Personal Information Collection Statement and Privacy Policy

We, Dayta AI Limited (“Dayta AI”) are committed to safeguarding your privacy as users of our Service (as defined below) and pledge to observe the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 in the Laws of Hong Kong) (the “Ordinance”). This Privacy Policy (“Policy”) applies to all services provided by us and sets out how we may collect, use, transfer, process, store and disclose your personal data (“Personal Data”).

For the purposes of this Policy, we will call our website (i.e. https://www.dayta.ai/) (the “Site”), apps and all corresponding support and interactions with you, including (i) the Site, its subdomains, and any other website where Dayta AI’s Terms of Use are posted; (ii) Dayta AI online hosted services; and (iii) Dayta AI’s “Technology,” meaning, collectively, our integrations, mobile applications, application programming interfaces (“APIs”), and tools and documentation (the Site as well as (i) through (iii), collectively, our “Service”, “Software” or “Cyclops”).

By using our Service, you consent to our collection, use, transfer, processing and disclosure of your Personal Data (as defined below) in accordance with this Policy. If you do not consent to our collection, use, transfer, process and disclosure of your Personal Data in accordance to this Policy, please stop using our Service immediately.

Types of Information and Data Dayta AI may collect and the Purpose of Collection

By using our Service, Dayta AI may be collecting the following categories of information from you.

a. Non-Identifiable Information

Like many other websites, the Site automatically collects certain non-identifiable information (“Non-Identifiable Information”) regarding Site users, such as the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the Site, the Internet address of the website from which you linked directly to the Site, the operating system use, the sections of the Site you visit, the pages read and images viewed and the content(s) you download from the Site. This Non-Identifiable Information is used for Site and system administration purposes and to improve the Site. We also may use Non-Identifiable Information to initiate interactive, real-time discussions with users. Your Non-Identifiable Information may be disclosed to others and permanently archived for future use.

b. Non-Personal Data

Non-Personal Data is information about a user, but by itself does not identify a specific individual (e.g. demographic information, usage data, device hardware and software data, broad geographic location, and download history etc) (“Non-Personal Data”).

By using our Service, Dayta AI may be collecting your Non-Personal Data. Dayta AI may collect Non-Personal Data directly from you, through our third-party service providers, or automatically through tools including, but not limited to, cookies, web beacons, and analytics programs embedded within our Service. We may use Non-Personal Data to create aggregate tracking information reports regarding the Site’s user demographics, traffic patterns and purchases etc. None of the tracking information in the reports can be connected to the identities or other Personal Data of individual users.

c. Personal Data

“Personal Data” shall have the meaning ascribed to it under the Ordinance in Hong Kong and may include a user’s name, postal mailing address, GPS location information, email address or telephone number or credit card information, etc (“Personal Data”).

By using our Service, you are voluntarily consenting that Dayta AI may collect your Personal Data. We will only collect Personal Data about you when you voluntarily provide it, opt-in or decline to opt-out of collection. Please keep in mind that some our Service may be unavailable to you if you choose not to share certain information with us.

We may use your Personal Data to contact and correspond with you, to respond to your inquiries, to process transactions and payments and to facilitate and enhance your use of the Site.

If your Personal Data changes, or if you no longer desire to use our Service, you may request to correct, update, or delete your Personal Data by making the appropriate changes to your Cyclops Account information by visiting our Site or by contacting us or our data protection officer by telephone or postal mail at the contact details listed below.

Cookies and Similar Technologies

The Site uses cookies, a technology that installs a small amount of information on a user’s computer to permit the Site to recognize future visits using that computer. Cookies statistics are collected for the purpose of managing and enhancing user convenience and use of the Site and do not identify you. For example, the information provided through cookies is used to recognize you as a previous user of the Site, so you do not have to enter your personal information every time, offer personalized web page content and information for your use, track your activity at the Site to respond to your needs and otherwise facilitate your Site experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Site and your ability to access certain features of the Site or engage in transactions through the Site.

Emails from us

From time to time, we may send emails, or other communications containing information about us or other matters (such as marketing or advertising messages, such as changes to features of Cyclops and special offers) that we believe will interest you. At any time you may ask us to stop sending you emails and other information by unsubscribing. We respect your privacy and do not sell, rent or abuse our user email list. Also, each email sent by us will tell you how to unsubscribe from further emails if you do not wish to receive them anymore, or you may inform us by contacting us or our data protection officer at the details set out below.

Protect your Information and Security

Dayta AI follows generally accepted industry standards to protect against unauthorized or accidental access, processing, erasure, loss or use of the transferred data. For Dayta AI, this includes, but is not limited to, ensuring that all Personal Data is collected via encrypted connection and is disclosed to authorized personnel only on a “need to know” basis. That said, we cannot guarantee absolute security of Information because no method of transmission over the Internet or electronic storage is 100% secure. To the extent that the collection, use and processing of Personal Data is done by our service providers who may process Personal Data on behalf of us (whether within or outside Hong Kong) , we adopt contractual measures or other means to ensure they comply with the terms of this Policy and the applicable requirements under the Ordinance.

Disclosure of Your Personal Data

We will not sell, rent or otherwise disclose your Personal Data to any third party, without your consent except in the following circumstances:

a. Disclosure to Service Providers

In order to process transactions, we may disclose some of your Personal Data to certain service providers. Before personal information is disclosed, the service provider will agree with us to protect the privacy of your Personal Data in a manner that is consistent with this Policy. If you do not wish us to provide your Personal Data to those service providers, you may not use the Site or our Service.

b. Law Enforcement and Legal Disclosure

We may disclose your Personal Data to government institutions and/or enforcement authorities that have asserted their lawful authority to obtain the Information or where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to our legal counsel.

How We Transfer Data We Collect

By using our Service, you agree that we may disclose and transfer the data we have collected including your Personal Data in connection with a transaction with another company which affects the control, governance, structure and/or management of all or a substantial part of Dayta AI’s business, or if required to satisfy applicable legal or regulatory requirements.

Retention of Personal Data

Dayta AI shall keep your Personal Data for as long as necessary to achieve the purpose for which it was collected and to comply with legal requirements. If Dayta AI no longer needs your personal information for any purpose, it will take reasonable steps to securely delete or destroy your personal information.

The Non-Personal Data and Personal Data of accounts with active subscriptions will always be available. Upon end of the subscription, such information will be retained for one year, and can be re-accessed after successful subscription renewal. After one year of end of subscription without successful subscription renewals, all the Non-Personal Data and Personal Data of the accounts will be automatically deleted from all Cyclops databases and will not be recoverable.

Accessing and/or Correcting your Personal Data

You may request to access, correct your Personal Data and/or obtain information regarding our privacy policies and practices by contacting our data protection officer at support@dayta.ai (see also contact details below). Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information, entitlement to challenge the accuracy and completeness of the information and the ability to have it amended as is appropriate. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. Dayta AI has the right to charge a reasonable fee for processing such data access and/ or correction request.

Changes

To accommodate changes on the Site, changing technology and legal developments, we have the sole discretion to change this Policy from time to time without any prior notice or liability to you or any other person. New versions of this Policy will be posted on the Site. Our collection, use and disclosure of your Personal Data will be governed by the version of our Policy in effect at that time. If we make any material changes to the Policy, we will notify you by email (sent to the email address specified in your Cyclops Account) or by means of a notice on theSite prior to the change becoming effective. Accordingly, when you use the Site, you should check the date of our Policy and review any changes since the last version.