1) The Highlights
- We collect only what we need to operate our website, respond to inquiries, provide demos/consultations, deliver and improve our Services, and meet our legal obligations.
- Typical data includes contact details you submit (e.g., name, email, phone), business details you share during onboarding, and limited technical data (e.g., IP address, device/browser data) via cookies/analytics.
- For customer chatbots and AI agents you deploy with us, we process the data you (or your users) submit to the bot as your processor and only according to your instructions.
- You have rights under applicable law (e.g., GDPR) to access, correct, delete, restrict, or object to processing and to withdraw consent where applicable.
- We use service providers (hosting, email, analytics, payments if enabled) under data processing agreements. We do not sell personal data.
- Children under 16 should not use our Services. We do not knowingly collect children’s data.
2) What Is Personal Data?
Personal Data means any information that identifies or can reasonably identify a natural person (e.g., name, email address, phone, IP, online identifiers). Non‑Personal Data is aggregated, de‑identified, or otherwise cannot reasonably identify a person.
3) Data We Process & Why
| Category | Examples | Purpose | Legal Basis (GDPR) |
|---|---|---|---|
| Contact & Inquiry Data | Name, email, phone, company, message content (e.g., consultation or demo requests, support tickets). | Reply to inquiries, schedule demos, provide support, and manage our relationship with you. | Legitimate interests in operating our business and responding to you; or steps prior to a contract / performance of a contract. |
| Account / Onboarding Data (for clients) | Authorized user details, role, login metadata, billing/admin contacts. | Set up and administer client accounts, authenticate access, provide the Services, issue invoices. | Performance of a contract; legitimate interests; legal obligation (e.g., invoicing, tax). |
| Service Usage & Logs | Interactions with our apps/agents, timestamps, basic diagnostic logs (not model weights). | Operate, secure, troubleshoot, and improve the Services; prevent abuse and fraud. | Legitimate interests in security and service improvement. |
| Website Analytics & Cookies | IP address, device/browser type, pages viewed, referrer, session data (via cookies or similar). | Measure and improve site performance; understand content usage; personalize where permitted. | Consent (where required); otherwise legitimate interests. See Consent & Cookies Policy. |
| Marketing Preferences | Email address, subscription status, open/click events. | Send product updates and newsletters (only if you opt in); manage unsubscribes. | Consent; legitimate interests for existing customers (soft opt‑in, where permitted). |
| Client End‑User Content (Your Bot/Agent) | Questions users ask your bot, files they upload, and conversation transcripts (as configured). | Provide the bot/agent functionality to you as the client. We process this as your processor under our agreement and DPAs. | Performance of a contract; processing as processor on your instructions. |
4) How We Collect Data
- Directly from you — when you submit forms, book demos, sign contracts, or communicate with us.
- Automatically — through cookies, logs, and similar technologies when you use our website or Services.
- From clients — when a client provisions users or routes bot conversations to us for processing on their behalf.
5) Your Privacy Rights
Depending on your jurisdiction (e.g., EEA/UK under the GDPR), you may have the right to request access, correction, deletion, restriction, portability, and to object to certain processing. Where we rely on consent, you may withdraw it at any time. To exercise rights, contact info@asenaytech.com. We may request reasonable information to verify your identity and will respond in line with applicable law.
6) Sharing Your Data
We share Personal Data only as needed:
- Service Providers / Processors (e.g., hosting, storage, email, analytics, payments if enabled) under contracts that require appropriate safeguards.
- Change of Control if we undergo a merger, acquisition, or similar transaction.
- Legal / Safety to comply with law, enforce our terms, or protect rights, security, and integrity.
- With your consent or at your direction.
We do not sell your Personal Data.
7) Cookies & Tracking
We use cookies and similar technologies to operate and improve our website. You can manage preferences via your browser settings and any consent banner we provide. Learn more in our Consent & Cookies Policy.
8) International Transfers
Asenay Tech Ltd is registered in Rwanda and operates with a presence in Germany. Where Personal Data is transferred internationally (including from the EEA/UK), we implement appropriate safeguards such as standard contractual clauses or equivalent mechanisms, and assess partners’ security and privacy practices.
9) Security
We use administrative, technical, and organizational measures appropriate to the risk (e.g., encryption in transit, access controls, logging). No method of transmission or storage is 100% secure; we continually improve our safeguards.
10) Data Retention
We retain Personal Data only as long as necessary for the purposes described above, to comply with legal obligations, resolve disputes, and enforce agreements. Retention periods may differ per record type and client configuration.
11) Children
Our Services are not directed to children under 16, and we do not knowingly collect children’s data. If you believe a child provided data to us, contact us and we will delete it.
12) Marketing
We may send product updates or newsletters if you opt in (or where permitted for existing customers). You can unsubscribe at any time via the link in the email or by contacting us.
13) Changes to This Policy
We may update this Privacy Policy from time to time. We will post the updated version here and adjust the “Updated” date above. Material changes will be highlighted or notified when appropriate.
14) Contact Us
Data Controller: Asenay Tech Ltd
Email: info@asenaytech.com
Registered office: Kigali, Rwanda • EU presence: Marburg, Germany
Note: This policy is provided for transparency and does not create additional contractual obligations beyond those in our Terms of Service and agreements with clients.