Last updated: April 4, 2023
This Privacy Policy is designed to provide data subjects with information on the processing of their personal data (any information relating to them) in the context of using our website and services provided by Beyond ML, including Sellesta, Recommendix and TuneTheAds (each of them is referred to as “Service”).
This Privacy Policy is based on the provisions of data protection laws, which may be applicable in the country of your residence.
Data controller with regard to personal data processed under this Policy is a company providing the Service under the agreement accepted by the data subject. For instance, it may be (1) Beyond ML Inc. (10 State street, Newburyport, MA 01950, United States) or (2) Beyond ML LLC (Republic of Armenia, Yerevan, 0026, Arshakunyats av., 49-22) (each of them is referred to as “Beyond ML”). Please refer to the Agreement if you would like to check the identity of the controller which defines the purposes and means of the processing in your particular situation.
Data subjects can contact Beyond ML on any questions relating to the processing of their personal data under this Privacy Policy by sending their request at [email protected].
Beyond ML processes personal data to ensure smooth operation of the website and Services; to provide the Service to its users/customers; to handle users’/customers’ requests; to comply with applicable laws; to market the Service; to improve the Service; to protect Beyond ML’s legal rights.
When doing so, Beyond ML relies on:
(1) the necessity of the processing for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
(2) the necessity of the processing of personal data to comply with its legal obligations;
(3) the necessity of the processing of personal data for the purposes of the legitimate interests pursued by Beyond ML.
In some cases, Beyond ML relies on (4) a consent of a data subject to process his or her personal data.
The legitimate interests of Beyond ML consist of: (1) compliance with applicable laws and regulations; (2) promoting the Service (except for the cases, where consent is required); (3) improvement of the Service, including with the use of machine learning tools; (4) conducting of aggregated analytics; (5) protection of Beyond ML’s legal rights.
Data subjects can get more information on the legitimate interests pursued by Beyond ML and relevant balancing tests by sending a request with the use of contact details specified in section 1 of this Privacy Policy.
Please note that if under applicable laws processing of your personal data can be justified only by consent or other relevant legal ground, we will obtain such consent or ensure presence of respective legal ground.
Beyond ML processes the following categories of personal data:
• registration/authentication data (email; company name; job title);
• contact details (email; phone number);
• automatically collected information about usage of the Service collected through cookies or similar technologies (learn more in our Cookie Policy available at https://sellesta.com/cookie-policy);
• information about payments for the usage of the Service;
• information about customer’s web-resources;
• personal data contained in the information access to which was provided by users in the process of using the Service (if any).
As part of some Services, Beyond ML can also have access to information about marketing campaigns that is stored by external provider of advertising services (Google Ads). In this regard, please note that our use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
We can also see aggregated statistics about conducted marketing campaigns, but such reports do not contain any personal data.
Beyond ML discloses certain personal data to the following recipients to the extent required or permitted by applicable law and/or based on their legitimate and reasonable requests:
• affiliate entities of Beyond ML which are a part of the same group of companies;
• providers of cloud services for storing and processing personal data;
• partners providing us sales and marketing services and solutions;
• providers of payment services;
• partners otherwise assisting in provision of the Service by Beyond ML and achievement of other purposes mentioned in the section 2 of this Privacy Policy;
• various state and municipal authorities if strictly required to respond to their legitimate formal inquiries;
• other third parties when it is required for compliance with applicable laws.
Beyond ML may transfer personal data of the data subjects to third countries, including those that do not provide the same level of data protection as in the country of your residence. When doing so, Beyond ML ensures implementation of security measures aimed at protection of your personal data in an appropriate manner.
The data subjects can get more information on the mechanisms of transfers to third countries by Beyond ML by sending a request with the use of contact details specified in section 1 of this Privacy Policy.
Beyond ML stores personal data as long as it is required to achieve the purposes of the processing specified in section 2 of this Privacy Policy, unless there are specific periods defined in applicable laws.
The data subjects, in respect of their personal data, have rights to:
1. access;
(The data subject can ask Beyond ML to confirm whether or not Beyond ML processes his/her personal data. If so, the data subject can access these personal data and can ask Beyond ML to explain certain details of the processing.)
2. rectification;
(The data subject can ask Beyond ML to correct inaccurate personal data concerning him or her. If it complies with the purposes of the processing, the data subject can ask Beyond ML to complete incomplete personal data.)
3. erasure (‘right to be forgotten’);
(The data subject can ask Beyond ML to erase personal data concerning him or her under applicable law. For example, this applies if (1) the personal data are no longer necessary in relation to the purposes for which they were processed; (2) the data subject withdraws consent to the processing and there is no other legal ground for the processing; (3) the personal data have been unlawfully processed.)
4. restriction on processing;
(The data subject can ask Beyond ML to mark the stored personal data with the aim to limit their processing in the future under applicable law. This applies if (1) the data subject contests the accuracy of the personal data; (2) the data subject asks to restrict the use of the personal data when their processing is unlawful; (3) the data subject needs personal data to protect their rights when Beyond ML no longer needs the personal data; (4) the data subject has objected the processing based on the legitimate interests pursued by Beyond ML or by a third party.)
5. objection to processing (if provided to the data subjects under applicable data protection laws);
(The data subject can object, on grounds relating to their particular situation, at any time to processing of personal data concerning him or her which is based on the legitimate interests pursued by Beyond ML or by a third party. Beyond ML shall no longer process the personal data unless Beyond ML demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.)
6. portability (if provided to the data subjects under applicable data protection laws);
(When the processing is based on consent of the data subject or on a contract with the data subject, the data subject can receive the personal data concerning him or her, which he or she has provided to Beyond ML, in a structured, commonly used and machine-readable format and can freely transmit those data to another service. Where technically feasible, the data subject can also ask Beyond ML to transmit the personal data directly to another controller.)
To exercise their rights, data subjects can contact Beyond ML with the use of contact details specified in section 1 of this Privacy Policy.
Where processing is based on consent (or explicit consent), the data subject has the right to withdraw consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal. To withdraw consent, the data subject can contact Beyond ML with the use of contact details specified in section 1 of this Privacy Policy.
When provided by applicable data protection laws, a data subject has the right to lodge a complaint with a supervisory authority in the area of data protection in the country of his/her residence.
There are no general statutory or contractual requirements for data subjects to provide Beyond ML with personal data processed under this Privacy Policy.
Beyond ML collects personal data from the data subjects themselves or automatically during usage of the Service.
Beyond ML may change this Privacy Policy from time to time at its sole discretion. If so, Beyond ML may notify the data subjects about these changes by an appropriate method. If there is no explicit notification, the data subjects may always review the up-to-date version of this Privacy Policy located at https://sellesta.com/privacy-policy.