Privacy Policy

This Privacy Policy outlines the type and manner of personal data collection when using Sage AI’s services. This policy establishes our approach to handling your personal data. We encourage you to review this policy carefully.

For queries regarding the management of your personal data, or if you wish to exercise your rights related to your data, feel free to reach out to Sage AI at any point through via email at [email protected].

This Privacy Policy has been enacted by Clanbeat Education OÜ, a company registered in Estonia (registry code 14530865). Our registered address is Tina str 26, 10126, Tallinn, Estonia.

Clanbeat Education OÜ is a company established under the laws of Republic of Estonia, operating the Clanbeat Sage AI website http://54.93.185.185/, its subdomains (hereinafter “Website”), and the web-based Clanbeat Sage AI services, including interfaces, associated media, documentation, updates and other components or materials incorporated therein or integrated therewith and all services enabled through those channels that are referred to as the “Services”. In this Privacy Policy, Clanbeat Education OÜ is referred to as “Sage AI”.

Sage AI provides leadership growth services catered towards individuals looking to enhance their leadership skills. We facilitate this by offering personalised and structured online 1-on-1 growth sessions. Additionally, Sage AI extends optional digital services for a thorough understanding of your current status, potential growth, and the entire personalised growth process.

Important Definitions

Unless specified otherwise within this Privacy Policy, the terminology utilised is consistent with the definitions outlined in the Clanbeat Sage AI Terms of Service, accessible at http://54.93.185.185/terms-of-service/, and/or as defined in Article 4 of the General Data Protection Regulation (EU) 2016/679 (hereafter referred to as “GDPR”) of the European Parliament and the Council.

“Personal data” Personal data pertains to any information that relates to an identified or identifiable natural person, also referred to as a data subject. An identifiable natural person can be identified either directly or indirectly. This identification can be based on various identifiers such as a name, personal identification code, location data, an online identifier, or specific characteristics. These can be physical, physiological, genetic, mental, economic, cultural or social traits pertaining to that natural person. 
“Data subject” Natural person who uses Sage AI Services or whose personal data is processed by Sage AI.
“User” Any person who has signed up to use Sage AI Services. 
“Service(s)” The term “Services” refers to any offerings made available through Sage AI at the time of accepting the Terms of Service, as well as any updates that may be introduced thereafter.  
“Processing” 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.
“Data Controller” 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. For the purposes of this Privacy Policy, User is the Data Controller of his/her personal data.
“Data Processor” Natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller; for the purposes of this Privacy Policy, Sage.ai is the Data Processor for the Users.

What personal data is processed while using the services?

  1. As a user of our Services, we collect and process certain personal data to facilitate your use of our offerings. Sage AIi only processes personal data that you directly provide to us during your usage of our Services. We do not, by default, collect personal data from third-party sources.
  2. The personal data we process may include:
    1. General Personal Information: This includes your first and last name and the name of your employer, if your employer is the one paying for the Services (otherwise, this is optional). This information is collected when you sign up for our Services and book your first session.
    2. Content You Provide: Any content you share during your leadership-focused growth sessions with our coaches remains confidential. However, if you choose to use additional supportive digital features such as assessments, analyses, and insights, we will process the information you provide during your interactions with these Sage AI created digital tools, as well as information you share during your sessions.
    3. Usage Data: We may gather data regarding your usage of our Services. This includes the features you use, along with the time, frequency, and duration of your activities. This usage data may be analysed for statistical purposes. It’s important to note that any published statistical information is de-personalized and only presented in a generalised form that doesn’t allow for the identification of any specific user. In instances where your employer is paying for the Services, they are entitled to receive an overview of your usage of the Services.

What is the legal basis for processing your personal data?

  1. Sage AI processes your personal data based on the following legal grounds:
    1. Contractual Necessity: The primary basis for our data processing activities is the necessity to perform our contractual obligations as set out in our Terms of Service. When you use our Services, we process your personal data to fulfil these obligations.
    2. Legitimate Interests: We may also process your personal data when it is necessary for our legitimate interests, in compliance with GDPR Article 6(1)(f). In such instances, we act as the Data Controller and ensure that the processing is proportionate, and that a legitimate interest impact assessment has been conducted. For instance, we might analyse our clients’ usage of our Services for the legitimate interest of improving our offerings.
    3. Legal Compliance: On occasion, we may need to process your personal data to comply with legal obligations that we are subject to. This is in accordance with GDPR Article 6(1)(c).
  2. Please note that we prioritise the protection of your personal data and abide by these legal grounds to ensure our processing activities align with the established privacy regulations.

How is your personal data shared by SAGE AI?

  1. When you use our Services, your personal data may be shared as follows: 
    1. Typeform: We use Typeform for user onboarding, feedback, and various assessments. When you interact with Typeform, certain personal data provided by you may be processed by Typeform in accordance with their privacy policy. We have chosen Typeform as a trusted service provider who adheres to stringent data protection standards.
    2. E-mail: We use e-mail for communication purposes. When you send or receive emails from us, your personal data may be processed by our email service provider in accordance with their privacy policy. We have chosen a reputable email service provider that prioritizes data security and confidentiality.
    3. Trafft booking system: We utilize the Trafft booking system for scheduling purposes. When you schedule appointments or interact with Trafft, your personal data may be processed by Trafft in accordance with their privacy policy. We have selected Trafft as a reliable service provider that upholds robust data protection measures.
    4. Notion: We use Notion as our Customer Relationship Management (CRM) system. When you interact with us through Notion, your personal data may be processed by Notion in accordance with their privacy policy. We have chosen Notion as a reliable CRM platform that prioritizes data protection.
    5. Google Drive: We utilize Google Drive for personal data storage, such as transcripts and session summaries. Access to the data stored on Google Drive is restricted to the coach and coachee. We have implemented appropriate security measures to safeguard your personal data stored on Google Drive.
  2. For the provision of our Services, we may need to share your personal data with specific third parties. These could include our IT suppliers, service providers, or other collaborators who assist in our operations. We carefully select these service providers and ensure they are trustworthy and adhere to stringent data protection standards.
  3. Sage AI commits to not transfer your personal data to countries outside the European Union (EU) or the European Economic Area (EEA).
  4. In all cases, we respect the principles of data minimization and limit the data shared only to what is necessary for fulfilling the intended purpose. Rest assured, the protection of your personal data is of paramount importance to us.

How long is your personal data retained?

  1. Sage AI is committed to not retaining personal data longer than is necessary for the purposes of processing the data or as required by applicable law.
  2. Your personal data will be kept for as long as you are actively using our Services. Generally, if you cease to use our Services, your personal data will be deleted. However, the specific duration for this period can vary based on individual circumstances and legal obligations.
  3. Please note that in certain cases, we may retain your data for a longer period if there’s a legal basis or obligation for doing so.

How do we protect your personal data?

  1. Sage AI takes the security of your personal data very seriously. We utilise a combination of technical and organisational measures designed to protect your data from unauthorised access, illegal processing, accidental loss, alteration, or destruction. We implement these measures in accordance with applicable laws and regulations.
  2. Our technical safeguards include, but are not limited to:
    1. Utilising appropriate computer security systems to safeguard digital data.
    2. Encrypting data in transit and at rest to secure it from unauthorised access.
  3. Our organisational measures consist of, but are not limited to:
    1. Implementing rigorous access control measures, ensuring only authorised personnel have access to your data.
    2. Instituting strict policies and procedures for the handling and processing of both digital and physical files, with a focus on minimising risks.
  4. We continually review and update our security practices and protocols to ensure they reflect the most up-to-date practices in the industry.

Cookies

  1. Our website uses cookies. This section incorporates our cookie policy (the “Cookie Policy”) that applies when you use the Services.
  2. Cookies are small data files stored on your hard drive by a website. Cookies help us monitor and improve the usage of our Services and your experience. We can use cookies to see which areas and features on our web based solutions are popular and to count visits to our Website to recognise you as a returning visitor and to tailor your experience of the Services according to your preferences. We may also use cookies for targeting purposes. 
  3. We use following type of cookies:
    1. Strictly necessary cookies that are essential in order to enable you to move around and   navigate on the Website.
    2. Functional cookies that record information about choices you have made and allow to tailor our Services. Functionality cookies remember choices you make or other online settings and provide personalised or enhanced features that you select, so that next time you visit you won’t have to enter all this information again.
    3. Statistics cookies that record information about the way our solutions are used. This allows us to make the structure, navigation, and content of our Services as user-friendly as possible.
    4. The specific cookies that the Platform uses are the following: 
Name Purpose Retention period
_ga Registers a unique ID that is used to generate statistical data on how the visitor uses the website 2 years
_gat Used by Google Analytics to throttle request rate 1 day
_gid Registers a unique ID that is used to generate statistical data on how the visitor uses the web site 1 day

You can delete or block cookies through your browser settings at any time. However, some cookies might be necessary to use the Services. Therefore, you understand that when blocking or deleting the cookies some features might not function correctly. 

For more general information about cookies including the difference between session and persistent cookies please see www.allaboutcookies.org. 

In case you have any questions concerning our Cookie Policy, you may contact us via contact details provided below.

Your rights

  1. At Sage AI, we’re committed to ensuring that your rights, as outlined under applicable data protection laws, are respected and facilitated. As the Data Controller, we welcome and process your requests pertaining to the enforcement of your rights as a data subject. Specifically, your rights include:
    1. The Right of Access: You have the right to access the personal data we process about you.
    2. The Right to Rectification: If you find any inaccuracies in your personal data, you have the right to request rectification.
    3. The Right to Erasure and Restriction: Should we not have a valid legal basis for processing your data, you have the right to request the erasure of your personal data and/or restriction of its processing.
    4. The Right to Data Portability: You are entitled to receive your processed personal data in a structured, commonly used, and machine-readable format, and you also have the right to transmit this data to another data controller.
    5. The Right to Object: You have the right to object to the processing of your personal data.
  2. If you believe that any of these rights have been violated, you have the right to lodge a complaint with the supervisory authority in your jurisdiction. In Estonia, this is the Data Protection Inspectorate, located at Tatari 39, Tallinn 10134. You may also email them at [email protected]. If you reside elsewhere, you can find a list of EU Data Protection authorities at https://edpb.europa.eu/about-edpb/board/members_en.

Governing law and jurisdiction

This Privacy Policy is governed by the laws of the Republic of Estonia. Any disputes arising from the implementation or interpretation of this Privacy Policy shall be resolved in the Harju County Court in the Republic of Estonia, unless the statutory law permits you to approach the court of your residence.

Contact information

If you have any questions or concerns regarding this Privacy Policy, the Cookie Policy, or how we handle your personal data, or if you wish to exercise your rights as described above, please don’t hesitate to contact us either via email or post at:

Clanbeat Education OÜ
Email: [email protected]
Address: Tina str 26, 10126 Tallinn, Estonia

We’re here to help and committed to protecting your personal information and privacy rights.