Privacy Policy

1. Introduction

Career Ear Limited, trading asEarlybird ("Earlybird", "we", "us","our") is committed to protecting and respecting your privacy. ThisPrivacy Notice explains how we collect, use, disclose, and safeguard your informationwhen you visit our website and use our services.

This policy together with ourTerms of Use applies to your use of:

● Earlybird website application software(Earlybird App) whether available on our site or hosted on any server or anymobile application platform.

● Earlybird website - https://getearlybird.ai

together “App Site”.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Career Ear Limited (trading as Earlybird) is registered for data protection with the UK Information Commissioner’s Office under registration number ZA692231 and observes the rules of the Data Protection Act 2018 and the UK GDPR.

Our full name: Career Ear Limited (registered in England and Wales under company number 11479497).

Our contact details: info@getearlybird.ai

For the purposes of applicable data protection laws (including the UK General Data Protection Regulation – “UK GDPR”), we act as a Controller for the data we collect directly from you and as a Processor for data we process on behalf of our customers.

This Privacy Notice was last updated on 10 March 2024.

2. Our Role as Controller and Processor

Earlybird plays a dual role when it comes to processing personal data. In some situations, we act as a Controller, and in others, we are the Processor.

Asa Controller: We determine the purposes and means of processing personal data. This includes data of potential and existing employees, suppliers, product testers, investors, website users, and technical data when you use our app.

Asa Processor: We process personal data on behalf of our customers based on their instructions. If you are an end-user of our customer's services, we act as the Processor, and the customer (such as your employment advisor's organization) is the Controller. For more information about how your data is processed, please refer to the privacy notice of the organization that referred you to our services.

3. What Data We Collect

We may collect and process thefollowing data about you:

3.1 Information You Provide to Us

● Personal details such as your name, email address, phone number, and job title.
● Information provided when filling in form son our website or app, such as registration details.
● Correspondence data when you contact us via email, phone, or other means.
● Conversation data through the Earlybird platform, including natural language voice conversations.

3.2 Information We Collect Automatically

● Technical data including the type ofdevice you use, unique device identifiers, IP address, browser type, andversion, time zone setting, browser plug-in types and versions, operatingsystem and platform, and other technology on the devices you use to access oursite.
● Usage data including information about howyou use our website, products, and services.

3.3 Information from Third Parties

● Data from third parties including our business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, and search information providers.

4. How We Use Your Data

We use the data we collect forthe following purposes:

4.1 To Provide and Improve Our Services

● To ensure you can use our website and app.
● To improve our website, app, and services based on your feedback and usage patterns.

4.2 To Communicate with You

● To send you updates, newsletters, and other communications related to our services.
● To respond to your inquiries and provide customer support.

4.3 To Comply with Legal Obligations

● To comply with legal and regulatory requirements.

5. Legal Basis for Processing Your Data

Our lawful basis for processing your data is a combination of Contract, Legitimate Interest, and Consent.

5.1 As a Controller

Contract: We use your contact details to provide you with the app and the appropriate technical support as needed, as well as service messages; this is our contract with you.
Legitimate Interest: We use legitimate interest when we use your data to keep you upto date with changes and improvements to our goods and services. Results of a legitimate interest balancing test indicate that this use is pursuing a legitimate interest, is necessary for the purpose of keeping you updated and growing our business, and unlikely to cause you risk or harm.
Consent: We process your data for marketing purposes based on your consent.

5.2 As a Processor

Contract: Processing personal data is necessary for the performance of a contract with our customers.
Legitimate Interest: We process personal data to improve the performance of the app and protect it from illegal use, based on the legitimate interests of our customers.

Contract: Processing personal data is necessary for the performance of a contract with our customers.
Legitimate Interest: We process personal data to improve the performance of the app and protect it from illegal use, based on the legitimate interests of our customers.

6. Sharing Your Data

We may share your personaldata with the following categories of recipients:

Service Providers: Companies that provide services on our behalf, such as hosting, data analysis, payment processing, information technology, customer service, email delivery, and marketing.
Business Transfers: We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, depending on the lawful basis, be permitted to use that data only for the same purposes for which it was originally collected by us. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to comply with legal obligations, protect and defend our rights or property, prevent fraud, act in urgent circumstances to protect the personal safety of users of our services, or the public.

7. International Data Transfers

We do not transfer personal data outside of the UK. In the event that we need to transfer personal data outside of the UK, we will:

1- Inform anyone whose personal data is affected.
2- Observe adequacy regulations and ensure protection by appropriate safeguards such as using standard contractual clauses.

We do not transfer personal data outside of the UK. In the event that we need to transfer personal data outside of the UK, we will:

1- Inform anyone whose personal data is affected.
2- Observe adequacy regulations and ensure protection by appropriate safeguards such as using standard contractual clauses.

8. Data Security

We have implementedappropriate security measures to prevent your personal data from beingaccidentally lost, used, or accessed in an unauthorized way, altered, ordisclosed. Access to your personal data is limited to those employees, agents,contractors, and other third parties who have a business need to know.

9. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Asa Controller: We retain personal data in accordance with the specific purposes for which it was collected and as outlined in section 9.
Asa Processor: Our data retention policy is to delete personal data of end users every 90 days, subject to any alternative agreements with the data controller.

10. Use of Data for Machine Learning

We use conversation and otherdata to train our machine learning models. This data does not and will nevercontain any personal data. We regularly delete personal data in accordance withour data retention policy and/or our controller's policy such that we wouldnever be able to identify you from the data that we hold.

11. Your Data Protection Rights

You have the following rights regarding your personal data:

Access: You have the right to request access to your personal data.
Rectification: You have the right to request that we correct any inaccuracies in your personal data.
Erasure: You have the right to request that we delete your personal data.
Restriction: You have the right to request that we restrict the processing of your personal data.
Objection: You have the right to object to our processing of your personal data.
Data Portability: You have the right to request a copy of your personal data in a machine-readable format.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on our website.

13. Contact Us

If you have any questions about this Privacy Notice, please contact us at info@getearlybird.ai.

This Privacy Notice was last updated on 10 March 2024.