Privacy Policy

INTRODUCTION

Ejento AI Inc. ("Ejento," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our website, services, or interact with us.

WHO WE ARE

Ejento AI Inc. is a provider of AI-powered solutions and services. This Privacy Policy applies to all personal data collected and processed by Ejento AI Inc. in connection with its services.

DATA CONTROLLER AND REPRESENTATIVES

The data controller responsible for the processing of your personal data is:

Ejento AI Inc.
2331 130th Ave NE, Suite 110 Bellevue, WA 9800.
privacy@ejento.ai

In compliance with Article 27 of the EU General Data Protection Regulation (EU GDPR) and the UK GDPR, we have appointed representatives in the European Union and the United Kingdom:

Our EU-GDPR Representative is:
Rickert Rechtsanwaltsgesellschaft mbH
– Ejento AI Inc. –
Colmantstraße 15
53115 Bonn
Germany
Email: art-27-rep-ejento@rickert.law

Our UK-GDPR Representative is:
Rickert Services Ltd UK
– Ejento AI Inc. –
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
Email: art-27-rep-ejento@rickert-services.uk

You may contact our EU or UK Representative for any matters relating to the processing of personal data under the EU GDPR or UK GDPR.

SCOPE

This privacy policy ("Privacy Policy") is incorporated by reference into Ejento AI Inc. Terms of Service. We at Ejento AI Inc. ("Company", "we", "us" "our" and "Ejento AI") are committed to safeguard your personally identifiable information/personal data ("PII") in accordance with applicable data protection laws as well as this Privacy Policy. We have prepared this Privacy Policy to inform you of the manner in which we collect, use, disclose, retain, transfer and handle ("Use"), and otherwise process the information we may collect about you from (a) your use of our Website, located https://ejento.ai/ and/or our products and/or services or software-as-a-service offerings hosted by or on behalf of Ejento AI Inc. (collectively, the "Services"), (b) your interactions with us online and at in-person events, or (c) any other circumstances in which we provide you with a copy of this Privacy Policy.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and Services, we will ask you to consent to our use of cookies when you first visit our website.

DEFINITIONS

Under this Privacy Policy:

Personally identifiable information/personal data ("PII") means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing means any operation or sets of operations which is performed on PII or on sets of PII, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of PII.

Processor means a natural or legal person, public authority, agency or other body which processes PII on behalf of the controller.

Recipient means a natural or legal person, public authority, agency or another body, to which PII are disclosed, including both processors and controllers.

Legal basis means a lawful ground for data processing under the GDPR or similar laws.

APPLICATION OF THIS PRIVACY POLICY

By engaging with the website and Services, you acknowledge that you have read and understood this Privacy Policy.

For users based in the EU and the UK, we are required to describe our role and our responsibility for PII.

If you access and use our website and/or the Services in your individual capacity, we are the "Data Controller" under EU privacy law.

If you access and use our website and/or Services in connection with an agreement entered into between your former, current, or prospective employer (referred to herein as "Employer") and Ejento AI (the "Enterprise Agreement"), and in accordance with that Enterprise Agreement, your Employer remains the data controller for certain PII you may be required to disclose in connection with your use of our website and/or Services, the terms of that Enterprise Agreement shall apply with respect to the processing of PII set forth therein. In these instances, we act as a "Data Processor" under EU privacy law, meaning that we process your PII to provide a service to your Employer and do so at their direction. If you have any questions about specific privacy practices in connection with your use of our website and/or Services through your Employer, please contact your Employer.

If we provide software-as-services offerings to our customers under an agreement with them and solely for their benefit. Our customers designate which of their personnel (including third party contractors, agents, etc.) are authorized as users of the customer's software-as-services accounts ("Authorized Users"). Authorized Users may access and use software-as-services offerings from all over the world, subject to the agreement between Ejento AI and the customer as well as any applicable laws.

This Privacy Policy does not apply to the content that our customers and their Authorized Users upload and store in software-as-services offerings ("Customer Content"). Ejento AI processes Customer Content solely on behalf of the customer and that customer is responsible for the collection and use of your data. Because of this, that customer's privacy Policy (and not this Privacy Policy) will apply to the customer's collection and use of Customer Content. Therefore, for any queries related to your data in Customer Content, you should refer to their privacy Policy and direct any queries to them. The customer's agreement with Ejento AI governs our use of and processing of Customer Content.

By using our website and/or Services, you are authorizing us to gather, share and retain data related to the provision of website and Services in accordance with this Privacy Policy, and (for non-EU residents) you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of Washington and the adjudication of any disputes arising in connection with Ejento AI website and/or Service will be in accordance with our Terms of service or the Enterprise Agreement, as applicable.

THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Personal Information includes any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (i.e., anonymized or aggregated data).

The categories of Personal Information about you that we may collect, use, store, and transfer include the following:

• Usage Data

  Includes information about how you use our application and services. The usage data may include your internet protocol (IP) address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.

• Account Data

  Include information about your name and email address.

• Profile Data

  Includes, if applicable and, in most cases, only when you choose to provide such information to us as part of the Services, your interests; preferences; website browsing history; social media account(s); demographic information, including but not limited to age, gender, race; education level; resume information; professional portfolio link; economic information or employment status; disability or accommodation information; and feedback and survey responses. Profile Data may also include information that you provide to us voluntarily throughout your journey as our student.

• Service Data

  Include information about our application visits, clicks, page views, background information, dietary preferences and feedback.

• Publication Data

  Include information that you post for publication on our application or through our services.

• Inquiry Data

  Include information contained in any enquiry you submit to us regarding products and/or services.

• Customer Relationship Data

  Include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer.

• Transaction Data

  Include information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our application. The transaction data may include your contact details, your card details and the transaction details.

• Notification Data

  Include information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters.

• Correspondence Data

  Include information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. Our application will generate the metadata associated with communications made using the application contact forms.

AGGREGATED & ANONYMIZED, NON-IDENTIFIABLE DATA

We also collect, use, and share aggregated and anonymous data such as statistical or demographic data for various purposes. We may use this type of data to analyze trends with respect to skills, jobs, employment, and the workforce generally; to administer, analyze, and improve the content and functionality of our application and/or services; for marketing; and to gather demographic information about our user base as a whole. We utilize unstructured machine learning technologies to understand user behaviors and to provide user-specific recommendations and other personalization of our application and/or services experience.

Aggregated or anonymized data may be derived from your Personal Information but is not considered to be Personal Information under applicable privacy laws as it does not directly or indirectly reveal your identity. However, if we combine or connect aggregated or anonymized data with your Personal Information in such a way that it can directly or indirectly identify you, we treat the combined data as Personal Information and only use it in accordance with the terms of this Privacy Policy.

We reserve the right to use anonymous or aggregated data for any purpose, including, but not limited to, those set forth above. We may also disclose such anonymously aggregate information to our Enterprise clients, partners or third-party service providers, excluding any Personal Information, except as otherwise provided in this Privacy Policy.

Virginia Consumer Data Protection Act De-Identified Data Disclosure. The Company may use de-identified data in some instances. The Company either maintains such data without attempting to re-identify it or treats such data as personal data subject to applicable law.

FAILURE TO PROVIDE REQUIRED PERSONAL INFORMATION

Where we are required to collect certain Personal Information by law or under the terms of a contract with you or your Employer, and you fail to provide that data when requested, we may not be able to perform under the respective contract and may not be able to provide access to or use of the Services. In the situation where we have already entered into a contract with you, we may be required to cancel the provision of the Services, but we will notify you in advance of such cancellation if this is the case.

HOW EJENTO AI COLLECTS YOUR INFORMATION

Direct Interaction

We collect your Personal Information when you:

1. Create an account on our application or register to use the services;
2. Participate in our application surveys, promotions, and competitions;
3. Post information to our application or services that includes Personal Information, for example, by posting in a chat room or on a blog post;
4. Communicate with us, for example, by submitting queries regarding our application or the services, interacting with our customer support, marketing, or sales teams, or requesting additional information from us, including newsletters or other marketing materials; and
5. Sign up, in person or online, for events or programs run by us or by the third-party organizations with which we partner.

Automated Technologies or Interactions

As you interact with our application and/or services, we also collect technical data such as anonymous usage statistics about your equipment, browsing actions, and patterns. We collect this information by using cookies, server logs, and other similar technology. See below for more information on our use of cookies.

COOKIES, AUTOMATIC DATA COLLECTION, & RELATED TECHNOLOGIES

About cookies

1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

We use cookies for the following purposes:

1. authentication – we use cookies to identify you when you use our website and as you navigate our application;
2. status – we use cookies to help us to determine if you are logged into our application;
3. personalization – we use cookies to store information about your preferences and to personalize the application for you;
4. security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our application and services generally;
5. analysis – we use cookies to help us to analyze the use and performance of our application and services and;
6. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies used by our service providers

1. Our service providers use cookies and those cookies may be stored on your computer when you visit our application.
2. We use Google Analytics to analyze the use of our application. Google Analytics gathers information about application use by means of cookies. The information gathered relating to our application is used to create reports about the use of our website. Google's privacy policy is available at https://policies.google.com/privacy.

PURPOSES FOR WHICH EJENTO AI USES YOUR INFORMATION

We have set forth below the ways in which we may use your Personal Information, along with the legal bases and legitimate business interests on which we rely to do so where appropriate.

Please note that we may process your Personal Information for more than one lawful ground depending on the specific purpose including both automated and manual (human) for which we are using your Personal Information. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made.

Please contact us if you need more information about the specific legal ground on which we are relying to process your Personal Information:

CHANGE OF PURPOSE

We will only use your Personal Information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the new purpose is compatible with the original purpose, please contact us at privacy@ejento.ai. If we need to use your Personal Information for an unrelated purpose, we will notify you and will explain the legal basis which allow us to do this.

NOTICE TO JOB APPLICANTS

When you apply for a job posted on our website, we may collect the PII that you voluntarily submit to us, including, but not limited to: name; personal email address; telephone number; postal address; education; employment history, and any other information included in a resume, cover letter, or personal LinkedIn profile; gender, race, or ethnic origin; veteran status; disability status; and information relating to references. We do not require your details of race or ethnic origin or your disability status, and it will not affect your application in any way if you do not provide such information. Where you do provide such information, we will use that information only as permitted by law for the purposes of diversity and equal opportunity monitoring. The PII that you submit in connection with a job application will be used by Ejento AI in accordance with this Privacy Policy and may be used for the following purposes: to evaluate your capabilities and qualifications for a job; to conduct reference checks; and to clear conflicts of interest and conduct background checks, if applicable and where applicable law allows. If you become an employee or contractor, any PII you submit will become a part of your file and may be used for other employment/work-related purposes. If you are located outside of the United States, please note that the PII that you submit will be transferred to, processed, and stored in the United States (and may also be stored in the relevant jurisdiction(s), as required by applicable law, if the job relates to one of our affiliated entities outside of the United States), and you consent to the transfer, storage, and processing of your information in the United States, if such consent is permitted by applicable law. For more information about the transfer of PII to the United States, please refer to the section of this Privacy Policy entitled "Transfers of Personally Identifiable Information to the United States." To the extent your PII contains details of your race or ethnic origin or physical or mental health or condition, you expressly consent to the collection, storage, and processing of this information for the purposes of your job application.

NOTICE TO EMPLOYEES, CONTRACTORS AND WORKERS

As your employer, Ejento AI is the controller of your PII that is provided, stored, processed or otherwise used by or for Ejento AI, and this means we are responsible for deciding how we hold and use PII about you. We will process PII (which may be held on paper, electronically, or otherwise) about you for the specific and explicit purposes set out in this Privacy Policy. We recognize the need to treat your PII in an appropriate and lawful manner, in accordance with this Privacy Policy and all applicable laws.

The Type of PII We Hold About You

We will collect, store and use some or all of the following categories or PII, some of which may constitute "sensitive" PII under the CPRA, about you:

1. Personal contact details such as name, title, addresses, phone numbers, and personal email addresses
2. Date of birth
3. Gender
4. Marital status and dependents
5. Next of kin and emergency contact information
6. National Insurance number/Social Security number/tax identification number
7. Passport details
8. Bank account details, payroll records and tax status information
9. Salary, annual leave, pension and benefits information
10. Start date
11. Location of employment or workplace
12. Recruitment information (including copies of CV/resume, education/qualifications, right to work documentation, references and other information included in a CV/resume or cover letter or as part of the application process)
13. Employment records (including job titles, work history, working hours, training records and professional memberships)
14. Compensation history
15. Performance/evaluation information
16. Information related to/generated in the course of the performance of your job, including without limitation in your emails, laptop files, and your calendar data relating to sales motions and meeting schedules and connected metadata such as, but not limited to, log files and time stamps
17. Disciplinary and grievance information
18. Footage and other video and audio information obtained through electronic means such as records, and call recordings
19. Information about, and included in, your use of our information and communications systems
20. Photograph(s)

We may also collect, store and use some of the following "special categories" of PII, some of which may constitute "sensitive" PII under the CPRA:

1. Trade union membership
2. Information about your health, including any medical condition, health and sickness records
3. Information about criminal convictions and offences, if a background check is sourced from, and provided by, an authorized background check provider
4. Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions

How We Will Use Information About You

We will only process your PII where the processing is necessary for the performance and efficient administration and management of your employment contract/relationship with Ejento AI and to enable us to meet our legal obligations as an employer, for example to pay you, monitor, evaluate and manage your performance and salary, and to administer and confer benefits in connection with your employment. In other cases, we may process your PII where such processing is necessary for the general conduct, promotion, execution, forecasting, revenue modelling and improvement of Ejento AI's business of marketing/selling, software and Services, for the performance of contracts with our customers, partners and prospects (this may include transfer of information about your education, professional skills, work history and CV/resume), for the protection of your vital interests, for our other legitimate interests as an employer and a provider of technology products and/or services, and to comply with our legal obligations as an employer or the legitimate interests of others. Processing of your PII may be done manually, automatically, or through the use of responsible AI.

Employees should note that, when they choose to participate in online chat and internal community collaboration/blogging tools, then what they post will be visible to any employee (or contractor with access rights) of Ejento AI worldwide. Employees should also note that tools and networks provided by Ejento AI for the performance by employees of their jobs (including but not limited to company-provided laptops and mobile phones, data networks and email servers) may be accessed by appropriate Ejento AI personnel, at all times in compliance with applicable laws. Except as set out in this Privacy Policy, Employees should have no general expectation of privacy. If employees do not accept the public nature of these tools and networks, they must refrain from using them. Employees must never post any type of offensive material.

Period of Storage

We, and any third parties we use, will not keep your PII for longer than necessary for the purposes specified above. The criteria used to determine that period are the duration of your employment relationship, the duration of the provision of the benefits associated with your employment and the duration of Ejento AI's legal, contractual, accounting and reporting obligations that relate to your employment. Data will be destroyed, erased, or pseudo/anonymized from or in our systems when it is no longer required.

HOW TO OPT OUT OF FUTURE COMMUNICATIONS

If you do not want us to contact you with marketing communications or other information regarding our goods and services (or if you agreed to be contacted for such purposes at the point Personal Information was collected by us but you no longer wish to be contacted or have your information used in such way), you can let us know by following the unsubscribe instructions on any communications sent to you. You can also unsubscribe at any time by contacting us at privacy@ejento.ai. Please note that if you have registered an account on our application or services, opting out of receiving marketing messages will not apply to Personal Information provided to us as a result of signing up to use our application or services, and we reserve the right to send you certain communications relating to your account, your registration, and your use of application and services, such as messages relating to account management, customer service, and system maintenance. These transactional account messages will thus be unaffected if you choose to opt out of marketing communications.

NOTICE TO CALIFORNIA USERS

Overview

The California Consumer Privacy Act of 2018 ("CCPA") became effective on January 1, 2020 and created a variety of privacy rights for California consumers. In November 2020, California amended the CCPA, effective January 1, 2023. Additionally, Virginia (effective January 1, 2023), Colorado (effective July 1, 2023), Connecticut (July 1, 2023), and Utah (December 31, 2023) have passed laws extending similar privacy rights to their consumers. We use this notice to make disclosures required by these state laws.

Notice

We do not rent, sell, or share Personal Information about you with third parties who are not our partners, affiliates, or service providers, or third-party suppliers, including for their own direct marketing purposes, unless you have opted in to such a disclosure or were offered the opportunity to opt out of such a disclosure at the time you provided your Personal Information and elected not to opt out, or we are required to do so by law. For more information about how we may share your Personal Information, please refer to the section of this Privacy Policy entitled "How Ejento AI May Share Your Personal Information"

"Do Not Track" Signals

Some web browsers may transmit "do not track" signals to the application and other online services with which the browser communicates. There is currently no standard that governs what, if anything, applications should do when they receive these signals. Therefore, our application, like many others, may not respond to "do not track" signals.

"Do Not Sell" Personal Information

You have the right to know whether your personal information is being sold. Your personal information is "sold" when it is provided with a third party for monetary or other valuable consideration for a purpose that is not a "business purpose" as set forth in the CCPA or other U.S. state data privacy laws. Please note a "sale" does not include when we disclose your personal information at your direction, or when otherwise permitted under law.

Ejento AI does not sell your personal information.

"Non-Discrimination" Statement

The Company will not discriminate against any consumer for exercising their rights under the California Privacy Rights Act.

In addition, California residents are entitled to know that third parties may collect Personal Information about your online activities over time and across different websites when you visit our website. For additional information about this, please refer to the section of this Privacy Policy entitled "Cookies, Automatic Data Collection, and Related Technologies."

For information about your privacy rights, please refer to the section of this Privacy Policy entitled "Your Legal Rights."

HOW EJENTO AI MAY SHARE YOUR PERSONAL INFORMATION

1. We may disclose your personal data to any member of our company insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.
2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3. Financial transactions relating to our application and services may be handled by our payment services provider Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4. We may disclose your Inquiry data to one or more of those selected third party suppliers of goods and services identified in our application for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant products and/or services. Each third party will act as a data controller in relation to the inquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
5. In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. With Your Consent: We may also disclose your information, including your Personal Information, where you have specifically provided your consent for disclosure. You may withdraw consent to disclosures where you have previously given specific consent by emailing us at privacy@ejento.ai.

SECURITY OF YOUR INFORMATION

We have implemented appropriate physical, technical, and administrative measures designed to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure. In addition, we limit access to your Personal Information to only those employees, agents, contractors, and other third parties who need to have access to such information for the operation of our business, including the operation of our application and services. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our application or the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of application or services like message boards. The information you share in public areas may be viewed by any user of the application or the services. Unfortunately, no electronic data transmission or storage of information can be guaranteed to be completely secure or error-free. We cannot warrant or guarantee the security of any Personal Information transmitted to our application or services. Any transmission of Personal Information is at your own risk.

CHILDREN'S PRIVACY

Our application and services are not intended for nor are they directed toward children under the age of 16, and we do not knowingly collect personal information from children under 16 years of age. If you believe that your child under the age of 16 may have provided us with Personal Information without your consent, you may alert us at privacy@ejento.ai. If we learn that we have inadvertently collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child's account.

EXTERNAL LINKS

The application or services may, from time to time, contain links to external websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We have no control over these third parties, and we are not responsible for the content of such websites or the privacy policies or practices of such third parties. You should carefully review the privacy policy of any such third-party website that you visit.

TRANSFERS OF PERSONAL INFORMATION TO THE UNITED STATES

The application and services are operated in the United States. If you are located outside of the United States, please be aware that the information we collect about you, including Personal Information, will be transferred to and processed and stored in the United States. For purposes of the Data Protection Act 1998, the General Data Protection Regulation 2016/679 (the GDPR) and any corresponding or equivalent national implementing law or regulations, if you are located in the United Kingdom, Ejento AI is the data controller with respect to any information collected by it in the United Kingdom and then transferred Ejento AI in the United States. All transfers of Personal Information from the European Economic Area, the United Kingdom, or Switzerland to the United States are done pursuant to the European Commission's standard contractual clauses or, when possible, the binding corporate rules of our third-party vendors, suppliers, or service providers, if applicable. Our company has offices and facilities in United States, Canada, Pakistan, India and Singapore. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. You have a legal right to request the Personal Information about you held by us. On request, we will provide you with a copy of this information. You also have a right to correct, amend, or delete such personal information where it is inaccurate or has been processed in violation of the Privacy Shield Principles. Please see elsewhere in this Privacy Policy for more information on types of Personal Information collected, purposes for data collection, types of third parties receiving Personal Information, and purposes of disclosure to such parties and your legal rights.

DATA RETENTION

We will only keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of your Personal Information; the purposes for which we process your Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements.

Details of retention periods for different aspects of your Personal Information are available on request by emailing us at privacy@ejento.ai.

YOUR LEGAL RIGHTS

Under the General Data Protection Regulation 2016/679 (the GDPR) and the California Consumer Protection Act (CCPA), data subjects located in the EU, UK, and California have the right under certain circumstances:

1. To be provided with a copy of your Personal Information held by us.
2. To request that we correct any of your Personal Information held by us.
3. To request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example).
4. To object to any further processing of your Personal Information, including the right to object to marketing.
5. To request that the Personal Information you have provided be transferred to a third party.
6. To withdraw consent, without detriment, where the basis of the processing of your Personal Information is based on consent.
7. To request that we delete any of your Personal Information held by us unless a legal exception applies.

To exercise your rights, please submit your verifiable request at privacy@ejento.ai. California residents may also exercise their privacy rights by writing email to us at privacy@ejento.ai.

You will not have to pay a fee to access your Personal Information (or exercise any other rights). We may, however, charge a fee if we believe your request is excessive, unfounded, or repetitive. Alternatively, we may refuse to comply with your request in these circumstances.

In response to any of the requests outlined above, we may need to request specific information from you to enable us to confirm your identity and to ensure you have the right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that your Personal Information is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request in order to speed up our response time.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If your request or concern is not satisfactorily resolved by us, and you are located in the EU or UK, you may approach your local data protection authority (see https://ec.europa.eu/info/law/law-topic/data-protection_en.html) who can provide further information about your rights and our obligations in relation to your Personal Information, as well as deal with any complaints that you have about our processing of your Personal Information.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed if your Personal Information changes during your relationship with us. You can update, correct, or delete any information you have provided to us through your use of the Site or Services by sending an email to privacy@ejento.ai.

If you have questions about unsubscribing from email or other communications, you may send an email to privacy@ejento.ai.

CHANGES TO OUR PRIVACY POLICY & PRACTICES

From time to time, we may revise or update our Privacy Policy. We will notify you of any changes by posting updates to the Privacy Policy on this web page. The date the Privacy Policy was last revised is identified at the top of the page.

REGULATORY COMPLIANCE AND UPDATES

We are committed to maintaining compliance with applicable global and local data protection laws. This Privacy Policy is designed to align with the requirements of:

1. The EU General Data Protection Regulation (GDPR) and UK GDPR;
2. US state privacy laws, including the California Consumer Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Utah Consumer Privacy Act (UCPA), and Connecticut Data Privacy Act (CTDPA);
3. The Swiss Federal Act on Data Protection (FADP); and
4. Other emerging privacy regulations in jurisdictions where we operate.

Where we transfer personal data across borders, we use legally recognized mechanisms such as the European Commission's Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA), or other appropriate safeguards.

As privacy laws evolve, we will update this Privacy Policy to reflect changes in regulatory obligations and industry best practices. Any material changes will be communicated through our website or, where legally required, via direct notice.

CONTACT INFORMATION

If you have any further questions about this Privacy Policy or Ejento AI's privacy practices, please contact us at the information below:

Physical address: 2331 130th Ave NE, Suite 110 Bellevue, WA 9800.

Email address for contact: privacy@ejento.ai.

Phone number for contact: +1 (877) 360-3442.