Teneo - Online Privacy Notice

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Teneo AI (‘’TENEO’’) is committed to protecting your privacy and ensuring the highest level of security for your personal information. This Privacy Notice explains the types of personal information we collect, how we use that information, who we share it with, how we protect that information and your legal rights. This Privacy Notice (“Notice”) applies to TENEO Services, teneo.ai, and any other services and features related to these products and subdomains, which are described below (the “Services”). 

If you are not a user of TENEO services, Teneo.ai nor any other services or features related to these products and subdomains, please check the applicable privacy policy here:  

Please read the following carefully to understand our views and practices regarding your personal information. 

WHO ARE WE? 

For the purposes of the applicable data protection law, the Data Controller is Teneo AI AB, with registered office at Stureplan 15, 2nd floor, 111 45 Stockholm, Sweden, with organization number 556840-2076. 

Th applicable data protection laws, shall include, but not be limited to the EU General Data Protection Regulation (2016/679) (‘’GDPR’’), the Data Protection Act 2018 and any other laws over which the European Commission has issued an adequacy decision.  

This Privacy Policy covers all personal information processed by Teneo AI acting as a Controller (as described in the GDPR) which means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly. The process complies with the principles and rights contained in the GDPR. 

WHAT DATA DO WE COLLECT AND HOW DO WE COLLECT IT? 

We may collect information about you from the following resources: 

Information we receive from you 

We may collect personal information, such as your name, e-mail address, job title, telephone number, and all other personal information that may be provided by you. This personal information is provided to us when you: 

Personal Data we collect or are furnished with from other sources. 

  • Platforms such as GitHub to manage code check-ins and pull requests. If you participate in an open source or community development project, we may associate your code repository username with your community account and the Contribution License Agreement so we can inform you of program changes that are important to your participation or relate to additional security requirements. 
  • Information from Partners. When you use any of the functionalities, we make available, we have been furnished with enough information from Partners to make TENEO Services available to you. 

Information we collect about you 

When you access to TENEO SaaS Products. As an Authorized User, we will monitor your usage and consumption of the SaaS Products. TENEO uses inspection and analytics techniques to better understand how the SaaS Products are being used by the Customer.  

We use only aggregated data, that does not contain personal identifiable data nor can be reverse engineered to contain personal identifiable data. 

TENEO may temporarily hold audit logs information to be able to find anomalous usage patterns that could indicate attacks and breaches of the SaaS Service and so to be able to provide an audit record of user’s actions performed during last year. Audit logs may contain IP addresses which could be considered Personal Information. Audit logs will be kept for a year. 

TENEO may temporarily link logs with a username, time stamp and event description to be able to do troubleshooting for the ongoing service, as well as keep a record of it to be able to do a follow-up on the issue and for a year after completion of the troubleshooting. 

When using Teneo AI online education and training applications. The following data is stored so we can provide you with an acceptable learning experience:  

  • Logs (within a third-party application call Moodle) contain detailed information about user activity within each course, including the date and time of when course-specific information was viewed and/or updated, the address of the machine from which the access was made, the browser identification information and information about the referring web page. These logs are used to create summary statistics which may be made internally available. Summary statistics do not include personal data. 
  • The Moodle system contains information about contributions to courses, including contributions to chat rooms and discussion forums, ownership of resources, assignment/file submissions, text matching scores and evidence of participation in other Moodle-based activities. 
  • Information and data related to users, including grades, feedback comments, scores, completion data, access rights and group membership is also recorded. 
  • Additional personal data may be held within individual courses, either within documents/resources uploaded to the course, or within activities within the course. Other than contributions to chat rooms and discussion forums which are submitted by individuals in a personal capacity, course maintainers are responsible for the information held about you that may be uploaded onto such courses. 

When you contact TENEO Support Centre. we will use your email, username and last login to be able to help you with your query. We will store the content of your ticket to be able to improve our services and be able to track your queries. 

When you visit our Website: developers.teneo.ai. We may use cookies and other technologies to automatically collect the following information: 

  • Cookie data, which comes from “cookies” (small data files stored on your computer or mobile device) and similar technologies. Cookie data helps us recognize you, remember your preferences, and learn more about you; some, but not all, cookie data is associated with the functionality we make available. You can use the Cookie Panel to disable them. To learn more about our use of cookies, web beacons, and similar technologies, click here to read our Cookie Policy. 

HOW WILL WE USE YOUR PERSONAL DATA?

Information
Purpose
Lawful grounds of the processing
Name, email address, company, job title, troubleshooting logs, username.
To verify your identity.

To set up and manage your account.

To protect the security and integrity of our websites and functionality we make available.

To contact you when necessary or appropriate.

To assist you with your query.
We may use your information in these ways as this is necessary for us to perform our contractual obligations towards you and we have a legal obligation to keep records of our contractual agreements.
Account credentials
To give you access to our services and products
We will process this personal data to perform the contractual obligation towards you.
Personal information you disclose when using TENEO Support Centre or contact Customer Success
To respond to your comments and questions.

To assist you with your query.

To respond to your enquiries
We may process this information because it is necessary for us to perform our contractual obligations towards you.
Within our online training and education applications built with a learning management system (LMS) called Moodle
Provide account access and be identifiable within the LMS.

Provide access to papers/sites within the LMS.

Provide the ability to upload, amend and delete certain information within the LMS.

Provide access to information, resources and activities uploaded to the LMS.

Control access to different parts of the LMS.

Help support LMS users.

For system administration and bug tracking.

Report on course, resource and activity access, activity completion, course completion and course data (such as grades, scores, submissions and content uploaded).

For producing usage statistics for management and planning purposes.
We will process this personal data to perform the contractual obligation towards you. The tool used may have different processing activities and would inform you of their own processing activities.

HOW DO WE STORE YOUR DATA?  

We have implemented technical and organisational security measures to safeguard your personal information in our custody or control. Such measures include, for example, limiting access to personal information only to employees and authorised service providers who need to know such information for the purposes described in this Privacy Notice, as well as other administrative, technical and physical safeguards.  

In using some of the functionalities we make available, you may come across links to websites and services operated by third parties. These third parties have their own privacy policies, which will apply to your activity if you click on the link or access their website or service. We do not accept any responsibility or liability for such external sites’ privacy and security practices. 

We endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification, and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors. 

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION? 

We will only keep your personal data during the length of the agreement, to be able to deliver the services we agreed to, and after termination if we think it could be useful for internal purposes and we still have your consent. We will keep it as long as the applicable laws in conjunction with our Information Security Management System requires it. When none of the justification above are met we will delete or anonymize all your personal data that we may hold, without prejudice of the exercise of your right to delete. Bear in mind we may not be able to accept your request if it makes impossible for us to deliver the service or contravenes a compulsory mandate by law. 

WITH WHOM MAY WE SHARE YOUR PERSONAL INFORMATION? 

Service providers: Your data may be stored with third parties acting as Processors, for the purposes of the GDPR, whose security measures at least represent the same security standard as in Teneo AI: 

Communication tools: We may communicate with you via email from our Customer Success Team. 

Cloud tools: Where we will store any agreement you have in place with us. 

Support tools: Tools needed to provide you with TENEO Support Centre 

Authentication tools: In case you register and need to access to our services. 

Moodle: Online training and education applications. 

Log analytics: Tools that help us collect, store, analyse and process your logs. 

While providing such services, these service providers may have access to your personal information. However, we will only provide our service providers with personal information which is necessary for them to perform their services, and we require them not to use your information for any other purpose. We use our best efforts to ensure that all our service providers keep your personal information secure. If you need more details about our Service providers, please contact us using the details below. 

Third parties required or permitted by law: In certain circumstances, we may be required to disclose or share your personal information to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies or to judicial or administrative authorities). 

We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public. 

Third parties connected with business transfers: We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice. 

We will not sell, trade, or rent your personal information to third parties. 

If you are a resident in the European Union, be aware that by continuing to use some of the functionalities we make available, some of your personal information may be transferred to and processed outside of the European Union, by us, our affiliates and our service providers. We take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice, national data protection laws and the General Data Protection Regulation (EU) 2016/679 requirements for data transfers outside the European Union, by using tools such as Standard Contractual Clauses, Adequacy Decisions, International Treaties and, of course, your consent. If you have any questions, please contact us at the details set out below. 

Teneo AI group entities:  we may share your information with our entities located in the European Union and which are legally bound by GDPR. Furthermore, TENEO operates within a ISMS which guarantees the same security standard to all European and non-European companies for the purpose of information security and GDPR.

NAME
ACTUAL LOCATION OF THE PROCESSING
TENEO AI AB (HQ)
Sweden
Teneo AI EMEA AB
Sweden
Artificial Solutions Iberia, S. L.
Spain
Artificial Solutions B.V.
Netherlands

WHAT ARE YOUR DATA PROTECTION RIGHTS? 

You have the following rights:  

  • Access the information we hold about you. We'll usually share this with you within 30 days of you asking us for it. With some of the functionalities we make available you can also ask 'what do you know about me' to see an overview of your account. 
  • Correction or deletion of the information we hold about you. If your information is incomplete or inaccurate, or you would like us to delete your information, please contact us using the details set out below. Unless we need to retain such data to comply with a legal obligation or to establish, exercise or defend legal claims. Bear in mind we cannot warranty accuracy of your personal data unless you provide us with the correct information. 
  • Restriction of our processing of your personal information. You can do this where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose, or because you do not want us to delete it.  
  • Portability. You can ask for the personal information we hold about you to be provided in a structured, electronic format, and sent to another data controller where it’s technically feasible, where this is (a) personal information which you have provided to us, and (b) we are processing that data on the basis of your consent or to perform a contract with you.  
  • Right to object. Where the legal justification for our processing of your personal information is our legitimate interest, you can object to such processing on grounds relating to your particular situation. We will stop processing your data unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim. 
  • Right to withdraw consent. If you have consented to our processing of your personal information, you can withdraw your consent at any time, free of charge This includes cases where you wish to opt out from marketing messages that you receive from us.  

You can make a request to exercise any of these rights in relation to your personal information by sending the request by mail to our group DPO, María Carrillo at Stureplan 15, 2nd floor, 111 45 Stockholm, Sweden, or by email to LegalCompliance@teneo.ai.  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated. 

You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. If you are based in, or the issue you would like to complain about took place, in the EEA, please click here for a list of local data protection authorities in the other EEA countries. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office and the Swiss Federal Data Protection and Information Commissioner.  

CHANGES TO OUR PRIVACY POLICY 

This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail. 

We reserve the right to change our Privacy Policy from time to time. If we add any different purpose of those included here, we will notify you and ask for your acceptance. If we decide to do any other changes to this Policy, we will update it directly in our websites. 

HOW TO CONTACT US  

If there are any questions or concerns regarding this Privacy Notice, please contact our DPO as follows: 

  • by email: María Carrillo, LegalCompliance@teneo.ai 
  • by post: Teneo AI, DPO, María Carrillo, Stureplan 15, 2nd floor, 111 45 Stockholm, Sweden.