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Privacy Policy

Last updated: September 12, 2024

1. Introduction

Tier One Analytics, Inc. is an IT consulting company headquartered at 1751 Pinnacle Dr #600, McLean, VA 22102, United States. This Privacy Policy covers and regulates the processing of personal data by the T1A group of companies, which includes: Tier One Analytics Inc., Tier One Analytics (Canada) Inc., Tier One Analytics s.r.o., Tier One Analytics GmbH, TIER ONE ANALYTICS DOO BEOGRAD, and Tier One Analytics sp. z o.o. (hereinafter referred to as "T1A"). T1A is referred to as either "the Company," "We," "Us," or "Our" in this Privacy Policy.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes T1A’s policies and practices regarding the collection, processing, and use of your personal data when you use our websites and in the usual course of business, such as in connection with our services, sales, and marketing activities (collectively referred to as “T1A Services”). It also informs you about your privacy rights and how the law protects you.

We recognize that information privacy is an ongoing responsibility, and we will update this Privacy Policy from time to time as we undertake new personal data practices or adopt new privacy policies.

We use your personal data to provide and improve T1A Services. By using T1A Services, you agree to the collection and processing of your personal information in accordance with this Privacy Policy.

We provide T1A Services to our customers and users (collectively referred to as “Customers”) under an agreement with them and solely for their benefit and the benefit of the personnel authorized to use T1A Services (“Authorized Users”). Our processing of personal data is additionally governed by our agreement with the relevant Customer. This Privacy Policy does not apply to (i) any products, services, websites, or content that are offered by third parties or that have their own privacy notice; or (ii) personal information that we collect and process in connection with our recruitment and employment activities, which are covered under our Employee Privacy Notice.

2. Interpretation and Definitions

2.1. Interpretation

The words with initial letter capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

2.2. Definitions

For the purposes of this Privacy Policy:

  • Cookies are small files that are placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history on that website among its many uses.
  • Device means any device that can access the T1A Websites, such as a computer, a cell phone, or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service Provider means any natural or legal person who processes the data on behalf of T1A. It refers to third-party companies or individuals employed by T1A to facilitate the T1A Services, to provide the T1A Services on behalf of T1A, to perform services related to the T1A Services, or to assist T1A in analyzing how the T1A Services are used.
  • Usage Data refers to data collected automatically, either generated by the use of the T1A Services or the Websites’ infrastructure itself (for example, the duration of a page visit, the frequency of your use, links that you click, and how often you log in).
  • Websites refers to T1A websites, accessible at https://t1a.com/ or https://getalchemist.io/
  • You mean the individual accessing or using the T1A Services, or the company or other legal entity on behalf of which such individual is accessing or using the T1A Services, as applicable.

3. Types of data; how we collect and use (process) your personal information

3.1. Personal Data

While using T1A Services, We may ask You to provide Us or You can provide by yourself with certain personally identifiable information that can be used to contact or identify You. With a few exceptions, this information is generally limited to:

  • Email address;
  • First name and last name;
  • Company’s name;
  • Job title;
  • Work phone number.

We may also collect other information that You provide through Your interactions with Us, for example if You request information about T1A Services, interact with our sales team or contact customer support, complete a survey, provide feedback, register for an event, or take part in marketing activities. We may keep a record of your communications with us and other information you share during the course of the communications.

We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services.

If you provide T1A with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Policy.

From time to time, T1A receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry.

3.2. Information we collect automatically
3.2.1. Usage Data

T1A also collects personal information about its Website visitors. As is true of most other websites, T1A’s Websites collect certain information automatically and store it in log files (Usage Data). The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of T1A’s website, including a history of the pages you view. We use this information to help us design our Websites to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our Websites, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
Some T1A Services, such as Alchemist, uses device fingerprint techniques to identify Customer’s device ID  and connect it with the issued license.

When you register to use T1A Services, we may collect your personal information, such as your name and email.

T1A has a legitimate interest in understanding how members, customers and potential customers use its Websites. This assists T1A with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet customer needs.

3.2.2. Cookies

We use Cookies and similar tracking technologies to track the activity on T1A Websites and store certain information. A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser and store information or settings on the device. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Services. The types of data collection tools we use may change over time as technology evolves.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Websites and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us ​​

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Targeting Cookies

Type: Session Cookies

Administered by: Us

Purpose: Targeting cookies are used to identify visitors between different websites, e.g., content partners, banner networks. Those cookies may be used by companies to build a profile of visitor interests or show relevant ads on other websites.

Performance Cookies

Type: Session Cookies

Administered by: Us

Purpose: Performance cookies are used to see how visitors use the website, e.g., analytics cookies. Those cookies cannot be used to directly identify a certain visitor.

T1A makes available a comprehensive COOKIE DISCLAIMER that describes the cookies and tracking technologies used on T1A Websites and provides information on how users can accept or reject them. You can see the disclaimer when you visit the T1A Websites. For more information about the cookies we use and your choices regarding cookies, please visit T1A’s Cookies Policy, available at: t1a.com/cookie-policy

3.3. Information we receive from other sources

We may obtain information about You from third party sources, including resellers, distributors, business partners, event sponsors, security and fraud detection services, social media platforms, and publicly available sources. Examples of information that we receive from third parties include marketing and sales information (such as name, email address, phone number and similar contact information), and other information about your interactions with our  Websites. We may combine such information with the information we receive and collect from You.

3.4. Use of Your Personal Data

T1A may use Personal Data for the following purposes:

  • To provide and maintain our Service , including to monitor the usage of our Service.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us.
  • To contact You: To contact You by email, telephone calls, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Consent: where you have given us explicit consent to process your data.
  • Contractual Necessity: where processing is necessary for the performance of a contract with you.
  • Legal Obligation: where we need to comply with a legal obligation.  
  • Legitimate Interests: where processing is necessary for our legitimate interests or those of a third party.

5. Data sharing and transfer

5.1. With whom we can share Your Personal Data

The personal information T1A collects from You is stored in one database hosted by a third party located in Germany. This third party does not use or have access to your personal information for any purpose other than cloud storage and retrieval.

If we involve sub-processors other than T1A’s Affiliates  in the processing of your personal data, a list of our third-party sub-processors will be approved by you through the signing of a separate DPA.

We may share your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of T1A assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include the T1A group of companies that We control or that are under common control with Us, which are the following:
    - T1A Inc (Address: 1751 Pinnacle Dr Suite #600 McLean, VA 22102);
    - Tier One Analytics s.r.o. (Address: Pernerova 676/51, 186 00 Prague, Czech Republic);
    - Tier One Analytics GmbH (Address: Mainzer straße 97, 65189 Wiesbaden, Germany);
    - Tier One Analytics sp.z o.o. (Address: Elektoralna 13 lok. 121, 00-137 Warsaw, Poland);
    - TIER ONE ANALYTICS DOO BEOGRAD (Address: Cara Nikolaja II 11, floor I, apartment 2, 11000, Belgrade, Serbia).
  • With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. 
 5.2. Bases for sharing your Personal Data

We can reveal your personal data to non T1A persons or businesses for their independent use based on Your request or Consent or based on the following grounds:

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation.
  • Protect and defend the rights or property of the Company.
  • Prevent or investigate possible wrongdoing in connection with the Service.
  • Protect the personal safety of Users of the Service or the public.
  • Protect against legal liability
  • Protect against legal liability
5.3.  International Data Transfers. Transferring and processing personal data outside the EEA

As an international organization, we may transfer your personal data to countries outside the European Economic Area (EEA), including the USA, Canada, and Serbia. We ensure that such transfers are conducted in compliance with applicable data protection laws and that appropriate safeguards are in place.

Your information, including Personal Data, is processed at the T1A's operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. These countries may not have equivalent data protection laws to the country where you reside.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information from the EEA or Switzerland between us and our business partners and service providers, and equivalent measures for transfers of personal information from the United Kingdom. T1A also offers our Customers the ability to enter into a DPA that contains the Standard Contractual Clauses, for transfers between us and our Customers.

T1A has its headquarters in the United States and operating offices in Germany, Poland, the Czech Republic, Canada and Serbia.

By using T1A’s Services, you acknowledge that your personal information will be processed outside the EEA, including in the USA, Serbia and Canada. The USA and Serbia have not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR.

Pursuant to Article 46 of the GDPR, T1A is providing for appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.

Depending on the circumstance, T1A also may collect and transfer personal data outside the EEA with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of T1A in a manner that does not outweigh your rights and freedoms. T1A endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with T1A and the practices described in this Privacy Policy. T1A also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate.

Since it was founded, T1A has received zero government requests for information.
For more information or if you have any questions, please contact us at: pd_US@t1a.com.

6. Security of Your Personal Data

We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information.  The security of Your Personal Data is important to Us, but remember that no security measures are perfect or impenetrable and no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

7. Data subject rights

7.1 Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.If you'd like to request more information under the California’s Shine the Light law, and if you are a California resident, You can contact Us using the contact information provided below.

7.2 California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

7.3. CCPA Privacy Rights (Do Not Sell My Personal Information)

Under the CCPA, among other rights, California consumers have the right to:

Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.

Request that a business delete any personal data about the consumer that a business has collected.

Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

7.4. GDPR Data Subject rights

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

  • Right to be informed
  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restrict processing
  • Right of data portability
  • Right to object
  • Rights related to automated decision making including profiling

This Privacy Policy is intended to provide you with information about what personal data T1A collects about you and how it is used.

If you wish to confirm that T1A is processing your personal data, or to have access to the personal data T1A may have about you, please contact us.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside T1A might have received the data from T1A; what the source of the information was (if you didn’t provide it directly to T1A); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by T1A if it is inaccurate. You may request that T1A erase that data or cease processing it, subject to certain exceptions. You may also request that T1A cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how T1A processes your personal data. When technically feasible, T1A will—at your request—provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, T1A will provide you with a date when the information will be provided. If for some reason access is denied, T1A will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email us at:pd_US@t1a.com. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation’s data protection authority.

8. Data storage and retention

Your personal data is stored by T1A on its servers, and on the servers of the cloud-based database management services T1A engages, located in Germany T1A retains service data for the duration of the customer’s business relationship with T1A and for a period of time thereafter, to analyze the data for T1A’s own operations, and for historical and archiving purposes associated with T1A’s services. T1A retains prospect data until such time as it no longer has business value and is purged from T1A systems. All personal data that T1A controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: pd_US@t1a.com

9. Children’s data

We do not knowingly attempt to solicit or receive information from children. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

10. Links to Other Websites

T1A Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11. Notice to Authorized Users

T1A Services are intended to be used by organizations. Where the T1A Services are made available to you through an organization (e.g., your employer), that organization is the administrator of the T1A Services and responsible for the accounts and/or services over which it has control. For example, administrators can access and change information in your account or restrict and terminate your access to the T1A Services. We are not responsible for the privacy or security practices of an administrator's organization, which may be different from this Privacy Policy. Please, contact your organization or refer to your organization's policies for more information.

12. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. If we make material changes, we provide a more prominent notice (for example, by adding a statement to the website landing page, providing notice through the Platform Services login screen, or by emailing you).

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. Questions, concerns or complaints

To request a copy of the Personal Information or if you have any questions about this Privacy Policy, update or correct inaccuracies in that information, or request to remove your information from our systems and stop contacting you, please email us to pd_US@t1a.com with a detailed request, including your full name, physical address, and email address.

You can also write to us at Tier One Analytics, Inc, 1751 Pinnacle Dr #600, McLean, VA 22102, UNITED STATES; Attn: Privacy.

If you interact with T1A through or on behalf of your organization, then your personal information may also be subject to your organization’s privacy practices and you should direct any questions to that organization.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. However, if you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority in the country in which you live.

Annex

A list of T1A third-party sub processors
Company Name: T1A
Last updated: September 12, 2024

Tier One Analytics, Inc and its affiliates (T1A Group of companies) may engage and use certain third-party data processors (“Sub-Processors”) to provide Services to our customers. In accordance with our obligations under the General Data Protection Regulation (GDPR) and other applicable data protection laws, we provide this list of Sub- Processors who may process personal data on our behalf. 

This list provides important information about the identity, location and role of each Sub-Processor. Please note that not all Sub-Processors are used in the provision of all services we provide and some may only be involved in assisting with the provision of specific services.

Sub-Processor
Location
Purpose of processing
Website/ Contact Details
Salesforce
United States
Sales
Google Suite
United States
Data Management and Storage
Amazon Web Services
United States
Cloud services, website hosting, and data center services
Jira
United States
Task Management System
Quickbooks online
USA
Bookkeeping, Issue invoices
HLB
Beograd
Bookkeeping
Datev
Germany
Bookkeeping
Pisa
Germany
Bookkeeping, Issue invoices
Owap (olesinski)
Poland
Bookkeeping
360 WEDO (ex Leesora)
Czech Republic
Bookkeeping
Wave
USA
Issue invoices
The following entities are the Group of Companies within our organization:
  • T1A Inc (Address: 1751 Pinnacle Dr Suite #600 McLean, VA 22102);
  • Tier One Analytics s.r.o. (Address: Pernerova 676/51, 186 00 Prague, Czech Republic);
  • Tier One Analytics GmbH (Address: Mainzer straße 97, 65189 Wiesbaden, Germany);
  • Tier One Analytics sp.z o.o. (Address: Elektoralna 13 lok. 121, 00-137 Warsaw, Poland);
  • TIER ONE ANALYTICS DOO BEOGRAD (Address: Cara Nikolaja II 11, floor I, apartment 2, 11000, Belgrade, Serbia).

Version History

Version
Date
Description
Author
Approved by
1.0
01 July 2024
Lawyer - Radmila Minacheva
CIO - Ivan Baranov
2.0
12 September 2024
Lawyer - Radmila Minacheva
CIO - Ivan Baranov

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