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Privacy Policy 1. Introduction This Privacy Policy explains how Peaky collects, uses, processes, and protects your personal information when you visit our website and join our waitlist. We are committed to protecting your privacy and handling your data in an open and transparent manner in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. 2. Data Controller Information Name: Peaky BV Address: Kouter 7B/202, 9000 Gent Data Protection Officer: [email protected] As the Data Controller, we determine the purposes and means of processing your personal data. We are responsible for ensuring that your personal data is handled in compliance with the GDPR and other applicable data protection laws. 3. Information We Collect 3.1 Waitlist Registration Data When you sign up for our waitlist, we collect information in a multi-step process: 1. Basic information Email address Consent to terms and conditions 2. Professional details Full name Company name Department information Other department details (if applicable) Whether you're interested in-house technical support 3. Business tools Accounting tool HR tool CRM tool BI & Analytics tool 4. Business struggles Information about specific business challenges and pain points you're experiencing 3.2 Contact Form Data When you reach out to us through our contact form, we collect: Email address Subject of inquiry Detailed message content 3.3 Automatically Collected Information We may automatically collect certain information when you visit our website, including: IP address Browser type and version Operating system Device information Cookie data Usage data 4. Legal Basis for Processing Under the GDPR, we process your personal data based on the following legal grounds: Consent: When you explicitly agree to the processing of your personal data for specific purposes, such as joining our waitlist Legitimate Interests: When processing is necessary for our legitimate interests in understanding market needs and developing our product, except where such interests are overridden by your interests or fundamental rights Legal Obligation: When processing is necessary for compliance with a legal obligation 5. How We Use Your Information We use the collected information for the following purposes: To manage our waitlist (Legal basis: Consent) To understand market needs and user requirements (Legal basis: Legitimate Interests) To conduct market research and analysis (Legal basis: Legitimate Interests) To communicate with you about your waitlist status (Legal basis: Consent) To respond to your inquiries (Legal basis: Legitimate Interests) To improve our website (Legal basis: Legitimate Interests) To detect, prevent, and address technical issues (Legal basis: Legitimate Interests) 6. Data Storage and Security We implement appropriate technical and organizational measures as required by the GDPR to maintain the security of your personal information, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. These measures include: Encryption of data in transit and at rest Regular security assessments Access controls and authentication measures Staff training on data protection Incident response procedures 7. International Data Transfers For users in the European Economic Area (EEA), we ensure that any transfer of personal data outside the EEA is done so with appropriate safeguards in place, such as: Standard Contractual Clauses approved by the European Commission Adequacy decisions by the European Commission Binding Corporate Rules where applicable 8. Your Rights Under GDPR Under the GDPR, you have the following rights: Right to Access: Obtain confirmation of whether we process your personal data and request a copy of that data Right to Rectification: Request correction of inaccurate personal data Right to Erasure: Request deletion of personal data in certain circumstances Right to Restrict Processing: Limit the way we use your personal data Right to Data Portability: Receive your personal data in a structured, commonly used format and transmit it to another controller Right to Object: Object to processing based on legitimate interests and direct marketing Right to Withdraw Consent: Withdraw your consent at any time, including removing yourself from our waitlist Right to Lodge a Complaint: File a complaint with a supervisory authority To exercise these rights, please contact us using the Data Controller information provided above. We will respond to your request within one month. 9. Data Retention Peaky will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable laws or legal obligations. 10. Data Sharing and Third Parties Peaky will only disclose your personal data to third parties if required for the purposes outlined in this Privacy Policy. This might involve sharing your personal data with: Software and cloud service providers Freelancers or other service providers We have implemented necessary contractual measures to ensure that these third parties treat your personal data in accordance with applicable privacy regulations (e.g. Article 28 GDPR).Additionally, we may disclose your personal data: To competent authorities: if legally required or necessary to protect our rights, or in the context of (future) legal proceedings In M&A context: If Peaky or its assets are acquired by a third party, your personal data may be part of the transferred assets 11. Changes to This Privacy Policy We may update our Privacy Policy from time to time. We will notify you of any material changes by: Posting the new Privacy Policy on this page Updating the “Last updated” date 12. Contact Us For any privacy-related queries, including exercising your GDPR rights, please reach out to our Data Protection Officer at [email protected] or using the contact form on our website.