Effective Date: July 2025
Last Updated: July 2025

Seez App Holding Ltd (“we”, “our”, or “us”) respects your privacy and is committed to protecting personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

This Privacy Policy explains how we collect, use, and protect personal data in the following contexts:

1. When acting as a data controller — e.g., data collected through our website, for marketing, or demo bookings.
   
   
2. When acting as a data processor — e.g., data processed on behalf of clients via chatbot services on their websites.
   
   

1. Data Controller Activities

When we determine the purpose and means of processing personal data, we act as a data controller.

1.1 Personal Data We Collect

We may collect the following data when you:

• Visit our website
  
  
  
  • IP address.
    
    
  • Browser type and settings.
    
    
  • Device identifiers.
    
    
  • Cookies (see our Cookie Policy).
    
    
• Request information, book a demo, or contact us
  
  
  
  • Name.
    
    
  • Email address.
    
    
  • Phone number.
    
    
  • Company name.
    
    
  • Message content.
    
    
• Receive marketing communications
  
  
  
  • Email address.
    
    
  • Interaction with emails (e.g., opens, clicks).

In the context of managing our internal operations, we also process personal data related to human resources (“HR”), including but not limited to:

• Recruitment and hiring (e.g., CVs/resumes, cover letters, references).
  
  
• Employment records (e.g., employment contracts, performance evaluations, training history)
  
  
• Payroll and benefits administration (e.g., bank details, tax identification, salary information).
  
  
• Legal compliance (e.g., work permits, health and safety requirements).
  
  
• Termination and exit procedures.

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1.2 Legal Bases for Processing

We process personal data based on the following lawful bases under Article 6 GDPR:

• Consent (e.g., marketing communications).
  
  
• Contract performance (e.g., responding to demo requests).
  
  
• Legitimate interest (e.g., improving our website and services).
  
  
• Legal obligation (where applicable).
  
  

1.3 Purpose of Processing

• Provide and manage access to our website and services.
  
  
• Respond to inquiries or demo requests.
  
  
• Send marketing communications (with your consent).
  
  
• Improve the quality and functionality of our services.
  
  
• Comply with legal obligations.
  
  

1.4 Data Retention

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements.

1.5 Data Sharing

We may share your data with:

• Service providers and processors (e.g., hosting, analytics, email platforms).
  
  
• Legal authorities where required by law.
  
  
• Within our corporate group, if applicable.
  
  

We do not sell or rent your personal data.

2. Data Processor Activities

When our clients use our chatbot service on their websites, we process personal data on their behalf and act as a data processor.

Seez is a provider of “Seezar”, an artificial intelligence powered live chat bot (the “ChatBot”) that empowers automotive dealerships (the “Dealerships”) to reach their customers, 24/7 by ensuring instant responses to customers enquiries (the “Services”). The ChatBot is seamlessly layered on top of Chat GPT-powered chatbot. This privacy policy will help customers that use our Services (collectively, “you”) and the Dealerships understand what information we collect and use on behalf of a Dealership, and the choices you have associated with that information. This privacy policy concerns your use of our Services and software that comprise the ChatBot that Seez operates for Dealerships. In operating the ChatBot for the Dealership, Seez is a service provider for the Dealership and all communications you have through the ChatBot are processed by Seez for the Dealership. Your communications with Seez are on behalf of the Dealership.

When you visit a website (the “Website”) that integrates the ChatBot and you use the Services, Seez may collect, retain and use information pertaining to your click and viewing behavior based on your use of the Services (“Behavioral Information”). If you also submit your Personal Information (as defined below), choices or preferences, as part of your use of the Services your Personal Information may be collected, retained, used and linked to your Behavioral Information that we have collected.

2.1 Nature of Processing

“Personal Information” means personally identifiable information that can be specifically associated with, or that is sufficient to identify, you and includes your name and contact information (your phone number, address or email address), driver’s license number or other governmental ID number, etc. If you engage in our live web chat through the ChatBot using our Services, we may also store any transcripts (“Transcripts”) from such conversations and link those Transcripts to your Personal Information and Behavioral Information.

Our chatbot may collect, store, and transmit the following categories of data as determined by our clients:

• Name.
  
  
• Email address.
  
  
• Phone number.
  
  
• Chat content.
  
  
• Any other data voluntarily provided by end users.
  
  

The exact nature and purpose of data collection is determined by the client, acting as the data controller.

2.2 Data Processing Agreement (DPA)

For each client, we enter into a Data Processing Agreement in accordance with Article 28 GDPR. The DPA outlines:

• Processing instructions.
  
  
• Security measures.
  
  
• Data breach notification procedures.
  
  
• Sub-processor authorizations.
  
  
• Data subject rights assistance.
  
  
• Deletion or return of data upon termination.
  
  

2.3 Sub-Processors

We ensure that all sub-processors provide adequate safeguards and enter into binding agreements to ensure GDPR compliance.

We will not sell your Personal Information, and we will not share your Personal Information, Behavioral Information and Transcripts with any third parties except for:

• The company or companies to whom Seez is providing services (or such company’s affiliates) including the Dealership and the companies on whose Website you have submitted your Personal Information. A list of current sub-processors is available on https://trust.seez.co/.
• The Technology Partners that provide services in conjunction with Seez (such as ATG).
• Our third-party service providers, such as OpenAI LLC (AI services), and Amazon Web Services EMEA SARL (hosting services).      
• Other third parties that you consent to (for example, a finance company, bank, or other financial institution when you request credit eligibility or apply for financing through a Dealership). Anonymous or aggregated Behavioral Information, meaning Behavioral Information that does not include Personal Information, may be used for providing aggregated statistical data for reporting and analytics purposes.

We share your Personal Information under the following principles:

• For business purposes — We may share your Personal Information with the third parties listed above in order to properly perform, improve or maintain our Services to you. We may also share your Personal Information between and among Seez and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership,
• With your consent or at your direction — We will share your Personal Information with entities outside of Seez when we have your consent to do so, or it is done at your direction,
• For external processing — As mentioned in Article VII of this privacy policy,
• For legal purposes — We share your Personal Information when we believe that the disclosure is reasonably necessary to (a) comply with applicable laws, regulations, legal processes, or requests from law enforcement or regulatory authorities, (b) prevent, detect, or otherwise handle fraud, security, or technical issues, and (c) protect the safety, rights, or property of any person, the public, or Seez,
• On a non-personal or aggregate basis — We may share your Personal Information with third parties on both a non-personally identifying basis and an aggregate basis.

3. Data Subject Rights

You have the following rights under GDPR:

• Access your personal data (Art. 15).
• Rectify inaccurate or incomplete data (Art. 16).
• Erase your data (“right to be forgotten”, Art. 17).
• Restrict or object to processing (Art. 18 & 21).
• Data portability (Art. 20).
• Withdraw consent at any time, where processing is based on consent.
• File a complaint in front Data Protection Authorities.

To exercise your rights, contact us at dpo@seez.co.

4. International Data Transfers

Where data is transferred outside the European Economic Area (EEA), we ensure such transfers are protected by appropriate safeguards, including Standard Contractual Clauses (SCCs) or adequacy decisions, as required under GDPR.

5. Security Measures

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including encryption, access controls, and secure data storage.

Your Personal Information is stored in AWS Hosted Servers based in the EU using security practices in accordance with industry standard practices.

We may also choose to engage other companies to store or process your Personal Information on our behalf. In every case, where we choose to do that, we will ensure that any company that we engage with is subject to the same standards of data security and provides you with the same level of personal information protection as we provide to you.

Seez is reasonably committed to maintaining the security of your Personal Information and has measures in place to protect such personal information against unauthorized or unlawful processing and against accidental loss, destruction or damage. Every person who has access to your Personal Information is contractually obligated to respect the confidentiality of your Personal Information and abide by the GDPR.

In some cases, your Personal Information may be stored in the Website owner’s databases (or the Website owner’s service providers’ databases). Please refer to the Website owner’s privacy policy for more information.

We are SOC 2 compliant, demonstrating our ongoing commitment to maintaining high standards of data security, availability, and confidentiality. This compliance ensures that our systems and controls are regularly audited by an independent third party to meet the stringent requirements of the AICPA Trust Services Criteria. Our SOC 2 certification underscores our dedication to protecting personal data processed both as a data controller and as a data processor.

6. Data retention period. 

We will retain your Behavioral Information and Personal Information for 6 months or as long as necessary for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Behavioral Information and Personal Information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your Behavioral Information and Personal Information, the purposes for which we process your information, whether we can achieve those purposes through other means, and the applicable legal requirements.  

Following the retention period mentioned hereinabove, your Behavioral Information and Personal Information will be permanently deleted.

7. Contact Us

If you have any questions or wish to exercise your rights, please contact:

Seez App Technology Ltd

Gate Avenue, South Zone, Entrance C, Level 1,

Seez Office, GA-SZ-L1-170

PO BOX: 418557

Email: dpo@seez.co

If you are not satisfied with our response, you have the right to lodge a complaint with your local Data Protection Authority.