This privacy policy will inform you as to how we look after your Personal Data when you visit our app or our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important Information and Who We Are

Purpose of this privacy policy

This privacy policy aims to give you information on how Automata collects and processes your Personal Data through your use of the website, including any data you may provide when you complete trial/partnership surveys, purchase our products, subscribe to our newsletter, give us your details in person at a meeting/tradeshow/conference, write to us with queries, or give us any feedback.

This website is not intended for minors (a person under the age of full legal responsibility) and we do not knowingly collect data relating to minors.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

Controller

Automata Technologies Limited, trading as Automata, is the controller and responsible for your Personal Data (collectively referred to as “Automata” “we”, “us” or “our” in this Privacy Policy).

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Full name of legal entity: Automata Technologies Limited

Email address: data@automata.tech

Registered Address: 3^rd Floor, 20 Old Bailey, London, United Kingdom, EC4M 7AN

Postal Address: 15-29 Windsor St, London N1 8QG

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated in November 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

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The Data We Collect About You

Personal Data, or Personal Information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:

• Identity Data – includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data – includes billing address, delivery address, email address and telephone numbers.
• Financial Data – includes bank account and payment card details, which is currently being done by a third party.
• Transaction Data – includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data – includes Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data – includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data – includes information about how you use our website and our products and services.
• Marketing and Communications Data – includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or app feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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How Your Personal Data Collected

We use different methods to collect data from and about you including through:

• Direct interactions – You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • purchase products from our website;
  • sign up to participate in a trial on our website;
  • create an account on our website or our programming software;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • in-person meetings where personal details have been shared;
  • enter a competition, promotion or survey; or
  • give us some feedback.

• Automated technologies or interactions – As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the section on cookies below for further details.

• Third parties or publicly available sources – We may receive Personal or Technical Data about you from various third parties as set out below:
  • analytics providers such as Google or marketing automation solutions based outside the EU;
  • search information providers such as Google based inside OR outside the EU.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based inside OR outside the EU. We use third-party payment providers to collect and process your financial details, where necessary, and we will not be collecting Financial Data directly.

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How We Use Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details above or unsubscribing from the marketing communications.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you on a trial for a product To register you as a new customer	Identity Contact Marketing and communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To process and deliver any orders of products you place, including: managing payments, fees and charges Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, promotion, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our programming software and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Usage Marketing and Communication Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

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Robot Data

This section provides you with a detailed view of the information collected in our “Robot Data” programme.

Robot Data is a programme which requires you to ‘opt-in’ to enable us to collect, store and visualise usage data from new and existing customer robots.

The data will allow us to derive insights from robot usage. The data collected may be used to inform product decisions designed to improve your experience.

The information will not be sold to any third parties, nor will it be made available to anyone outside of Automata.

What we are collecting

Data is collected from your robot if you have chosen to opt into the Robot Data programme. Robots set up in an online state will live stream data to our secure Cloud service. Here the data will be collected, stored and eventually pushed to our analytics platform.

We collect data based on the concept of “Events” which occur every time the robot encounters an action. Depending on the type and frequency of Events, we may use this information to determine how the robot was used over a period of time.

An example of the typical information collected on the robots can be seen in the table below (we may change or introduce new Events from time to time).

Example event name	Typical Data Collected from the event	Questions that may be asked
Robot bootup	Current software version Is the robot set up and online? Last software update result	Was the robot turned on today? Was the latest software update installed successfully?
Robot update	Current software version Target software version for update	What version is the robot being updated to and from?
Robot alive ping	Histogram of API Usage Histogram of user agents	How is the robot controlled? Which API routes is the robot programmed with?
Robot was setup	*Network config (censored)	How long does it take to setup the robot?
Robot network config changed	*Network config (censored)	Is the robot setup on WiFi and are all the robots on the same network?

*We do not intend to collect any personal information from you in relation to the Robot Data. As a precautionary measure, we have decided to censor some of the data to avoid any concern over what could be deemed as personal data. For example, this will be done with the Network configuration data to obscure any information which might indicate your setup infrastructure. This will allow us to see how many times that configuration was used, but not the values of that configuration.

Why we are collecting Robot Data

We aim to provide you with the best experience we can offer. In order to identify areas which need improvement we need to measure the success and shortcomings of the active products, this involves:

Collecting, storing and analysing Robot Event Data to enable us to:

• Improve your support experience
  • Faster response times
  • Easier diagnosis of issues
  • Higher-quality reference documentation
• Ensure that the most valued features are prioritised and delivered
• Improve your product experience
  • More intuitive software
  • Easier connectivity setup
  • Faster programming
• Spot issues in robots before they become problems

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Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Automata for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transaction.

Cookies

Cookies are small text files that we place in visitors’ computer browsers to store their preferences. Our cookies themselves do not contain any personal information. Our cookies may reference the personal information you provided during registration. We reference the information you provided via an encrypted identifier. Where we link these unique identifiers with your personal information, we will treat the unique identifiers as personal information as long as they are linked. We use the registration information you provided to contact you if you lose your password or contact you about updates and changes at Automata. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate Automata. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following the directions provided in your Internet browser’s “help” file. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the email address listed above. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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Disclosures of Your Personal Data

We may have to share your Personal Data with the parties set out below for the purposes set out in the “Purposes for which we will use your personal data” table above.

• External Third Parties are set out below:
  • Service providers acting as processors based in the United States who provide IT and system administration services.
  • Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
• Where we use certain service providers, we may use specific contracts which may have been approved by the European Commission which give Personal Data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the US.

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Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.

• Request access to your Personal Data – This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of your Personal Data. – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. – This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.
• Object to processing of your Personal Data – You may object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your Personal Data – This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your Personal Data – We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent. Where we are relying on consent to process your personal data, you may withdraw that consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details above.

No fee usually required – You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you – 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.

Time limit to respond – 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 a number of requests. In this case, we will notify you and keep you updated.