INTRODUCTION

In the course of its business, Provizio Ltd (“us”, “we”, or “our”) processes personal data about a range of identifiable individuals. This includes, but is not limited to, data about:

• Current, past and prospective employees, contractors and workers
• Customers, prospective customers and their staff
• Suppliers, partners, investors and other business contacts
• Visitors to our premises
• Visitors to and users of our website, https://provizio.ai
• Members of the public whose personal data is incidentally captured by our sensing technology during research, development, testing and demonstration activities (for example, images of individuals or vehicle registration plates recorded on public roads)

Provizio Ltd. develops radar and AI perception technology and operates https://provizio.ai, alongside providing its products and services (together, the “Business”).

This Privacy Policy explains how we collect, use, safeguard and disclose personal data from all sources across the Business. In doing so we are subject to a range of legislation – principally the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018 – governing how these activities may be carried out and the safeguards we must put in place.

Where this policy refers to use of our website, your continued use of the site indicates your agreement to the collection and use of information as described here. Unless otherwise defined, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Definitions

BUSINESS means all products, services and activities of Provizio Ltd, including research, development, testing and demonstration.

WEBSITE means the https://provizio.ai website operated by Provizio Ltd.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

SPECIAL CATEGORY DATA means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, or data concerning a person’s sex life or sexual orientation.

USAGE DATA is data collected automatically either generated in the course of employment, by the use of our website or from our website infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes and manner in which personal data is processed. For the purposes of this Privacy Policy, Provizio Ltd is the Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes data on behalf of the Data Controller.

DATA SUBJECT is any living individual who is the subject of Personal Data.

WHOSE DATA WE PROCESS AND WHY

We collect and use personal data for different purposes depending on the individual’s relationship with us. The main contexts are set out below.

Employees, contractors and job applicants

For staff and workers, we process personal data to manage recruitment, employment and the working relationship. This includes contact and identity details, recruitment and vetting information, contract and payroll data, bank details, tax and social welfare information, emergency contacts, performance and training records, IT usage and access logs, and any other data required to administer employment and comply with employment, tax and health-and-safety law.

Lawful bases: performance of the employment contract; compliance with legal obligations (e.g. tax, employment and health-and-safety law); our legitimate interests in running the business; and, where relevant, consent. Special category data (such as health data for sick leave or accommodations) is processed only where an additional GDPR Article 9 condition applies, such as employment-law obligations.

Customers, suppliers and business contacts

For customers, prospective customers, suppliers, partners, investors and their staff, we process business contact details, correspondence, contractual and commercial information, and records necessary to manage the relationship, deliver and receive services, and process payments.

Lawful bases: performance of a contract; our legitimate interests in managing and developing business relationships and marketing our products to business contacts; compliance with legal obligations; and consent where required (for example, certain electronic marketing).

Personal data captured during research, development and testing

Provizio’s sensing and perception technology may, during testing, demonstration and data-collection activities – including on public roads and at test grounds – incidentally capture personal data such as images of individuals, pedestrians, cyclists and vehicle registration plates.

We are committed to minimising the impact of this activity on the privacy of members of the public. Where such personal data is captured we apply data-protection-by-design measures, which may include limiting collection to what is necessary for the research or development purpose, anonymising or removing identifiable information (such as blurring faces and plates) as early as practicable in the processing chain, restricting access, encrypting stored data, and applying defined retention limits.

Lawful basis: our legitimate interests in developing safe automotive perception and autonomy technology, balanced against the rights and freedoms of the individuals concerned and subject to the safeguards above. Where required, a Data Protection Impact Assessment is carried out before such processing begins, and customer-specific and jurisdictional requirements are also applied.

Website users

While using our website, we may ask you to provide personally identifiable information, which may include your email address, together with Cookies and Usage Data. We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out at any time by following the unsubscribe link.

We also collect Usage Data – information your browser or device sends when you visit our website, which may include your IP address, browser type and version, the pages you visit, the time and date and duration of your visit, unique device identifiers, mobile device type, operating system and other diagnostic data.

Lawful bases: consent (for example, for non-essential cookies and marketing); and our legitimate interests in operating, securing and improving our website.

USE OF DATA

Provizio Ltd. uses collected data for purposes including:

a. to provide, maintain, operate and improve our website, business, products and services;

b. to develop, test and validate our sensing and perception technology;

c. to administer recruitment, employment and the working relationship;

d. to manage relationships with customers, suppliers, partners and investors;

e. to notify you about changes to our products or website;

f. to provide customer support and respond to enquiries;

g. to gather analysis and insight so that we can improve our products and website;

h. to monitor usage and to detect, prevent and address technical and security issues;

i. to carry out our obligations and enforce our rights under contracts entered into with you, including billing and collection;

j. to provide notices about your account or subscription;

k. to provide news, offers and information about goods, services and events similar to those you have purchased or enquired about, unless you have opted out;

l. to comply with our legal and regulatory obligations;

m. in any other way we describe when you provide the information, or for any other purpose with your consent.

RETENTION OF DATA

We retain Personal Data only for as long as necessary for the purposes set out in this Privacy Policy, including to comply with our legal obligations, resolve disputes, and enforce our agreements and policies. Different categories of data are retained for different periods according to our retention schedule; for example, employment records, business records and research data are each held for periods appropriate to their purpose and legal requirements. Usage Data is generally retained for a shorter period, except where used to strengthen security or improve functionality, or where we are legally required to retain it for longer.

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Transfers of personal data outside the European Economic Area are reviewed before they take place to ensure they meet the requirements of the GDPR, relying on an adequacy decision of the European Commission or appropriate safeguards such as Standard Contractual Clauses. Provizio Ltd. takes all steps reasonably necessary to ensure your data is treated securely and that no transfer takes place to an organisation or country unless adequate controls are in place.

DISCLOSURE OF DATA

We may disclose personal data that we collect or that you provide:

a. For law enforcement – where required to do so by law or in response to valid requests by public authorities.

b. Business transaction – if we or our subsidiaries are involved in a merger, acquisition or asset sale, personal data may be transferred.

c. Other cases – we may also disclose your information: to our subsidiaries and affiliates; to contractors, service providers and other third parties who support our business; to our customers and partners where necessary to deliver our products and services; to fulfil the purpose for which you provided it; for any other purpose disclosed when you provide the information; with your consent; or where we believe disclosure is necessary or appropriate to protect the rights, property or safety of the Company, our customers or others.

SECURITY OF DATA

The security of your data is important to us. We maintain an information security management system and apply technical and organisational measures appropriate to the risk. However, no method of transmission or electronic storage is 100% secure, and while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

YOUR DATA PROTECTION RIGHTS UNDER THE GDPR

The GDPR is one of the most significant pieces of legislation affecting how Provizio Ltd. carries out its processing activities – see https://eur-lex.europa.eu/eli/reg/2016/679/oj. It is our policy to ensure that our compliance with the GDPR and other relevant legislation is clear and demonstrable at all times.

If you wish to know what Personal Data we hold about you, or to have it removed from our systems, please email our Data Protection Officer at dpo@provizio.ai.

In certain circumstances, you have the following data protection rights:

a. the right to access, update or delete the information we hold on you;

b. the right of rectification, if that information is inaccurate or incomplete;

c. the right to object to our processing of your Personal Data;

d. the right of restriction, to request that we restrict the processing of your personal information;

e. the right to data portability, to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;

f. the right to withdraw consent at any time where we rely on your consent to process your personal information.

We may ask you to verify your identity before responding, and we may be unable to provide our products and services without certain necessary data. Each right is supported by procedures within Provizio Ltd. that allow the required action to be taken within the timescales set out in the GDPR.

These timescales are shown below:

DATA SUBJECT REQUEST	TIMESCALE
The right to be informed	One month
The right of access	One month
The right to rectification	One month
The right to object	On receipt of objection
The right to restrict processing	Without undue delay
The right to data portability	One month
The right to withdraw consent	Without undue delay

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. In Ireland this is the Data Protection Commission (www.dataprotection.ie); if you are located elsewhere in the EEA, you may contact your local authority.

Breach notification

It is Provizio Ltd’s policy to be fair and proportionate when informing affected parties about breaches of personal data. In line with the GDPR, where a breach is known to have occurred that is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This is managed in accordance with our Information Security Incident Response Procedure. Under the GDPR, the supervisory authority may impose fines of up to four percent of annual worldwide turnover or twenty million euro, whichever is higher.

CONTACTING THE DATA PROTECTION OFFICER

The Data Protection Officer at Provizio Ltd. can be contacted at dpo@provizio.ai.

YOUR RIGHTS UNDER US PRIVACY LAWS (CalOPPA / CCPA)

CalOPPA requires commercial websites and online services to post a privacy policy – see The California Online Privacy Protection Act (CalOPPA). In accordance with CalOPPA we agree that: users can visit our site anonymously; our Privacy Policy link includes the word “Privacy” and is easily found; users will be notified of any changes on this page; and users can change their personal information by emailing dpo@provizio.ai.

Our policy on “Do Not Track” signals: we honour “Do Not Track” signals and do not track, plant cookies, or use advertising when a “Do Not Track” browser mechanism is in place. You can enable or disable this in the Preferences or Settings page of your web browser.

COOKIES

Our website uses HTTP cookies to store user-specific data. A cookie is a short piece of data exchanged between a web browser and a web server that takes on meaning only for the web application.

There are two types: first-party cookies, created by our website, and third-party cookies, created by other websites (such as Google Analytics). There are three categories: cookies essential to basic functionality, functional cookies for performance, and targeted cookies to improve the user experience.

We use cookies to make our website more user-friendly. Some cookies remain stored until you delete them, allowing us to recognise your browser on your next visit. You can view, change or delete cookies in your browser settings:

• Safari: Managing Cookies and Website Data
• Firefox: Delete cookies
• Chrome: Delete, activate and manage cookies
• Internet Explorer: Deleting and Managing Cookies

If you do not allow cookies via your browser settings, some functions and pages on our website may not work as expected.

SERVICE PROVIDERS

We may employ third-party companies and individuals to facilitate our website, provide it on our behalf, perform related services or assist us in analysing how it is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are contractually obligated not to disclose or use it for any other purpose.

ANALYTICS

We use analytics.google.com to monitor and analyse the use of our website. We reserve the right to use other third-party service providers to do so, subject to appropriate data-protection safeguards.