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WealthPilot Customer Data Research and Development Privacy Policy
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1. INTRODUCTION
This WealthPilot Customer Data Research and Development Privacy Policy (also referred to as the ‘Privacy Policy’ or ‘policy’) informs data subjects (‘you’) on the collection and use (collectively referred to as ‘processing’ or ‘process’) of your personal information in connection with WealthPilot’s artificial intelligence and machine learning (“AI/ML”) activities in order to analyze, develop, and improve WealthPilot products and services, and for security and compliance purposes. This Privacy Policy also explains your privacy rights in relation to these processing activities.
This Privacy Policy was created on June 7, 2023. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this site. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our website).
As used in this Privacy Policy, ‘personal information’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, or information about your use of WealthPilot products and services, or your interactions with WealthPilot. Personal information about you that WealthPilot may process is also referred to as ‘information about you.’ For more detail about the types of information about you that WealthPilot may process, please refer to section 4 below.
2. SCOPE
This Privacy Policy applies to WealthPilot’s processing of personal information that WealthPilot has obtained from an WealthPilot customer when agreed to by contract with that customer to use such information for AI/ML processing for the purposes specified in this Privacy Policy.
3. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?
WealthPilot is responsible for processing your personal information in scope of this Privacy Policy.
4. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?
Personal information that can directly or indirectly identify you may include, for example:
- Contact details: Name, email, phone number, mailing address, zip code;
- Company and employment data: your employment with and role within a company, including information related to such company such as company name, size, location, as well as publicly available company information and activity;
- Device information: Information related to a device interacting with WealthPilot products, services, and websites including IP address, browser, device type, operating system, the presence or use of “apps”, screen resolution, preferred language;
- Interactions with WealthPilot services or products: Information related to the use of WealthPilot services and products, such as products and services purchased, subscriptions, features used or platform preferences, or performance of WealthPilot services or products;
WealthPilot may also collect customer and systems operations data, which may incidentally contain personal information:
- Customer data: Data provided by WealthPilot customers (when agreed to by contract with the customer) such as transaction data, invoices or receipts, product inventory, and other customer-provided datasets;
- Systems operations: Information related to the use, operation, and performance of WealthPilot systems such as log files, event files, and other trace and diagnostic files.
5. FOR WHAT COMMERCIAL OR BUSINESS PURPOSE DO WE USE YOUR PERSONAL INFORMATION?
In cases where the processing of personal information is not central to the purposes of processing for the below AI/ML activities, WealthPilot will limit the use of personal information when technically possible or feasible. ‘Dataset’ refers to a set of data that may contain this limited personal information.
We use personal information for the following business purposes:
- to analyze, develop, improve, and optimize the use, function and performance of WealthPilot products and services to provide our customers with a more intelligent experience.
- to manage the security of websites, networks and systems and the products and services WealthPilot provides to our customers; and
- to comply with applicable laws and regulations and to operate our business.
These purposes are described below in further detail.
- to analyze, develop, improve, and optimize the use, function and performance of WealthPilot products and services to provide our customers with a more intelligent experienceWealthPilot will use these datasets for internal research for technological development and demonstration and to improve, upgrade, or enhance WealthPilot products and services to provide more intelligent, automated and predictive functionalities.
- to manage the security of our sites, networks and systems and the products and services WealthPilot provides to our customersWealthPilot processes datasets to detect, prevent, or predict malicious, deceptive, fraudulent, or illegal activity on WealthPilot sites, networks, and systems, as well as on WealthPilot products and services used by our customers. AI/ML activities, subject to this policy, allow WealthPilot to provide more intelligent and predictive functionalities to investigate, prevent, or predict malicious activity, fraud, or bad actors.
- to comply with applicable laws and regulations and to operate our businessIn some cases, we may process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the operation of our business.Example: WealthPilot may process the datasets to conduct audits and investigations, for finance and accounting, archiving and insurance purposes, or to process individual rights requests.
6. CATEGORIES OF SOURCES OF PERSONAL INFORMATION
Personal information subject to this Privacy Policy is provided to WealthPilot from WealthPilot customers when agreed to by contract with the customer.
7. FOR INFORMATION ABOUT YOU COLLECTED, WHAT IS OUR LEGAL BASIS?
WealthPilot will process information about you as may be necessary for internal research for technological development and demonstration and to improve, upgrade, or enhance WealthPilot products and services based on our legitimate interests when such processing has a limited privacy impact on the individual.
WealthPilot will process information about you as may be necessary to detect, prevent, or predict malicious, deceptive, fraudulent, or illegal activity on WealthPilot sites, networks, and systems based on our legitimate interests in order for WealthPilot to safeguard such systems.
WealthPilot may also process personal information as necessary for compliance with our legal obligations.
8. FOR WHAT PERIOD DO WE RETAIN INFORMATION ABOUT YOU?
WealthPilot maintains personal information provided by WealthPilot customers for processing to achieve the intended purposes described in this Privacy Policy for only as long as necessary, which is approximately 3 months but no longer than 12 months. WealthPilot will maintain evidence of access, opt-out, or deletion requests as long as necessary to document WealthPilot’s compliance with such requirements.
9. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?
Sharing within WealthPilot
Information about you can be shared throughout WealthPilot’s organization as needed for the purposes of processing.
WealthPilot employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.
Sharing with or selling with third parties
We do not share or sell personal information subject to this Privacy Policy with third parties for any commercial purposes.
We may share such personal information with the following third parties for a business purpose:
- third-party service providers (for example, IT service providers, lawyers and auditors) in order for those service providers to perform business functions on behalf of WealthPilot;
- relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
- as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.
10. HOW IS PERSONAL INFORMATION PROTECTED GLOBALLY?
Personal information is processed as necessary in accordance with this policy. If personal information is transferred to an WealthPilot recipient in a country that does not provide an adequate level of protection for personal information under applicable data protection law in the country where such information was collected, WealthPilot will take adequate measures designed to protect the personal information, such as ensuring that such transfers are subject to an adequate transfer mechanism as required under relevant data protection laws.
11. HOW IS INFORMATION ABOUT YOU SECURED?
WealthPilot has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.
12. WHAT ARE YOUR PRIVACY RIGHTS?
Pursuant to applicable laws and regulations, individuals in certain jurisdictions may have data subject rights enabling them to opt-out of third party sharing or selling, delete or correct, or request to access and receive a copy of their personal information in WealthPilot’s possession or for which WealthPilot is otherwise responsible.
WealthPilot provides rights to individuals to access, amend, correct, or delete data for personal information that directly identifies such individuals, such as their name or email address.
We will respond to your request consistent with applicable law. WealthPilot will not discriminate against consumers who have exercised the deletion, opt-out, or access rights provided to them in this Privacy Policy.
13. DOES WEALTHPILOT PROCESS PERSONAL INFORMATION FROM CHILDREN OR OTHER SENSITIVE PERSONAL INFORMATION?
We do not knowingly process personal information of children under 16 years of age or personal information that is sensitive or “special” under applicable data protection laws.
WealthPilot will not use the personal information processed under this policy to make decisions related to an individual’s eligibility for employment, credit, healthcare, or insurance purposes or to make decisions solely by automatic means where the decision has a legal or significant effect on the individual, or in any way that may or does discriminate against any person or promote bigotry, racism or harm.
14. HOW TO CONTACT WEALTHPILOT IF YOU HAVE QUESTIONS, COMMENTS OR COMPLAINTS?
WealthPilot has appointed a Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, or if you wish to exercise your right to access to your offline personal information as described in this Privacy Policy, please contact the Data Protection Officer by sending us an inquiry.
15. FILING A COMPLAINT
If you have any complaints regarding our compliance with this Privacy Policy, please contact us by sending us an inquiry. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.
16. WEALTHPILOT CORPORATE HEADQUARTERS
WealthPilot’s corporate headquarters are located at:
105/838 Collins Street
Docklands, Victoria, 3008
Australia
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