Privacy._

CBK.AI LTD (crmkit)

Company Number 16132916

86-90 Paul Street, London, EC2A 4NE, United Kingdom

1. Introduction

1.1 Important information and who we are

Welcome to the crmkit Privacy and Data Protection Policy (“Privacy Policy”).

crmkit is an agent-first CRM operated by CBK.AI LTD (”crmkit”, “ChatBotKit”, “we”, “us”, or “our”). We are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include customers, employees and staff members, and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Who is Your Data Controller and Privacy Contact

CBK.AI LTD is your Data Controller and responsible for your Personal Data.

We have designated a privacy contact (“Privacy Contact”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data, please contact the Privacy Contact using the details set out below:

• Full name: Petko D. Petkov
• Email address: privacy@chatbotkit.com
• Postal address: 86-90 Paul Street, London, EC2A 4NE, United Kingdom

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.

1.3 Processing Data on Behalf of a Controller

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see section 2.2 below for more information on those bases);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. Legal Basis for Data Collection

2.1 Types of Data / Privacy Policy Scope

“Personal Data” 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. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it from you.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email communications from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We are required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.

2.3 Use of Third-Party APIs and Data

crmkit connects to third-party services, such as email delivery providers and, where you choose to use them, the AI agents and platforms you connect to crmkit (for example Claude, Claude Code or ChatGPT), to provide its services. We expressly affirm that data obtained through these APIs is not used to develop, improve, or train generalized AI and/or ML models.

3. How We Use Your Personal Data

3.1 Our Uses

We will only use your Personal Data when the law allows us to. The purposes for which we use your data may be broader than described, but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Privacy Contact.

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 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 our Privacy Contact.

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.

3.4 Restrictions on Use of Data

We use data collected for the purpose it was collected for and in accordance with this Privacy Policy. Specifically, for data obtained through third-party APIs, we do not use this data to develop, improve, or train generalized AI and/or ML models.

4. Your Rights and How You Are Protected

You may delete your account and workspace data at any time - this will remove your records from our systems and our related software.

We do not guarantee the ability to delete all stored data. If you would like us to delete or correct personally identifiable data, let us know and we will action your request as soon as practicable.

crmkit does not use passwords. Access is granted through a one-time passcode (OTP) sent to your email, which mints a bearer token that your agent stores and reuses. This token grants access to your data, so you need to prevent unauthorised access by keeping it secret, limiting access to the device or agent that holds it, and revoking it if you believe it has been exposed. You can access the information associated with your account at any time through the crmkit API.

4.2 How Does crmkit Protect Customers’ Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us, and any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 Opting Out of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by opting out within an email. Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to Request Your Data and the Process for Obtaining It

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

5. Your Data and Third Parties

5.1 Will We Share Your Data With Third Parties?

We may share Personal Data with interested parties in the event that CBK.AI LTD anticipates a change in control or the acquisition of all or part of our business or assets, or with interested parties in connection with the licensing of our technology.

If crmkit is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the privacy policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

6. How Long Will We Retain Your Data For?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. Age Limit for Our Users

You must not use crmkit unless you are aged 18 or older. If you are under 18 and you access crmkit by lying about your age, you must immediately stop using crmkit. This website and service are not intended for children and we do not knowingly collect data relating to children.

8. Notification of Changes and Acceptance of Policy

We keep our Privacy Policy under review and will place any updates on this webpage. By using crmkit, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of crmkit will constitute your express acceptance of any modifications to this Privacy Policy.

9. Interpretation

All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address.

Our staff are not authorised to contract on behalf of CBK.AI LTD, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a crmkit or ChatBotKit address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any of our rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the legal department.