Privacy Policy

This privacy policy gives you information about how OGAM AI collects, uses, shares, secures and processes your personal data in compliance with General Data Protection Regulation (EU) 2016/679 (GDPR) and Data Protection Act 2018. Our services are not intended for children under 18 years and we do not knowingly collect data relating to children.

Last Updated: 4/23/25

1. Introduction

OGAM AI is the controller and is collectively referred to as "COMPANY", "we", "us" or "our" in this privacy policy. This privacy policy does not apply where OGAM AI acts as a data processor and processes personal data on behalf of commercial customers.

We have appointed a data protection officer (DPO) 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, please contact the DPO using the information set out in the contact details section.

2. Types of Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, any previous names, username or similar identifier, title, date of birth.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you interact with and use our website, products and services. If you communicate with us via our chatbot, we collect your name, contact information and the contents of your conversation with us. We also may collect the content data which you input into our program.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is Your Personal Data Collected

We use different methods to collect data from and about you including:

When you use our services.
When you register, purchase or have access to the Platform, you will usually be required to provide us with your name and email address. You may also be required to provide us with other information necessary for the use of the Platform or additional information that you choose to disclose to us, such as your professional details or your user preferences.
Your interactions with us.
You may give us your personal data by filling in online forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services or subscribe to our service or publications;
- create an account with us;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us feedback or contact us.
When using our Services, you may provide information in various formats (referred to as “Incoming information”). Our Services may generate responses based on this Incoming information (referred to as “Outgoing information”). Collectively, Incoming information and Outgoing information are referred to as “Content”. In the event that you choose to include personal data with your Incoming information, we will collect this personal data and it may be included in the Outgoing information generated by the platform.
Automated technologies or interactions
As you interact with the Platform, we will automatically collect Technical Data about your equipment, searching actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

We may also collect personal data about you from third parties:
- Our partners and service providers
- Publicly available sources
- Your employer or institution
- Other public or paid-for sources.

4. How We Use Your Personal Data

Legal Bases

Data Protection Act 2018 requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract, we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Performance of the Platform

We may use your personal data to:

To provide, maintain, and improve the Platform.
To process and analyse uploaded content, including papers and user-provided questions and statements.
To personalize your experience and offer tailored recommendations.
We may also use anonymize and aggregate user data for the purposes of monitoring the Platform usage in order to help us to develop the Platform. This allows us to:
Enhance product features and offerings.
Conduct internal research and analytics.
Develop or fine-tune our own AI models.

5. Disclosures of Your Personal Data

Third-Party Sharing

We do not sell or share user-provided content (e.g., uploaded papers or questions) with third parties for their own marketing purposes.

Service Providers

We may engage with other Data Processors to process Personal Data on our behalf. In each case, a formal, written contract is in place with the Processor, outlining their obligations in relation to the Personal Data, the specific purpose or purposes for which they are engaged, and the understanding that they will process the data in compliance with the Irish Data Protection legislation and GDPR. Failure of a Data Processor to manage data in a compliant manner will be viewed as a breach of contract and will be pursued through the courts.

In connection with the above purposes, we might be required to transfer your personal data outside the EU. If and to the extent that we are required to do so, we will ensure that appropriate measures are in place to comply with our obligations under the applicable law covering such transfers. This may include entering into a contract governing the transfers that contains the “standard contractual clauses” approved for this purpose by the European Commission.

We share data with trusted third-party service providers for:

Payment processing,
Data hosting and processing,
Analytics and user interaction tracking.

Legal Compliance

We may disclose information if required by law, regulation, or court order

6. Data Retention and Security

Data Security

We use industry-standard security measures to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit the access of third parties. We also keep your information confidential.

We have procedures in place to manage any data security breaches. Where a personal data breach occurs, which is likely to result in a high risk to your rights and freedoms, we shall, without undue delay, notify you. The Data Protection Commissioner will be notified within 72 hours of the data breach coming to our attention.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

7. Cookies and Tracking

We, along with our service providers, use cookies, scripts, and similar technologies (“Cookies”) to manage our Services and gather information about you and your interactions with them. These technologies enable us to recognize you, tailor your experience, personalize content, market relevant products or services, and analyse usage patterns to enhance the security and functionality of our Services.

Types of Cookies Used

Essential Cookies: Required for the Platform’s core functionality.
Performance Cookies: Used to understand user interactions and improve the Platform.
Marketing and Analytics Cookies: Enable UTM tracking and campaign analysis.

Managing Cookies

You can control cookie preferences through your browser settings. However, disabling cookies may impact your ability to use certain features of the Platform.

8. Your Rights

You have a number of rights under data protection laws in relation to your personal data.

Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
In addition to processing requests to rectify incorrect, inaccurate, or incomplete data, we may periodically contact you to update or correct your personal data. If you object to how your personal data is being processed, you may request its complete erasure from our records at any time.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction
of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please submit your request in writing, either thought our online portal by clicking here or by email to our DPO at support@ogam.ai.
To help us process your request efficiently, please:

Be as specific as possible about the information you wish to receive and the preferred format.
Provide valid proof of identification to verify your request

There is typically no charge for submitting a request. However, if a request is excessive or unfounded, we may charge a reasonable administrative fee, the details of which will be provided to you.
We have implemented a Subject Access Request (SAR) procedure to ensure efficient and timely processing of such requests, with a standard response time of 30 days. In cases where the request is complex, we may extend this period by up to two (2) additional months, and we will inform you accordingly.
Please note that Subject Access Requests may be subject to certain legal or regulatory restrictions. If we are unable to fulfil your request, we will provide you with a clear explanation of the reasons for any refusal.

9. Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO in the following ways:

Email address: support@ogam.ai
Postal address: Fort Clever Software, Ltd., 68 An Sean Dún, Ennis, Co Clare, V95 HW3R, Ireland

10. Complaints

You have the right to make a complaint at any time to the Data Protection Commissioner (DPC), a regulator for data protection issues (https://www.dataprotection.ie/). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

11. Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. This version was last updated on 23rd April 2025.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

12. Third-party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

13. Marketing

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party Marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of Marketing

You can ask to stop sending you marketing communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences in your account settings or by contacting us here.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.