PRIVACY POLICY

1. WHO WE ARE

SCLNG AI LIMITED (Company Registration Number: 792436) is a company registered in Ireland with registered office at 13 Adelaide Road, D02 P950 Dublin, Ireland. We are the data controller for the personal data we collect through our Demo and Business Qualification Service AI Chatbot ("Demo and Business Qualification Service").

Contact Information:

• Email: management@sclng.ai
• Address: 13 Adelaide Road, D02 P950 Dublin, Ireland
• Company Registration Number: 792436
• Data Protection Contact: management@sclng.ai

2. WHAT THIS POLICY COVERS

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our Demo and Business Qualification Service available at sclng.ai. This policy should be read alongside our Terms of Service.

3. INFORMATION WE COLLECT

3.1 Information You Provide Directly

• Conversation data: Questions you ask the chatbot and responses you provide
• Business information: Details about your company, role, business needs, and requirements you share during qualification
• Account information: If you sign up, we collect email address and any other registration details
• Contact details: Information you provide when requesting follow-up contact

3.2 Information We Collect Automatically

• Technical data: IP address, browser type, device information, and interaction timestamps
• Usage data: How you interact with the chatbot, response times, and session duration

4. HOW WE USE YOUR INFORMATION

4.1 Primary Purposes

We process your personal data for the following purposes:

Demo and Business Qualification Service Provision:

• To operate and maintain the chatbot functionality
• To generate responses to your questions
• To provide you with an accurate demonstration of our capabilities

Business Qualification:

• To assess whether our full service would be suitable for your business needs
• To understand your business requirements and challenges
• To tailor potential future communications and proposals

Service Improvement:

• To analyze and improve our chatbot responses and functionality
• To develop better qualification processes
• To enhance user experience

4.2 Legal Basis for Processing

We process your data based on:

• Consent: When you agree to use our Demo and Business Qualification Service
• Legitimate interests: For service improvement and business development
• Pre-contractual measures: When assessing potential business relationships

5. SHARING YOUR INFORMATION

5.1 Third-Party Service Providers

Large Language Model (LLM) Processing:

• Your conversation data will be sent to one or more third-party LLM providers via their APIs for AI processing
• Current providers include Anthropic and Google (Gemini API)
• We may use different providers from time to time for comparison and service improvement purposes
• Each provider processes this data according to their own privacy policies
• We have appropriate data processing agreements in place with our LLM providers that include Standard Contractual Clauses approved by the European Commission
• Data transfer to these providers is necessary for the chatbot functionality

Provider-Specific Information:

• Anthropic: More details at www.anthropic.com and www.anthropic.com/legal/data-processing-addendum
• Google: More details at cloud.google.com/terms/data-processing-addendum
• We will update this section when we add or change providers

5.2 Internal Sharing

• Sales team: May review qualification information to provide appropriate recommendations
• Technical team: May access conversation data for service improvement and troubleshooting
• Management: May access aggregated and anonymized usage statistics

5.3 Legal Requirements

We may disclose your information if required by law, court order, or to protect our legal rights.

6. INTERNATIONAL TRANSFERS

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), specifically:

• United States: Where Anthropic's or Google's Gemini services are hosted

We ensure appropriate safeguards are in place for all international transfers, including:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Other appropriate safeguards as required by GDPR
• For more details please see section 5.1 of this Privacy Policy

7. HOW LONG WE KEEP YOUR DATA

We retain your personal data for the following periods:

• Conversation history: 12 months from your last interaction
• Business qualification data: 12 months from your last interaction
• Technical logs: 6 months for security and troubleshooting purposes
• Marketing consent records: Until consent is withdrawn plus 3 years

After these periods, we will securely delete or anonymize your data unless we have a legal obligation to retain it longer.

8. YOUR RIGHTS

Under GDPR and Irish data protection law, you have the following rights:

8.1 Access and Portability

• Right of access: Request a copy of your personal data
• Data portability: Receive your data in a structured, machine-readable format

8.2 Correction and Deletion

• Rectification: Request correction of inaccurate personal data
• Erasure: Request deletion of your personal data ("right to be forgotten")

8.3 Processing Control

• Restriction: Request limitation of processing in certain circumstances
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Withdraw consent for processing at any time

8.4 Exercising Your Rights

To exercise any of these rights, contact us at management@sclng.ai. We will respond within one month of receiving your request.

9. AUTOMATED DECISION-MAKING

Our Demo and Business Qualification Service may use automated systems to:

• Generate responses to your questions
• Assess the relevance of generated answers
• Evaluate your responses for follow-up qualification questions
• Apply rate limiting to manage service usage

You have the right to request human review of any automated decisions that significantly affect you.

10. SECURITY MEASURES

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Access controls and authentication systems
• Regular security assessments and updates
• Staff training on data protection

11. COOKIES AND TRACKING

Our Demo and Business Qualification Service is currently not using cookies or other tracking technology.

12. CHILDREN'S PRIVACY

Our Demo and Business Qualification Service is intended for business use and is not directed at individuals under 16 years of age. We do not knowingly collect personal data from children under 16.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• For significant changes, providing direct notice via email if we have your contact details

14. COMPLAINTS

If you have concerns about how we handle your personal data, you can:

1. Contact us directly at management@sclng.ai
2. Lodge a complaint with the Irish Data Protection Commission:
   • Website: dataprotection.ie
   • Email: info@dataprotection.ie
   • Phone: +353 (0)761 104 800

15. CONTACT US

For any questions about this Privacy Policy or our data processing practices, please contact us:

• Email: management@sclng.ai
• Address: 13 Adelaide Road, D02 P950 Dublin, Ireland
• Company Registration Number: 792436
• Subject Line: "Privacy Policy Inquiry - Demo and Business Qualification Service"