Privacy Policy

1. Introduction

Simon Wilby ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage with our AI development services. This policy is designed to comply with the General Data Protection Regulation (GDPR), China's Personal Information Protection Law (PIPL), and the California Consumer Privacy Act (CCPA).

2. Data Controller Information

Simon Wilby is the data controller responsible for your personal data. For any inquiries regarding this policy or your data rights:

Email: simon@wilby.ai
Phone: 212-202-0004
Data Protection Officer: privacy@simonwilby.ai

3. Information We Collect

We may collect the following types of information:

Personal Information: Name, email address, phone number, and company information when you contact us or subscribe to our newsletter.
Usage Data: Information about how you interact with our website, including pages visited, time spent, and navigation patterns.
Technical Data: IP address, browser type, device information, and operating system.
Communication Data: Records of correspondence when you contact us for inquiries or consultations.

4. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

Consent: When you have given explicit consent for specific processing activities (e.g., newsletter subscription).
Contract: When processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
Legitimate Interests: When processing is necessary for our legitimate interests, provided these do not override your fundamental rights and freedoms.
Legal Obligation: When processing is necessary to comply with a legal obligation.

5. How We Use Your Information

We use the information we collect to:

Respond to your inquiries and provide requested services
Send you updates about our AI technologies and services (with your consent)
Improve our website and user experience
Analyze usage patterns to enhance our offerings
Comply with legal obligations

If you are located in the European Union or European Economic Area, you have the following rights under the General Data Protection Regulation:

Right of Access (Article 15): You have the right to obtain confirmation of whether we process your personal data and access to that data.
Right to Rectification (Article 16): You have the right to have inaccurate personal data corrected without undue delay.
Right to Erasure / Right to be Forgotten (Article 17): You have the right to request deletion of your personal data under certain circumstances.
Right to Restriction of Processing (Article 18): You have the right to restrict processing of your personal data in certain situations.
Right to Data Portability (Article 20): You have the right to receive your personal data in a structured, commonly used, machine-readable format.
Right to Object (Article 21): You have the right to object to processing based on legitimate interests or direct marketing.
Right Not to be Subject to Automated Decision-Making (Article 22): You have the right not to be subject to decisions based solely on automated processing, including profiling.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

To exercise these rights, please contact our Data Protection Officer at privacy@simonwilby.ai. We will respond to your request within 30 days.

7. Your Rights Under PIPL (China Users)

If you are located in the People's Republic of China, you have the following rights under the Personal Information Protection Law (PIPL):

Right to Know and Decide (Article 44): You have the right to know and make decisions about the processing of your personal information, and to restrict or refuse the processing by others.
Right to Access and Copy (Article 45): You have the right to access and obtain copies of your personal information from us.
Right to Rectification and Supplementation (Article 46): You have the right to request correction or supplementation of your personal information if it is inaccurate or incomplete.
Right to Deletion (Article 47): You have the right to request deletion of your personal information under specified circumstances, including when the purpose of processing has been achieved or when you withdraw consent.
Right to Explanation (Article 48): You have the right to request an explanation of the rules for processing your personal information.
Right to Withdraw Consent (Article 15): Where personal information is processed based on consent, you have the right to withdraw your consent. Withdrawal does not affect the lawfulness of processing before withdrawal.
Right to Refuse Automated Decision-Making (Article 24): You have the right to refuse decisions made solely through automated decision-making that have significant impact on your rights and interests.
Right to Portability (Article 45): You have the right to request transfer of your personal information to another personal information handler you designate.

Cross-Border Data Transfer: In compliance with PIPL Article 38, any transfer of personal information outside of China will only occur after conducting a security assessment, obtaining certification, or entering into a standard contract as required by the Cyberspace Administration of China (CAC).

To exercise your rights under PIPL, please contact us at privacy@simonwilby.ai. We will respond within 15 working days as required by law.

8. Your Rights Under CCPA (California Users)

If you are a California resident, you have the following rights under the California Consumer Privacy Act:

Right to Know: You have the right to know what personal information we collect, use, disclose, and sell.
Right to Delete: You have the right to request deletion of your personal information.
Right to Opt-Out: You have the right to opt-out of the sale of your personal information. Note: We do not sell personal information.
Right to Non-Discrimination: You have the right not to be discriminated against for exercising your CCPA rights.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of data in transit and at rest
Regular security assessments and audits
Access controls and authentication measures
Employee training on data protection
Incident response procedures

10. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws. Retention periods vary based on the type of data and purpose of processing. Upon request for deletion or when data is no longer needed, we will securely delete or anonymize your personal information.

11. International Data Transfers

Your personal data may be transferred to and processed in countries outside your country of residence. When transferring data internationally, we ensure appropriate safeguards are in place:

EU/EEA Transfers: Standard Contractual Clauses (SCCs) approved by the European Commission
China Transfers: Security assessments and standard contracts per PIPL requirements
Other Jurisdictions: Contractual protections and adequacy assessments

12. Cookies

Our website may use cookies and similar tracking technologies to enhance your browsing experience. We use:

Essential Cookies: Required for basic website functionality
Analytics Cookies: Help us understand how visitors interact with our website (with consent)
Preference Cookies: Remember your settings and preferences

You can control cookie preferences through your browser settings or our cookie consent banner.

13. Third-Party Services

We may use third-party services for analytics, hosting, and other purposes. These services have their own privacy policies governing the use of your information. We only work with third parties that demonstrate adequate data protection measures.

14. Children's Privacy

Our services are not directed to individuals under the age of 16 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

15. Contact Us

If you have any questions about this Privacy Policy, your data, or wish to exercise your rights, please contact us at:

Email: simon@wilby.ai

Privacy Inquiries: privacy@simonwilby.ai

Phone: 212-202-0004

16. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. For significant changes, we may also notify you via email.