share Your Personal Information With:

• AI Software’s Subcontractors. AI Software, together with its subcontractors, helps us to develop, run and improve the App and other services, while we are providing you with our services and providing you with the App offerings. If you chose to use the App and provide your consent to obtain personal information as contemplated in this Privacy Policy while opening the User Account and/or using the App, please note that we may share some of your information with AI Software’s subcontractors. However, in such case AI Software shall be only allowed to use your information in order to obtain aggregated data (e.g. improving the App features, purchasing habits of certain age and gender groups, etc.) and we shall not share any of your information that may as the end-product uniquely identify you or any other user of the App. Further, such information may be further disclosed by AI Software to its subcontractors on the basis of our legitimate interest to fulfil their obligations towards us. For more information, please contact us following the instructions in the “Contact Us” section.
• Third Parties at Your Direction or Request. In certain cases you may also elect to share your personal information with third persons. Please be aware that some or all of your information shared in such manner may be publicly available and used by third persons. We do not take any responsibility for actions and omissions of such third persons.
• Business Partners. We may share information with our business partners in order to help run the App offerings in a smooth and undisturbed manner and help you provide better user experience. Such disclosure may include third parties like customer service providers, advertising and marketing partners, email service providers, texting service providers, cloud storage providers, storage providers, our and their subcontractors. However, we shall not share any of your information that may as the end-product uniquely identify you or any other user of the App.
• Payment Providers. In case that we use third parties in processing your payment, payment providers may request us to provide certain personal information in order to help cultivate the payment and facilitate the payment.
• Service Providers and Contractors. We use third parties that perform services on our behalf as needed to carry out their obligations to us. Our service providers may have access to personal information as needed to provide data analysis, infrastructure provisioning, IT services, customer services, email delivery services, promotional, marketing and other similar services. However, we shall not share any of your information that may as the end-product uniquely identify you or any other user of the App.
• Analytics Providers. We work with third-party analytics providers to better understand the demographics of our users, and to personalize, enhance and improve the App and our services.
• Social Media. We may use social media plugins on our services (e.g. a “share” or “like” button), and your use of these plug-ins, may result in the disclosure of certain of your information to the social media platform in question, and possibly presented on your social media profile, to be shared with others in your network – however, we will only share your information with these social media platforms if you have provided your express consent for us to do so.
• Business Transaction or Reorganization. We may disclose your information to third parties: (i) in the event that we sell or buy any business or assets (for example, as a result of liquidation, bankruptcy or otherwise). In such transactions, we may disclose your data to the prospective seller or buyer of such business or assets; or (ii) if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
• Legal Obligations and Rights. We may disclose personal information to third parties, such as legal advisors and law enforcement, as required by law or subpoena or if we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our services and the App; (c) detect, suppress or prevent fraud or reduce credit risk and collect debts owed to us; and/or (d) exercise or protect the rights, property, or personal safety of us.
• Public. We may make available through the App and our services certain features which may enable you to post information and materials, for example, comments, ratings and reviews. Please note that any information you provide in connection with such services may be available to the general public. Please do not disclose your personal information in these public or interactive areas, and we urge you to exercise discretion and caution when deciding to disclose any other information and/or materials in these public or interactive areas on our services or the App.
• Consent. Where not provided herein, we may disclose personal information about you to other third parties with your consent.

We may also use aggregate personal information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes as long as the end-product does not uniquely identify you or any other user of the App and/or our services.

‍

‍

4. Control Over Your Information

Profile and Data Sharing Settings. You may update your profile information in your User Account settings.

How to Control Your Communications Preferences: You can stop receiving promotional email communications that we send by clicking the “unsubscribe link” provided in such communications. This unsubscribe action applies only to promotional email communications that we send. You may not opt out of service-related communications (e.g., verification, transactional communications, changes/updates to features of the App and/or our services, technical and security notices).

Modifying or Deactivating Your Information: If you would like to review, modify, or deactivate your User Account, you can go to the “Account” tab or similar tab within the App. We may not be able to modify or deactivate your information in all circumstances.

‍

‍

5. Third-Party Tracking

• Google Analytics. We use Google Analytics to recognize you and link the devices you use when you visit or use the App, login to your User Account on our services or the App, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how the users interact with our services or the App and to tailor our content to you. You should learn on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site. You should also learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On.

‍

‍

6. How We Store and Protect Your Information

Data Storage and Transfer. Your information collected through our services and the App is stored and processed in [insert country]. If you are located in other regions with laws governing data collection and use that may differ from the law of mentioned country where servers are located, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

Keeping Your Information Safe. We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our services. However, no security system is impenetrable and we cannot guarantee the security of our systems. Please recognize that protecting your personal information is also your responsibility. Accordingly, we strongly recommend that you choose unique passwords that are not reused across other App or websites, and otherwise take precautions when communicating your personal information on the internet. If you know or have reason to believe that your User Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your User Account, please contact us following the instructions in the “Contact Us” section below.

‍

‍

7. Children’s Privacy

Our services are not directed to children under the age of [18]; nor do we knowingly attempt to collect or solicit personal information from children under the age of [18]. In the event that we are informed that we have inadvertently collected personal information from a child under age [18], we will disable our services and delete the provided information as quickly as possible. If you believe that we have any information from a child under mentioned age, please contact us following the instructions in the “Contact Us” section below.

‍

‍

8. Changes to Our Privacy Policy

We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the "Effective" date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you by email to your registered email address or through other appropriate communication channels. All changes shall be effective from the Effective Date unless otherwise provided. If you do not object before the date the when revised Privacy Policy becomes effective, your continued access to or use of the App and/or services or you otherwise engaging us will be subject to the revised Privacy Policy.

‍

‍

9. How to Contact Us

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to support@reputeo.com

‍

‍

10. YOUR RIGHTS

AI Software respects your rights to privacy: it is important that you have control over your personal information. In that sense, we are acting in accordance with Serbian Law which is compliant with General Data Protection Regulation (”GDPR”). Therefore, we would like to make you aware of your rights, as further elaborated below.

Who is responsible for processing your personal information? We are acting as a “data controller” for all the personal information obtained on you, in sense of Serbian law and the GDPR. AI Software is acting as a “data collector” and “data processor” for such personal information.

What Personal Information do we collect (including by automated means)? Personal information that we are collecting are presented in Section 1 above.

Why and how do we use your Personal Information? We use your personal information, including the reasons for their use, in accordance with the Sections 2-4 above.

How do we protect and manage your Personal Information (including international transfers)? Your personal information is originally stored in [insert country] as of the moment you have started engaging with us, based on your consent to apply this Privacy Policy. We generally do not transfer your data outside the country where they are stored, however where we transfer your personal data to countries outside the Serbia, EEA, United Kingdom or Switzerland we also require all third party data recipients to process your information in a secure manner and in accordance with the GDPR (e.g. through the signing of the EU standard contractual clauses). If you have further questions about this or would like to request to view copies of the applicable safeguards (where required), please contact us at the contact details provided in Section 9.

What are the retention periods? We retain your personal information for as long as it is necessary for your use of our services and exercise our rights in relation to the information involved. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. That basically means, that we may still retain a limited portion of your personal information so that we can maintain a continuous relationship with you if and when we are in contact with you again, and to comply with our internal processes and any regulatory obligations. We will also retain your data, if necessary, for legal claims. When we no longer need your personal data, we will securely delete or destroy it.

Who do we share your Personal Information with? We share your information in accordance with the Section 3 above.

YOUR RIGHTS AND CHOICES.

• ACCESS YOUR DATA: You can ask us, free of charge, to confirm we process your personal data and for a copy of your personal data.
• DELETE YOUR DATA: You can ask us to delete all or some of your personal data.
• CHANGE OR CORRECT DATA: You can ask us to change or fix your data.
• PORTABILITY: You can ask for a copy of personal data you provided in a machine readable form. This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format; and
• OBJECT TO PROCESSING OF YOUR PERSONAL INFORMATION: You can use this right where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
• OBJECT TO AUTOMATED DECISION-MAKING INCLUDING PROFILING. You can use this right where that is not to be subject of any automated decision-making by us using your personal information or profiling of you;
• REQUEST THE RESTRICTION OF PROCESSING OF YOUR PERSONAL INFORMATION. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
• OBJECT OR RESTRICT USE OF DATA AND WITHDRAW CONSENT: Besides your above mentioned rights, you can ask us to stop using some or all of your data, e.g. if we have no legal right to keep using it. You can ask us to stop processing your personal data for direct marketing purposes. If you object to such processing, we ask you to share the reason for your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. Please note that we may charge a small fee in order to cover the costs of processing your requests.

For information about how to make these requests, you can contact us using the contact information provided in Section 9, and we will review your request while considering applicable laws.

Updates to this part of the Privacy Policy. We will update this part of the Privacy Policy from time to time. When we make changes to this part of the Privacy Policy, we will change the effective date at the beginning of this notice. All changes shall be effective from the effective date unless otherwise provided in the notification. If you do not object before the date the revised notice becomes effective, you will be subject to the such revised notice.

How to contact us? You can contact as per contact details provided in the Section 9 above.

‍

‍

11. Governing Law

By choosing to apply this Privacy Policy, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of Republic of Serbia, without reference to the choice of law or conflicts of law principles thereof, and will be subject to the dispute resolution clause contained in the Terms of Service which is incorporated herein by reference regardless of the fact whether Terms of Service apply to you or not.