Membrace Privacy Policy

Last updated: November 15, 2022

This Privacy Policy (“Privacy Policy”) is designed to provide data subjects (individuals) with information on the processing of their personal data (any information relating to them) processed by Beyond ML Inc. (“Beyond ML Inc.”) in the context of use of Membrace (https://membrace.ai) (“Service”) by users.

1. Controller

Beyond ML Inc. is the controller of personal data processed under this Privacy Policy. It means that Beyond ML Inc. determines the purposes and means of processing of the personal data.

Data subjects can contact Beyond ML Inc. on any questions relating to the processing of their personal data under this Privacy Policy by either of the following methods:

Email: info@membrace.ai

Postal address: 10 State street, Newburyport, MA 01950, United States

2. Purposes and legal bases for the processing

Beyond ML Inc. processes personal data to provide the Service to its users; to comply with applicable laws; to market the Service; to improve the Service; to protect Beyond ML Inc.’s legal rights.

When doing so, Beyond ML Inc. relies on (1) the necessity of the processing for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (2) the necessity of the processing of personal data to comply with its legal obligations; (3) the necessity of the processing of personal data for the purposes of the legitimate interests pursued by Beyond ML Inc.. In some cases, Beyond ML Inc. relies on (4) a consent of a data subject to process his or her personal data.

The legitimate interests of Beyond ML Inc. consist of (1) compliance with applicable laws and regulations; (2) promoting the Service (except for the cases, where consent is required); (3) improvement of the Service; (4) protection of Beyond ML Inc.’s legal rights. Data subjects can get more information on the legitimate interests pursued by Beyond ML Inc. and relevant balancing tests by sending a request with the use of contact details specified in section 1 of this Privacy Policy.

3. Categories of personal data concerned

Under this Privacy Policy, Beyond ML Inc. processes the following categories of personal data:

1) full name;

2) email address;

3) phone number;

4) other registration/authentication data which may be provided by the users in the process for using the Service (if any);

5) information about use of the Service collected through cookies or similar technologies.

For sources of personal data please see section 11 of this Privacy Policy.

4. Recipients of personal data

Beyond ML Inc. discloses certain personal data of the data subjects to the following recipients to the extent permitted by applicable law:

• affiliate entities of Beyond ML Inc. which are a part of the same group of companies;

• partners or contractors otherwise assisting in provision of the Service by Beyond ML Inc. and achievement of other purposes mentioned in the section 2 of this Privacy Policy, in particular provider of the Toloka service (https://toloka.ai/);

• various state and municipal authorities if strictly required to respond to their legitimate formal inquiries;

• other third parties when it is required for compliance with applicable laws.

5. Transfers to third countries

Beyond ML Inc. may transfer personal data of the data subjects to third countries, including those that do not provide the same level of data protection as in the country of your residence. When doing so, Beyond ML Inc. ensures implementation of security measures aimed at protection of your personal data in an appropriate manner.

The data subjects can get more information on the mechanisms of transfers to third countries by Beyond ML Inc. by sending a request with the use of contact details specified in section 1 of this Privacy Policy.

6. Storage periods

Beyond ML Inc. stores personal data of the data subjects as long as it is required to achieve the purposes of the processing specified in section 2 of this Privacy Policy. In particular, it means that Beyond ML Inc. keeps users’ personal data for as long as they use Service and after they stop using the Service, their personal data are stored for a period of 3 (three) years, unless there are specific periods defined in applicable laws.  

7. Basic rights of data subjects

The data subjects, in respect of their personal data, have rights to:

1) access;

(The data subject can ask Beyond ML Inc. to confirm whether or not Beyond ML Inc. processes their personal data. If so, the data subject can access these personal data and can ask Beyond ML Inc. to explain certain details of the processing.)

2) rectification;

(The data subject can ask Beyond ML Inc. to correct inaccurate personal data concerning him or her. If it complies with the purposes of the processing, the data subject can ask Beyond ML Inc. to complete incomplete personal data.)

3) erasure (‘right to be forgotten’);

(The data subject can ask Beyond ML Inc. to erase personal data concerning him or her under applicable law. For example, this applies if (1) the personal data are no longer necessary in relation to the purposes for which they were processed; (2) the data subject withdraws consent to the processing and there is no other legal ground for the processing; (3) the personal data have been unlawfully processed.)

4) restriction on processing;

(The data subject can ask Beyond ML Inc. to mark the stored personal data with the aim to limit their processing in the future under applicable law. This applies if (1) the data subject contests the accuracy of the personal data; (2) the data subject asks to restrict the use of the personal data when their processing is unlawful; (3) the data subject needs personal data to protect their rights when Beyond ML Inc. no longer needs the personal data; (4) the data subject has objected the processing based on the legitimate interests pursued by Beyond ML Inc. or by a third party.)

5) objection to processing;

(The data subject can object, on grounds relating to their particular situation, at any time to processing of personal data concerning him or her which is based on the legitimate interests pursued by Beyond ML Inc. or by a third party. Beyond ML Inc. shall no longer process the personal data unless Beyond ML Inc. demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.)

6) portability.

(When the processing is based on consent of the data subject or on a contract with the data subject, the data subject can receive the personal data concerning him or her, which he or she has provided to Beyond ML Inc., in a structured, commonly used and machine-readable format and can freely transmit those data to another controller. Where technically feasible, the data subject can also ask Beyond ML Inc. to transmit the personal data directly to another controller.)

To exercise their rights, data subjects can contact Beyond ML Inc. with the use of contact details specified in section 1 of this Privacy Policy.

8. Withdrawal of consent

Where processing is based on consent (or explicit consent), the data subject has the right to withdraw consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal. To withdraw consent, the data subject can contact Beyond ML Inc. with the use of contact details specified in section 1 of this Privacy Policy.

9. Right to lodge a complaint with a supervisory authority

When Article 77 of the GDPR applies, a data subject has the right to lodge a complaint with a supervisory authority in particular in the member state of the European Union of his or her habitual residence, place of work or of an alleged infringement of applicable law.

10. Necessity to provide personal data

Users shall provide Beyond ML Inc. with personal data processed under this Privacy Policy so that Beyond ML Inc. can provide the Service to users. If user do not provide Beyond ML Inc. with the relevant personal data, user will not be able to use the Service.

11. Sources of personal data

Beyond ML Inc. collects personal data from data subjects themselves.

12. Other information

Beyond ML Inc. ensures the compliance with the Children`s Online Privacy Protection Act (COPPA) and does not knowingly collect personal information from children under the age of thirteen (13). Beyond ML Inc. informs Users from EEA that our Service is not directed to children under 16, and we do not knowingly collect personal data from children under 16. If a parent or any other authorized person becomes aware that his or her child has provided us with personal data without his/her consent, he or she should promptly contact Beyond ML Inc. and we take reasonable steps to ensure that such personal data is deleted from Service.

13. Changes to this Privacy Policy

Beyond ML Inc. may change this Privacy Policy from time to time at its sole discretion. If so, Beyond ML Inc. notifies the data subjects about material changes by an appropriate method. If there is no explicit notification, the data subjects may always review the up-to-date version of this Privacy Policy located at https://membrace.ai/privacy.

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