Personal data

MKD WORD S.L, , with share capital of €1,000, registered in Spain under number B56372634, with its registered office at Calle Torres y Amat 21 08001 Barcelona (hereinafter “MKD WORD S.L”) operates the website accessible at the following address: the Site.

MKD WORD S.L places particular importance on protecting your Personal Data because, if you entrust it to us, we must take the greatest care of it and, above all, explain transparently how we collect and use it.

The purpose of this Privacy Policy is to:

• Explain clearly and simply why and how we use the information we collect when you use our Services;
• Detail the options we offer so that you can control the use of your Data, the rights you have over it and how to exercise them.

MKD WORD S.L undertakes to comply with the following two (2) essential principles:

• The User remains in control of their Data;
• Users’ Data is processed transparently, confidentially and securely.

Respect for your privacy and Personal Data is a priority for us, and we undertake to process your Personal Data in strict compliance with the French Data Protection and Privacy Act of January 6, 1978 (hereinafter the “LIL” or “Data Protection and Privacy Act”), as amended, and the EU General Data Protection Regulation of April 27, 2016 (hereinafter the “GDPR”).

Data sharing with AI providers:

We take the protection of our users’ personal data very seriously and apply appropriate security measures to ensure that all information is protected on our website.

In order to provide the service, we may transmit to third-party artificial intelligence API providers only the content that users voluntarily submit through the platform, including their prompts and any files they explicitly choose to upload and share. This processing is strictly limited to what is necessary to generate responses and provide the requested service.

No other user data is shared with these artificial intelligence API providers. In particular, personal account data, payment information and any other information unrelated to the submitted content remain within our systems and are not transmitted to these providers.

1. PRELIMINARY DEFINITIONS

The terms mentioned below have the following meaning in this Privacy Policy:

• Subscription: means the paid monthly “PRO Access” subscription that the Subscriber may take out on the Site.
• One-time Purchase: means the one-off Order for a Product placed by a Customer on the Site, without subscribing to the Subscription.
• Customer: means the contracting party of MKD WORD S.L, who may qualify as a consumer under Spanish law and case law, i.e. an individual acting for purposes outside their commercial, industrial, craft, professional or agricultural activity, or as a professional under Spanish law and case law, i.e. an individual or legal entity, public or private, acting for purposes within the scope of their commercial, industrial, craft, professional or agricultural activity, including when acting in the name or on behalf of another professional. A professional Customer means companies or self-employed individuals. Customer refers interchangeably to the User who makes a One-time Purchase, benefits from the trial offer or subscribes to a Subscription on the Site.
• Order: means the purchase of Products by a Customer on the Site.
• Data or Personal Data: means personal data that allows a User to be identified directly or indirectly and that is subject to Processing under this Privacy Policy, as defined in Article 4(1) of the GDPR.
• Personal Area: means the interface hosted on the Site where all data provided by the Customer is compiled and which allows them to access the Site and Services. Access to the Personal Area is provided using the Login Details, from the “My Account” section of the Site.
• Login Details: means the Customer’s email address and password required to access the Personal Area on the Site.
• Products: means all products marketed by MKD WORD S.L on the Site, namely unlimited access to Chat, a cloud space and discussion history.
• General Data Protection Regulation or GDPR: means Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the Processing of Personal Data and the free movement of such Data.
• Data Controller: means the person who determines the means and purposes of Processing in accordance with Article 4(7) of the GDPR.
• Services: means the services comprising digital services offered as part of the Subscription.
• Site: means the Site published by MKD WORD S.L and accessible at the following address: https://ai-chatpro.com/. The Site includes all web pages and features accessible to Users.
• Processor: means the individual or legal entity, public authority, service or other body that Processes Personal Data on behalf of and according to the instructions of the Data Controller in accordance with Article 4(8) of the GDPR.
• Processing/Process: means any of the operations referred to in Article 4(2) of the GDPR, carried out on Personal Data in connection with the performance of this Privacy Policy.
• User: means any person who accesses and browses the Site, whether a Customer, subscriber or non-subscriber, or simply an internet user.

This Privacy Policy applies to all Users who access and browse the Site and aims to inform Users about how their Data may, where applicable, be collected and Processed by MKD WORD S.L.

2. HOW DO WE COLLECT YOUR DATA?

All User Data is collected directly from the User, for example when registering on the Site or during exchanges with MKD WORD S.L (contact requests, correspondence, etc.).

3. WHAT ARE THE PURPOSES AND LEGAL BASES OF THE PROCESSING WE CARRY OUT?

When the legal basis used for the Processing operations we carry out is based on the pursuit of a legitimate interest, you, as the data subject, may obtain additional information about the balancing of interests upon request.

In all cases, MKD WORD S.L collects only the Personal Data necessary for the explicit and specific purposes set out below:

PURPOSES	DETAILS OF THE PURPOSES	LEGAL BASES
Use of Chat	Allow the user to access the AI-ChatPro assistant and interact through queries; retain history for tracking and continuity	Contractual: necessary to provide the service; Consent when accepted by the user
Payment Management	Payment for ordered Products, billing monitoring, maintenance of accounting records and legal supporting documents.	Legal obligation arising from Articles L102 B et seq. of the French Tax Procedure Code.
Contract Archiving	Archiving of contracts entered into between the Customer and MKD WORD S.L for an amount exceeding €120 including tax.	Legal obligation arising from Article L.213-1 of the French Consumer Code.
Customer Experience	Management and publication of Customer reviews	User consent.
Sending News and Commercial Offers	Management of newsletter subscriptions and sending of commercial offers.	User consent.
Proper Operation and Continuous Improvement of the Site	Ensure the proper operation and continuous improvement of the Site and its features (necessary updates: adding new features, adapting to technical developments, etc.).	Our legitimate interest in ensuring the best possible level of operation and quality of the Site, notably through visit statistics; User Consent when required.
Management of Requests to Exercise Rights under the GDPR and the Amended Data Protection and Privacy Act	This Processing covers all operations required to monitor rights requests sent to MKD WORD S.L (qualification of the request, investigations, performance of specific technical operations, etc.). It concerns only cases where MKD WORD S.L acts as Data Controller.	Legal obligation arising from the GDPR and the Data Protection and Privacy Act.

MKD WORD S.L is also authorized to use this Personal Data in order to fulfill a legal or regulatory obligation.

In any event, and for each defined purpose, MKD WORD S.L will implement all available means to ensure the security and confidentiality of the Personal Data entrusted to it, in compliance with applicable laws and regulations.

4. WHAT DATA IS COLLECTED?

The mandatory or optional nature of the Personal Data collected and the possible consequences of failing to provide it are indicated during the various interactions with Users.

You can find below details of the Data we may hold about you:

The information provided below is not intended to be exhaustive and is primarily intended to inform you about the categories of Data that MKD WORD S.L may Process.

PROCESSING	PERSONAL DATA COLLECTED
Use of Chat	Query content (prompts) Discussion history Associated metadata (date, time, language)
Payment Management	Payment data (bank card number, expiration date, security code) Data required to issue invoices (billing address)
Contract Archiving	Email address Archive number
Customer Experience	Email address Login details (login)
Sending News and Commercial Offers	Email address
Proper Operation and Continuous Improvement of the Site	Data collected through cookies and other trackers on our Site. For more details, see our cookie policy: https://ai-chatpro.com/cookies
Management of Rights Exercise Requests	Email address Where applicable, a copy of proof of identity

In any event, MKD WORD S.L undertakes to Process all collected Data in compliance with the GDPR and the Data Protection and Privacy Act.

5. WHO CAN ACCESS YOUR PERSONAL DATA?

Within the scope of their respective duties and for the purposes described above, the main persons who may have access to your Data are:

• Authorized personnel of MKD WORD S.L;
• Service providers responsible for managing and hosting the Site and MKD WORD S.L’s IT system;
• Service providers responsible for payment management (bank);
• Where applicable, authorized personnel of our Processors;
• Where applicable, the relevant courts, mediators, accountants, statutory auditors, lawyers, bailiffs, debt collection companies, police or gendarmerie authorities in the event of theft or a judicial requisition;
• Third parties likely to place cookies on your devices (computers, tablets, smartphones, etc.) when you consent to this.

Your Data is not disclosed, exchanged, sold or rented to any person other than those mentioned above without your express prior consent and in accordance with applicable legal and regulatory provisions.

6. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain your Personal Data only for as long as necessary for the purposes pursued, as described above and summarized in the table below.

PROCESSING	DURATION
Use of Chat	Throughout the contractual relationship, followed by storage in an intermediate archive for the applicable limitation period (five (5) years for evidentiary purposes).
Payment Management	For bank card payments, in accordance with Article L.133-24 of the French Monetary and Financial Code, this Data may be retained for evidentiary purposes in the event of a possible transaction dispute or claim, in intermediate archives, for thirteen (13) months from the debit date (extended to 15 months for deferred-payment cards). Data relating to the PAN and visual security code is not stored, and Data relating to the expiration date is deleted when that date is reached. Issued invoices and accounting data are retained for ten (10) years from their issuance.
Contract Archiving	Contracts entered into between the Customer and MKD WORD S.L for an amount exceeding €120 including tax are retained for ten (10) years in accordance with Article L.213-1 of the French Consumer Code.
Customer Experience	Data is retained for three (3) years from the date the review is published on the Site.
Sending News and Commercial Offers	Data is retained until consent is withdrawn (unsubscribe via the link provided for this purpose) or, where applicable, throughout the contractual relationship, followed by storage in an intermediate archive for three (3) years after the end of the contractual relationship, or for three (3) years after the last contact with MKD WORD S.L.
Proper Operation and Continuous Improvement of the Site	The retention period for the various cookies installed by MKD WORD S.L is detailed in the cookie policy available at: https://ai-chatpro.com/cookies.
Management of Rights Exercise Requests	Personal Data relating to the management of rights requests is retained for as long as necessary to Process the request, followed by storage in an intermediate archive for the applicable criminal limitation period, namely six years, in an intermediate archive (Article 8 of the French Code of Criminal Procedure).

7. WHAT ARE YOUR RIGHTS REGARDING PERSONAL DATA?

In accordance with the Data Protection and Privacy Act and the GDPR, you have several rights relating to your Personal Data:

• Right of access (Article 15 GDPR), rectification (Article 16 GDPR), updating and completion of your Personal Data (learn more);
• Right to restrict or erase your Personal Data (Article 17 GDPR) when it is inaccurate, incomplete, ambiguous or outdated, or when its collection, use, disclosure or retention is prohibited (learn more);
• Right to withdraw your consent at any time (Article 13-2c GDPR);
• Right to data portability for the Personal Data you have provided to us when your Personal Data is subject to automated Processing based on your consent or a contract (Article 20 GDPR);
• Right to determine what happens to your Personal Data after your death and to choose whether or not we communicate your Personal Data to a third party you have previously designated (Article 85 LIL) (learn more).

These rights may be exercised:

• By email at: [email protected];
• By post at: MKD WORD S.L – Calle torres y amat 21, 08001 Barcelona 2

Finally, you may also lodge a complaint with the supervisory authorities, in particular the CNIL (https://www.cnil.fr/fr/plaintes).

8. WHAT ABOUT CONNECTION DATA, COOKIES AND OTHER “TRACKERS”?

MKD WORD S.L uses Connection Data on its Site (date, time, Internet address, visitor’s computer protocol, page viewed) and cookies (small files stored on your computer) that allow us to identify you, remember your visits and benefit from Site audience measurement and statistical data, particularly regarding the pages viewed.

Depending on the purposes, Users may consent to, refuse or choose the placement of certain types of cookies on their devices.

The procedures for placing cookies and the rights available to Users are set out in the Site’s Cookie Policy.

9. IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

As a general rule, we Process your Data within the European Union.

However, given the nature of our activities, and subject to informing you in advance, we may be required to transfer your Personal Data outside the European Union.

In such cases, MKD WORD S.L will inform you of the measures taken to control this transfer and ensure its compliance.

10. WHAT SECURITY MEASURES ARE IN PLACE TO PROTECT YOUR DATA?

MKD WORD S.L undertakes to implement all appropriate technical and organizational measures to ensure the security of Data Processing and the confidentiality of your Data, in accordance with the amended Data Protection and Privacy Act and the GDPR.

To this end, MKD WORD S.L takes appropriate precautions, considering the nature of your Data and the risks presented by the Processing, to preserve its security and, in particular, prevent the Data from being altered or damaged or unauthorized third parties from accessing it (physical protection of premises, user authentication process with personal and secure access via confidential login details and passwords, connection logging, encryption of certain data, etc.).

11. UPDATES TO THE PRIVACY POLICY

We may update this Privacy Policy to reflect, for example, changes relating to the Data Processing implemented or for other operational, legal or regulatory reasons.

We therefore invite you to review this Privacy Policy regularly to stay informed about the use of cookies and related technologies.

The date shown at the top of this Privacy Policy is the date of the latest update.