Gravel AI - Privacy Policy

Last Updated: 06-December-2022

Gravel AI Ltd (“Gravel AI”, “we,” or “us”) respects your privacy. This Privacy Policy (this “Policy”) describes how we collect, process, share and safeguard Personal Information (as defined below) we gather when you visit our website at https://gravelai.com/ (the “Site”), when you have direct exchanges with our representatives in person or online, or when you access and use our services (the “Services”).  It also tells you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns.

1. Personal Information We Collect

We may collect Personal Information about you from the different sources listed below.  In this Policy, “Personal Information” means any information relating to an identified or identifiable natural person.  Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.

Information provided by you

• Registering for an account.  When you register on our Site to create an account, we will ask you to provide us with details including your name, job title, employer and email address.

• Correspondence and other communications.  When you contact us via email, in-app chat tools, via any virtual platform or by other means such as at a trade show, conference or webinar, you may provide us with Personal Information, such as your name and contact details (including home or work address, email address and phone number), your job title and the company you work for, and the content, date and time of our communications.

Information collected via automated means

• Cookies and similar technologies.  We and third parties may automatically collect information about your online activities via cookies, invisible tags, and similar technologies (collectively “cookies”) in your browser.  This information may include Personal Information, such as your IP address, web browser and device type and information about your interactions with our Site, such as the time of your visit to our Site and where you have clicked.

• Device Information.  We receive information about the device and software you use to access our Site and Services, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site and Services.

• Usage Information.  To help us understand how you use our Site and Services and to help us improve them, we automatically receive information about your interactions with our Site and Services, including but not limited to the pages or other content you view, the searches you conduct, and the dates and times of your visits.

Information collected from other sources

• Information from third parties.  We may obtain Personal Information about you from third parties, such as your employer if they enter into a contract with us for the provision of our Services or from third parties such as Rocket Reach and Apollo.  This information may include name, title, company name, addresses, telephone number and email address.

• Information from public sources.  We may obtain Personal Information about you from public sources, such as LinkedIn or your employer’s website.  This information may include your job title, your previous job titles and contact details, such as your telephone number and email address.

2. How We Use Personal Information

We may use your Personal Information for the following purposes:

• Providing our Services. We use Personal Information about you to operate, maintain, debug and provide our Services, such as in the course of administering access to areas of our Site, or processing transactions and payments.

• Analytics and product development. We use Personal Information about you to analyze usage trends and preferences to improve our Services, as well as to develop new products, services, features, and functionalities.

• Communicating with you and your employer.  We may use your contact details to contact you and your employer, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support.

• Marketing and surveys. We may use your Personal Information to provide you with relevant marketing materials and to invite you to participate in surveys. We may contact you for these purposes by post, telephone or by email. You will be given an opportunity to unsubscribe from receiving such communications.

• Legal. We may use your Personal Information to enforce this Policy, to defend our legal rights and to comply with our legal obligations and internal policies. We will also use your Personal Information as necessary to comply with applicable laws and regulations, or comply with judicial processes or government agency requests.

• Fraud.  To find and prevent fraud, and respond to trust and safety issues that may arise.

3. How We Use Cookies and Similar Technologies

Below is an overview of the types of cookies we may use to collect Personal Information.

• Strictly Necessary Cookies.  Some cookies are strictly necessary to make our Services available to you.  We cannot provide you with our Services without this type of cookies.

• Functional cookies.  These cookies are necessary for the Site and Services to operate.  For example, session customization cookies are necessary to provide our Site in the language of your preference.  Without these cookies, we may not be able to provide you with certain website functionalities.

• Analytical cookies.  We also use cookies for analytics purposes in order to operate, maintain, and improve our Site and Services.  We may use our own analytics cookies or use third party analytics providers, such as Google Analytics, to collect and process certain analytics data on our behalf.  You can learn about Google’s privacy practices by going to https://www.google.com/policies/privacy/partners/.

• Performance cookies. We use cookies to understand and analyze the way that our Site and Services operate, and use these insights to improve how they function. This allows us to provide a better experience for our visitors.

• Advertising cookies. We work with third party advertising companies to show you ads we think may be of interest to you. To do so, we and our advertising partners may place and access cookies through our Site and Services, and otherwise collect or access Personal Information collected over time and across different online services. For example, we may use cookies provided by LinkedIn.

4. On What Legal Grounds We Process Personal Information

If you are located in the European Economic Area, Switzerland or the United Kingdom (“Europe”), we only process your Personal Information based on a valid legal ground, including when:

• Consent.  You have consented to the use of your Personal Information, for example when you consent to receive marketing communications.  You can withdraw consent at any time.

• Contract.  We need your Personal Information to provide you with our Services, including responding to your inquiries.

• Legal obligation.  We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations.

• Legitimate interest.  We or a third party may have a legitimate interest in using your Personal Information, in particular for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services.  We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

5. How We Share Your Personal Information

We may disclose Personal Information to third parties if you consent to us doing so, as well as in the following circumstances:

• Service providers.  We work with third party service providers to operate our Services, including by providing IT-hosting, maintenance, and other services for us.  These third parties may have access to or process your Personal Information as part of providing those services for us.

• Legal.  We may disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.  We also reserve the right to disclose your Personal Information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Services and any facilities or equipment used to make our Services available, or (v) protect our property or other legal rights, including to enforce our agreements, or the rights, property, or safety of others.

• Merger.  We may disclose or otherwise transfer Personal Information to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

6. Your Rights in Relation to Your Personal Information

You have the rights described below, which you may be able to exercise in relation to your Personal Information:

• You may request access to the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company.  In addition, you have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

• You may withdraw any consent you previously provided to us regarding the processing of your Personal Information at any time and free of charge.  We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Policy.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

7. Cookie Preferences

You can block cookies by setting your internet browser to block some or all cookies.  However, if you use your browser settings to block all cookies (including essential Cookies) you may not be able to access all or parts of our Site or Services.  You can change your browser settings to block or notify you when you receive a cookie, delete cookies or browse our Site or Services using your browser’s anonymous usage setting.  Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.  If you do not agree to our use of cookies or similar technologies which store information on your device, you should change your browser settings accordingly.  You should understand that some features of our Site or Services may not function properly if you do not accept cookies or these technologies.  Where required by applicable law, you will be asked to consent to certain cookies and similar technologies before we use or install them on your computer or other device.

8. Data Security

We use physical, organizational, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain.

9. Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.  When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations. We will generally retain Personal Information for three years, following our last processing of it.

10. Cross-Border Data Transfers

We may transfer your Personal Information to countries other than the country where you are located, including to the U.S. or any other country in which we or our service providers maintain facilities.  If you are located in Europe, the UK or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer your Personal Information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

We comply with applicable legal requirements when transferring Personal Information to countries other than the country where you are located.  For instance, we may transfer your Personal Information to countries for which adequacy decisions have been issued or use contractual protections for the transfer of Personal Information.  If you are located in Europe or the UK, you may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of Europe.

11. Changes to this Policy

We may update this Policy from time to time to reflect changes in our privacy practices.  If we modify this Policy, we will indicate the date of the latest revision at the top of this Policy.

12. Our Contact Information

If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Information, please contact us by email at [email protected] or by writing to us at: 86-90 Paul Street, London EC2A 4NE