Active Peers AI Privacy Policy  

When we talk about “Active Peers” “us” or “we” in this policy, we are talking about Active Peers AI. Active Peers AI fully respects your right to privacy and we are committed to ensuring that your privacy is protected. Please read the following to learn more about how we collect, use, process, and disclose your information, including personal information and how we keep it secure. For the purpose of the EU General Data Protection Regulation 2016/679 and the Data Protection Act 2018 (the “Act”), the data controller is Active Peers.

This Privacy Policy outlines Active Peers AI practices with respect to information collected from users who access our website at www.activepeers.ai and www.platform.activepeers.ai, or otherwise share personal information with us. 

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter "Personal Information") is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

 We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

• Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
• Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail and your job background. 
• Users' clients information to engage in the Active Peers AI process which includes their name, website, location, phone number and other information.
• Participants' information to engage in the Active Peers AI process which includes their full name, e-mail, gender, age group, education level and other information.

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information for the following:

• Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
• To communicate with you and to keep you informed of our latest updates and services;
• To serve you advertisements when you use our Site (see more under "Advertisements"); 
• To market our websites and products (see more under "Marketing"); 
• Conducting statistical and analytical purposes, intended to improve the Site.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

• Hosting and operating our Site;
  
• relevant types of third parties, such as: AWS, Google, Aratok, Mailgun, Blacknight, Airtable, Stripe
• Providing you with our services, including providing a personalised display of our Site;
• Storing and processing such information on our behalf; 
• Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
• Providing you with marketing offers and promotional materials related to our Site and services; 
• Performing research, technical diagnostics or analytics;

 We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

You may request to: 

• Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
• Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
• Request rectification of your personal information that is in our control.
• Request erasure of your personal information. 
• Object to the processing of personal information by us. 
• Request to restrict processing of your personal information by us.
• Lodge a complaint with a supervisory authority.
  
  

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below:

https://www.dataprotection.ie/



Customer is the Controller and Business as defined under the Data Protection Laws, and Customer determines the means and purposes for which Customer Personal Data is Processed by Active Peers AI. To the extent Active Peers AI processes Customer Personal Data subject to the Data Protection Laws, Active Peers AI is a processor and service provider as defined under the Data Protection Laws, and Active Peers AI will process the Customer Personal Data according to the instructions set forth in this DPA, the Agreement, and as required under Data Protection Laws. Customer and Active Peers AI are independent controllers and businesses, as defined under the Data Protection Laws, with respect to Business Contact Data. Either party may process business contact data as necessary for the purpose of (i) carrying out its obligations under the agreement, (ii) applicable legal or regulatory requirements, (iii) requests and communications with the other party, (iv) administrative, business, and marketing purposes, and (v) to protect its respective rights in accordance with applicable law and, in the case of Active Peers AI, maintaining the security and integrity of the Active Peers AI products. Active Peers AI hereby certifies that it understands the restrictions and obligations.

a. Control Measures

Active Peers AI has implemented reasonable system access controls and physical access controls designed to limit access based on authorisation and prevent personnel and others who should not have access from obtaining access to Active Peers AI systems housing Customer Personal Data.

b. System Access Controls

Active Peers AI's system access control measures include the following:

i. Restricting unauthorised users from accessing information not needed for their roles through role-based user access and using least privileged principles.

ii. Unique user accounts identifiable to individual users, password requirements, and two-factor authentication.

iii. Provisioning and removal of employee access to Customer Personal Data when access is no longer required.

iv. Periodic access reviews to ensure that only Active Peers AI personnel who still require access to Customer Personal Data have it.



c. Physical Access Controls

Active Peers AI utilises cloud hosting infrastructure, currently Amazon Web Services (“AWS”) hosting infrastructure, with regard to the Active Peers AI Products. All physical security controls are managed by the cloud hosting provider. Annually, Active Peers AI reviews the applicable security and compliance reports of its cloud hosting provider to ensure appropriate physical security controls, including:

i. Use of data centres with physical and environmental controls appropriate to the risk for Customer Personal Data and for the equipment, assets, or facilities used to hold and Process such Customer Personal Data (e.g. use of key card access controls and security guard monitoring).

ii. Use of data centres with 24/7 security protection, automatic fire detection and suppression, fully redundant power systems, and other reasonable environmental controls.

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

ActivePeers AI retains the collected participants' survey and feedback data for 3 months as necessary to provide our services. After this period, the system automatically anonymise their names and emails addresses. Any recorded audio/video data is stored for a period of time depending on your membership level. Free membership - 6 months, Basic - 1 year, Plus - 2 years, and Premium - 3 years. The recorded audio/video data also can be deleted manually by the user.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorised use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy . Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

We understand the importance of protecting children’s privacy, especially in an online environment. Active Peers AI is not directed to children under the age of 13 (or other age as required by local law) and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will take reasonable steps to delete such information from our files as soon as is practicable. If you learn that your child has provided us with personal information without your consent, you may contact us here.

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us here.

+353 (0)1 8386110

Greenway Hub, TU Dublin,

Grangegorman Lower, Dublin 7, Ireland

Last Modified in December 2024