Privacy Policy

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Introduction

Data Initiative S.R.L., a Romanian limited liability company, with its headquarters in 21, Ciocirliei street, Busteni, Prahova, Romania, registered with the Romanian Trade Registry under no. J29/103/2020, having fiscal registration code 42136661 (“AgainstData®”, “we”, or “us”), is the personal data controller and the entity that administers the https://againstdata.com/ website (the “Site”) and https://app.againstdata.com/ application (the “AgainstData App” or the “App”) through which your personal data is collected and processed when you use our Site and App.

We are committed to respecting your privacy, by complying with the applicable data protection laws and regulations, including the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).

Through this privacy policy (“Policy”) we explain to you the purposes for which we collect and use your personal data, the processing grounds on which we rely, the categories of personal data we process, the duration of the processing of such data, and the entities to which we may disclose such data (where applicable).

This Policy (together with the Terms and Conditions of the Site and AgainstData App, the Cookies Policy and any other documents available in the Site and App) aims to provide you with information about the processing of personal data provided to us by you or that we collect as part of our relationship with you through Site and AgainstData App and your access to the services available on the App (“Services”).

Please read the following carefully to understand our practices regarding your personal data and how we will treat them.

Processing of personal data

In the following sections you will find information regarding the purposes of the processing of personal data, the legal ground of the processing for each applicable purpose, the categories of processed data, the duration of the processing, the source of the data collection, the recipients and the transfer of personal data.

Use of Analytics and Marketing Technologies

In order to understand how Users interact with the Site and to measure the effectiveness of our advertising campaigns, we use certain third-party technologies, including:

• Google Tag Manager – a tag management system provided by Google Ireland Limited, used to manage and deploy tracking scripts on our Site.
• Meta (Facebook) Pixel – a marketing and analytics tool provided by Meta Platforms Ireland Limited, used to measure conversions and optimize advertising campaigns.
• Bing - a tagging system provided by Microsoft, used to manage and deploy tracking scripts on our Site. These technologies may collect online identifiers and usage data, such as IP address, device information, browser characteristics, visited pages, and actions performed on the Site following interaction with advertisements.

Where required by applicable law, these technologies are activated only after obtaining your prior consent via our cookie management tool. You may withdraw your consent at any time through the cookie settings available on the Site.

Meta Platforms Ireland Limited, Microsoft and Google Ireland Limited may act as independent controllers with respect to certain processing activities carried out through their respective technologies. We recommend consulting their privacy policies for further information on how they process personal data.

HOW WE USE AI

First things first: We do not read the content of your correspondence with private individuals. When the AI Deletion Agent is enabled, we identify emails from companies and track the email threads relating only to the data deletion requests you send to those companies. We do not use your personal data to train our AI agents and models. We do not sell your data.

What data we use to provide

• Email classification: For paid subscribers, including lifetime licence holders, AI uses email details such as subjects, sender and reply-to addresses, dates and message identifiers to categorise messages. Free users’ scanned emails are not sent to an AI model.
• AI Unsubscribe Agent: Processes your typed request (up to 100 characters) and up to ten previous user messages to identify whether you want to unsubscribe or clean up emails and extract filters such as company, category or recency. No email content, sender lists or mailbox data is sent to the model.
• AI Deletion Agent: When enabled, the agent checks your Inbox and Sent folder for messages relating to deletion requests. It retrieves and processes full email content only for those requests, including relevant company replies and attachment text. It also uses deletion case histories, your chats with the agent, profile and saved details, and public company privacy information. ### How AI helps and what you control

When AI Deletion Agent is enabled, AI categorises messages, extracts information relevant to deletion requests and prepares follow-up actions. In Review mode, drafts require your approval. In Auto mode, the AI agent can send replies from your account and follow confirmation links on your behalf.

The AI agent requires permission to read, organise and send emails. By default, it moves filed deletion-request messages out of your Inbox without deleting them or marking them as read. You can switch this setting off.

You may save details such as your name, contact information, date of birth or account references for use in authorised communications with companies. You can delete these individually. The saved-details feature does not accept passwords or identity documents.

What we keep

We retain classification results and supporting excerpts from deletion-request messages, deletion case records, company replies, case chats and outgoing messages for the life of your account. For incoming messages that do not match a deletion case, we retain only basic email details and classification results, never their full content. Saved details remain until you delete them or your account.

The separate chat assistant’s conversation disappears from the product after a browser refresh, but messages, prompts and responses are recorded in our internal monitoring system.

We also use self-hosted tools to understand App usage and make sure AI performs as intended.

AI model training

Our AI processing stays in the EU, and your data is not used to train AI models. To help explain what companies do with your data, we use their public privacy policies and review the information before publishing it. We also keep records needed to run the service, separately from the AI processing itself.

Collection of personal data

AgainstData® collects personal data from:

• Your Google or Microsoft account when you sign in.
• Your connected mailbox, within the permissions you grant and the features you use. Full email content is accessed only for deletion-request threads with companies, as described above.
• Information you provide in the App, including chats and saved details, and your interactions with our Services.
• Company replies, relevant attachment text and confirmation pages used to manage your deletion requests. We do not create or manage your Google or Microsoft account. Google and Microsoft remain responsible for their own processing of your personal data.

Recipients of your personal data

In order to provide the AgainstData App and the Services to the best of its ability, or in order to fulfil its legal obligations or in pursuit of its legitimate interests in accordance with the processing purposes set out herein, AgainstData® may disclose personal data to the following categories of recipients: (i) AgainstData®'s contractual partners and service providers (such as the supplier Google Cloud Platform (GCP) which provides us with the cloud hosting infrastructure); (ii) public authorities, financial auditors or institutions competent to carry out inspections and controls on the AgainstData®'s business and assets.

Such public authorities or institutions may be: The National Supervisory Authority for Personal Data Processing, the National Tax Administration Agency or other authorities with the power to check our databases; (iii) for compliance with a legal requirement or to protect the rights and assets of AgainstData® or other entities or persons, such as courts, lawyers, notaries, bailiffs; (iv) third party acquirers, to the extent that AgainstData®'s business would be transferred (in whole or in part) in the context of a share or asset sale or any other type of business re-organization. (v) analytics and advertising partners, such as Google Ireland Limited and Meta Platforms Ireland Limited, when Users consent to analytics or marketing cookies.

Transfer of personal data abroad

In the context of providing our Services and facilitating your use of the App, we may transfer certain personal data to countries located outside of the European Economic Area (“EEA”) or the United Kingdom (“UK”), whose legislation on the protection of personal data differs from that of the EEA and the UK. For example, we may transfer your personal data to the United States when engaging service providers to process personal data on our behalf. When such transfers occur we rely on the standard contractual clauses adopted by the European Commission. For more information in this regard, please contact us by using the details included in the Contact details section below. Certain analytics and advertising partners, including Google and Meta, may process personal data outside the EEA or UK. Where such transfers occur, we rely on the European Commission’s Standard Contractual Clauses and other legally recognized transfer mechanisms.

Refusal of the processing and consequences thereof

The provision of your personal data is necessary in order to register on the AgainstData App and to receive the Services. Refusal to provide personal data, necessary to achieve the purposes mentioned above, will make it impossible for AgainstData® to register you on the App and, implicitly, to give you access to the Services available on the App.

What happens to your personal data after the cessation of the data processing

We delete or anonymise your personal data when the retention periods described in this Policy end, unless we have a lawful reason to keep it longer. Any retained data remains protected under this Policy. We will inform you if we use it for a new purpose.

Security of the data processing

AgainstData® constantly evaluates and upgrades the security measures implemented as to ensure a secure and safe personal data processing.

The data subject’s rights in respect of the data processing

Within the context of the processing of your personal data, you have the following rights:

• a) The right of access to the processed personal data: you have the right to obtain a confirmation whether or not your personal data are being processed, and, if affirmative, to have access to the type of personal data and to the conditions of processing, by addressing a request in this respect to the data controller indicated in Contact Details section below;
• b) The right to request the rectification or erasure of personal data: you have the possibility to request, by sending a request in this respect to the data controller indicated in Contact Details section below, the rectification of inaccurate personal data, the supplementation of incomplete data or the erasure of your personal data in case (i) the data are no longer needed for their original purpose (and no new lawful purpose exists), (ii) the lawful basis for the processing is the data subject’s consent, the data subject withdraws that consent, and no other lawful ground exists, (iii) the data subject exercises the right to object and the controller has no overriding grounds for continuing the processing, (iv) the data have been processed unlawfully, (v) erasure is necessary for compliance with EU law or Romanian law, or (vi) the data were collected in connection with the informational society services offered to children (if the case), where specific requirements regarding consent are applicable;
• c) The right to request the restriction of processing: you have the right to obtain the restriction of processing in cases where: (i) you consider that the processed personal data are inaccurate, for a period enabling the controller to verify the accuracy of the personal data; (ii) the processing is unlawful, however you don’t want us to erase your personal data, but to restrict the use of data; (iii) in case the data controller no longer needs your personal data for the above-mentioned purposes, but you are requiring the data for establishing, exercising or defending a legal claim or (iv) you have objected to processing pending the verification whether the legitimate grounds of the data controller override those of the data subject;
• d) The right to withdraw your consent for processing, when the processing is based on consent, without affecting the lawfulness of processing undertaken until that moment;
• e) The right to object to the data processing on grounds relating to your particular situation, when the processing is based on legitimate interest and to object at any moment to the data processing for direct marketing purposes, including profiling;
• f) The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly affects the data subject in a significant manner;
• g) The right to data portability, meaning the right to receive your personal data, which you provided to the data controller in a structured, commonly used and machine-readable format and the right to transfer those data to another controller, if the processing is based on your consent or the performance of a contract and is undertaken by using automatic means;
• h) The right to file a complaint with the Romanian Data Protection Authority (ANSPDCP) or the data protection authority in the country in which you live or work or where you think an infringement of data protection laws occurred. The above rights may be exercised at any time. For the purpose of exercising these rights, you can always send a notice in writing, dated and signed or in electronic format, to the address indicated below.

Contact details

You may address any question using the following contact details:

Data Initiative S.R.L., postal address: 21, Ciocirliei street, Busteni, Prahova, Romania, e-mail address: data@againstdata.com.