Privacy Policy

Introduction

This privacy policy aims to give you information about how Edgify AI Limited (“Edgify”, "we," "us," or "our") collects and uses your personal data through your use of our Site, Dashboard, Solution or other services, or where you visit a store operated by one of our retail customers in which the Solution is deployed, and tells you about your privacy rights and how the law protects you.

Controller

Edgify AI Limited (company number: 09359462), a company incorporated in England with its registered address at 307 Euston Road, London, England, NW1 3AD is the controller and is responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

• Full name of legal entity: Edgify AI Limited
• Email address: support@edgify.com
• Postal address: Edgify AI Limited, 307 Euston Road, London, England, NW1 3AD

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Third-party links

The Site and the Dashboard may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site or the Dashboard, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, job title and company.
• Contact Data includes email address, telephone numbers and mailing address.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access the Site or Dashboard.
• Usage Data includes information about how you interact with and use the Site, Dashboard and Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Customer Data includes images and video footage incidentally captured by cameras at the point-of-sale in our retail customers’ stores, which may show the heads, faces, upper bodies, hands and arms of shoppers (including adults and children accompanying them), store employees and bystanders, and potentially payment cards or ID held within the camera’s field of view.

We do not intentionally collect any Special Categories of personal data about you. However, Customer Data may incidentally reveal information such as your religious beliefs (for example, religious dress) or a visible disability (for example, a wheelchair or crutches). We do not use Customer Data to identify you, and we do not carry out any facial recognition, biometric identification or behavioural profiling on it.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data when:

• you request a demo or register an account via the Site;
• express an interest in obtaining information about us or our products and Services; or
• by corresponding with us by post, phone, email or otherwise.

Automated technologies or interactions. As you interact with the Site or Dashboard, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy ([Insert Link to Cookie Policy]) for further details.

Third parties or publicly available sources. We will receive Technical or Usage Data from Google Analytics about you.

Our retail customers. Where our Solution is deployed in a retail store, cameras at the point-of-sale capture real-time video footage (the “Footage”). Faces or other identifiers may be incidentally captured in the Footage, and while we try our best to deploy technology which automatically blurs such personal data before the Footage is uploaded to the cloud and shared with us, the blurring is not 100% accurate. Therefore, some unblurred images of individuals (i.e. the Customer Data) may be shared with us from our retail customer.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where we have obtained your consent to use your personal data for a specified purpose.

Opting out of marketing. As our customer, we may send you marketing messages about our products or Services. You can ask us or third parties to stop sending you marketing messages at any time by emailing us at support@edgify.com, following the opt-out links on any marketing message sent to you or by contacting us at any time.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Use	Type of data	Legal basis
To administer and protect our business, the Site, the Dashboard and our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical (d) Usage	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) or consent, having obtained your prior consent to receiving direct marketing communications.
To monitor trends so we can improve the Services.	(a) Identity (b) Contact (c) Technical (e) Usage	Necessary for our legitimate interests (to develop our Services, define types of customers for our products and services, to develop our business and to inform our marketing strategy).
To train and improve the accuracy of our Solution and services, including the face-detection (blurring) technology used across our Solution and the scan-event detection capabilities, for the benefit of all of our customers and products.	Customer Data	Necessary for our legitimate interests (to develop and improve our products, and to ensure that faces are reliably blurred so that the privacy of individuals in our customers' stores is protected).

Direct marketing

We may send direct marketing communications to you via email or telephone from time to time where permitted to do so and you have not otherwise opted out of receiving such communications from us.

We may also analyse your Identity, Contact, Technical and Usage Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Customer Data and AI Training

We use Customer Data to train the underlying AI models used in the Solution. This training is focused on the items being scanned, scan events and the success of the face blurring, rather than on any individual or their personal data. Customer Data is used for training in two ways:

• Scan event accuracy: Customer Data relating to loss detection and product recognition is used solely to improve the accuracy of the Solution deployed for the specific retail customer from whom it was received. It is not sold or monetised and is not used for any other purpose. In carrying out this training we act as a processor on behalf of the relevant retail customer, which is the controller of that data, and you should refer to that retailer’s privacy notice for further information.
• Facial blurring accuracy: Customer Data is also used to train and improve our face-detection (blurring) model, which is a shared component deployed across all of our customers and products. Because this model is designed to detect heads in order to blur them, this training necessarily uses unblurred images, and we only do so with the relevant retail customer’s express permission. We act as a controller of Customer Data used for this purpose, as described in this privacy policy.

Children: Children may appear incidentally in Customer Data where they accompany adults at checkouts. We do not target, identify or differentiate children, and blurring applies equally regardless of age. To make sure our blurring model works well for everyone, we have included additional images containing children in our training dataset and we measure its performance on children’s heads separately.

Customer Data is protected by encryption, strict role-based access controls limited to a small number of authorised personnel, and audit logging. No decision or action with legal or similarly significant effect is taken about any individual based solely on automated processing of Customer Data, and trained models do not contain recoverable images of any individual.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law

Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Third parties for the purpose of providing the Services to you.
• Our affiliates and/or companies within the group.
• Service providers acting as our processors, including our cloud hosting provider (Google Cloud Platform), which host and store Customer Data on our behalf.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that our arrangements have a legal basis or, if necessary, an appropriate safeguard is in place to protect your personal data during and after the transfer.

Customer Data may be accessed by our personnel in the UK and at our development centre in Israel. Israel is recognised as providing an adequate level of protection for personal data under UK law.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Customer Data uploaded to the cloud for model training is automatically deleted after 90 days.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have a right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

Please note that we do not use facial recognition and cannot search Customer Data by reference to an individual’s identity. If you wish to exercise your rights in relation to Customer Data, please provide details of your visit (for example, the store, checkout lane and date and time, such as from your receipt) so that we can locate any relevant footage. Where we process Customer Data as a processor on behalf of a retail customer, we may refer your request to that retailer.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Consent means that you have given us permission (your consent) to process your personal data for one or more specific purposes.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Dashboard means the platform which may be licensed to your employer or any other entity which engages you that allows you to access the Services.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Services means the services provided by Edgify to your employer or any other entity which facilities your access to the Dashboard.

Solution means Edgify’s edge-based artificial intelligence solution for product recognition and loss detection at the point-of-sale in physical retail stores.

Site means our website at https://edgify.ai/.

We keep our Privacy Policy under regular review. Any changes we make to this privacy statement in the future will be posted to the Site. Any such changes will ensure that your rights are fully safeguarded. In any event, we encourage you to check the updated statement published on the Site from time to time.

Questions: support@edgify.com