数据保护

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the perceptos GmbH (hereinafter "Perceptos"). The use of the websites of Perceptos (e.g. the website https://www.ideaclouds.net, landing pages, blogs, wikis, etc.; hereinafter “websites”) is possible without any indication of personal data; however, if a data subject wants to use a web app or web platform hosted by Perceptos (hereinafter “SaaS services”) processing of personal data could become necessary. For instance, this applies to the web app “IdeaClouds” reachable via https://app.ideaclouds.net/ and to IdeaClouds Enterprise platforms hosted by Perceptos. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Perceptos. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, the Perceptos has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through the websites and SaaS services hosted by Perceptos. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

Definitions

The data protection declaration of the Perceptos is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of that data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Name and address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

perceptos GmbH

Leopoldstraße 8-10

80802 Munich

Germany

Phone: +49 89 / 2154 1266

Email: info@ideaclouds.net

Website: https://www.ideaclouds.net

Cookies

The websites and SaaS services of Perceptos use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, the Perceptos can provide the users of the websites and SaaS services with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our websites and SaaS services can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize the users of our websites and SaaS services. The purpose of this recognition is to make it easier for users to utilize our websites and SaaS services. For instance, a user who uses the IdeaClouds web app via the IdeaClouds website that uses cookies, does not have to enter access data each time the IdeaClouds website is accessed, because this is taken over by the IdeaClouds website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our websites and SaaS services by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our websites and SaaS services may be entirely usable.

Collection of general data and information

The websites and SaaS services of the Perceptos collect a series of general data and information when a data subject or automated system calls up the websites or SaaS services. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our websites or SaaS services (so-called “referrers”), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using this general data and information, the Perceptos does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our websites and SaaS services correctly, (2) optimize the content of our websites and SaaS services as well as its advertisement, (3) ensure the long-term viability of our information technology systems and technology of our websites and SaaS services, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Perceptos analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

Registration for our SaaS services

The data subject has the possibility to register for the corresponding web service of the controller e.g. via the IdeaClouds website by entering personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering for a SaaS service of the controller e.g. via the IdeaClouds website, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

Participation in workshops without registration

Registered persons have the possibility to set the access rights for the workshop they created as a host: a) "Only invited users can participate" or b) "Only registered users can participate" or c) "Anyone with a link can participate". With the latter setting, people can participate in a workshop even without registration. These persons only have to enter a name or alias in order to participate in the workshop. The name or alias is used to identify the participant in the workshop. Via the IdeaClouds website, the date and the time of the workshop entry are also stored. After 30 days, the user profile temporarily created for the participant, including the name or alias provided, is automatically deleted.

Contact possibility via websites and SaaS services

The websites and SaaS services of the Perceptos contain information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties with the exception of the cases described in this declaration.

Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Rights of the data subject

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• the purposes of the processing;

the categories of personal data concerned;

the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

the existence of the right to lodge a complaint with a supervisory authority;

where the personal data are not collected from the data subject, any available information as to their source;

the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

The personal data have been unlawfully processed.

The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Perceptos, he or she may, at any time, contact any employee of the controller. An employee of Perceptos shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Perceptos will arrange the necessary measures in individual cases.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.

The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.

The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Perceptos, he or she may at any time contact any employee of the controller. The employee of the Perceptos will arrange the restriction of the processing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of the Perceptos.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

The Perceptos shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If the Perceptos processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Perceptos to the processing for direct marketing purposes, the Perceptos will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Perceptos for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of the Perceptos. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Perceptos shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Perceptos.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Perceptos.

Links to other websites

Our websites and SaaS services also contain links to other websites that are not operated by us. As far as the user visits such websites, the data protection regulations and other information applicable on this website should be observed. Perceptos assumes no responsibility for the data protection standard and the handling of personal data of other companies.

Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

Provision of SaaS services

Our SaaS services can be used free of charge (“IdeaClouds Free”) by the registered person (user) or even after paying a license fee (“IdeaClouds Business” and “IdeaClouds Enterprise”). Once a person registers as a user for IdeaClouds e.g. through our IdeaClouds website, our IT team is assigned to provide that person with the SaaS service “IdeaClouds” so that that person can host an IdeaClouds workshop or join a IdeaClouds workshop as a guest. Participation is also possible without registration.

The purpose of Perceptos' storage of personal data (email address) is therefore to provide the SaaS services. The legal basis for the storage of personal data (contact information, company name and data for the application, administration and payment of a registered user) is a contract for the provision of the service that the user enters into when registering with Perceptos.

Our IT staff have access to the administrative data and application data of registered SaaS services users for data communication, IT security, quality assurance (debugging), and maintenance. Our support and sales representatives have access to contact and communication information (such as email), employment data, and contract information for the purpose of communicating, billing, and providing support.

Unless otherwise agreed with the customer, the SaaS services is hosted (Server and network infrastructure for storing data, server functionality) by us on a server of our hosting partner Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen) in Germany, so our hosting partner has access to master data, communication data (e.g. email) , IPs and application data possible. However, the accessibility is only taken on demand for the purpose of data communication service provision, IT security, quality assurance (debugging) and maintenance. Our affiliate may only process this information in accordance with our instructions.

The following describes the criteria for deleting the personal information used to provide our SaaS services:

• Invoice, payment and contract data will be stored for 10 years after expiration (from the end of the financial year)

User account can be deleted at any time by the user

Privacy Permissions including IPs are stored for 3 years (starting at the end of the fiscal year)

Access IPs are stored for security reasons (data protection control, intrusion detection, spam prevention) for 6 months

Security measures for data security

After a user's login attempt, they will be used to verify security and privacy issues in our SaaS services (e.g. IdeaClouds software) and related frameworks (notification and control of the entry, modification and deletion of personal data under § 76 BDSG) for the purpose of fulfilling the legal requirement to secure the processing of personal data and to identify potential security vulnerabilities in our SaaS services which stores communication data, IPs of registered as well as unregistered users and customers as well as Perceptos employees.

Our IT staff uses email addresses and IPs for the purpose of data communication and identification of potential security and privacy issues in the SaaS services.

Since our SaaS services (e.g. IdeaClouds web app) are hosted on a server of our hosting partner Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen) in Germany, this can theoretically also be based on contact and communication data (e.g. email), IPs, application data for Purpose of data communication service delivery, IT security, quality assurance (debugging) and on-demand maintenance access.

For security reasons (data protection control, intrusion detection, spam protection), access IPs and emails are stored for half a year.

The following software is also used to process the data:

• Server and network infrastructure (Hetzner GmbH) for storing personal data and server functionality.

Email communication via IdeaClouds

IdeaClouds provides email functionality that can be used by IdeaClouds users for different purposes such as inviting workshop participants, receiving notifications, sending support requests and system messages. Our current email service provider is Amazon Web Services EMEA SARL 38 avenue John F. Kennedy, L-1855 Luxembourg (EU). Note for IdeaClouds Enterprise platforms: This mail server can be replaced by a customer's own mail server if requested by the customer.

Transactional emails (e.g., reminders at the end of the contract term, notices of changes to the GTC) are sent via the email service provider "SendinBlue" (Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany).

Processing of support requests

When a person sends us an inquiry through the appropriate contact form on our websites or SaaS services (e.g. IdeaClouds usage question), it will be emailed to our support team and emailed to you by one of our support staff to help the requesting user / customer solve the problem.

In this case, the contact and communication data sent by the requesting person are used: To answer the email, the corresponding support staff uses only the email address of the requesting person in order to be able to transmit the answer to his question by email. Email addresses from emails with support requests are only used to answer support requests. The corresponding emails will be deleted no later than 1 month after the request has been processed. We use the email services of Google Workspace (Google Inc., 1600 Amphitheater Parkway, Mountain View, California 94043 USA) to send emails.

Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.