Artificial Solutions Website, Lyra and Elbot Privacy Notice

May 2018

Contents

  1. Who are we?
  2. What information do we collect from you?
  3. How do we use your personal information?
  4. Do we use your personal information for direct marketing?
  5. With which third parties do we share your personal information?
  6. Do we transfer personal information outside the European Economic Area?
  7. What are your rights?
  8. How do we protect your personal information?
  9. How long do we keep your personal information?
  10. How can you contact us?
  11. Which version of this Privacy Notice applies?

Artificial Solutions is committed to protecting your privacy and ensuring the highest level of security for your personal information. This Privacy Notice explains the types of personal information we collect, how we use that information, who we share it with, how we protect that information and your legal rights. This privacy policy (“Policy”) applies to Artificial Solutions and its programmes including Teneo, heylyra.com, it’s subdomains like portal.heylyra.com, the Lyra and Elbot apps, and any services and features related to Lyra and Elbot (the “Services”).

Please read the following carefully to understand our views and practices regarding your personal information.

1. Who are we?

For the purposes of applicable data protection laws, the data controller is Artificial Solutions Holding Ash AB, with registered office at Mäster Samuelsgatan 60, 8th floor, 111 21 Stockholm, Sweden, with organization number 556734-1556.

This Privacy Notice covers all personal information processed by Artificial Solutions which means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly.

2. What information do we collect from you?

We may collect information about you from the following sources:

2.1 Information we receive from you

We may collect personal information, such as your name, postal address, e-mail address, job title, telephone number, and all other personal information that may be provided by you. This personal information is provided to us when you:

When you visit our websites, use Lyra or Elbot, we may use cookies and other technologies to automatically collect the following information:

To learn more about how we use cookies and how to control which cookies are used, please see our Cookie Policy available at [insert hyperlink]. We don’t use any cookies on www.heylyra.com, so the Cookie Policy only applies to your use of www.artificial-solutions.com.

3. How do we use your personal information?

We process the following information: For the following purposes: Based on the following justification:
Name, address, email address, [password,] company, job title, date of birth To verify your identity.

To set up and manage your account.

To protect the security and integrity of our websites and Lyra.

To improve your experience on our websites and on Lyra.

To contact you when necessary or appropriate.

We may use your information in these ways as this is necessary for us to perform our contractual obligations towards you. We also have a legitimate interest in processing your information to maintain our relationship with you.
Personal information you disclose in emails sent by you to Artificial Solutions and in chat conversations between you and our virtual dialogue agent (for example, on Lyra) To respond to your comments and questions. We may process this information because it is necessary for us to perform our contractual obligations towards you and respond to your enquiries. We also have a legitimate interest in processing the information you give us
Name, email address To ensure that we do not contact you if you have asked us not to. We understand that you may prefer for us not to contact you with details of our products and services. We keep records of your preferences in order to do this. We have a legitimate interest in processing this information to ensure that we do not send you marketing if you do not want to receive it.
Anonymized or pseudonymized information To improve the software products developed by Artificial Solutions e.g. to train machine learning algorithms, improve product features or create new products that are developed and sold by Artificial Solutions. However, log data is never provided directly to clients of Artificial Solutions. We have a legitimate interest in processing this information to improve our products.

In addition to the above, we may process any of the information relating to you in order to comply with legal requirements that apply to us (such as tax and financial reporting requirements).

4. Do we use your personal information for direct marketing?

With your permission, we may send you carefully selected information about our products and services. You have the right to opt out of receiving direct marketing at any time. We do not sell your data or use your data for advertisements.

5. With which third parties do we share your personal information?

Your personal information is intended for Artificial Solutions but may be shared with third parties in certain circumstances:

Artificial Solutions’ group of companies: We may share your personal information among our group of companies, including our subsidiaries, our head office and branches, in order to open your account with us, administer our services and products, provide you with customer support, understand your preferences, provide, maintain and improve Lyra, send you information about our products and services that may be of interest to you and conduct the other activities described in this Privacy Notice.

Our service providers: We use other companies, agents or contractors to perform services on our behalf or to assist us with the provision of Artificial Solutions’ services and products to you. We may share personal information with the following categories of service provider:

In the course of providing such services, these service providers may have access to your personal information. However, we will only provide our service providers with personal information which is necessary for them to perform their services, and we require them not to use your information for any other purpose. We will use our best efforts to ensure that all our service providers keep your personal information secure.

Third parties required or permitted by law: In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies or to judicial or administrative authorities).

We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public.

Third parties connected with business transfers: We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.


We will not sell your personal information to third parties.


Please note our websites may, from time to time, contain links to and from the websites of our partners or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your personal information. You should check the privacy policies of third party websites before you submit any personal information to them.

6. Do we transfer personal information outside the European Economic Area?

Your personal information may be transferred to and processed in the USA, by ourselves, our affiliates and our service providers. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice.

If you live outside the United States, we transfer personal data outside the EU in accordance with EU data protection law, including where it is necessary to provide the Services and perform the Terms of Use.

Standard Contractual Clauses. We may use a legal mechanism known as “standard contractual clauses” to protect information transferred outside the EU. Standard contractual clauses refer to contracts between companies transferring personal information (for example, from Artificial Solutions Iberia, S. L. to Artificial Solutions Scandinavia AB) that contain standard commitments approved by the EU Commission protecting the privacy and security of the information transferred. To request a copy of the clauses, please email us at LegalCompliance@artificial-solutions.com.

Privacy Shield. We may also rely on the EU-US Privacy Shield where we transfer your information to the United States, such as to certain of our third party service providers, where such recipients are certified to receive your information under the Privacy Shield Program.

By continuing to use Lyra, you understand that we may transfer and store your data outside your home country, including to and in the US, as described in this Policy. The privacy protections and the rights of authorities to access your personal information in some of these countries may not be the same as in your home country; Lyra will only transfer personal data as permitted by law, and will take steps intended to ensure appropriate protection of your personal information. If you have questions, please contact us at the details set out below.

7. What are your rights?

You have the following rights available to you:

You can make a request to exercise any of these rights in relation to your personal information by sending the request by mail to the Senior Management Team at Mäster Samuelsgatan 60, 8th floor, 111 21 Stockholm, Sweden or by email to LegalCompliance@artificial-solutions.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. If you are based in, or the issue relates to, the UK, you can contact the Information Commissioner’s Office here.

If you are based in, or the issue you would like to complain about took place, elsewhere in the EEA, please click here for a list of local data protection authorities in the other EEA countries.

8. How do we protect your personal information?

We have implemented technical and organisational security measures to safeguard your personal information in our custody or control. Such measures include, for example, limiting access to personal information only to employees and authorised service providers who need to know such information for the purposes described in this Privacy Notice, as well as other administrative, technical and physical safeguards.

In using Lyra, you may come across links to websites and services operated by third parties (for example, if Lyra provides a link to a video on YouTube or displays a restaurant on Yelp). These third parties have their own privacy policies, which will apply to your activity if you click on the link or access their website or service. We do not accept any responsibility or liability for such external sites’ privacy and security practices.

While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

9. How long do we keep your personal information?

We keep your information only so long as we need it to provide the Artificial Solutions services to you that you require and fulfil the purposes described in this policy. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or anonymise it so that we can’t identify you.

10. How can you contact us?

If there are any questions or concerns regarding this Privacy Notice, please contact us as follows:

11. Which version of this Privacy Notice applies?

This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.

We reserve the right to change our Privacy Notice from time to time. If we decide to change our Privacy Notice we will notify you of these changes via email and post an alert on our websites.

[May 2018]
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