Introduction

Protex AI Limited, a private company limited by shares registered in Ireland (registered number 691369), with its registered office at Nexus Innovation Centre, Sreelane, University of Limerick, Limerick, Co. Limerick (the “Company”), has developed “ProtexAI”, a software platform more particularly described below.

The Protex AI Platform is a computer-vision based software platform which provides proactive safety technology to help companies in their mission to realize an injury-free workplace. It uses existing CCTV infrastructure coupled with cutting-edge deep-learning and cloud-based technologies to continuously and autonomously audit in real-time the safety procedures of warehouses, factories, and ports.

Definitions

‍Cookie Policy: means the document presented in our Website and Software regarding the data processing we conduct via cookies.

‍Data controller: means a natural or legal person that determines the purposes and means of the personal data processing.

‍Data processing or simply processing: means any activity relating to the use of personal data, including collection, retention, transfer, and disposal.

‍Data processor: means a natural or legal person which processes personal data on behalf of the data controller.

‍Data subject: means the person whose personal data is being processed.

‍EU: means the European Union.

‍GDPR: means Regulation (EU) 2016/679.

‍CCPA: means California Consumer Privacy Act.

‍Personal data: means any information which relates to an identifiable natural person.

‍Software means the AI-powered image processing based workplace that has been developed and owned by ProtexAI or applications and any third-party or other software, and all new versions, updates, revisions, improvements, and modifications.

‍“Website” means the ProtexAI website with the domain name *.protex.ai

Personal Data We Collect

We collect personal data about you when you provide it directly to us through the Protex AI Platform, and when personal data about you is automatically collected in connection with your use of the Protex AI website *.protex.ai (the “Website”). Protex AI does not disclose your personal data to third parties, except as outlined in this Privacy Policy.

Personal Data Collected Directly From You

We receive personal data directly from you (as a job application candidate, user, or website visitor) when you provide it to us through use of the Website, submit data through creating an account, or submitting a job application via the Protex AI Website. This includes, but is not limited to:

• Your name, contact information (such as home address, phone number, email address), gender, work permit or visa information, employment and education history, references, prior employer obligations, job title, and other work-related information.
• Desired salary, willingness to relocate, job preferences.
• Publicly available information relevant for job applications (e.g., information shared via job search and career networking sites).
• Interview details and outcomes.
• Information from third-party data providers.
• Image, Job Title, SSO (Single Sign-On) access to basic Google/Microsoft data.
• Non-biometric images (visual data) obtained as a result of camera recordings taken by our customers and transferred to ProtexAI by our customers.

Personal Data Automatically Collected

Some personal data is automatically collected when you use the Website, such as:

• IP address;
• device identifiers;
• browser information;
• cookie data.

Personal Data Collected to Improve Your Experience

We use technologies such as PostHog and Microsoft Clarity to better understand our users' needs and optimize our service and experience. This includes:

• PostHog: Helps us understand user behavior (e.g., time spent on pages, clicked links) and build our service with user feedback. PostHog uses cookies and other technologies to collect data on users' behavior and devices (IP address, device screen size, device type, browser information, geographic location, preferred language). Sensitive content is masked before sending to PostHog. PostHog stores this information in a pseudonymized user profile and is contractually forbidden to sell the data collected on our behalf. PostHog's Privacy Policy

• Microsoft Clarity: Captures interactions on our website such as page rendering and user interactions (mouse movements, clicks, scrolls). Sensitive content is masked before sending to Clarity. Clarity is GDPR compliant as a data controller. Microsoft Clarity's Privacy Policy

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track activity and improve our services. These include:

• Cookies or Browser Cookies: A small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service.

• Flash Cookies: Used to collect and store information about your preferences or activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. More information on Flash Cookies

• Web Beacons: Small electronic files known as web beacons used to count users who have visited pages or opened an email and for other related website statistics.

Types of Cookies We Use

• Necessary / Essential Cookies: These session cookies are essential to provide you with services available through the Website and to enable you to use some of its features.

• Cookies Policy / Notice Acceptance Cookies: These persistent cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies: These persistent cookies allow us to remember choices you make when you use the Website.

How We Use Personal Data

We process personal data to operate, improve, understand, and personalize our services. For example, we use personal data to:

• Personalize Protex AI content based on your preferences.
• Communicate with you.
• Review job applications.
• Send webinar invites to sign-ups.
• Protect against fraudulent, illegal, or harmful actions.
• Provide support and assistance.
• Comply with legal or contractual obligations.
• Improve user experience.
• Enforce our terms and conditions.
• Resolve disputes.

The Software is an occupational health and safety platform based on artificial intelligence and image processing. the data processing specified below, we can process personal data on behalf of our customers as a data processor based on the authorization given by our customers and in accordance with the purpose of helping our customers ensure occupational health and safety and fulfilling our contractual obligations, within the periods specified by our customers, without the opportunity to directly reach the relevant persons, within a system where our customers can unilaterally prevent our data processing at any time.

In this context, we process non-biometric images (visual data) obtained as a result of camera recordings taken by our customers and transferred to ProtexAI by our customers.

During such visual data processing, we do not continuously record camera footage of our customers and we do not perform any tracking or data processing activities in addition to the camera monitoring activities carried out by our customers. We only give warnings through the Software if the Software detects an erroneous or dangerous situation in terms of occupational health and safety in the image processed through the cameras available at its customers' facilities. If there is no faulty or dangerous situation in terms of occupational health and safety in the processed image, the analyzed video frame is deleted and not stored by ProtexAI. Only in case of faulty or hazardous situations or to increase the accuracy rates of artificial intelligence, data is collected from the selected camera for labeling and model training purposes and the images are saved.

In all the images on the Software, human faces are completely blurred/masked and pseudonymized.

DISCLAIMER: We provide our services by connecting to cameras already located on our customers' facilities and act as a data processor on behalf of our customers. Thus, it is not possible for us to fulfill the clarification obligation for data processing activities under the applicable law directly to the data subjects (employees). Our customers may need to add "ensuring occupational health and safety" or any other statement they deem appropriate among the data processing purposes stated in their existing clarification texts regarding camera surveillance activities.

Legal Bases For Processing

We collect and process your personal data only when we have legal bases for doing so under the applicable law.

In cases where we are the data controller; we process your personal data based on the following legal reasons:

For the Website

Sending newsletters/marketing communications

• Data Types: E-mail
• Lawful Basis: We have your explicit consent.

Support services

• Data Types: Name, surname, e-mail
• Lawful Basis: It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Employment applications

• Data Types: Name, surname, e-mail address, phone number, current company name, country, information included in the resume/CV, additional information you may choose to provide
• Lawful Basis:
  • It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • We have a legitimate interest (to conduct our HR processes and evaluate potential employees).

Partnership applications

• Data Types: Name, surname, e-mail address, company name, company location, additional information that you may provide
• Lawful Basis:
  • It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • We have a legitimate interest (to conduct our partnership processes and evaluate potential partners).

Demo/sales applications

• Data Types: Name, surname, work e-mail, company name, position, company industry, location, service/modules requested, additional information that you may provide
• Lawful Basis:
  • It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • We have a legitimate interest (to conduct our sales processes and evaluate potential customers).

Operating, customizing, and improving Website

• Data Types: Log data, device data, cookies
• Lawful Basis: We have a legitimate interest (to improve our Website so we can provide you with a more user-friendly, transparent and accessible Website experience).

Analytics and market research

• Data Types: Log data, device data, cookies
• Lawful Basis:
  • We have a legitimate interest (to track your Website use, conduct market research and provide you with higher quality services).
  • We have your explicit consent.

Legal obligations

• Data Types: All data
• Lawful Basis: Legal obligations.
  

For the Software

Opening your account and providing our services

• Data Types: Name, surname, e-mail, phone number, photo
• Lawful Basis: It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Conducting sale and after-sale operations

• Data Types: Name, surname, e-mail, phone number, additional information that you may provide
• Lawful Basis:
  • It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • We have a legitimate interest (to conduct our sales operations).

Providing support services

• Data Types: Name, surname, e-mail, phone number, additional information that you may provide
• Lawful Basis: It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Manage requests and complaints

• Data Types: Name, surname, e-mail, phone number, additional information that you may provide
• Lawful Basis: It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Improving our Software

• Data Types: Log data, device data, cookies
• Lawful Basis: We have a legitimate interest (to improve our Software so that we can provide you with a higher quality Service).

Sending updates about our Software and services

• Data Types: Name, surname, e-mail address
• Lawful Basis: It’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Analytics and market research

• Data Types: Log data, device data, cookies
• Lawful Basis:
  • We have a legitimate interest (to track your Software use, conduct market research and provide you with a higher quality service).
  • We have your explicit consent.

Legal obligations

• Data Types: All data
• Lawful Basis: We need to process your data to comply with a legal obligation.

Analyzing, developing, testing, improving and operating our Software and providing and supporting our services via Software

• Data Types: Visual data
• Lawful Basis: As detailed above, we use such visual data as data processor, for the sole purpose of providing you with services as determined by the customer, and train our software to provide high quality service.

Data Subject Rights

Under Data Protection Laws, you have rights including:

• Accessing and receiving detailed information about your personal data.
• Rectifying or erasing personal data.
• Restricting processing.
• Data portability.
• Objecting to processing and automated decision making.

To exercise your rights, you can contact us at info@protex.ai with the subject line "Data Subject Rights Request". Please specify the right you wish to exercise and provide us with sufficient information to verify your identity (e.g., a copy of your ID).

We aim to respond to all legitimate requests within one month. If your request is particularly complex or if you have made a number of requests, it may take us longer, but we will notify you of the need for an extension within the original one-month period and explain why the extension is necessary. The additional time needed will not exceed two additional months. If you are not satisfied with our response, you can lodge a complaint with the Data Protection Commissioner or your local supervisory authority.

Disclosing Your Information

We may disclose personal data:

• If you violate our terms and conditions or other policies.
• In connection with investigations of fraud, IP infringement, piracy, or unlawful activity.
• To processors performing tasks on our behalf, such as delivery services, hosting services, analyzing data, billing, and marketing assistance.
• In the event of a merger or acquisition.
• In response to legal requests or to protect Protex AI’s rights.

Data Retention

Protex AI retains personal data for as long as necessary for the purposes described in this policy, unless longer retention is required by law or for legal proceedings or investigations.

Third-Party Links

Our Website may contain links to third-party sites. We do not control these sites and are not responsible for their privacy policies. Review their policies before providing personal data.

Service-related Announcements and Changes

Any changes to this Privacy Policy will be posted on the Website and, where appropriate, through email notification. Protex AI may send service-related announcements, which you cannot opt-out of.

Legal Requests and Preventing Harm

We may share personal data with regulators or law enforcement:

• In response to legal requests.
• To detect, prevent, and address fraud or illegal activities.
• To protect ourselves, our users, or others from harm.

Legal Basis for Processing Personal Data

We process personal data:

• To prepare and enter employment contracts.
• With your consent, which you may revoke at any time.
• To comply with legal obligations.
• To protect vital interests.
• For legitimate interests in recruitment and hiring processes.

Contacting Us

For further information about this Privacy Policy or the processing of your personal data by or on behalf of Protex AI, please contact us at info@protex.ai.

Data Controller

Protex AI Ltd.

3 Castle Street,

Dublin 2,

Ireland

Data Protection Officer

Ciaran O’ Mara

You also have the right to lodge a complaint with Protex AI Limited’s lead supervisory authority, the Irish Data Protection Commissioner, or your local supervisory authority.