This document (“Information Notice” or “Privacy Policy“) has been written, pursuant to Article 13 and 14 of EU Regulation 2016/679 (“Regulation”), in order to allow you to understand how your personal data, as more fully defined below, will be processed in the context of your use of the Sites and to learn about our Privacy Policy. The purpose of the Privacy Policy is toprovide you with the information necessary to give your explicit and informed consent to the processing carried out throughthe Sites www.expert.ai, https://community.expert.ai/, http://developer.expert.ai/ and https://try.expert.ai/ (hereinafter collectively referred to as the “Sites“), if you deem it appropriate.

The information or data you may provide, or which may otherwise be collected through the Sites, in the context of your use of expert.ai’s services, such as the registration to the Natural Language API developer platform provided on the websitehttp://developer.expert.ai/ (“Natural Language API”) or to expert.ai’s community, the use of the NL Platform (“Platform”)or the use of our analysis & classification tool provided on the website https://try.expert.ai/, the request to have further information on our products and services, etc. (hereinafter, the “Services”) as defined in the “Purposes of processing” Section, will be used by expert.ai in compliance with the principles of lawfulness, fairness, transparency, purpose limitation, storage limitation, data minimization, accuracy, integrity and confidentiality.

Index

• Data Controller
• Data Protection Officer
• Personal Data processed:
  a. Name, contact details and other Personal Data
  b. Job applications. Special Categories of Personal Data
  c. Third party Personal Data provided voluntarily by the user
  d. Publicly available online data
  e. Browsing data
• Cookies
• Purpose of the processing
• Legal basis, data controllership and mandatory or discretionary nature of the processing
• Recipients of Personal Data
• Transfers of Personal Data
• Data Retention
• Data subjects’ rights
• Amendments
• Additional information regarding local processing, where applicable, and privacy law
• License

1. Data Controller

Unless otherwise specified in relation to the individual processing purposes mentioned in this Privacy Policy, for the purposes of this Privacy Policy Relevant Company of the expert.ai Group means:
Expert System Enterprise Corp., with registered office in 6110 Executive Boulevard, Suite 690, Rockville (U.S.A.), MD 20852.
Expert System Iberia S.l.u., with registered office in Calle Poeta Joan Margall, 3-5, escalera izquierda, planta 1ª, derecha, 28020, Madrid, Espana.
Expert System France S.a., with registered office in 15 – 17, rue Traversiere, 75012 Paris, France.
Expert System Deutschland Gmbh., with registered office in Weinbergsweg 3c, 61348 Bad Homburg v. d. Höhe.

Expert System Cogito Ltd., with registered office in Unit 203, Second Floor China House 401 Edgware Road, NW2 6GY, London – United Kingdom.
Expert System Canada – Semantic T. Inc., with registered office in 900-2001 av.McGill College Montréal (Québec) H3A1G1 – Canada.

2. Data Protection Officer

It is possible to contact the expert.ai Group Data Protection Officer (“DPO”) by writing to: [email protected].

3. Personal Data processed

As you use the Sites and/or the Services, we inform you that the Company and/or the expert.ai Group’s Relevant Company may collect and process information related to you, which may consist – also depending on your decisions on how to use theServices – of an identifier such as a name, an identification number, an online identifier (hereinafter referred to as “Personal Data“). Your Personal Data may be collected either because you voluntarily provided it (for example, when filling out an online form or when you decide to register to the Natural Language API or to expert.ai’s community and set your profile) or simply by analyzing your behavior on the Sites.

Please note that payments for the services provided by the Natural Language API are made through a third-party platform(depending on the country in which you are located, e.g. PayPal or others), which operates as an independent data controller anddoes not allow expert.ai to access your payment information, such as credit card number or other data that you must provide tocomplete the purchase. Expert.ai will, however, use your billing information, which will be requested at the time of purchase, forany relevant tax and accounting obligations and to send you the invoice relative to your purchase.

Personal Data which may be processed through the Sites are as follows:

a. Name, contact details and other Personal Data

In some sections of the Sites (e.g. Contact Us, Resources, Newsletter, online training programs, community’s profile settings, Natural Language API registration form, event registration form, etc.), you may be asked to enter information such as your name, surname, telephone number, email address, job title, company you work for, etc.

b. Job applications. Special Categories of Personal Data

By sending your application and your CV from the “Careers” section on www.expert.ai, you authorize the Company and/or the expert.ai Group’s Relevant Company to process your Personal Data. We kindly ask you not to disclose Personal Data which may fall under the category of Personal Data referred to in Article 9 of the Regulation – i.e. “[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”, unless you consider this to be strictly necessary, and to provide your consent if you decide to share them by authorization to be included in the CV. The processing of such Personal Data may be permitted as it is based on your consent according to the applicable rules on personal data protection. We kindly ask you not to disclose any such types of Personal Data unless you consider this to be strictly necessary. In any case, expert.ai would stress the importance of providing your explicit consent to process the Special Categories of Personal Data, if you decide to share it, nonetheless.opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”, unless you consider this to be strictly necessary, and to provide your consent if you decide to share them by authorization to be included in the CV. The processing of such Personal Data may be permitted as it is based on your consent according to the applicable rules on personal data protection. We kindly ask you not to disclose any such types of Personal Data unless you consider this to be strictly necessary. In any case, expert.ai would stress the importance of providing your explicit consent to process the Special Categories of Personal Data, if you decide to share it, nonetheless.

c. Third party Personal Data provided voluntarily by the user.

As mentioned above, in some parts of the Sites (such as the “Contact Us” section on www.expert.ai, the comment boxes under the topics created by expert.ai’s community members, or when you add a text or type in a web URL in the analysis & classification tool), you may insert text messages or information which may contain third party Personal Data.

In any situation where you decide to share Personal Data related to other persons through the Sites, you will be considered as an independent data controller regarding that Personal Data and will have to assume all inherent legal obligations and responsibilities. To this end, you must fully indemnify expert.ai against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, initiated by the third parties whose Personal Data have been processed through the use of the Sites in violation of the applicable rules on personal data protection. In any case, if you provide or in other way process Personal Data of third parties in using the Sites, you henceforth guarantee – assuming all related responsibilities – that this specific processing is grounded on an appropriate legal basis which legitimizes the processing of the information in question.

d. Publicly available online data

As part of the presentation and promotion activities (“Demo”) of its semantic analysis platform, the Company may also process documents and information publicly available online that may contain Personal Data (e.g. in newspaper articles, magazines, etc.). Such processing is based on the legitimate interest of the Company to demonstrate the correct functioning and capabilities of the Demo(s) and is carried out for the time strictly necessary to achieve the aforementioned purpose. For further information you can write to: [email protected].

e. Browsing Data

The computer systems and software procedures used to operate the Sites acquire, in the course of their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. While expert.ai does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information is also considered Personal Data. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Websites, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. Data could be used to ascertain liability in case of hypothetical computer crimes against the Sites, the Platform or third parties: except for this eventuality, at present, data on web contacts do not persist for more than seven days.

4. Cookies

Information regarding the use of cookies can be found in the Cookie Policy available:

• here for the website www.expert.ai,

5. Purpose of the processing

The Company (and/or, where relevant, the expert.ai Group’s Relevant Company) intends to use your Personal Data, collected through the Sites, for the following purposes.

To provide Services you request, such as the download of the materials shared on the Sites (e.g. in the “Resources” section on www.expert.ai), requiring a Demo, subscribing to events, to online training programs and/or expert.ai’s community, providing you access to the Natural Language API you request, using the Platform or our analysis & classification tool, responding to a request sent to addresses you may find on the Sites (“Provision of the Service“).

To analyze the CV and to contact the candidates who submit their applications through the addresses you may find in the “Careers” section on www.expert.ai (“Recruitment“).

To carry out marketing activities, such as to conduct surveys, studies, research, market statistics and send you newsletter, advertising and information material via e-mail, telephone and/or through the official pages of expert.ai on social media related to the activities, the products and the services of expert.ai (“Marketing“). You can, at any time, object to the processing or withdraw your consent that you have previously granted to traditional or automated methods by giving notice to the Company and/or the expert.ai Group’s Relevant Company without any formality by writing to the addresses indicated in the “Data Subjects’ Rights” Section of this Privacy Policy, without prejudicing the lawfulness of the processing founded on your previous consent.

To carry out direct marketing activities via e-mail for services similar to those you have subscribed to through the Sites, unless you objected to such processing initially or in subsequent communications (“Soft Opt- In”).

To analyze your preferences, habits, interests, and consumption choices expressed through the use of the Websites and the services offered, and,
where appropriate, by using non-essential cookies, in order to send you commercial communications and personalized promotions on the services offered by expert.ai (“Personalization”).

To fulfil the legal obligations which required the Company and/or the expert.ai Group’s Relevant Company to collect and/or further process certain types of Personal Data (“Compliance“).

To prevent or identify any fraudulent conduct by using the Websites in order to allow the Company and/or the expert.ai Group’s Relevant Company for legal defense (“Abuse/Fraud”).

To verify information relevant to the use of the Platform in order to ensure the security of the services we provide (“Security”).

To carry out statistical analysis without the possibility of identifying the user (“Statistics”).

To disclose, where a subscription to the expert.ai online training programs occurs, Personal Data (name, surname, company role, and – if applicable – LinkedIn account) of the contractual representative or another contact point of the partners of expert.ai on expert.ai social media accounts, in order to promote the certification obtained (“Disclosure”).

In case you intend to participate in events or activities organized by expert.ai and its business partners, to communicate or share your Personal Data with these partners for their independent promotional purposes “Communication to Third Parties”). Details about the business partners
to whom expert.ai may disclose your data will be available during event registration.

6. Legal basis data controllership and mandatory/discretionary nature of the processing

The legal bases the Company (and/or, where relevant, the expert.ai Group’s Relevant Company) rely on for the processing of Personal Data for the purposes referred to in aforementioned Section Purposes of the processing, are as follows:

Provision of the Service: the processing for this purpose is carried out by the Company in its capacity as autonomous data controller. Such processing is necessary to provide the Service and for the performance of the contract. The provision of your Personal Data for this purpose is optional, however, failure to provide them would imply the inability to initiate the requested Services provided through the Sites or to respond to requests.

Recruitment: the processing for this purpose is necessary for the Company (or, where appropriate, the expert.ai Group’s Relevant Company) to be able to consider your application and, therefore, it is necessary in order to start the selection process. The provision of your Personal Data is optional, but any failure to provide it would make it impossible to evaluate your profile. If you decide to provide special categories of Personal Data (e.g. data concerning health, religious beliefs, etc.), the Company (or, where appropriate, the expert.ai Group’s Relevant Company) may require your specific consent which, in this case, may be inserted at the bottom of your application. In this regard, we would like to remind you not to provide such type of information unless strictly necessary and that in the absence of your consent to the processing of special categories of Personal Data related to you, if you provide such type of data, your application cannot be taken into consideration.

Marketing: the processing for this purpose is carried out by Expert.ai S.p.A. jointly with Expert System Enterprise Corp. and the expert.ai Group’s Relevant Company involved from time to time (in relation to the geographical area of reference, as described below in this Privacy Policy) as joint controllers “Joint Controllers”). Such processing is based on your consent or, if applicable, on legitimate interest. It is not mandatory for you to give your consent to the Joint Controllers for this purpose and you can withdraw your consent at any time without any consequences (except for the fact that you will no longer receive marketing communications from the Data Controller). You may withdraw your previously granted consent or object every time to the processing by following the instructions provided in the “Data Subjects’ Rights” Section of this Privacy Policy.

Soft Opt-In: the processing for this purpose is carried out by the Company in its capacity as autonomous data controller. Such processing is based on the interest of the Company to send marketing communications by email regarding products and services similar to those requested through the Sites. You may interrupt the receipt of these communications, without any consequence for you (with the exception of the failure to receive such further communications from the Company) using the link at the bottom of each of these emails.

Personalization: the processing for this purpose is carried out by Expert.ai S.p.A. jointly with Expert System Enterprise Corp. and the expert.ai Group’s Relevant Company involved from time to time (in relation to the geographical area of reference) as Joint Controllers. Such processing is based on your consent. It is not mandatory to give your consent to the Joint Controllers for this purpose and you may withdraw it at any time without any consequences (except the impossibility to benefit from the personalization of the commercial offers that will be received by the Joint Controllers). You may withdraw your previously granted consent by following the instructions provided in the “Data Subjects’ Rights” Section of this Privacy Policy.

For Marketing and Personalization purposes, where applicable in relation to the geographical area of reference, the Relevant Company acting as Joint Controller is: Expert System Iberia S.l.u. (for Spain), Expert System France S.a. (for France), Expert System Deutschland Gmbh (for Germany), Expert System Cogito Ltd. (for the United Kingdom), Expert System Canada–- Semantic T. Inc. (for Canada).

• Compliance: the processing for this purpose is carried out by the Company (or, where appropriate, the expert.ai Group’s Relevant Company) in its capacity as autonomous data controller and is necessary in order to fulfil any legal obligations. When you provide Personal Data, they must indeed be processed according to the applicable regulations, which could entail their retention and disclosure to the Authorities for accounting, tax, or other obligations.
• Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activity or abuse in the use of the Sites and therefore allow the Company or the expert.ai Group’s Relevant Company, in its capacity as autonomous data controller, to defend in court.
• Security: the processing for this purpose is carried out by the Company in its capacity as autonomous data controller and it is based on the legitimate interest of the Company.
• Statistics: it is specified that such processing is not performed on Personal Data and therefore can be freely carried out by expert.ai.
• Disclosure: processing for this purpose is carried out by the Company in its capacity as autonomous data controller. Such processing is based on your consent. It is not mandatory to give your consent to the Company for this purpose and you may withdraw it at any time without any consequences (except from the impossibility – after the subscription to the expert.ai online training programs– to disclose your Personal Data on expert.ai’s social media accounts in order to promote the certification you obtained). You may withdraw your previously granted consent by following the instructions provided in the “Data Subjects’ Rights” Section of this Privacy Policy.
• Communication to third parties:: processing for this purpose is carried out by the Company as an autonomous data controller. This processing is based on your consent. It is not mandatory to give your consent to the Company for this purpose and you are free to withdraw it at any time without any consequence (except the impossibility of communicating your Personal Data to expert.ai’s business partners). You may withdraw your previously granted consent by following the instructions provided in the “Data Subjects’ Rights” Section of this Privacy Policy.

7. Recipients of Personal Data

Your Personal Data may be shared with the subjects mentioned below (collectively “Recipients”):

• subjects typically acting as data processors, namely: persons, companies or professional firms providing the Company (or, where appropriate, the expert.ai Group’s Relevant Company) with advice and consulting in accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
• subjects to engage with in order to provide the Services (for instance hosting providers or email platform providers);
• persons authorized to perform technical maintenance (including maintenance of network equipment and electronic communications networks);

• persons authorized by the Company (or, where appropriate, the expert.ai Group’s Relevant Company) to process the Personal Data required for carrying out activities strictly related to the provision of the Services, who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality, for example the Company and/or expert.ai Group’s Relevant Company employees;
• business partners of expert.ai in case of events organized by the Data Controller in which you intend to participate (or have already participated);
• public entities, bodies, or authorities to disclose your Personal Data to in accordance with Compliance, Abuse/Fraud purposes or under the orders of the authorities.

8. Transfers of Personal Data

Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. Expert.ai ensures that your Personal Data are processed by these Recipients in accordance with the applicable rules on data protection. Indeed, transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. Further information is available from expert.ai by writing to the following email address: [email protected].

9. Data Retention

Personal Data processed for Provision of the Service purposes will be kept by the Company for the period deemed strictly necessary to fulfil such purposes. In any case, as these Personal Data are processed for the provision of the Services, the Company will retain them for a longer period of time, particularly as may be necessary under applicable law to protect the Company’s interests against possible claims relating to the Services.

Personal Data processed for Recruitment purposes will be kept by the Company and/or expert.ai Group’s Relevant Company for 24 months and they may be used to contact you for any future job opportunities at expert.ai.

Personal Data processed for Marketing and Personalization purposes will be kept by the Joint Controllers until you withdraw your consent or until you object to the processing (where applicable). Once the consent has been withdrawn, the Joint Controllers will no longer use your Personal Data for such purposes, but they may retain them in any case, in particular if it may be deemed necessary in order to protect the interests of the Joint Controllers from potential complaints based on such processing.

Similarly, Personal Data processed for the purposes of Disclosure and Communication to Third Parties will be retained bythe Company until you withdraw your consent or until you object to the processing (where applicable). Once the consent has been withdrawn, the Company will no longer use your Personal Data for such purposes, but may still retain it, in particular if it may be deemed necessary in order to protect the interests of the Joint Controllers from potential complaints based on such processing.

Personal Data processed for Soft Opt-in purposes will be kept by the Company until you object to the processing for such purpose.

Personal Data processed for the Compliance purpose will be retained by the Company or by expert.ai Group’s Relevant Company for the period provided for by specific legal obligations or applicable law.

Personal Data processed to prevent Abuse/Fraud and for the Security purpose will be retained by the Company (or, if appropriate, by expert.ai Group’s Relevant Company) for the time deemed strictly necessary for the aforementioned purposes, and thus until it is bound to keep them so as to protect himself in court to communicate such data to the competent Authorities.

Further information about the data retention period and the criteria used to determine this period can be asked by writing to the Data Controller at the e-mail addresses provided in the Data subjects’ rights in Section of this Privacy Policy.

10. Data subjects’ rights

Under Article 15 et seq. of the Regulation, you, as a data subject, are entitled to request at any time, to the Company or, where appropriate, to the expert.ai Group’s Relevant Company, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing, pursuant to Article 21 of the Regulation. You are also entitled to request the restriction of the processing of your Personal Data in the cases set out in Article 18 of the Regulation, as well as to obtain the Personal Data you have provided in a structured, commonly used and machine-readable format, in the cases set out in Article 20 of the Regulation. You may interrupt the reception of Soft Opt-in, by using the appropriate link you may find at the bottom of each e-mail you receive.

Requests should be made in writing to: [email protected] or to the work address of the Company (or the expert.ai Group’s Relevant Company) listed above.

11. Amendments

This Privacy Policy entered into force on 05/07/2024. The Company reserves the right to amend this Privacy Policy partly or fully, or simply to update its content, e.g., as a result of changes in applicable law. The Company will inform you of such changes as soon as they are introduced.

12. Additional information regarding local processing, where applicable, and privacy law

This Privacy Policy has been drafted in compliance with the European Union and Italian data protection legislation, as expert.aiGroup has its registered office in Italy. For further information with specific regard to the processing of Personal Data by expert.ai in compliance with the data protection laws applicable in your Country, please write to: [email protected].

13. License