SAMMY: The AI Customer Success Solution

Launch YC: SAMMY Labs - AI Customer Success Agents. Your users, delighted.

INTRODUCTION
Welcome to SAMMY Labs Ltd T/A SAMMY (“we”, “us”, or “our”). We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our platform and services (collectively, the “Services”).

For the purposes of the Data Protection Act 2018 and the UK General Data Protection Regulation (“UK GDPR”), the data controller is SAMMY Labs Ltd, registered in the United Kingdom and registered office (see CONTACT US section)

INFORMATION WE COLLECT
We may collect and process the following personal data about you:

IDENTITY DATA: First name, last name, username or similar identifier.
CONTACT DATA: Email address, telephone numbers.
FINANCIAL DATA: Payment card details.
PROFILE DATA: Your username and password, preferences, feedback, and survey responses.
USAGE DATA: Information about how you use our Services.
MARKETING AND COMMUNICATIONS DATA: Your preferences in receiving marketing from us and our third parties.

As you interact with our Services, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

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:

PERFORMANCE OF CONTRACT: To provide and maintain our Services.
LEGITIMATE INTERESTS: To manage our relationship with you and to improve our Services.
LEGAL OBLIGATIONS: To comply with a legal or regulatory obligation.

Purposes for which we will use your personal data include:

To register you as a new user.
To process and deliver your subscription.
To manage our relationship with you.
To administer and protect our business and Services.
To deliver relevant content and advertisements to you.
To make recommendations to you about goods or services which may interest you.

DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal data with:

SERVICE PROVIDERS: Third parties who provide IT and system administration services.
PROFESSIONAL ADVISERS: Including lawyers, bankers, auditors, and insurers.
REGULATORS AND OTHER AUTHORITIES: Who require reporting of processing activities.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

INTERNATIONAL TRANSFERS
Your personal data may be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”). Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it.

DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data, including:

ACCESS: Request access to your personal data.
CORRECTION: Request correction of your personal data.
ERASURE: Request erasure of your personal data.
RESTRICTION: Request restriction of processing of your personal data.
TRANSFER: Request the transfer of your personal data.
OBJECT: Object to processing of your personal data.
WITHDRAW CONSENT: Withdraw consent at any time where we are relying on consent to process your personal data.

COOKIE POLICY

A cookie is a small data text file that is stored on the hard drive of your computer or mobile device. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, the website’s domain name, and some digits and numbers. Cookies cannot be used to run programs or deliver viruses to your computer. At no time will our cookies collect your personally identifiable information.

When you visit our Website, we will store certain types of persistent cookies on your computer in order to authorize access to our private content and to facilitate and customize your use of our Website. A persistent cookie remembers information, settings, preferences, or sign-on credentials that you have previously saved.

ESSENTIAL COOKIES
Essential cookies allow us to offer you the best possible experience when accessing and navigating through our Sites and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account.

FUNCTIONALITY COOKIES
Functionality cookies let us operate the Sites in accordance with the choices you make. For example, we will recognize your username and remember the choices you made during future visits.

ANALYTICAL COOKIES
These cookies enable us and third-party services to collect aggregated data for statistical purposes on how our visitors use our Website. These cookies do not contain or collect Personal Information and are merely used to help us improve your user experience of the Sites.

Once you leave our Sites, our persistent cookies remain on your hard drive. This helps create a convenient and faster website experience.

You are always free to decline or restrict our cookies through your browser settings. However, due to the nature of our essential cookies, some parts of our Sites may not work properly. You can find general information on the Internet about cookies and details on how to delete them from your computer and mobile devices.

At the moment we only use essential cookies, but we reserve the right to add functionality and analytical cookies in the future.

INTEREST-BASED ADVERTISING
You can opt out of interest-based advertising from third-party providers who follow the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising at:
www.aboutads.info/choices

YOUR CHOICES
You may at any time:

Stop receiving marketing or promotional emails, direct mail, phone, and mobile marketing communications;
Update and correct your Personal Information; and
Request removal of information you post on our digital properties (in some cases, we may not be able to remove your content or Personal Information, in which case we will let you know if we are unable to do so and why).

To do any of these, let us know by:

Following the directions in a marketing email, direct mail, or mobile communication that you receive from us; or
Providing your request and current contact information through one of the contact methods listed under “Contact Us” below.

DISCLOSURE OF INFORMATION
We may disclose information collected from and about you as follows:

To our related companies and service providers, to perform a business, professional, or technical support function for us;
To our business, sales, and marketing partners and affiliates, advertisers, or other third parties who may contact you with their own offers;
As necessary if we believe that there has been a violation of the Sites’ Terms of Use or of our rights or the rights of any third party;
To respond to legal process (such as a search warrant, subpoena, or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and
In the event that our Company or substantially all of its assets are acquired, or there is a restructuring, your Personal Information may be one of the transferred assets.

We may also disclose your Personal Information with your express consent. We may share aggregate, deidentified, or non-personally identifiable information about the Sites’ users with third parties.

Please note that if you voluntarily submit any Personal Information for posting on the Sites (such as a review or a blog post), the information becomes publicly available and can be collected and used by others. Please use care before posting information about yourself online.

RETENTION OF PERSONAL INFORMATION
We retain Personal Information that we receive for as long as necessary to fulfill the purposes for which the information was collected, to provide our services and products, to pursue legitimate business purposes, to enforce our agreements, and to comply with all applicable laws.

SECURITY
We maintain commercially reasonable and appropriate measures designed to safeguard the Personal Information we collect. We have taken physical, electronic, and administrative steps to secure the information we collect from visitors to the Sites.

Unfortunately, no data transmission over the Internet nor any data storage system is 100% secure. While we strive to protect your information, we cannot ensure or warrant the security of such information on our or third-party sites. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us using the contact options on our “Contact Us” page.

CHILDREN’S PRIVACY
The Sites are not directed to children (anyone under 18 years of age), nor do we knowingly solicit or collect any Personal Information from children without verifiable parental consent. We will promptly investigate and then delete such information from our systems if warranted. If you are a parent or legal guardian of a child and become aware that your child has provided us with Personal Information, please contact us immediately using the contact information detailed in the “Contact Us” section below. Parents and legal guardians always have the right to inspect any information we may have inadvertently collected from their child and to request its deletion.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, EACH OF THE PARTIES HEREBY IRREVOCABLY WAIVES ANY AND ALL RIGHT TO TRIAL BY JURY IN ANY LEGAL PROCEEDING ARISING OUT OF OR RELATED TO THIS AGREEMENT OR THE TRANSACTIONS CONTEMPLATED HEREBY.

Customer agrees that in the event of a breach or threatened breach of the access rights or confidentiality obligations herein, the Company will suffer irreparable harm for which no adequate monetary remedy exists, and shall be entitled to seek injunctive and other equitable relief, in addition to any other legal or equitable remedies available.

BASIS FOR PROCESSING PERSONAL INFORMATION
We may process Personal Information under the following conditions:

Consent: You provided your consent for one or more specific purposes.
Performance of a Contract: Provision of Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations.
Legal Obligations: Processing Personal Information is necessary for compliance with a legal obligation to which the Company is subject.
Legitimate Interests: We have a business or commercial reason to use your information, so long as this is not overridden by your rights or interests.

We will gladly help clarify the specific legal basis that applies to the processing and whether the Personal Information is a statutory, contractual, or necessary requirement for entering into a contract.

WHAT WE USE YOUR PERSONAL INFORMATION FOR
Below is a summary of what we use (process) your Personal Information for and our reasons:

To provide products and/or services to you.
Reason: For the performance of our contract(s) with you or to take steps at your request before entering into a contract.
To prevent and detect fraud against you or our Company.
Reason: For our legitimate interests or those of a third party, to minimize fraud that could be damaging for both parties.
Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies.
Reason: To comply with our legal and regulatory obligations.
Operational reasons, such as improving efficiency, training, and quality control.
Reason: For our legitimate interests or those of a third party, to be as efficient as we can.
Ensuring the confidentiality of commercially sensitive information.
Reason: For our legitimate interests or those of a third party, to protect trade secrets and other commercially valuable information.
Statistical analysis to help us manage our business.
Reason: For our legitimate interests or those of a third party, to be as efficient as we can.
Preventing unauthorized access and modifications to systems.
Reason: For our legitimate interests or those of a third party, to prevent and detect unauthorized and/or criminal activity.
Updating and enhancing customer records.
Reason: For the performance of our contract(s) with you, to comply with legal and regulatory obligations, and/or for our legitimate interests or those of a third party.
Corporate Filings/Statutory Returns.
Reason: To comply with our legal and regulatory obligations.
Ensuring safe working practices, staff administration, and assessment.
Reason: To comply with our legal and regulatory obligations and for our legitimate interests, such as following our internal procedures and working efficiently.
Marketing our existing and new products and services and those of selected third parties to:
- Existing and former customers;
- Third parties who have previously expressed an interest in our products or services;
- Third parties with whom we have had no previous dealings.
  Reason: For our legitimate interests or those of a third party, to promote our business.

PROMOTIONAL COMMUNICATIONS
We may use your Personal Information to send you updates (by email, text message, telephone, or post) about our products and services, including exclusive offers, promotions, or new products and services.

We have a legitimate interest in processing your Personal Information for promotional purposes (see the section above on the Basis for Processing Personal Information). This means we do not usually need your consent to send you promotional communications. However, if consent is needed, we will ask for it separately and clearly.

We will always treat your Personal Information with the utmost respect and never sell or share it with other organizations outside of the Company for marketing purposes. You have the right to opt out of receiving promotional communications at any time by contacting us using the “Contact Us” information below.

THIRD-PARTY WEBSITES
The Sites may contain links to third-party websites (such as social media sites like Facebook and Twitter) that may have privacy policies different from our own. We are not responsible for the activities and practices on these websites. We recommend reviewing the privacy policy posted on any external site before disclosing any Personal Information. Please contact those websites directly if you have any questions about their privacy policies.

WHERE YOUR PERSONAL INFORMATION IS HELD
Personal Information may be held at our offices and those of our third-party service providers, representatives, and agents as described above (see “Disclosure of Information”). Some of these third parties may be based outside the European Economic Area. For more information, including how we safeguard your Personal Information when this occurs, see “Transferring Your Personal Information Out of the EEA.”

TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA
We may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Information is transferred abroad, we will ensure compliance with the applicable laws in that jurisdiction in line with our obligations.

To deliver services to you, it is sometimes necessary for us to share your Personal Information outside the European Economic Area (EEA); for example, your information (including Personal Information) may be processed at the Company’s operating offices or in other locations where data protection laws differ from those in your jurisdiction. This means that this information may be transferred to—and maintained on—computers located outside your state, province, country, or other governmental jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Information will take place to an organization or country unless there are adequate controls in place, including the security of your data and other Personal Information.

If you would like further information, please contact us or our Data Protection Officer (see “Contact Us” below).

ACCESS, CORRECTION, & DELETION
We respect your right to access and correct your Personal Information. You may exercise your rights—subject to applicable laws—to request that we delete or restrict access to your Personal Information. In some cases, we may need to retain it for legally permitted purposes, and we will explain this to you if necessary.

If you need assistance correcting or updating your Personal Information, or if you would like to request that we delete your Personal Information, please contact us using the contact information provided in the “Contact Us” section.

CALIFORNIA PRIVACY RIGHTS DISCLOSURE
If you are a California resident, the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), the California Online Privacy Protection Act (CalOPPA), and other applicable privacy and data protection laws provide you with additional rights regarding your personal information. California law permits our customers who are California residents to request certain information about our disclosure of Personal Information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. To make such a request, please write to us at the following address: privacy@sammylabs.com

CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. Any changes we may make will be posted on this page, and where appropriate, notified to you by email.

SAMMY Labs Ltd
Email: privacy@sammylabs.com
Address: Techspace Aldgate East, 32-38 Leman St, London E1 8EW

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.