PRIVACY POLICY

Last updated May 2024

Seez App Holding Ltd and its subsidiaries (“Seez”, “we”, “us”), comply with the General Data Protection Regulation (the “GDPR”) regarding the collection, use, and disclosure of your personal information. 

I- Introduction

Seez is a provider of “Seezar”, an artificial intelligence powered live chat bot (the “ChatBot”) that empowers automotive dealerships (the “Dealerships”) to reach their customers, 24/7 by ensuring instant responses to customers enquiries (the “Services”). The ChatBot is seamlessly layered on top of Chat GPT-powered chatbot. This privacy policy will help customers that use our Services (collectively, “you”) and the Dealerships understand what information we collect and use on behalf of a Dealership, and the choices you have associated with that information. This privacy policy concerns your use of our Services and software that comprise the ChatBot that Seez operates for Dealerships. In operating the ChatBot for the Dealership, Seez is a service provider for the Dealership and all communications you have through the ChatBot are processed by Seez for the Dealership. Your communications with Seez are on behalf of the Dealership.

II- Collecting User Behavioral Information and Personal Information

When you visit a website (the “Website”) that integrates the ChatBot and you use the Services, Seez may collect, retain and use information pertaining to your click and viewing behavior based on your use of the Services (“Behavioral Information”). If you also submit your Personal Information (as defined below), choices or preferences, as part of your use of the Services your Personal Information may be collected, retained, used and linked to your Behavioral Information that we have collected. 

“Personal Information” means personally identifiable information that can be specifically associated with, or that is sufficient to identify, you and includes your name and contact information (your phone number, address or email address), driver’s license number or other governmental ID number, etc. If you engage in our live web chat through the ChatBot using our Services, we may also store any transcripts (“Transcripts”) from such conversations and link those Transcripts to your Personal Information and Behavioral Information. 

III- Cookies and other tracking technologies

To enhance your experience and provide more personalized service, we may use a feature called a cookie or other similar methods to track your behavior while using the Services. Cookies are small files that your web browser places on your computer’s hard drive. They are used for a variety of purposes, such as tracking click behavior. 

The data that is tracked through these mechanisms may include, but are not limited to: 

• your domain name, 
• your IP address,
• the type of web browser, device, and operating system being used, and 
• the pages of the Website that you visit or the files that you request. 

Most internet browsers enable you to block cookies in the preferences or settings of the internet browser. Please refer to your browser’s documentation for instructions on how to block cookies in your browser’s settings. Also, many websites offer consent management tools that allow you to manage your consent to different cookies categories. 

IV- Linking Behavioral Information to Personal Information

If you voluntarily provide Seez with your name and contact information during a live web chat through the ChatBot, we may link your Behavioral Information to your Personal Information.

V- Basis of  lawful processing

When our Services are offered in circumstances where the GDPR applies, the obligations imposed by the GDPR mean that Personal Information can only be used if there is a lawful reason to do so.           

We invite you to carefully read the below to understand the difference between the “data controller” and the “data processor”: the data controller, means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Information. The data processor means a natural or legal person, public authority, agency or other body which engages in Personal Information processing (such as, collection, structuring, storage, use or disclosure, etc.), when applicable, on behalf of the controller.     

In the context of the provision of the Services, Seez will be collecting, retaining and using your Personal Information when you visit the website of a Dealership that integrates the ChatBot. In this respect, the Dealership will be the data controller and Seez will be the data processor which processes collected Personal Information on behalf of the Dealership. In some instances, Seez provides its Services in conjunction with technology partners (the “Technology Partner(s)”), such as Automotive Transformation Group Limited (“ATG”) who provides first line of support to the Dealerships and have access to the dashboard where the Transcripts are stored. In these cases, the Dealership  will be the data controller, the Technology Partner will be the data processor and Seez will be a sub-processor.                 

Under GDPR the data controller is responsible for ensuring that      Personal Information is processed lawfully. Processing will only be lawful where one of the following applies.

• You have consented to the processing.
• The data controller needs to use it for the purposes of a legitimate interest, and its reasons for using it outweigh any prejudice to your data protection rights
• It is necessary to enter into or perform a contract between you and the data controller.
• The data controller needs to use it to comply with its legal obligations
• The use is necessary to protect your vital interests (or another person’s)
• The data controller needs to use it to perform a task in the public interest.                                        

VI- To whom your Personal Information is disclosed and the principles under which we share your Personal Information

In order to fulfill the Services and/or to meet our legal obligations, we may be required to share and/or transfer your Personal Information with or to other organizations and companies. 

We will not sell your Personal Information, and we will not share your Personal Information, Behavioral Information and Transcripts with any third parties except for:

• The company or companies to whom Seez is providing services (or such company’s affiliates) including the Dealership and the companies on whose Website you have submitted your Personal Information, 
• The Technology Partners that provide services in conjunction with Seez (such as ATG). 
• Our third-party service providers, such as OpenAI LLC (AI services), and Amazon Web Services EMEA SARL (hosting services).       
• Other third parties that you consent to (for example, a finance company, bank, or other financial institution when you request credit eligibility or apply for financing through a Dealership). Anonymous or aggregated Behavioral Information, meaning Behavioral Information that does not include Personal Information, may be used for providing aggregated statistical data for reporting and analytics purposes.

We share your Personal Information under the following principles:

• For business purposes — We may share your Personal Information with the third parties listed above in order to properly perform, improve or maintain our Services to you. We may also share your Personal Information between and among Seez and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership,
• With your consent or at your direction — We will share your Personal Information with entities outside of Seez when we have your consent to do so, or it is done at your direction, 
• For external processing — As mentioned in Article VII of this privacy policy,
• For legal purposes — We share your Personal Information when we believe that the disclosure is reasonably necessary to (a) comply with applicable laws, regulations, legal processes, or requests from law enforcement or regulatory authorities, (b) prevent, detect, or otherwise handle fraud, security, or technical issues, and (c) protect the safety, rights, or property of any person, the public, or Seez,
• On a non-personal or aggregate basis — We may share your Personal Information with third parties on both a non-personally identifying basis and an aggregate basis.

VII- How we store your Personal Information

Your Personal Information is stored in AWS Hosted Servers based in the EU using security practices in accordance with industry standard practices.

We may also choose to engage other companies to store or process your Personal Information on our behalf. In every case, where we choose to do that, we will ensure that any company that we engage with is subject to the same standards of data security and provides you with the same level of personal information protection as we provide to you.

Seez is reasonably committed to maintaining the security of your Personal Information and has measures in place to protect such personal information against unauthorized or unlawful processing and against accidental loss, destruction or damage. Every person who has access to your Personal Information is contractually obligated to respect the confidentiality of your Personal Information and abide by the GDPR. 

In some cases, your Personal Information may be stored in the Website owner’s databases (or the Website owner’s service providers’ databases). Please refer to the Website owner’s privacy policy for more information.

VIII- How long we retain Behavioral Information and Personal Information.

We will retain your Behavioral Information and Personal Information for 6 months or as long as necessary for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for Behavioral Information and Personal Information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your Behavioral Information and Personal Information, the purposes for which we process your information, whether we can achieve those purposes through other means, and the applicable legal requirements.   

Following the retention period mentioned hereinabove, your Behavioral Information and Personal Information will be permanently deleted.

IX- Your privacy rights

As a consumer, subject to applicable laws ruling your jurisdiction, you have certain rights (subject to the conditions specified by the GDPR). These may include:

• The right to access your Personal Information along with other related information,
• The right to rectify any Personal Information and complete any incomplete personal information,
• The right to require us to erase your Personal Information in certain situations,
• The right to object or restrict the processing of your Personal Information,
• The right to data portability, which means the right to receive (or for a third party you have chosen to receive) an electronic copy of the Personal Information you have given to us.

If you wish to make any request concerning the above-mentioned rights, please contact us at info@seezar.ai and we will respond to your request without undue delay and in any event within one month of receipt of the request (subject to an extension where necessary).

We always want to make sure that the Personal Information we hold about you is accurate and up to date. Therefore, if you think any Personal Information we hold about you is incorrect or incomplete, please email or write to us at the address given above as soon as possible so we can update our records.

X- Personal Information breach

When a Personal Information breach is likely to result in a high risk to your rights and freedoms, we shall communicate the Personal Information breach to the data controller without undue delay. The data controller is then responsible for any onward communication with you.      

XI- Your consent to this privacy policy and its enforcement

YOU CONFIRM AND AGREE THAT BY USING OUR CHATBOT AND PARTICIPATING IN OUR SERVICES IN ANY WAY, YOU:

(A) UNCONDITIONALLY CONSENT TO AND AGREE TO ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, INCLUDING WITHOUT LIMITATION AUTOMATICALLY CONSENTING TO THE COLLECTION, USE AND SHARING OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS PRIVACY POLICY; AND

(B) ARE DEEMED TO HAVE CHECKED THE PRIVACY POLICY OF EACH OF THE RELEVANT DEALERSHIP AND OPENAI      (https://openai.com/enterprise-privacy) AND AGREED THERETO. 

XII- Third parties websites 

The ChatBot may direct you to other websites that are not operated or controlled by Seez, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this privacy policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

XIII- Changes to this privacy policy

This privacy policy will be revised periodically and any revised privacy policy will be posted on this page, so we encourage you to review it regularly.

XIV- Contact Information

If you have any questions or comments about our privacy policy, please contact us at: info@seezar.ai