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Privacy Policy & Cookies

Effective Date: October 06, 2025

This Policy describes the personal data collection and processing practices for the Seenly.ai website and the SaaS services provided by Etienne Solutions SRL, in accordance with Regulation (EU) 2016/679 (“GDPR”) and applicable national laws.

This Policy covers two distinct roles we fulfill:

Data Controller: For the data of our direct customers (billing data, user accounts, our own marketing).
Data Processor: For the data that customers input into the platform for analysis (prompts, logs). These are governed in detail under the Data Processing Agreement (DPA).

1. IDENTITY OF THE CONTROLLER

Your data is processed by:
ETIENNE SOLUTIONS SRL (“Seenly”, “We”, “Us”)
Registered office: Bucharest, Romania
Tax Identification Number (CUI): 33090409
Trade Registry Number: J40/4960/2014
DPO / Privacy Email: [email protected]

Given the B2B (Business-to-Business) nature of our services, we primarily process data belonging to representatives of legal entities. However, we treat these details with the same level of security as any personal data.

2. WHAT DATA WE COLLECT AND HOW WE OBTAIN IT

We collect information in three main ways:
(A) Directly from you,
(B) Automatically through service usage, and
(C) Through tracking technologies (Cookies).

2.1. Data Provided Directly (When you create an account or contact us)

Identification & Contact Details:
Name, surname, professional email address, phone number, job title, company name.

Authentication Data:
Username, password (stored securely using hashing).

Financial Data:
Billing address, company tax identifiers, bank details.
Note: We do not store full credit card details; payments are processed exclusively and securely by Stripe.

Communications:
Messages or support tickets sent to our support team.

2.2. Data Collected Automatically (When using the application)

Technical Logs:
IP address, browser type, operating system, internet provider (ISP), access timestamps.

Usage Data:
Login frequency, accessed features, dashboard configurations, encountered errors.

AI Metadata:
Volume of processed prompts, types of LLM models used (without accessing the actual prompt content for unauthorized purposes).

3. PURPOSES AND LEGAL BASES FOR PROCESSING

We process your data strictly for the purposes listed below, based on the legal grounds defined under GDPR:

Purpose of Processing

Legal Basis (GDPR)

Service Provision: Account creation, authentication, access to SaaS features

Performance of Contract (Art. 6(1)(b))

Billing & Financial Management: Invoicing, payment processing, accounting

Legal Obligation (Art. 6(1)(c))

Security & Optimization: Fraud prevention, cyberattack detection, debugging

Legitimate Interest (Art. 6(1)(f))

Customer Support: Replies to tickets, administrative notifications

Performance of Contract (Art. 6(1)(b))

Marketing & Newsletters: Sending updates, offers, invitations

Consent (Art. 6(1)(a))

4. COOKIE POLICY AND SIMILAR TECHNOLOGIES

The Seenly.ai website and app use cookies for core functionality and analytics.

4.1. What are cookies?

A cookie is a small text file stored on your device that allows us to recognize you upon return or maintain your session.

4.2. Types of cookies used:

Essential (Strictly Necessary):
Mandatory for the platform to function (session cookies, CSRF security cookies, Stripe payment cookies).
No prior consent required.

Analytics (Statistics):
Help us understand how the website is used (e.g., Google Analytics 4).
Collect anonymized usage information.

Marketing (Optional):
Used to display relevant ads on other platforms (e.g., Google Ads, LinkedIn Insight Tag, Meta Pixel).

4.3. Cookie Management

Upon your first visit, you will be asked for consent for non-essential cookies.
You can withdraw this consent at any time via your browser settings (Chrome, Firefox, Safari, Edge) or tools like Ghostery or AdBlock.

Refusing essential cookies may make the Platform unusable (e.g., login may not work).

5. WHO HAS ACCESS TO YOUR DATA?

We do not sell your data to third parties.
We only share it with trusted partners (Processors) strictly necessary for service operation:

Payment Processor:
Stripe (Ireland/USA) – for subscription payments.

Cloud Infrastructure & Hosting:
Servers hosted in the European Union (AWS / DigitalOcean / Google Cloud), compliant with industry security standards (ISO 27001).

Traffic Analytics:
Google Analytics (anonymized data).

Email Services:
Transactional email providers (e.g., SendGrid / AWS SES) for sending invoices and password resets.

Authorities:
Only if required by law or court order.

All partners are contractually bound to confidentiality and GDPR compliance.

6. INTERNATIONAL DATA TRANSFERS

We prioritize storing all data within the European Economic Area (EEA).

When we use providers located outside the EEA (e.g., USA), we ensure lawful transfers using:

  • European Commission Adequacy Decisions (e.g., EU-US Data Privacy Framework).

  • European Commission Standard Contractual Clauses (SCCs) signed with respective providers.

7. DATA SECURITY

Etienne Solutions SRL applies strict technical measures to protect data:

Encryption:
All sensitive data is encrypted in transit (HTTPS/TLS 1.2+) and at rest (encrypted databases).

Access Control:
Administrative access is role-based (RBAC) and protected via 2FA.

Backups:
Daily backups are performed to prevent data loss.

Passwords:
We never store passwords in plain text; only secure hashing algorithms (e.g., bcrypt/argon2).

However, no method of online transmission is 100% secure.
If you suspect account compromise, contact us immediately.

8. DATA RETENTION

Active Account:
Data is retained for the entire duration of the account.

After Account Closure:

  • Usage data (logs, analytics) is deleted 30 days after closure.

  • Billing data is retained for 10 years, per Romanian Accounting Law.

  • Marketing data is deleted immediately upon unsubscribe.

9. YOUR GDPR RIGHTS

As a data subject, you have the following rights:

  • Access – Request a copy of your personal data.

  • Rectification – Correct inaccurate or incomplete data.

  • Erasure (“Right to be Forgotten”) – Request deletion when data is no longer needed or consent is withdrawn (except mandatory fiscal data).

  • Restriction – Request suspension of processing in certain cases.

  • Portability – Receive your data in a structured format (CSV/JSON).

  • Objection – Object to processing for direct marketing purposes.

To exercise any right, send a written request to [email protected].
We will respond within a maximum of 30 days.

10. DATA ENTERED BY CLIENTS (PROCESSOR ROLE)

For data you upload into the platform for analysis (prompts, AI content):

  • Seenly acts as Data Processor.

  • The Client acts as Data Controller and must have a lawful basis for the data entered.

  • Seenly will not access the content of your prompts except through automated processing or for explicit technical troubleshooting requested by you.

  • We do NOT use your confidential data to train public AI models without your explicit consent.

11. UPDATES AND CONTACT

We reserve the right to update this Policy.
Any major changes will be communicated by email or via an in-app notification.

Questions?
Contact our Data Protection Officer:

📧 [email protected]
🏢 Bucharest, Romania – Etienne Solutions SRL

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