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PRIVACY POLICY of Ampwise Estonia OÜ In force since: 1 June 2025 Last updated: 30 July 2025 This Privacy Policy describes the principles on how Ampwise may process your Personal Data when you are using our Platform available at https://app.ampwise.ai/ The principles for processing other data than Personal Data submitted by the Customer to the Platform is described in the Data Processing Principles. This Privacy Policy is integrated into and subject to the General Terms. If you have questions about how we process your Personal Data or if you wish to submit us requests for exercising your rights involved in processing of your Personal Data, please contact us using the contact details provided in this Privacy Policy. The Platform may not be used if you do not agree to these General Terms and the Privacy Policy, as may be amended from time to time. DEFINITIONS Ampwise or we - Ampwise Estonia OÜ, a private limited company registered under the laws of the Republic of Estonia, registry code 16735784, legal address Pärnu mnt 160j, Tallinn 11317, Estonia. Applicable Law - all valid European Union legal acts and all valid legal acts of the Republic of Estonia, including, but not limited to, the national implementation acts for GDPR which are applicable during the validity of these terms and conditions or shall be applicable after the terms and conditions enter into force Customer - any legal person who uses the Platform (through its Users) under a respective agreement with Ampwise. Data Controller - a natural or legal person, public sector authority, agency or other body who, alone or jointly with others, determines the purposes and means of the personal data processing. For the purposes of these terms, the data controller is Ampwise. Data Processor - a natural or legal person, public sector authority, agency or other body who processes the personal data on behalf of the Data Controller. Data Subject - natural person whose personal data is processed by Ampwise. In the context of this Privacy Policy, “Data Subject”, “User’” and “You” refer the same. GDPR - the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). General Terms - the general terms and conditions for using the Platform, which are available at www.ampwise.ai Personal Data - 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. Platform - the platform managed by Ampwise, which is available at https://app.ampwise.ai/. Privacy Policy -this document outlining the principles under which Ampwise processes Personal Data. User - any natural person who uses the Platform on behalf of the Customer. In the context of this Privacy Policy, “Data Subject”, “User” and “You” refer the same. WHY WE PROCESS PERSONAL DATA AND WHAT PERSONAL DATA DO WE PROCESS? When the Customer has opted to use our Platform, we need to process your Personal Data to enable Customers (through their Users) to use the Platform and the services provided by Ampwise on the Platform. Ampwise as the Data Controller processes Personal Data for the purposes set out in this Privacy Policy. Ampwise processes Personal Data based on the Applicable Law, including the Personal Data Protection Act and other legal acts that address personal data processing. Ampwise processes Personal Data based on the principles of personal data protection set out in the GDPR, including the principle of minimum interference, according to which we process only the data that are required for managing the Platform and achieving our purposes. Upon the use of our Platform, we process Personal Data that is submitted to us directly by the Customers or Users in the course of using our Platform. Such data includes the following data: general personal information and contact details: name (first and last name), e-mail address, phone number; account related details: login details and information (such as password) used for creating an account on the Platform; technical information: technical information collected in the course of your use of the Platform, for example the operating system of your device and other data collected via cookies (please see the section “Cookies”below). WHAT IS THE LEGAL BASIS FOR PROCESSING PERSONAL DATA? Data processing for contract performance. Ampwise processes personal data primarily for the purposes of performing contractual obligations that arise from the General Terms and the agreement concluded with the Customer thereunder. The legal basis for personal data processing in this case is article 6(1)(b) of the GDPR (processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract). Data processing for the performance of a legal obligation. Ampwise processes Personal Data also where it is required to perform legal obligations applicable to Ampwise. For example, if a court requests Personal Data from Ampwise under an applicable court order or court judgement or if a law enforcement agency requests Personal Data under an applicable regulation. Also, if Ampwise is obligated to retain Personal Data, for example, under the Accounting Act or other applicable legal acts. In case of such processing, the legal basis for Personal Data processing is article 6(1)(c)of the GDPR (processing is necessary for compliance with a legal obligation to which the Data Controller is subject). Data processing on the basis of legitimate interest. Ampwise may process your personal data also when it is necessary for Ampwise’s legitimate interest in certain cases. In such case, the legal basis for Personal Data processing is article 6(1)(f) of the GDPR. Ampwise shall process Personal Data on the basis of legitimate interest only in case such processing is not outweighed by the basic rights and freedoms of the Data Subject for which the Personal Data must be protected. Only data that has been received from the Data Subject or created during the performance of the agreement under the General Terms is processed on the basis of legitimate interest. Ampwise may have legitimate interest in the processing of Personal Data if this is necessary to prepare, submit or defend legal claims. For example, such need may arise in a situation where the Data Subject has violated the General Terms, primarily failed to pay the monthly fee for using the Platform. Ampwise may also have legitimate interest in processing Personal Data if this is necessary to ensure the technical functionality of the Platform (please see the section “Cookies” below). The data processed on the basis of legitimate interest shall be retained in compliance with the general statutory limitation period for claims (generally 3 years). More details on the retention period can be found in the section “Overview of processed personal data”. OVERVIEW OF PROCESSED PERSONAL DATA Purpose Collected Personal Data Legal basis Retention period Providing the Platform to Customers Contact details: name, e-mail address, telephone number. GDPR article 6 (1) (b), after the termination of the contract GDPR article 6 (1) (f) During the term of the agreement with the Customer, plus 3 years from termination based on our legitimate interest until the end of the limitation period (§ 146 (1) of An Act on the General Part of the Civil Code) Registration of User accounts Account related details: login details and password selected for the account GDPR article 6 (1) (b), after the termination of the contract GDPR article 6 (1) (f) During the term of the agreement with the Customer, plus 3 years from termination based on our legitimate interest until the end of the limitation period (§ 146 (1) of An Act on the General Part of the Civil Code) Answering the inquiries of the Data Subject Name, e-mail and other Personal Data that is submitted to us directly by you via Platform or via any other channel (for example, by sending an e-mail) GDPR article 6 (1) (f) Until the end of the limitation period of the claim related to which the inquiry is submitted. Generally, the limitation period is 3 years (§ 146 (1) of An Act on the General Part of the Civil Code) Accounting documents Documents required for the performance of a legal obligation GDPR article 6 (1) (c) 7 years under the Accounting Act (§ 12 (4) of the Accounting Act) Data collected with cookies Please see under section “Cookies” TRANSFER OF PERSONAL DATA AND USE OF DATA PROCESSORS Ampwise may transfer Personal Data outside the EEA (e.g., to OpenAI), however such transfer is strictly made to the minimum extent necessary for providing services on the Platform, and only in accordance with Standard Contractual Clauses (SCCs) and Data Processing Agreements (DPAs) in place between Ampwise and the recipient. Ampwise may use Data Processors for Personal Data processing. Data Processors assigned by Ampwise, who in limited circumstances may process the Personal Data, are, for example, IT-service providers (cloud infrastructure, AI processing providers, IT software developers) or other providers of services required for the functioning of the Platform. Ampwise only uses Data Processors to the minimum extent necessary to provide the contractual services on the Platform to the Customer. Ampwise uses as Data Processors only such partners whose reliability Ampwise has verified and who have committed to processing Personal Data in compliance with the Applicable Law. A list of such trusted Data Processors is available in the Data Processor Register. Ampwise does not sell or share data for advertising or unrelated purposes. COOKIES Our Platform uses cookies. Cookies are small text files containing information stored on the computer and used for tracking or identification. The Platform uses the following cookies: Strictly necessary cookies, that are essential in order to enable you to navigate and use the features of the Platform. They do not collect information that identifies a visitor. Performance cookies, that collect information about how visitors use the Platform and help us improve site performance. They do not collect information that identifies a visitor. Functional cookies, that help the Platform record visitor preferences and allow for personalized content. These cookies cannot track browsing activity on other websites. The specific cookies that Platform uses are the following: Cookie Domain Description Validity Type AUTH_SESSION_ID .ampwise.ai KEYCLOAK_IDENTITY .ampwise.ai KEYCLOAK_SESSION .ampwise.ai The Platform only uses essential cookies that are strictly necessary for authentication and session management. These cookies are stored locally in your browser and are required to enable secure login functionality and maintain user sessions. We do not use tracking, analytics, marketing, or third-party cookies. You have the right to delete or block (disable) cookies at any time by changing your browser settings. However, some cookies might be necessary for the functionality of Platform. Cookies can be disabled by following the instructions under the browser’s “help” section. More information on how cookies operate or how to disable cookies is also available on the website www.allaboutcookies.org. RIGHTS OF THE DATA SUBJECT Ampwise shall ensure all the rights of the Data Subject arising from the Applicable Law. In particular, the Data Subject shall inter alia have the following rights: right to access: the right to ask at any time whether Ampwise holds any personal data about them or not and receive information about which Personal Data Ampwise is processing about them; right to rectification: the right to request from Ampwise the supplementation or rectification of their personal data if these are insufficient, incomplete or inaccurate; right to object: the right to submit objections to Ampwise concerning the processing of one’s Personal Data, for example if the personal data is processed on the basis of the legitimate interests of Ampwise; right to erasure: the right to request the erasure of Personal Data, for example, if the Personal Data are processed based on the Data Subject’s consent and the Data Subject has withdrawn their consent; right to restriction of processing: the right to request from Ampwise the restriction of processing of Personal Data under the Applicable Law, for example, where Ampwise no longer needs the Personal Data for the purposes of the processing or where the Data Subject has objected to processing; right to withdraw the consent for processing Personal Data: if the processing of Personal Data is based on the Data Subject’s consent, the Data Subject has the right to withdraw the consent given to Ampwise at any time; right to data portability: the right to receive from Ampwise the Personal Data that the Data Subject has provided to and which are processed on the basis of the Data Subject’s consent or for the performance of a contract concluded with the Data Subject, in writing or in a generally used electronic format and, if technically possible, request that Ampwise transfers these data to another Data Controller; right to lodge a complaint: If the Data Subject is of the opinion that the processing of their Personal Data has violated their rights, they have the right at any time to file this claim to the Data Protection Inspectorate / Tatari 39, 10134 Tallinn, info@aki.ee, www.aki.ee. List of national Data Protection Authorities in EU is available at https://edpb.europa.eu/about-edpb/board/members_en. The rights of the Data Subject listed in this section regarding the processing of their Personal Data are not absolute rights. In certain cases, the rights of other Data Subjects or the legal obligations of Ampwise may limit the rights of the data subject. In order to exercise the rights pertaining to the processing of Personal Data or to submit requests concerning the processing of personal data, please contact us using the contact details provided in the section “Miscellaneous” below. SECURITY OF PERSONAL DATA Ampwise shall ensure the security of Personal Data processing, for the purposes of protecting Personal Data from accidental or unauthorised processing, disclosure or destruction. Considering the state of the art and costs of implementation, and the nature, scope, context and purposes of the personal data processing as well as the risk to the rights and freedoms of data subjects, of varying likelihood and severity, that may result from personal data processing, Ampwise shall apply appropriate technical and organisational measures upon personal data processing to ensure the protection of personal data. MISCELLANEOUS Upon changes in legal acts or practice, Ampwise has the right to make amendments to the Privacy Policy which shall be immediately published on the Platform. This Privacy Policy is governed by the laws indicated in the General Terms and is subject to the same jurisdiction clause as set out in the General Terms. In case of questions concerning the processing of Personal Data or to submit requests concerning the processing of Personal Data, please contact us at: In case of any questions regarding the General Terms, Privacy Policy or the Platform, please contact us at: Ampwise Estonia OÜ Registry code: 16735784 Legal address: Pärnu mnt 160j, Tallinn 11317, Estonia Email: sales@ampwise.ai