Privacy policy

At Flai d.o.o. (collectively “Flai” or “we”), accessible at www.flai.ai, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by Flai and how we use it. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at info@flai.ai

This Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in www.flai.ai, and all flai.ai subdomains and for users of app.flai.ai. This policy is not applicable to any information collected offline or via channels other than this website.

For the purpose of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable natural person; 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.

We are committed to comply with the regulations applicable to all processing of Personal Data that we implement, in particular the provisions of the General Data Protection Regulation (EU Regulation 2016/679 – “GDPR”).

1. Controller

The controller who is responsible for the data processing according to the terms of the EU General Data Protection Regulation (GDPR) is:

FLAI, družba za tehnološke storitve, d.o.o.
Bravničarjeva ulica 13
1000 Ljubljana
registration number. 9027459000
VAT ID number: SI 98445944
Email: info@flai.ai

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at info@flai.ai

2. What information we collect?

We collect your Personal Data with the aim to provide and continually improve our products and services. Generally, we may collect certain information that identifies you, information about how you use our service, and the information that you create while you interact with our service.

Personal Data that we collect from you may include the following:

• contact data, including email addresses, phone numbers
• inventory data, including names, addresses, job titles
• usage data, including web sites visited, date and time of access (time stamp),
• meta-data/communications data, including information about equipment, IP addresses
• billing information, which may include, billing addresses, VAT numbers or other tax numbers,

3. How do we collect your data?

Flai may directly collect your Personal Data you provide us, when you:

• use or view our website via your browser’s cookies;
• fill in contact form or send us an email;
• register for our login area and set up an account in order to use our website’s full range of functions;
• subscribe to our newsletter in which we inform you about current products and services;
• apply for a position via our applicant management system;
• complete a customer survey or provide feedback on any of our contact forms or via email;
• complete transactions through our website, such as fulfilling an order for our Service;
• perform search queries on our websites;
• request assistance from our support team;
• register for or attend our marketing events;

During each of your interactions with us, we collect information about your connection and your browsing (in accordance with the consent you give us). Different technologies can be used to collect those data. We refer to them generically as a "cookie".

4. How we use your information

By using the website, our services or subscribing to our marketing communications, Flai will collect and use your Personal Data for the following purposes (the “Purposes”):

4.1 that are based your consent pursuant to Art. 6(1)(a) GDPR:

• (a) promotion of our products/services and brand (i.e. newsletters, testimonials, email marketing campaigns, location-based marketing, digital marketing campaigns, response to enquiries, events, webinars, public relations activities etc)
• (b) consumer profiling (non-automated, track online behaviour, marketing analytics, user feedback, track website usage, Google Analytics, etc.)

You have a right to withdraw consent at any time which does not affect the lawfulness of processing based on consent before its withdrawal.

4.2 that are necessary for performance of contractual obligations pursuant to Art. 6(1)(b) GDPR:

• (a) access to our service;
• (b) sending you informational messages about our service;
• (c) onboarding & maintenance Emails (i.e you will automatically receive, after you finalized the sign-up and creation of your Flai account, emails that may include product onboarding tips, products and services updates to help you to access and use the platform in order to meet your needs. Such emails are part of the contract you concluded with Flai)
• (d) enforcement of our rights and obligations that arise from the contract entered into between you and us, including for billing and collection;
• (e) notification about your account and/or subscription, including expiration and renewal notices;
• (f) IT Services (provide and manage electronic communication interfaces, provide IT support, test products, systems and applications, manage software and applications);
• (g) customer support (i.e. manage user accounts, verify identity);

If you do not provide us with the data we need for performance of contractual obligations, we might not be able to provide you with certain services.

4.3 that are based on our legitimate and shared interest to provide services to you pursuant to Art. 6(1)(f) GDPR

• (a) interaction with us through the usage of sign-up forms and questionnaires to help us to provide better services;
• (b) manage customer profitability (manage customer profiles, plan and forecast sales, track conversion actions etc);
• (c) research and development (i.e. track product performance, deploy bug fixes, offer online products/services etc);
• (d) to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies;
• (e) to comply with applicable legal obligations, including responding to an authority or court order or discovery request;
• (f) for marketing of products or services similar to the ones you have already purchased.

We can also process Personal Data if we reasonably consider that we need to use it for another reason and that reason is compatible with the above Purposes (e. g. for preserving particular evidence under the applicable data protection laws, or in the context of legal statutes of limitation for example). If we need to use your Personal Data for an unrelated purpose, we will notify you prior to this further Personal Data processing and provide you the relevant privacy information notice and will take other required actions.

We currently do not use automated decision making. However, if this changes we will amend this policy accordingly and notify you thereof.

5. Storing of your information

Flai uses technical and organisational security measures protect the Personal Data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorised persons. Our security procedures are continually updated.

Your Personal Data will not be kept in a form that allows you to be identified for any longer than is reasonably considered necessary by Flai for achieving the purposes for which it was collected or processed or as it is established in the applicable laws related to data retention periods. Your Personal Data will, in any case, be retained for the duration of your relationship or engagement with Flai as well as thereafter for a reasonable time to ensure that Flai has the records it needs in the event of a dispute or regulatory investigation and to ensure that any ongoing obligations can be complied with, such as complying with requests from regulators. For further information regarding retention, please contact us as set out above.

6. Sharing of your information

When we process your Personal Data, it may occur that the data is transferred to other places, companies or persons or that it is disclosed to them. We only transfer your Personal Data to third parties if there is a legal basis for doing so, especially when you have given your explicit consent to this, this is necessary for the performance of the contract with you, there is a legal obligation for the disclosure, or transfer is necessary for the purposes of legitimate interests, and there is no reason to assume that you have an overriding legitimate interest to not transfer your data, as well as for the establishment, exercise or defence of legal claims.

Flai may share your Personal data with the following recipients:

• Regulators, authorities, and other third parties. As necessary for the Purposes described above, personal data may be transferred to regulators, courts, and other authorities (e.g., tax and law enforcement authorities), independent external advisors (e.g., auditors), insurance providers, internal compliance and investigation teams (including external advisers appointed to conduct internal investigations).
• Acquiring entities. If Flai may be sold or transferred in whole or in part (or such a sale or transfer is being contemplated), your personal data may be transferred to the acquiring entity as part of the transfer itself or as part of an initial review for such transfer (i.e. due diligence), subject to any rights provided by applicable law, including jurisdictions where the potential acquirer is located.
• Data processors. As necessary for the Purposes described above, Personal data may be shared with one or more third parties, whether affiliated or unaffiliated, to process personal data under appropriate instructions ("Data Processors"). The Data Processors may include data centres that store our website and databases, IT service providers that maintain our systems or provide CRM functionalities and consulting firms, payment service provider within the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are embedded in a website, and other service providers, and will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal information, and to process the personal information only as instructed. Our current key processors include Google (Google Analytics and Google Ads), HubSpot, Fathom and Microsoft Clarity.

As you may expect, some of the recipients we may share Personal Data with may be located in countries outside of Europe. In some cases, this may include countries located outside the European Union and / or European Economic Area ("EAA").

Some countries where recipients are located have already been assessed by the European Commission as ensuring an adequate level of protection for this data (including those within the EEA), whereas others are not deemed to ensure an adequate level of protection according to EU GDPR.

If recipients are located in other countries that are not deemed to ensure adequate protections for personal data, Flai will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. This could include (without limitation) using appropriate safeguards such as the Standard Contractual Clauses which the European Commission has assessed as providing an adequate level of protection for personal data. You can ask for a copy of the appropriate safeguards by contacting us as set out above.

7. Analytics, advertising and marketing tools

To operate, measure and improve our website and marketing, we use the tools described below. We load and manage them through Google Tag Manager (provided by Google Ireland Limited) and apply Google Consent Mode. Except for our own strictly first-party measurement and our cookieless analytics, these tools are activated only after you accept analytics/marketing cookies via our cookie banner; until then, no analytics or advertising cookies are set and only limited, cookieless signals may be processed.

7.1 Google Analytics

Our website uses Google Analytics, which is offered to their customers from Europe, the Middle East and Africa (EMEA) by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics 4 uses cookies to analyse how our website is used and to compile reports on website activity. Google Analytics 4 does not log or store your full IP address. The data generated in this context can be transmitted by Google to a server in the USA for evaluation and stored there. It is activated only after you accept analytics cookies.

We have concluded a data processing agreement with Google for the use of Google Analytics as well as standard contractual clauses in the event that personal data is transferred to the USA or other third countries. Please see also for detailed information in Google's privacy policy at https://policies.google.com/.

The following data is processed by Google Analytics, in particular:

• (a) Approximate location (country and, if applicable, city), derived from the IP address, which is not stored;
• (b) Referrer URL (previously visited page);
• (c) Pages accessed (date, time, URL, title, length of stay);
• (d) Downloaded files;
• (e) Clicked links to other websites;
• (f) if necessary, achievement of certain goals (conversions);
• (g) Technical information: operating system; browser type, version and language; device type, make, model and resolution.

7.2 Google Ads and remarketing

We use Google Ads (provided by Google Ireland Limited), including remarketing and conversion measurement, to evaluate our advertising campaigns and to show you relevant ads on third-party websites and platforms. If you accept marketing cookies, Google may set cookies such as _gcl_au and DoubleClick cookies (see section 9) and may combine this information with Google Analytics data for measurement and remarketing. Data may be processed by Google in the USA under the standard contractual clauses. For more information, see Google's privacy policy at https://policies.google.com/.

7.3 HubSpot

We use HubSpot (provided by HubSpot, Inc.), hosted in HubSpot's EU data centre, as our customer-relationship and marketing platform. HubSpot powers our contact, newsletter and event forms and, where you accept marketing cookies, our marketing analytics and attribution. HubSpot sets cookies (see section 9, for example hubspotutk) that identify your browser so that a form you submit can be associated with your visit. HubSpot may transfer data to the USA under the standard contractual clauses. The HubSpot tracking script is loaded only after you accept; if you decline, our forms still work but without cross-page attribution.

7.4 Fathom Analytics

We use Fathom Analytics, a privacy-focused website-analytics service, to understand aggregate site usage. Fathom is cookieless: it does not set cookies, does not track you across other websites and does not build a personal profile. It collects only aggregated, non-identifying statistics.

7.5 Flai first-party analytics

We also operate our own first-party analytics. When you visit, we generate a random session identifier that is stored in your browser's local storage, and we record page views – including the page path, the referrer, your browser's user-agent string, a timestamp and any campaign parameters (UTM) present in the URL – to our own servers at api.flai.ai. We use this only to measure how our site is used and to carry your session across to our application by adding the identifier to links to app.flai.ai, hub.flai.ai and docs.flai.ai. It does not set advertising cookies and is not used to build cross-site profiles. Because it is strictly first-party and necessary for these purposes, it operates on the basis of our legitimate interest (Art. 6(1)(f) GDPR).

7.6 Microsoft Clarity

We use Microsoft Clarity (provided by Microsoft) to understand how visitors use our site through aggregated usage metrics and anonymised session replays and heatmaps. Clarity masks page content and does not capture the text you type into forms. If you accept analytics cookies, Clarity sets cookies (see section 9, for example _clck and _clsk) and may process data in the USA under the standard contractual clauses. It is activated only after you accept analytics cookies.

8. Analytical Tools

We also use tools for analytical purposes and for the purpose of development new products or services (“analytical tools”).

However, the data collected is stored exclusively pseudonymously, so that no direct conclusions can be drawn about the persons.

In the following section, we would like to explain these technologies and the providers used for them in more detail. The data collected may include, in particular:

• (a) The IP address of the device;
• (b) The identification number of a cookie or information in web storage;
• (c) The device identifier of mobile devices (e.g. Device ID);
• (d) Referrer URL (previously visited page);
• (e) Pages accessed (date, time, URL, title, length of stay);
• (f) Downloaded files;
• (g) Clicked links to other websites;
• (h) If necessary, achievement of certain goals (conversions);
• (i) Technical information: operating system; browser type, version and language; device type, make, model and resolution;
• (j) Approximate location (country and if applicable city).

9. Cookies

This website uses cookies and similar technologies (including your browser's local storage), set either by us or by third parties.

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you. Cookies set by us are called first-party cookies. We also use third-party cookies – cookies from a domain different than the one you are visiting – for our advertising and marketing efforts. Some information is stored in your browser's local storage rather than in cookies. Below we list, by category, the cookies and local-storage items we use, their purpose and how long they last.

Except for the strictly necessary items, these are set only if you accept them via our cookie banner. You can change or withdraw your choice at any time by clearing this site's stored data in your browser, which brings the banner back.

9.1 Strictly necessary

These are necessary for the website to function and to remember your privacy choice; they cannot be switched off. They do not store any advertising identifiers.

9.2 Analytics

These help us count visits and traffic sources so we can measure and improve the performance of our site. Google Analytics and Microsoft Clarity cookies are set only if you accept; Fathom is cookieless; our first-party items are stored in your browser's local storage.

9.3 Marketing

These are set, if you accept, by our advertising and marketing partners to measure campaigns and show you relevant ads. They may be based on uniquely identifying your browser and device.

10. Hyperlinks

Our website contains so-called hyperlinks to websites of other providers. If these hyperlinks are activated, you will be redirected from our website directly to the website of the other providers. you can recognize this, among other things, by changing the URL. We cannot accept any responsibility for the confidential handling of your data on these third-party websites, as we have no influence on the fact that these companies comply with the data protection regulations. Please inform yourself about the handling of your personal data by these companies directly on these websites.

11. Your rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• (i) Right of access
  You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including but not limited to the categories of personal data processed, the purpose of the processing, and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy, we may charge a fee.
• (ii) Right to rectification
  You may have the right to rectify inaccurate or incomplete personal data concerning you. We encourage you to review this information regularly to ensure that it is accurate and up to date.
• (iii) Right to erasure (right to be forgotten)
  You may have the right to ask us to erase personal data concerning you, if certain conditions are met.
• (iv) Right to restriction of processing
  In limited circumstances, you may have the right to request that we restrict processing of your Personal Data. However where we process Personal Data for the Purposes, we believe that we have a legitimate interest in processing that data which may override a request that you make.
• (v) Right to data portability
  You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity, if certain conditions are met.
• (vi) Right to object
  Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data (including profiling), by us and we can be required to no longer process your 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.

You also have the right to lodge a complaint with the competent data protection supervisory authority, which in the Slovenian Information Commissioner.

12. Modification of the Privacy Policy

We reserve the right to change this Privacy Policy in accordance with the data protection regulations. The current version can be found here at this point or another place on our website that can easily be found.