Privacy Policy

1. Types Of Data

We only ask for personal information when we truly need it to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used.

Among the types of personal data that our website collects, by itself or through third parties, are: Cookies and Usage Data. Complete details on each type of personal data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the data collection. Personal data may be freely provided by the user or, in the case of Usage Data, collected automatically when using this website.

Unless specified otherwise, all data requested by our website is mandatory and failure to provide this data may make it impossible for our website to provide its services. In cases where our website specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the availability or the functioning of the Service. Users who are uncertain about which personal data is mandatory are welcome to contact SpexAI.

Any use of Cookies – or other tracking tools – by our website or by the owners of third-party services used by our website serves the purpose of providing the Service required by the user, in addition to any other purposes described in this document and in the Cookie Policy, if available. Users are responsible for any third-party personal data obtained, published, or shared through our website and confirm that they have the third party’s consent to provide the data to SpexAI.

2. Mode And Place Of Processing

Methods of Processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. The data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to SpexAI, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of our website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data Processors by SpexAI. The updated list of these parties may be requested from SpexAI at any time.

Legal Basis of Processing
The Owner may process personal data relating to users if one of the following applies:
– Users have given their consent for one or more specific purposes. Note: Under some legislations, SpexAI may be allowed to process personal data until the user objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply whenever the processing of personal data is subject to European data protection law;
– Provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
– Processing is necessary for compliance with a legal obligation to which SpexAI is subject;
– Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in SpexAI;
– Processing is necessary for the purposes of the legitimate interests pursued by SpexAI or by a third party.

In any case, SpexAI will gladly help to clarify the specific legal basis that applies to the processing, and whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place
The data is processed at SpexAI’s operating offices and in any other places where the parties involved in the processing are located. Depending on the user’s location, data transfers may involve transferring the user’s data to a country other than their own. To find out more about the place of processing of such transferred data, users can check the section containing details about the processing of personal data. Users are also entitled to learn about the legal basis of data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by SpexAI to safeguard their data. If any such transfer takes place, users can find out more by checking the relevant sections of this document or inquire with SpexAI using the information provided in the contact section.

Retention Time
Personal data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• personal data collected for purposes related to the performance of a contract between SpexAI and the user shall be retained until such contract has been fully performed.
• personal data collected for the purposes of SpexAI’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by SpexAI within the relevant sections of this document or by contacting SpexAI.

The Owner may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, SpexAI may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

3. Purposes Of Processing

The data concerning the user is collected to allow SpexAI to provide its services, as well as for analytical purposes.

Google Analytics
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the data collected to track and examine the use of our website, to prepare reports on its activities, and to share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Users can find more information on Google’s privacy practices [here](https://policies.google.com/privacy).

4. Rights Of Users

Users may exercise certain rights regarding their data processed by SpexAI. Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.
• Object to the processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their data. Users have the right to learn if data is being processed by SpexAI, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
• Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, SpexAI will not process their data for any purpose other than storing it.
• Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from SpexAI.
• Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user’s consent, on a contract which the user is part of, or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details About The Right To Object To Processing
Where personal data is processed for a public interest, in the exercise of an official authority vested in SpexAI, or for the purposes of the legitimate interests pursued by SpexAI, users may object to such processing by providing a ground related to their situation to justify the objection. Users must know that, however, should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether SpexAI is processing personal data for direct marketing purposes, users may refer to the relevant sections of this document.

How To Exercise These Rights
Any requests to exercise user rights can be directed to SpexAI through the contact details provided in this document.

5. Data Protection Information In The Application Process

We process applicant data only for the purpose and within the framework of the application procedure in accordance with the statutory provisions. The processing of applicant data is carried out to fulfill our (pre-)contractual obligations within the framework of the application procedure in accordance with Art. 6 Para. 1 S. 1 lit. b. GDPR or pursuant to Art.