Privacy Policy

1. Introduction

Expertion Technology OU ("Company," "we," "us," or "our"), a company registered in Estonia, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use the Agent Mio platform and related services (collectively, the "Service").

This policy is designed to comply with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and other applicable data protection laws. By using our Service, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

The data controller for the purposes of applicable data protection legislation is:

Expertion Technology OU
Email: [email protected]
Website: agentmio.com

3. Personal Data We Collect

We may collect the following categories of personal data:

Information you provide directly: name, email address, company name, job title, payment information, and any other information you provide when creating an account, filling out forms, or contacting us.

Information collected automatically: IP address, browser type and version, operating system, device identifiers, pages visited, time and date of visits, time spent on pages, referring URL, and other diagnostic data.

Information from third-party services: When you connect social media accounts (such as Instagram) to the Service, we may receive profile information, account identifiers, and content data as authorized by you and the respective platform's policies. Specifically, when you connect your Instagram account, the Service reads comments posted on your Instagram content in order to facilitate comment management and AI-powered reply suggestions.

Access tokens: When you authorize the Service to connect to your social media accounts, we store encrypted access tokens that allow us to interact with those platforms on your behalf. These tokens are encrypted at rest using industry-standard encryption and are used solely to maintain your authorized connection to the platform. You may revoke these tokens at any time by disconnecting your account from the Service.

Cookies and tracking technologies: We use cookies and similar technologies to collect information about your browsing activity. For more details, please see our Cookie Policy.

4. Legal Bases for Processing

Under the GDPR, we process your personal data based on the following legal grounds:

• Contract performance (Art. 6(1)(b)): Processing necessary to provide the Service you have requested, manage your account, and process payments.
• Legitimate interests (Art. 6(1)(f)): Processing necessary for our legitimate interests, such as improving the Service, ensuring security, preventing fraud, and communicating with you about the Service, provided these interests are not overridden by your rights and freedoms.
• Consent (Art. 6(1)(a)): Where you have given explicit consent, such as for marketing communications or non-essential cookies. You may withdraw consent at any time.
• Legal obligation (Art. 6(1)(c)): Processing necessary to comply with applicable laws and regulations, such as tax and accounting requirements.

5. How We Use Your Data

We use your personal data for the following purposes:

• To provide, operate, and maintain the Service, including reading comments on your connected Instagram accounts
• To generate AI-powered reply suggestions for comments on your social media content, using artificial intelligence and machine learning technologies to analyze comment context and propose relevant responses for your review and approval
• To create and manage your account
• To securely store encrypted access tokens required to maintain your authorized connections to third-party platforms
• To process transactions and send billing-related communications
• To communicate with you, including responding to inquiries and sending service-related notifications
• To personalize and improve your experience with the Service
• To analyze usage patterns and trends to improve the Service
• To detect, prevent, and address technical issues and security threats
• To comply with legal obligations
• To send marketing communications where you have opted in (you may opt out at any time)

6. Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

• Service providers: Third-party vendors who perform services on our behalf, such as payment processing, hosting, analytics, email delivery, customer support, and artificial intelligence processing for generating reply suggestions. These providers are contractually obligated to protect your data and process it only as instructed by us.
• Third-party integrations: Social media platforms and other services you connect to through the Service, in accordance with your authorizations.
• Legal requirements: When required by law, regulation, or legal process, or to protect the rights, property, or safety of Expertion Technology OU, our users, or the public.
• Business transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your data may be transferred to the acquiring entity.

We do not sell your personal data to third parties. We do not share your personal data for third-party advertising purposes.

7. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data outside the EEA, we ensure adequate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions by the European Commission
• Other appropriate safeguards as permitted under the GDPR

You may request a copy of the safeguards in place by contacting us at the address provided below.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining retention periods, we consider the nature and sensitivity of the data, the purposes for processing, and applicable legal requirements.

When you delete your account, we will delete or anonymize your personal data within 30 days, except where we are required to retain certain data for legal, tax, or accounting purposes.

9. Your Rights Under GDPR

Under the GDPR, you have the following rights regarding your personal data:

• Right of access (Art. 15): You have the right to request a copy of the personal data we hold about you.
• Right to rectification (Art. 16): You have the right to request correction of inaccurate or incomplete personal data.
• Right to erasure (Art. 17): You have the right to request deletion of your personal data under certain circumstances.
• Right to restriction (Art. 18): You have the right to request that we restrict the processing of your personal data under certain circumstances.
• Right to data portability (Art. 20): You have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object (Art. 21): You have the right to object to the processing of your personal data based on our legitimate interests.
• Right to withdraw consent (Art. 7(3)): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit and at rest, access controls, regular security assessments, and employee training. Social media access tokens are stored using industry-standard encryption at rest and are never exposed in plaintext.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.

11. Children's Privacy

The Service is not directed at individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16 without parental consent, we will take steps to delete that data promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or by posting a prominent notice on the Service at least 30 days before the changes take effect. We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our data processing practices, please contact us at:

Expertion Technology OU
Data Protection Contact
Email: [email protected]
Website: agentmio.com