Privacy policy

Legal Information

We strive to protect all personal information that we receive or generate. Privacy Policy explains our data protection practices for our visitors. This Privacy Policy also explains the nature of the personal information we collect, the means by which we collect it, the purposes for which we collect it, and how we use, process, protect, and share it.

Please read this entire Privacy Policy before submitting information to this Website. By accessing or using this Website for any purpose and by submitting any of your personal information to us, you are consenting to the terms and conditions of this Policy. If you disagree with any part of this Privacy Policy, please do not use this Website or any of our other services and do not share any personal information with us.

Data Controller: Intrepid Fox Project Limited, reg. No 15741576, legal address: 1 Kings Avenue, London, United Kingdom, N21 3NA.

Contact information: e-mail address: [email protected]

Definitions And Legal References

Personal Data (or Data) - Any information that directly, indirectly, or in connection with other information, allows to identify a natural person.

Usage Data - Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User (or You)- The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject - The natural person to whom the Personal Data refers.

Data Processor - The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller - The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller in this case is Intrepid Fox Project Limited, reg. No 15741576, legal address: 1 Kings Avenue, London, United Kingdom, N21 3NA.

GDPR - the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

This Website - The means by which the Personal Data of the User is collected and processed.

Service - The service provided by the Controller as described in the relative terms and on this Website.

Collected Data

The personal information we collect varies by User and purpose, but our primary purpose is the efficient and satisfactory conduct of our business and for related legal purposes.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party's consent to provide the Data to the Data Controller.

The Data concerning the User is collected to allow the Data Controller to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as contacting the User and sending emails using mailing list. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Data Controller.

We collect the following categories of Personal Data for the following activities:

• Visiting the Website
  • Browsing data/Usage data
• Contacting Intrepid Fox support teams
  • Identification data (full name, surname)
  • Contact data (e-mail address, phone number)
  • Content of your request
• Allowing the visitors and Users to exercise their data protection rights
  • Identification data
  • Contact data
  • Content of the request
  • Data necessary to reply to the request addressed to Intrepid Fox
• Complying with legal requests or manage litigation
  • Data necessary to prove Intrepid Fox compliance to its obligations and/or manage legal proceedings
• Interacting with us on social media
  • Personal data from a social media network accounts, i.e., your name, surname, other information you will provide during the communication (if any)
• Requesting a demo
  • Identification data (name)
  • Contact data (e-mail address)
• Subscribing to our newsletter
  • Contact data (e-mail address)

Collected Data using our AI solutions

Generally we do no process personal data of natural persons within our AI solutions, since according to the Recital 14 of the GDPR, it only applies to natural persons and does not cover the processing of personal data concerning legal persons, in particular undertakings established as legal persons or legal entities. However, we still might process personal data in some cases, where legal entities representative or natural persons personal data is involved.

Intrepid Fox, when providing AI services, merely acts as a processor within the meaning of Article 28 of the GDPR and processes the personal data according to the bank and fintech company instructions. In such cases we process the following data:

Business Nature Verification

We collect the personal data through the use of personal information provision services, OCR (Optical Character Recognition) services when checking invoices, contracts, checks, and other documents from the user to verify the nature of the business.

We may collect the personal data from individuals who make inquiries within our solution.

• Name
• Date of birth
• Address
• Telephone number
• E-mail address
• Personal identification number
• Citizenship
• Other data from the inquiries within our solutions

Ownership Structure Verification

In order to provide our AI solutions, we use personal data obtained from services provided by third parties based on information collected by us to determine and verify ownership structure.

We collect data from certificates and extractions from shareholder registers. Personal data provided in registers in accordance with their terms and conditions, co-use policies, etc.:

• Name
• Date of birth
• Address
• Telephone number
• E-mail address
• Personal identification number
• Citizenship
• Other data from the inquiries within our solutions

Directors Powers Verification

Our AI solution collects data from documents that define decision-making powers in a company, such as Articles of Association and Power of Attorney.

• Name
• Date of birth
• Address
• Telephone number
• E-mail address
• Personal identification number
• Citizenship
• Other data from the inquiries within our solutions

Purpose Of Data Collection

We use the Personal Data that we collect or receive from our Users for the purposes described in this Policy and for other business purposes allowed by law, including the development, delivery, and performance of our services, sharing with our affiliates for related business purposes, and as follows:

• To provide and maintain our Services, including to monitor the usage of our Services.
• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication.
• To manage your requests: To attend and manage your requests to us.
• To respond to your requests and questions, resolve disputes, investigate and address your concerns, and monitor and improve our responses;
• To help maintain the safety, security, and integrity of our Website, databases, and technology assets;
• For testing, research, analysis, and a product and service development, including to improve our Website and Services;
• For facilitating and processing your transactions with us and with our third party affiliates and business partners;
• To respond to law enforcement requests and as required by applicable laws, court orders, or governmental regulations;
• To fulfil our legal obligations, such as tax reports, etc.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, marketing and your experience.

We process Personal Data on the following legal basis for the following purposes:

• Offering communication between Intrepid Fox and the User: User Consent. (Article 6 (1) “a” of GDPR)
• Responding to the User/visitor’s request for information related to the Services offered by Intrepid Fox or request for assistance: Contract. (Article 6 (1) “b” of GDPR)
• Manage the request(s) of the Users related to their data protection rights: Legal obligation of Intrepid Fox, especially regarding GDPR compliance. (Article 6 (1) “c” of GDPR)
• Enhance and improve the Services and Website: Legitimate interests of Intrepid Fox to offer optimized Services. (Article 6 (1) “f” of GDPR)
• Justify and demonstrate Intrepid Fox’s compliance with legal obligations in case of legal request and/or protect Intrepid Fox’s interests in legal proceedings: Legitimate interest of Intrepid Fox to be able to demonstrate its compliance. (Article 6 (1) “f” of GDPR)
• Allow access to Services as provided on the Website: Contract. (Article 6 (1) “b” of GDPR)
• Processing Usage/Browsing data: Consent. (Article 6 (1) “a” of GDPR)
• Providing our Demo at a request of the User: Consent. (Article 6 (1) “a” of GDPR)

Legal basis for our AI solutions.

When using the AI services, clients of the banks and fintech companies (user of our services represents/is employed by such companies) upload and process various data (e.g. data of their customers, partners, suppliers, merchants, investors, or another legal or natural person whom the client wishes to verify via using of the service) through our services.

In such a case, the personal data is under the control of the bank/fintech company and Intrepid Fox may process such personal data for the purposes and to the extent necessary to provide the services ordered by the bank/fintech company in accordance with Terms and Conditions and Data Processing Agreement between the parties. Hence, in such a situation, Intrepid Fox acts as a data processor and processes the personal in accordance with the data processing agreement concluded with the bank/fintech company.

This lawful basis of Article 6 (1) (b) of the GDPR for the bank/fintech company applies where the processing using AI is objectively necessary to deliver a contractual service to the relevant client of the bank/fintech company, or to take steps prior to entering into a contract at the individual’s request.

As explained above, we mainly use the data for the rendering of the services which the bank/fintech company has ordered from us and for communicating with the client of the bank/fintech company, however, if a client of the bank/fintech interacts with our service or website, our legal basis for processing the personal data as described hereunder may vary depending on the personal data at issue as well as the context in which we collect it. Ordinarily, we process personal data about you in reliance on your consent or on legitimate interest. We may also process data to comply with our legal obligations, or to fulfil a contract.

Methods Of Data Processing

Intrepid Fox takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Intrepid Fox, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Intrepid Fox.

Currently we use the following Data Processors:

1. 1. Amazon AWS

   For data storage we use Amazon AWS cloud services hosted within EU, which is compliant with the GDPR. Our services within Amazon AWS are hosted in the United Kingdom. For more information about Amazon AWS, please visit https://aws.amazon.com/compliance/data-privacy-faq/.

2. 2. Microsoft (Azure)

   Microsoft’s AI products and solutions are compliant with applicable data protection and privacy laws today. The AI GPT models we use are hosted on the Microsoft Azure cloud environment localized in the Sweden. Microsoft Azure AI solution does not train on user input data. For more information please see - Microsoft Products and Services Data Protection Addendum,   Microsoft’s Product Terms, and the Microsoft Privacy Statement.

3. 3. Google Cloud

   We use Google cloud services for hosting of our OCR (Optical Character Recognition) solution. The OCR (Optical Character Recognition) system is hosted in Google Cloud environment which is localised in the United Kingdom. For more information about Google cloud services, please visit https://cloud.google.com/privacy/gdpr.

Transfers And Sharing Of Data

Intrepid Fox only process EU User Personal Data on servers located in the EU, UK, Switzerland for EU/EEA clients.

If personal data is transferred outside the European Union and the EEA countries, Intrepid Fox has taken adequate measures to secure that user personal data are processed in compliance with GDPR. Whenever we transfer personal data to countries outside of the EEA, UK or Switzerland we ensure that at least one of the following safeguards is in place:

1. 1. We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data;
2. 2. Ensure the transfer is subject to a specific derogation in the GDPR or national laws; or
3. 3. Use the standard contractual clauses as the transfer mechanism when a case-by-case analysis has been performed.

Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data protection as it has in the EU, EEA or UK.

We may share your personal data with following recipients:

• Internal recipients - your Personal data will only be disclosed to authorize employees that require an access to fulfil their obligations (e.g. support teams, developers, etc.). Our employees are specifically trained and made aware of the sensitivity of your Personal Data and the requirements necessary to ensure the protection of your right to privacy.
• Data Processors - in order to provide the Services, Intrepid Fox may communicate your Personal Data to other entities acting as Data Processors.
• Judicial, administrative and other public authorities - Intrepid Fox may have to share or disclose some of your Personal Data if it is required to do so by the law, by a request meaning from a competent authority, to comply with a court order, to obtain legal remedies or defend Intrepid Fox rights, to contribute with investigations (e.g. fraud, identity theft, etc.).

Retention Time

We will retain information, including Personal Data of Users for as long as needed to provide our Services or respond to requests, but not longer than 2 years after our latest communication. We only retain and use the information and Personal Data as necessary to comply with our agreements, legal obligations, and the resolution of any disputes.

We delete Personal Data when (a) it is no longer used for any purposes, or (b) a Data Subject requests deletion of their Personal Data or objects to us processing their Data pursuant to their GDPR or other state or national rights (unless we have a valid legal justification to retain it, such as to resolve disputes or comply with our legal obligations).

Intrepid Fox may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data will be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Rights Under GDPR

Users may exercise certain rights regarding their Data processed by Intrepid Fox. In particular, Users have the right to do the following:

Right to be informed.

We will always use this Policy and other notice, if required, to inform you in a concise, transparent, intelligible and easily accessible manner about the processing of your personal data from the moment we obtain personal data from you. If we do not obtain personal data from you directly, we will provide you the information within a reasonable period after obtaining them, but within one month at the latest, unless the provision of such information proves impossible or would involve a disproportionate effort (e.g. we have no contact information about you).

Right of access to personal data.

You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed. If we process your personal data, we will provide you with the information that you request or that we are required to provide by the law.

If we do process personal data about you, we will provide you with a copy of the personal data which are subject to the processing free of charge. For any further copies requested by the data subject, we may charge a reasonable fee based on the administrative costs of making such copies. The right to obtain a copy of the personal data undergoing processing shall not adversely affect the rights and freedoms of others.

Where you make the request by electronic means, the information will be provided in a commonly used electronic form, unless otherwise requested by you.

Right to erasure / right to be forgotten.

We will erase your personal data without undue delay where one of the following grounds applies:

• your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw the consent on which the processing is based and there is no other legal ground for their processing;
• you object to the processing of your personal data and there are no overriding legitimate grounds for the processing or you object to the processing of your personal data for the purposes of direct marketing;
• your personal data have been unlawfully processed;
• your personal data have to be erased to comply with a legal obligation under European Union or Member State law to which Intrepid Fox is subjected;
• your personal data have been collected in relation to the offer of information society services to a child.

The above does not apply to the extent that the processing of the personal data is necessary:

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation imposed by European Union or Member State law which requires processing and to which the Intrepid Fox is subject to or for the performance of a task carried out in the public interest or in the exercise of official authority;
• for reasons of public interest in the area of public health;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as the exercise of the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing;
• for the establishment, exercise or defence of legal claims.

We communicate any erasure of personal data to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about the recipients of the personal data which have been notified if you request it.

If we refuse to erase your personal data based on the exemptions specified above, we will inform you thereof within one month of receipt of the request, reason the grounds for the application of the exemptions, and instruct you in accordance with the requirements of the applicable laws and regulations.

Right to restriction of processing.

You have the right to restrict your personal data processing in the following cases:

• the accuracy of the personal data is contested by you; in this case, the processing is restricted for a period enabling us to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
• you have exercised your right to object the processing of the personal data; in this case, the processing is restricted until we determine whether our legitimate grounds override your legitimate interests.

As a result of restricted processing of personal data, we may continue to store the relevant personal data but they may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State. In such cases you will be informed before the restriction of processing is lifted.

Right to data portability.

You have the right to receive your personal data processed by us provided that one of the following conditions is met:

• the personal data are processed for a specific purpose on the basis of your consent;
• the personal data is processed by automated means;
• if the personal data are from a special category processed for one or more specified purposes on the basis of your explicit consent; or
• the processing of the personal data is necessary for the performance of a contract to which you are a party or in order to execute precautions accepted at your request prior to entering into a contract.

The personal data provided to Intrepid Fox is deemed to include data which you have disclosed to us directly, intentionally and actively, e.g. by means of completing a form, as well as personal data generated on the basis of your activity on our Website, e.g. the location data, application login dates, etc.

We will provide the data in a structured, commonly used and machine-readable format. You may transmit the personal data obtained by us to another data controller. In your request, you may choose whether we should provide the personal data to you or whether you will exercise your right to have your personal data transmitted directly from us to another controller/processor, where technically feasible.

Right to object.

As regards the processing of personal data under the legal ground of legitimate interest of Intrepid Fox, you may object to the processing of your personal data on grounds relating to your particular situation described in the objection. You may object by using the contact details provided below.

After we receive your objection we will cease the processing of (but will still keep) your personal data to assess whether we have compelling legitimate grounds for their processing which override your interests, rights and freedoms, or whether we need your personal data for the establishment, exercise or defence of our legal claims. If we conclude that we do have such grounds, we will inform you accordingly, including advising you on your options for further defence, and we will continue to process such personal data. On the contrary, if we conclude that we do not have sufficient grounds for the processing of the personal data, we shall inform you accordingly and erase such personal data.

You have the right to object at any time to the processing of personal data for direct marketing purposes.

Right not to be subject to a decision based solely on automated processing, including profiling.

We process your personal data with respect for your right not to be subject to a decision based solely on automated processing which significantly affects you, including profiling (i.e. any form of automated processing of personal data consisting of the use of personal data to analyse, predict or evaluate certain aspects concerning you - e.g. your economic situation, interests, etc.).

However, in controlling your personal data, we may make you a subject of an automated decision if such a decision is necessary for entering into, or conclusion of, a contract between you and us, or is authorised by European Union which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or is based on your explicit consent.

Right to lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

In order to exercise your rights specified above or make any queries regarding this Policy or the processing of your Personal Data, please use Intrepid Fox Project Limited contact details: Postal address: 1 Kings Avenue, London, United Kingdom, N21 3NA. E-mail: [email protected] .

If User has any issues regarding data processing done by Intrepid Fox, User can send request to competent national data protection authority - the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom. More information is available at www.ico.org.uk.

Additional Information About Data Collection And Processing

Legal action

The User's Personal Data may be used for legal purposes by Intrepid Fox in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from Intrepid Fox at any time. Please see the contact information at the beginning of this document.

Visiting Third-Party Websites

Our Website may contain links or references to third party websites. These websites are outside of our control, and the privacy policies of these sites may differ from our own. Please be aware that we have no control over these third-party Websites and our Privacy Policy does not apply to such websites. We encourage you to check the terms of use and privacy policies of such sites before disclosing any personal information via such sites. The privacy notice of the third party site will govern how information collected from you is used by the controller of the respective third party website. You can always know what website you are on by checking the Uniform Resource Locator (URL) in the location bar within your browser.

Changes To This Privacy Policy

Intrepid Fox reserves the right to make changes to this Privacy Policy at any time by notifying its Users on this Webpage and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to Intrepid Fox. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, Intrepid Fox shall collect new consent from the User, where required.

The Privacy Policy was last updated on 14 Mar, 2024.