1. Introduction ‍

Our privacy policy will help you to understand what personal data and information we collect at Baily Labs, how Baily Labs uses it, and what choices you have. When we talk about “Baily Labs,” “we,” “our,” or “us” in this policy, we are referring to ACN Digital Holdings Ltd, the company that provides the Services, with registered address at 20 Harcourt Street, Dublin 2, D02H364, Ireland. When we talk about the “Services” in this policy, we are referring to our online tools, platform and other consulting services. Our Services are currently available over the web, for use via a web browser or applications specific to your desktop or mobile device.

Please read this Privacy Policy carefully before accessing or using our services. If you do not wish that we process your personal data in the manner detailed in this Privacy Policy, please do not submit any personal data to us, browse our website or request any of our services.If you are in the European Union, you may have data protection rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR") as implemented into national law and as each may be amended, extended or re-enacted from time to time (collectively “Data Protection Legislation”). Where the GDPR applies to the personal data we receive about you, you will enjoy full rights under the GDPR as a ‘data subject’. In this Privacy Notice, the terms ‘controller’, ‘data subject’, ‘personal data’, ‘processor’ and 'processing' (and any derivatives of this term) each have the meaning given under Data Protection Legislation. Please note that ‘personal data’ does not include data where the identity has been removed (i.e. anonymous data).

2. Identifying the Data Controller and Processor

Data Protection Legislation differentiates between the controller and the processor of personal data.

2.1 Baily Labs is the controller of personal data and information as outlined in this Privacy Policy. 2.2 Baily Labs may also process personal data and information as a processor, and where Baily Labs collects or processes such data and information, it does so for and on behalf of a controller.‍

3. Personal data and information we collect and receive

The personal data and information we collect and process varies depending on how you use our Services. Typically we collect and process the following types of personal data and information:

3.1 User Data: If you join an organisation and create a user account with us, you are a “user,” as further described in the Baily Labs Terms and Conditions. Information relating to the user is referred to in this policy as “User Data”. Here are some examples of User Data: first and last name of user, contact details of user. You may be a user who is using the Services by invitation of an organisation or other third party that created the account for our Services (“Customer”). Whether that Customer is your employer, another organisation, or an individual, that Customer determines its own policies regarding storage, access, modification, deletion, sharing, and retention of personal data, which may apply to your use of the Services.  Please check with the Customer about the policies and settings it has in place.

3.2 Customer Data: Content and information submitted by users to the Services is referred to in this policy as “Customer Data”. Here are some examples of Customer Data: business name, business phone number, business name

3.3 Transaction data: We or third party payment companies may collect and store billing address and credit card information of our Customers.

3.4 Technical Data: When you use the Services, our servers automatically record information, including information that your browser sends whenever you visit a website, or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the web page you visited before using the Services, your browser type and settings, the date and time of your use of the Services, information about your browser configuration and plug-ins, language preferences, and cookie data; precise GPS location from mobile devices is collected only with your permission. WiFi and Internet Protocol addresses received from your browser or device may be used to determine approximate location.

3.5 Usage Data: We may collect information about the device you are using the Services on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. If, when using the Services, you integrate with a third party service, we will connect that service to ours. The third party provider of the integration may share certain information about your account with Baily Labs. However, we do not receive or store your passwords for any of these third party services.

3.6 Interactions Data: This is information about how you are accessing and using the Services, which may include administrative and support communications with us and information about the teams, people, features, content, and links you interact with, and what third party integrations you use, if any.

3.7 Marketing and Communications Data: Baily Labs may also receive information from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful. This might be aggregate level information, such as which Internet Protocol addresses go with which zip codes, or it might be more specific information, such as about how well an online marketing or email campaign performed.

We collect, use and share aggregated data such as statistical or demographic data for various purposes. Aggregated data may be derived from personal data but is not considered personal data in law as this data does not directly or indirectly reveal the identity of the data subject.

We do not carry out any automatic decision making or profiling.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services).‍

4. How we collect information‍ Typically, we collect information in the following ways:

4.1 Direct Interactions 4.1.1 You may provide us with your personal data and information when contacting us through our website features; when you register as a user or when the Customer purchases or requests any of our services; and when you attend any of our events. You may also provide us with your personal data and information when corresponding with us by post, phone, e-mail or otherwise. 4.1.2 Automated technologies or interactions: As you interact with our website, we collect your personal data, such as Technical Data or Usage Data. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy in this regard

4.1.3 Third party sources: We may receive technical data and information about you from analytics providers such as Google Analytics, as well as our advertising partners. Please see our Cookie Policy in this regard. We also receive Third Party Data from affiliates in our corporate group, our partners, or others that we use to make our own information better or more useful.‍

5. How we use your personal data and information‍

We process your personal data and information in accordance with applicable data protection law. We have set out below a description of the ways we use your personal data and information and the legal grounds for this processing. We have also identified the legitimate interests relied upon where appropriate.

5.1 Performance of a contract with our Customer

5.1.1 We process personal data and information, including User Data and Customer Data, where it is necessary for the performance of the contract for our Services or to take steps to enter into a contract for our Services. This may include: provision of our services, processing and managing Customer orders, registering users, setting up user accounts, communicating with users concerning the use of our Services, providing Customer service support and dealing with queries, complaints and disputes. This is necessary for the provision of the Services to you; necessary for the performance of a contract, or in order to take steps prior to entering into a contract; and is necessary for our legitimate interests (of providing the Services)

5.2 Process and Manage orders

5.2.1 We process personal data, including User Data, Customer Data and Transaction Data to perform our contracts, provide our service, manage payments and charges, and collect money owed to us. This may include: processing Transaction data and keeping track of billing and payments. This is necessary for the provision of the Services to you; necessary for the performance of a contract, or in order to take steps prior to entering into a contract; and is necessary for our legitimate interest (of providing the Services and to identify and/or prevent fraud).

5.3 Managing our Relationship with our Customers.

5.3.1 We process personal data and information, including Customer Data, to manage and improve our relationship with you. This may include: arranging your attendance at our events, providing information regarding our Services and events, providing Customer service support and dealing with queries, complaints and disputes, notifying you about changes to our terms and/or our privacy policy. This is necessary for the provision of our Services to you; necessary for the performance of a contract, or in order to take steps prior to entering into a contract; is necessary for our legitimate interests (for providing the Service, developing our business and informing our marketing strategy). We may also notify you about changes to our Terms and/or this Privacy Policy. This is necessary to comply with a legal obligation.

5.4 Administering and protecting our business

5.4.1 We process personal data and information, including Technical Data, Usage Data and Interaction Data to administer and protect our business and our website. This may include: troubleshooting, data analysis, testing, system maintenance, support and reporting. This is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to identify and/or prevent fraud).