Privacy Policy
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General
- NALIOS respects your privacy and undertakes all effort to keep secure any information it obtains from you or about you. This Privacy Policy describes practices with respect to the personal data NALIOS collects from you when you subscribe to and use NaliosAI (www.ai.nalios.com), the Odoo®-related AI software created by NALIOS (hereinafter, the “Tool”).
- The Tool can only be used by companies for business purposes. NALIOS only collects the minimum number of personal data to enable you to use the Tool.
- THE TOOL CAN ONLY BE USED IN ORDER TO ASK ODOO®-RELATED QUESTIONS. YOU EXPRESSLY UNDERTAKE NOT TO SEND ANY PERSONAL DATA IN THE SOFTWARE OF THE TOOL (I.E. ANY INFORMATION WHICH IS RELATED TO AN IDENTIFIED OR IDENTIFIABLE NATURAL PERSON), NOR SENSITIVE DATA (I.E. DATA REVEALING RACIAL OR ETHNIC ORIGIN, POLITICAL OPINIONS, RELIGIOUS OR PHILOSOPHICAL BELIEFS, TRADE UNION MEMBERSHIP, 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).
- Any personal data will be collected by NALIOS in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter, the "GDPR") and the Belgian Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data.
- This Privacy Policy is part of the Terms of use, which is a separate document available on this page. The Terms of use outline the legal contract between you and NALIOS for using the Tool.
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WHAT PERSONAL DATA IS COLLECTED BY NALIOS?
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NALIOS collects, processes and stores the following personal data when you sign up to use the Tool:
Category of personal data Description User Data Personal data that NALIOS needs to create your account and to enable you to use the Tool.
The type of personal data collected and used is:- Your name.
- Your company name.
- Your email address.
- Your phone number.
- Your country.
Payment Data Personal data that NALIOS needs to invoice the subscription to the Tool.
The type of personal data collected and used is:- VAT number.
- Registered office of your company.
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NALIOS collects, processes and stores the following personal data when you use the Tool:
Category of personal data Description Usage Data Personal data collected and processed about you when you're accessing or using the Tool.
The type of personal data collected and used is:- Information about how you use the Tool: your actions with the Tool (including date and time), such as search queries, browsing history or account settings.
- Technical data: online identifiers such as cookie data and your IP address.
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NALIOS processes and stores the information that you insert in the Tool:
Category of personal data Description Question Data You have to pay the Subscription Fee via NALIOS'payment partners. They may send personal data to NALIOS in order to allow it to send you invoices, to process your payment and to grant you access to the Tool. -
NALIOS processes and stores the personal data that it receives from third party sources you sign up to use the Tool:
Category of personal data Description Payment Data You have to pay the Subscription Fee via NALIOS' payment partners. They may send personal data to NALIOS in order to allow it to send you invoices, to process your payment and to grant you access to the Tool.
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NALIOS collects, processes and stores the following personal data when you sign up to use the Tool:
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WHAT IS NALIOS' PURPOSE AND LEGAL BASIS FOR COLLECTING YOUR PERSONAL DATA?
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NALIOS collects, processes and stores your personal data necessary for the performance of the contract concluded with you, namely, to comply with its obligations under such contract. Such legal basis is used for the following purposes and categories of personal data:
Purpose Category To provide access to the Tool in accordance with NALIOS' contract with you. User Data
Usage Data
Payment DataTo answer the Odoo®-related questions you ask in the Tool. User Data
Question DataTo diagnose, troubleshoot, and fix issues with the Tool. User Data
Usage Data
Question DataTo notify you on the updates or upgrades to the Tool. User Data To process your payment. User Data
Payment Data -
NALIOS asks you to actively indicate your consent to NALIOS' use of your personal data for the following purposes:
Purpose Category To register your application in order to get access to the (temporary) Beta version of the Tool. User Data For marketing, promotion or advertising. User Data
Usage DataIf the processing of personal data is based on your consent, you have the right to withdraw your consent at any time, without this affecting the legality of the processing on the basis of the permission before your withdrawal. You can inform NALIOS of such withdrawal by sending an email to ai@nalios.com. -
NALIOS has a legitimate interest in processing your personal data when it uses your personal data in a certain way, which is necessary and justified considering any possible risks to you and other users of the Tool:
Purpose Category To evaluate and develop new features, technologies, and improvements to the Tool. User Data
Usage Data
Question DataTo conduct business planning and reporting. User Data
Usage Data
Question DataFor marketing, promotion or advertising. User Data For security purposes. User Data
Usage Data
Payment Data
Question DataTo keep your user account preferences. Usage Data -
NALIOS must process your personal data to comply with legal obligations for the following purpose:
Purpose Category To comply with a legal obligation that NALIOS is subject to. User Data
Payment Data
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NALIOS collects, processes and stores your personal data necessary for the performance of the contract concluded with you, namely, to comply with its obligations under such contract. Such legal basis is used for the following purposes and categories of personal data:
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TO WHOM DOES NALIOS SEND YOUR PERSONAL DATA?
- Subject to Article 4.3, NALIOS undertakes not to transfer your personal data outside the European Economic Area.
- NALIOS may communicate your personal data to the following recipients:
- (a) subcontractors who provide certain services under the terms of a subcontracting agreement and for the purpose of providing technical assistance to NALIOS,
- (b) payment partners in order to allow them to process your payments and for anti-fraud purposes,
- (c) competent authorities to whom NALIOS would be legally obliged to disclose information in the context of legal proceedings or to detect technical and/or security problems, and
- (d) in the event NALIOS changes its corporate structure by changing its legal form, merger, acquisitions and sales, the contracting company(ies).
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Since the Tool has been built on the API developed by Open AI L.L.C, the later will have access to the questions you ask in the chatbot of the Tool. Such questions cannot be qualified as “personal data” as defined in the GDPR since Open AI L.L.C. does not have access to your User Data, Usage Data and Payment Data. Therefore, the Question Data alone will not allow the identification of a natural person. However, if you do not comply with Articles 1.3 of this Privacy Policy, please note that:
- (a) Open AI L.L.C. is located in the United States of America, where the level of data protection is not essentially equivalent to the level of data protection offered within the European Economic Area.
- (b) Open AI L.L.C. processes the data according to its own Privacy Policy (www.openai.com/policies/privacy-policy).
- (c) Open AI uses sub-processors that are also located outside the European Economic Area (www.platform.openai.com/subprocessors).
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HOW DOES NALIOS PROTECT YOUR PERSONAL DATA?
- NALIOS takes appropriate technical and organisational measures to prevent unnecessary retention and unauthorised access of your personal data. However, be aware that no system is ever completely secure.
- Among others, the following safeguards have been put in place by NALIOS:
- (a) Firewall / UFW
- (b) Fail2ban (connexion SSH/HTTP)
- (c) Strong passwords to SSH
- (d) Regular update of passwords
- To protect your account on the Tool, NALIOS encourages you to: (a) use a strong password, which should be different from the passwords you use for other tools, (b) update your password regularly, (c) do not save it on your computer, smartphone or tablet in a form that is unencrypted and not password protected, (d) keep your credit card details safe.
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HOW DOES NALIOS STORE YOUR PERSONAL DATA AND FOR HOW LONG?
- The personal data that NALIOS collects from you is transferred to a data-server hosted in Düsseldorf (Germany).
- NALIOS undertakes not to retain your personal data for longer than is necessary for the performance of the contract and undertakes to delete your personal data in accordance with the period mentioned in the following table:
User Data NALIOS will delete such data within one (1) year after the termination of the contract. NALIOS will not delete your user account and your user data immediately to give you the opportunity to start using the Tool again if you wish. Usage Data NALIOS will delete such data within one (1) month after the termination of the contract. Payment Data NALIOS has to retain the data for a period of ten (10) years in order to comply with tax law in Belgium. NALIOS will delete your data after such period. Question Data NALIOS will store the data to enable machine learning in its Tool. Since NALIOS shall delete the User Data and Usage Data, the Question Data will be pseudonymised and NALIOS will no longer be able to identify the individual who asked the questions. NALIOS will therefore be allowed to keep the Question Data for as long as it wishes.
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WHAT ARE YOUR DATA PROTECTION RIGHTS?
- NALIOS provides you with the following tools so that you have full control over your personal data.
- Right of access. You have a right of access to your personal data. To exercise your right of access, you can send an email to ai@nalios.com. Personal data that NALIOS has collected about you will be sent to you by email on the email address provided when you signed up to create an account.
- Right of rectification. You may, at any time, ask NALIOS to complete or modify your personal data if you find them to be incomplete, incorrect or obsolete.
- Right to object. You have the right to object to NALIOS processing your personal data. The exercise of this right of objection is only possible in one of the following two situations:
- (a) when the exercise of this right is based on NALIOS' legitimate interests; or
- (b) when the exercise of this right is intended to prevent the data collected by NALIOS from being used for commercial prospecting purposes.
- Right to erasure. You have the right to request NALIOS to erase your personal data as soon as possible, in particular when:
- (a) the personal data is no longer necessary for the purposes for which they were collected or otherwise processed;
- (b) you withdraw your consent on which the processing of your data is based;
- (c) your data has been unlawfully processed by NALIOS;
- (d) your data must be erased in order to comply with a legal obligation under EU or Belgian law.
Please note, however, that even if you exercise your right to erasure, NALIOS may retain certain information about you where it is required to do so by law (such as tax and accounting legislation) or where it has a legitimate interest to do it. - Right to restriction. You may request NALIOS to restrict the processing of your personal data, if:
- (a) you contest the accuracy of your personal data, for a period enabling NALIOS to verify the accuracy of the personal data;
- (b) the processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead;
- (c) NALIOS no longer needs your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
- (d) you objected to processing pursuant to Article 7.4 pending the verification whether the legitimate grounds of NALIOS override yours.
- Right to portability. You also have the right to receive the data you have provided to NALIOS, in a structured, commonly used and machine-readable format, and have the right to transmit (or request the transmission of) that data to a controller other than NALIOS where the processing of your data is based on consent or on the performance of the contract or where the processing is carried out by automated means.
- To exercise the rights mentioned in Articles 7.2 to 7.7, you may contact NALIOS by sending an email to the following email address: ai@nalios.com. NALIOS undertakes to reply within a reasonable period of time to any request relating to the exercise of the aforementioned rights. This period shall not exceed one (1) month from receipt of your request, unless NALIOS decides to exercise its right to extend this period, which shall be a maximum of two (2) months.
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AMENDMENTS TO NALIOS' PRIVACY POLICY
- NALIOS may occasionally make amendments to this Privacy Policy. Therefore, NALIOS encourages you to periodically review this Privacy Policy for the latest information on its privacy practices.
- If NALIOS makes any material changes to this Privacy Policy, NALIOS will notify you in accordance with applicable law prior to the amendments becoming effective.
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CONTACT
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Any question about the present Privacy Policy or privacy practices can be sent to NALIOS by:
- Email: ai@nalios.com
- Post: Rue Phocas Lejeune 25 Box 5, 5032 Gembloux (Belgium)
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You are also entitled to request further information or lodge a complaint with the Belgian Data Protection Authority:
- Email: contact@apd-gba.be
- Post: Rue de la Presse, 35, 1000 Bruxelles (Belgium)
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Any question about the present Privacy Policy or privacy practices can be sent to NALIOS by: