This Privacy Policy describes the privacy practices of H.AI SAS (“we”, “us”, “our” or “H Company”) and how we handle personal information that we collect in connection with H Company’s AI Agents offering for the Runner H Service and the Tester-H Service (together the “H Services”) whose use are subject to the Runner H Service Terms of Service and the Tester-H Service Terms of Service, as data controller.

This Privacy Policy does not apply to personal information we process as data processor on behalf of users to provide them with the H Services. In that case, such a user will act as the controller and its privacy policy will apply to the processing of Your personal information. We may act as data controller for some processing of personal information when providing our H service as described in this Privacy Policy. 

H.AI SAS is the entity responsible for the processing of personal information under this Privacy Policy (as a data controller, where provided under applicable law such as the EU General Data Protection Regulation(GDPR)).

Definitions

• “AI Agents” means artificial intelligence models that use AI features and that are provided by H Company to You to perform tasks for You based on Your Inputs in the context of the H Services.
• “Action(s)” means to the exclusion of Input and Output, any and all content, decisions, recommendations, interactions, operations, steps, actions and transactions generated or executed by the AI Agents as part of the H Services and any data associated thereto, including AI Agents internal status sequence, screenshots of websites visited, content of documents, websites or URL of websites visited and/or accessed as part of the the interaction with the AI Agents, in response to an Input.
• “Input(s)” means data You input into the AI Agents for the purpose of the H Services, including files, documents, text commands or other instructions, queries, textual cues, or feedback.
• “Output” means the results, responses, or deliverables produced by the AI Agents for the purpose of the H Services, including but not limited to textual, or visual output, with the exception of Actions, such as the AI Agent’s navigation script or website screenshots displayed by the AI Agent throughout the AI Agents operation.
• “You” means any person (i) who uses, accesses, browses and/or subscribes to the H Services, or (ii) whose personal information may be processed by us through the use of our H Services by our customers or as part of the training of our AI Agents.

Personal information we collect

• Contact and identification details, such as Your first and last name, email address, and phone number, company and any other information that You may provide when You create an account with us, including Your password.
• Payment and billing information, when the use of the H Services require a payment from You;
• Content of Inputs that our users put into our AI Agent for the H Services, to the extent such Inputs contain personal information. Users of the H Services have control over the personal information they provide to us. Users of the H Services must refrain from providing any sensitive personal information (including information about an individual’s health, race, ethnicity, political opinions, religious or philosophical beliefs, sex life or sexual orientation, trade union membership, or genetic data) in the Inputs. If users provide us with information about another person, users must ensure that the data subjects agree to have their personal information in an Input, and users are responsible for providing them with this Privacy Policy.
• Content of Actions, to the extent such Actions contain personal information such as in the following but not limitative examples: if users request our H Services to access websites or documents that contain personal information.
• Content of Output, to the extent such Outputs contain personal information such as in the following but not limitative examples: websites screenshot of the testing operation performed by the AI Agent for the Tester-H Service or a written report based on a specific request for the Runner H Service.
• Usage information, such as information about how You use the H Services, and interact with us, such as security logs or technical information collected automatically as described below in the section “Automatic data collection”.
• Information indirectly provided to us, our AI Agents are trained on data that are publicly available on the Internet, which may contain personal information.

Sources of personal information

• Users. Our users control the information they provide to us. Users might provide us directly or indirectly with personal information about You, such as with Input or Actions containing personal information or leading to processing of personal information.
• Other sources. We may obtain Your personal information from other third parties, such as publicly available sources for the training of our AI Agents.

Automatic data collection

• User ID. When You use our H Services You will be assigned a H Company user ID.
• Device data, such as Your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
• We use cookies, web beacons (e.g., pixel tags), and local and session storage technologies to collect some of this information. For more information on how we use these technologies, please visit our Cookie Policy.

How we use personal information

• Assess the proper functioning and trends of our AI Agents, the H Services, train our AI Agents and improve the  H Services, and otherwise for research and development. Our AI Agents are trained on Your and other users’ Inputs, Actions and Outputs, usage information associated with Your email address. For the Tester-H Service, We carry out this processing based on our legitimate interests to analyze the functioning of our AI Agent and the Tester-H service to improve our AI Agent, the Tester-H service or improve or create any new service or product for You and other users, and otherwise to use Your personal information for research and development. For the Runner H Service, We carry out this processing based on Your consent to analyze the functioning of our AI Agent and the Runner H Service to improve our AI Agent, the Runner H Service or improve or create any new service or product for You and other users, and otherwise to use Your personal information for research and development. Notwithstanding the above, We will only use users’ Inputs, Actions and Outputs to improve the H Services, develop new services, and develop, train, improve or fine-tune the AI Agent, and any underlying AI models, when permitted by publishers’ rules regarding the access and use of their applications by the AI Agent. For example, we will not improve the H Services, develop new services, and develop, train, improve or fine-tune the AI Agent, and any underlying AI models based on any users’ Inputs, Actions and Outputs relating to the use of Google services (including but not limited to Gmail, Google sign-in or Google Calendar).
• Enrichment. It is in our legitimate interests to use personal information we obtain from third parties to enrich and verify personal information we process about You to better understand who uses the H Services.
• Interest-based advertising. We engage our advertising partners, including third-party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically collected data described above) about Your interactions over time across our H Services, our communications, and other online services, and use that information to serve online ads that may interest You. Where required by law such as in the European Union, we will undertake such advertising activities on the basis of Your consent; otherwise, we will do so only if it is in our legitimate business interests to undertake such activities. No Input, Actions or Output from the H Services are used for this purpose.
• Compliance and protection, including:
  
  • To comply with applicable laws, lawful requests, and legal process, such as to respond to requests from government authorities or reply to Your requests regarding Your personal information.
  • In our legitimate interests to protect our, Your, or others’ rights, privacy, safety, or property (including by making and defending legal claims).
  • Auditing our internal processes for compliance with legal and contractual requirements and internal policies. Where we do not have a legal obligation, we do so in our legitimate interests.
  • Enforce the terms and conditions that govern our H Services, we do so on the basis of the performance of our contract with You.
  • In our legitimate interests to prevent, identify, investigate, and deter fraudulent, harmful, unauthorised, unethical, or illegal activity, including cyberattacks and identity theft.

Artificial Intelligence provided by third parties

H Company may also leverage third-party AI technology provided by our service providers. This technology is trained to generate intelligent responses in conversations with You and when performing tasks on Your request. Its Actions are based on information collected through the concerned H Services, including Your Inputs.

H Company shares Your information with the AI service providers that power H Company. They will only use Your personal information to respond to and action Your prompts and instructions; they will not use Your data to train their AI models.

How we share personal information

We may share your personal information with:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, AI technology providers, customer support, email delivery, and website analytics services).

Advertising partners. Third party advertising companies, including for the interest-based advertising purposes described above.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganisation, sale, or other disposition of all or any portion of the business or assets of, or equity interests in H Company (including, in connection with a bankruptcy or similar proceedings).

Your rights and choices

Personal information requests. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:

• Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily-usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
• Additional rights, such as to object to our processing of Your personal information under the conditions of applicable law (right to object) and request that we restrict our use of personal information (right of restriction), and where we rely on consent for our processing, You may withdraw Your consent to our processing of Your personal information. Finally, as permitted under applicable law, You also have the right to obtain and transfer Your personal information to another entity (right of portability).

To exercise the above rights, contact us as set out in the “How to contact us” Section below. Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you.

In some instances, your rights and choices may be limited, such as where fulfilling your request would impair: the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

Right to complain. Depending on where you reside, such as if you reside in the European Economic Area (EEA) or United Kingdom (UK), you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. Click here to find your local supervisory authority in the EEA. In the UK, the competent authority is the Information Commissioner’s Office.

We do not perform automated individual decision making, including profiling, that may produce a legal effect on You or that similarly significantly affects You or any other person. 

Other sites and services

The use of our H Services may contain or lead to links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Retention

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until You withdraw Your consent (where applicable). To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Data security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect.

International data transfers

We may transfer personal information to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.

Children

Our H Services are not intended for use by children under 18 years old. If we learn that we have collected personal information through the H Services from a child under 18, we will delete it.

Changes to this privacy policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.

How to contact us

Responsible entity. H.AI SAS is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law).

Contact us. If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at privacy@hcompany.ai or at the following mailing address:

H.AI SAS
22 Rue Drouot
Paris France 75009

If you are based in the United Kingdom, you can also contact us at:

H.AI Technology Limited
23 Copenhagen Street,
London UK N1 0JB