1. Introduction

 

AiZEN (“AiZEN”, “we”, “us” or “our”) is a business operated and established in Jersey, Channel Islands.

AiZEN provides expert-network, research, consulting, artificial intelligence, technology, business-support and related services to businesses, investment firms, professional-services firms and other organisations.

We respect the privacy of our Clients, Experts, consultants, prospective clients, website visitors, suppliers, contractors and other individuals with whom we interact.

This Privacy & Cookie Policy explains how we collect, use, disclose, store, transfer and protect Personal Data when you interact with AiZEN, use our website or services, participate in an expert engagement, communicate with us or otherwise provide information to us.

AiZEN processes Personal Data in accordance with applicable data-protection laws, including the Data Protection (Jersey) Law 2018 (“DPJL”), where applicable.

This Policy should be read alongside any applicable Client agreement, Expert Terms and Conditions, Code of Conduct, Data Processing Agreement, engagement terms and other notices provided by AiZEN.

 

2. Who We Are

 

For Personal Data for which AiZEN determines the purposes and means of processing, AiZEN acts as the data controller.

For certain services, AiZEN may process Personal Data on documented instructions from a Client. In those circumstances, AiZEN may act as a data processor and the Client may act as controller.

In other circumstances, AiZEN and another organisation may independently determine their respective purposes for processing, or may jointly determine certain purposes and means. The applicable agreement will govern those responsibilities where appropriate.

Business: AiZEN
Principal place of business: St Helier, Jersey
Privacy contact: hello@aizen.je
Website: aizen.je

 

3. Scope

 

This Policy applies to Personal Data relating to:

• Experts and prospective Experts;
• Clients and prospective Clients;
• Client employees, representatives and authorised users;
• consultants and contractors;
• suppliers and business partners;
• website visitors;
• event participants;
• individuals who communicate with AiZEN; and
• other individuals whose Personal Data we process in connection with our business.

“Personal Data” means information relating to an identified or identifiable natural person.

 

4. Personal Data We May Collect

 

Depending on your relationship with AiZEN, we may collect:

 

Identity and Contact Information

 

Name, business email address, personal email address where appropriate, telephone number, location, nationality, business address and other contact information.

 

Professional Information

 

Job title, employer, previous employers, industry, areas of expertise, professional biography, CV or résumé, qualifications, education, professional memberships, board positions, advisory roles, employment dates and professional experience.

 

Expert Compliance Information

 

Information relating to eligibility to participate in engagements, conflicts of interest, employment restrictions, confidentiality obligations, regulatory status, sanctions screening, professional credentials and compliance declarations.

Where necessary and lawful, this may include information obtained through appropriate due-diligence or verification processes.

 

Client Information

 

Organisation, role, contact details, project requirements, research requests, service history, communications, authorised users, billing information and other information necessary to deliver our services.

 

Financial Information

 

Bank or payment details, billing information, invoices, tax information and records necessary to make or receive payments.

AiZEN does not intend to collect payment information beyond what is reasonably required for legitimate business, accounting and compliance purposes.

 

Engagement Information

 

Project briefs, screening responses, availability, expert-client interactions, engagement history, feedback, correspondence and related records.

Where appropriate and subject to applicable requirements, AiZEN may record, transcribe or summarise certain calls, meetings or interviews. Where required, participants will be informed before recording or transcription occurs.

 

Technical and Website Information

 

IP address, browser information, device information, operating system, website usage, referral source, session information and cookie or analytics information.

 

Communications

 

Emails, telephone communications, messages, forms, meeting notes and correspondence with AiZEN.

 

Publicly Available Information

 

We may obtain professional information from lawful public sources such as company websites, professional directories, regulatory records, publications and professional networking platforms.

 

5. How We Collect Personal Data

 

We may collect Personal Data:

• directly from you;
• from your employer or organisation;
• from Clients;
• from Experts;
• through our website;
• through email, telephone, video calls and other communications;
• from professional networking platforms and public sources;
• from referrals;
• from authorised recruitment, verification, compliance or due-diligence providers; and
• from service providers supporting our operations.

We will seek to ensure that information collected is relevant and proportionate to the purpose for which it is processed.

 

6. How We Use Personal Data

 

AiZEN may process Personal Data to:

 

Provide Our Services

 

Operate expert calls, consultations, research projects, surveys, interviews, workshops, advisory assignments, AI projects, technology services, outsourced business services and related engagements.

 

Identify and Match Experts

 

Assess an Expert’s professional background, experience and suitability and introduce relevant Experts to Clients.

This may involve providing a Client with limited professional profile information, such as an Expert’s role, experience, industry expertise and qualifications.

 

Conduct Compliance and Due Diligence

 

Verify professional information, identify conflicts, assess engagement eligibility, conduct sanctions or other appropriate risk screening and prevent fraud, misconduct, bribery, insider dealing or other prohibited activity.

 

Administer Engagements

 

Arrange calls and meetings, manage projects, process Expert payments, invoice Clients, maintain records and provide operational support.

 

Protect Confidential Information

 

Implement and enforce confidentiality, information-security and compliance controls.

 

Communicate With You

 

Respond to enquiries, provide service information, invite Experts to relevant opportunities, administer relationships and provide important operational or compliance notices.

 

Improve AiZEN

 

Analyse service performance, improve processes, develop products and services and conduct internal business analytics.

Where AiZEN uses artificial intelligence or automated technologies for operational support, appropriate controls will be applied according to the nature and sensitivity of the information involved.

 

Marketing and Business Development

 

Communicate with existing and prospective business contacts about AiZEN services where permitted by law.

Recipients may opt out of direct marketing communications at any time.

 

Legal and Regulatory Purposes

 

Comply with legal obligations, establish or defend legal claims, respond to lawful requests, maintain records and protect AiZEN, its Clients, Experts and other parties.

 

7. Lawful Bases for Processing

 

Depending on the circumstances, AiZEN may process Personal Data because:

• processing is necessary to enter into or perform a contract;
• processing is necessary to comply with a legal obligation;
• processing is necessary for legitimate interests pursued by AiZEN or another party, where those interests are not overridden by the rights of the individual;
• you have provided consent where consent is the appropriate lawful basis; or
• another lawful basis permitted by applicable law applies.

Where we rely on consent, you may withdraw that consent subject to applicable law. Withdrawal does not affect the lawfulness of processing undertaken before withdrawal.

 

8. Expert Profiles and Client Introductions

 

A central part of AiZEN’s Expert Network service is connecting Clients with individuals possessing relevant professional expertise.

Where appropriate, AiZEN may provide Clients with professional information about an Expert to allow the Client to assess suitability for an engagement.

This may include professional biography, current or former roles where appropriate, industry experience, qualifications, expertise and relevant screening responses.

We seek to limit disclosure to information reasonably required for the engagement.

Clients receiving Expert Personal Data must use it only for legitimate engagement-related purposes and in accordance with applicable agreements and laws.

 

9. Background Checks and Compliance Screening

 

Experts and other relevant parties may be subject to proportionate compliance checks.

Depending on the engagement and risk involved, these may include:

• identity or professional verification;
• employment-history verification;
• qualification or licensing verification;
• conflict-of-interest checks;
• sanctions screening;
• regulatory checks; and
• review of relevant publicly available professional information.

AiZEN may use appropriately selected third parties to conduct these checks.

Providing inaccurate, misleading or materially incomplete information may result in suspension or termination of an Expert’s relationship with AiZEN.

 

10. Artificial Intelligence and Automated Technologies

 

AiZEN may use approved artificial intelligence and automation tools to support research, administration, analysis, matching, transcription, document processing, service delivery and internal operations.

AiZEN seeks to apply appropriate safeguards according to the sensitivity of the information involved.

Client Confidential Information and Personal Data will not knowingly be used to train publicly available general-purpose AI models by AiZEN unless this has been appropriately authorised and is lawful.

AiZEN will not intentionally make a decision producing legal or similarly significant effects on an individual solely through automated processing unless permitted under applicable law and appropriate safeguards are in place.

 

11. Recording and Transcription

 

Certain expert calls, interviews, meetings or other engagements may be recorded, transcribed or summarised where appropriate.

Where required, AiZEN will provide notice and obtain any consent or other authorisation required before recording.

Recordings and transcripts may be used for agreed service delivery, quality assurance, compliance, research or other disclosed purposes.

Unauthorised recording, distribution or publication of an AiZEN-facilitated engagement is prohibited where restricted by the applicable engagement terms.

 

12. How We Share Personal Data

 

AiZEN may share Personal Data with:

• Clients where necessary to facilitate services;
• Experts and consultants where necessary for an engagement;
• authorised contractors and personnel;
• technology, cloud, communications and IT providers;
• payment and accounting providers;
• compliance, verification and screening providers;
• professional advisers;
• regulators, authorities, courts or law-enforcement bodies where required;
• prospective purchasers, investors or advisers in connection with a legitimate business restructuring, investment, transfer or sale, subject to appropriate safeguards; and
• other parties where you have authorised the disclosure or where disclosure is otherwise lawful.

Service providers handling Personal Data on AiZEN’s behalf are expected to be subject to appropriate confidentiality, data-protection and security obligations.

AiZEN does not sell Personal Data as a business model.

 

13. Client Data and Data-Protection Roles

 

Information supplied by a Client remains subject to the rights, confidentiality obligations and contractual arrangements agreed between AiZEN and that Client.

Data-protection responsibility is determined according to the processing activity.

Where AiZEN processes Personal Data solely on documented instructions from a Client, AiZEN will act as processor to the extent specified in the relevant agreement.

Where AiZEN independently determines why and how Personal Data is processed, including certain Expert-network administration, compliance, billing, security and legal activities, AiZEN may act as controller.

Nothing in this Policy transfers intellectual-property ownership of Client materials or Expert materials except as expressly provided in an applicable agreement.

 

14. International Data Transfers

 

AiZEN operates from Jersey and may work with Clients, Experts, contractors and service providers internationally.

Personal Data may therefore be processed in or accessed from jurisdictions outside Jersey.

This may include approved service providers or delivery resources in India, the United Kingdom, the European Economic Area and other jurisdictions depending on the service.

Where Personal Data is transferred internationally, AiZEN will seek to implement the transfer mechanism and safeguards required by applicable data-protection law.

Depending on the circumstances, safeguards may include contractual protections, appropriate transfer clauses, risk assessments, access controls, data minimisation, encryption and other technical or organisational measures.

 

15. Information Security

 

AiZEN maintains proportionate technical and organisational safeguards designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Measures may include:

• role-based access controls;
• multi-factor authentication;
• encryption where appropriate;
• controlled access to Client information;
• confidentiality obligations;
• security requirements for contractors and service providers;
• secure business systems;
• incident-response procedures; and
• data minimisation.

No system can guarantee absolute security, but AiZEN seeks to maintain safeguards proportionate to the nature and risk of the information processed.

 

16. Data Retention

 

AiZEN retains Personal Data only for as long as reasonably necessary for the purposes for which it was collected, including service delivery, Expert-network management, contractual obligations, compliance, dispute resolution, accounting and legal requirements.

Retention periods depend on the nature of the information and applicable requirements.

When information is no longer required, AiZEN may securely delete, anonymise or otherwise dispose of it.

 

17. Your Data-Protection Rights

 

Subject to applicable law and relevant exemptions, you may have rights including:

• access to Personal Data held about you;
• correction of inaccurate or incomplete Personal Data;
• erasure in applicable circumstances;
• restriction of processing;
• objection to certain processing;
• data portability where applicable;
• withdrawal of consent where processing relies on consent; and
• rights relating to certain automated decision-making.

Requests may be submitted to:

hello@aizen.je

We may need to verify your identity before acting on a request.

You may also have the right to raise a complaint with the Jersey Office of the Information Commissioner.

 

18. Personal Data Breaches

 

AiZEN maintains procedures for identifying, assessing, containing and responding to suspected Personal Data breaches.

Where a breach is subject to notification requirements, AiZEN will notify the relevant authority and affected individuals where required by applicable law.

 

19. Third-Party Websites

 

Our website or communications may contain links to third-party websites.

AiZEN does not control the privacy practices of independent third-party websites, and you should review their privacy notices before providing Personal Data.

 

COOKIE POLICY

 

20. What Are Cookies?

 

Cookies and similar technologies are small files or technologies used by websites to operate functionality, remember preferences, understand website usage and, where applicable, support marketing.

 

21. Cookies We May Use Strictly Necessary Cookies

 

Required for core website functions, security and service operation.

These cannot generally be disabled through our consent system where they are necessary for the service requested.

 

Functional Cookies

 

Help remember preferences and provide enhanced functionality.

 

Analytics Cookies

 

Help us understand how visitors interact with our website and improve performance.

 

Marketing Cookies

 

May be used to understand campaign effectiveness or provide relevant marketing where applicable.

 

22. Cookie Consent

 

Where applicable law requires consent, non-essential cookies will not be activated until the required consent has been obtained.

You may accept, reject or manage non-essential cookie categories through the cookie controls made available on our website.

Withdrawal or modification of consent will not affect the lawfulness of processing that occurred before the preference was changed.

 

23. Third-Party Technologies

 

AiZEN may use third-party technology providers for website hosting, analytics, communications and other functionality.

Where these providers use cookies or similar technologies, their processing will be governed by the applicable contractual arrangements and privacy requirements.

The specific cookies used by the AiZEN website should be identified in the website’s cookie preference centre.

 

24. Children

 

AiZEN’s services are directed towards businesses and professional users and are not intended for children.

We do not knowingly seek to collect Personal Data from children through our business services.

 

25. Changes to This Policy

 

We may update this Policy to reflect changes in our business, technology, services, legal requirements or compliance practices.

The current version will be published on our website with its effective or last-updated date.

 

26. Contact Us

 

Questions, requests or concerns concerning this Policy or AiZEN’s processing of Personal Data may be sent to:

AiZEN
St Helier, Jersey, Channel Islands
Email: hello@aizen.je

You may also contact the Jersey Office of the Information Commissioner regarding your data-protection rights.