PRIVACY POLICY

of websites https://www.briefd.io

mobile application AutoBrief Companion

and https://app.briefd.io

WELCOME TO BRIEFD’S PRIVACY POLICY.

WE AS A COMPANY RESPECT YOUR PRIVACY AND ARE COMMITTED TO PROTECTING YOUR PERSONAL DATA. THIS PRIVACY POLICY WILL INFORM YOU AS TO HOW WE LOOK AFTER YOUR PERSONAL DATA WHEN YOU VISIT OUR WEBSITE (REGARDLESS OF WHERE YOU VISIT IT FROM), USE OUR MOBILE APPLICATION AND TELL YOU ABOUT YOUR PRIVACY RIGHTS AND HOW THE LAW PROTECTS YOU.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR APPLICATION OR CONTINUE WITH BROWSING OUR WEBSITE AND LET US KNOW IF YOU HAVE ANY QUESTIONS OR OTHER FEEDBACK REGARDING IT.

1 INTRODUCTION

1.1 When using the Briefd software (“Application”) subject to the Terms and Conditions available at our website: https://www.briefd.io and https://app.briefd.io with subdomains (collectively the “Website”), the company BRIEFD d.o.o. (“BRIEFD”) may collect and process certain personal data. This Privacy Policy describes how personal data are being collected, used or otherwise processed. BRIEFD undertakes to handle and secure the personal data in accordance with this Privacy Policy and the applicable legislation in the field of data protection in force.

1.2 The Website may contain link to third-party sites, which are not operated by BRIEFD. By clicking to a link to the third-party site, you will be taken to websites that are not under BRIEFD’s control. For the privacy questions concerned the privacy policies of such third parties may apply.

2 BRIEFD AS OWNER AND DATA CONTROLLER

2.1 Data Controller. For the personal data associated with the Users (e.g. of the User itself or User’s employees, contractors or other individuals acting on behalf of the User; “Users”, “You”, “Your”) collected through Application or other individuals accessing the Website or Application BRIEFD družba za ravoj mobilnosti d.o.o. ( “We”, “Us”, “Our” or “BRIEFD”) acts as data controller and is responsible for Your Personal Data.

2.2 Data Controller’s contact details. If You have any questions about this Privacy Policy or the exercise of your rights, we can be reached at the following contacts:

• (a) Company: BRIEFD družba za razvoj mobinosti d.o.o.
• (b) Email: info@briefd.io
• (c) Telephone number: 01 828 0181
• (d) Postal address: Štukljeva cesta 40, 1000 Ljubljana

2.3 BRIEFD has not designated any data protection officer. Irrespective of that, for any information, question or other communication regarding personal data you may contact Miha Medven at miha.medven@briefd.io.

3. TYPES OF PERSONAL DATA COLLECTED

3.1 Among the types of Data that this Application collects and processes, by itself or through third parties, there are:

• (a) Identity Data includes Your first name, last name, username or similar identifier.
• (b) Contact Data includes Your work address, work email address, work telephone number and work position.
• (c) Financial Data includes Your bank account and payment card details.
• (d) Transaction Data includes details about payments to and from You and other details of products and services You have purchased from Us.
• (e) Profile Data includes Your username and password.
• (f) 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, and other technology on the devices You use to access this Application.
• (g) Usage Data includes information about how You use Our Application products and services.
• (h) Marketing and Communications Data includes Your preferences in receiving marketing from Us and Our third parties and Your communication preferences.

3.2 Aggregated Data. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from Your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal Your identity. For example, We may aggregate Your Usage Data to calculate the percentage of users accessing a specific Application feature. However, if We combine or connect Aggregated Data with Your Personal Data so that it can directly or indirectly identify You, We treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

3.3 Special Categories of Personal Data. 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.

3.4 Where We need to collect Personal Data by law, or under the terms of a contract We have with You, and You fail to provide that Data when requested, We may not be able to perform the contract we have or are trying to enter into with You (for example, to provide You with goods or services). In this case, We may have to cancel a product or service You have with Us, but We will notify You if this is the case at the time.

4. MODE OF COLLECTING PERSONAL DATA

4.1 We use different methods to collect Personal Data from and about You including through:

• (a) Direct interactions. You may give Us Your Identity and Contact Data by filling in forms or by corresponding with Us by post, phone, email or otherwise. This includes Personal Data You provide when You:
  • (i) apply for Our products or services;
  • (ii) create an account on Our Application;
  • (iii) subscribe to Our service or publications;
  • (iv) request marketing to be sent to You;
  • (v) enter a competition, promotion, or survey; or
  • (vi) give Us feedback or contact Us.
• (b) Automated technologies or interactions. As You interact with Our Website, We will automatically collect Technical Data about Your equipment, browsing actions and patterns. We collect this Personal Data by using cookies [see Our Cookie Policy https://autobrief.io/cookies/] and other similar technologies.

5. PURPOSE OF PERSONAL DATA PROCESSING

5.1 Legal basis of processing. We may process Personal Data relating to You if one of the following applies:

• (a) Performance of contractual obligations BRIEFD processes personal data associated with You for the performance of a contractual obligations regarding the use of Application in accordance with Terms and Conditions, meaning to operate the Application and deliver the services to Your, provide support, facilitate Your usage of the Application and perform related services (e.g. maintenance), billing transactions, to process Your request(s) regarding the Application, informing You about other products or service connected with the Application or products or services available from BRIEFD, and other activities within contractual relationship when using the Application.
• (b) Consent Certain Personal Data (e.g. e-mail address, phone number) may also be used or processed based on the consent for the purpose of informing about BRIEFD’s products or services connected with the Application or other products and services available from BRIEFD. Such Personal Data may be stored until Your consent is withdrawn but no longer than the time necessary for fulfilment of the purpose. You may withdraw the consent to process the Personal Data for the below purposes at any time by sending an e-mail to: info@briefd.io.The withdrawal of consent does not impact the lawfulness of processing Personal Data before the withdrawal and does not impact the processing of Personal Data on other grounds in accordance with this Privacy Policy.
• (c) Legitimate interests For certain cases BRIEFD has developed legitimate interests for processing of such personal data. The legitimate interest of BRIEFD include:
  • (i) informing You about changes to Our Application / Website or about new functionalities on the Application / Website;
  • (ii) performance of direct marketing to You as Our existing User regarding new BRIEFD services and products;
  • (iii) enforcing any legal action, claim or dispute or to defend BRIEFD against any such action, claim or dispute;
  • (iv) compliance with court order or other legal processes or legal and regulatory requirements of governmental authorities;
  • (v) ensuring information security, including unauthorized access to Application or confidential information. Such processing may last until the purpose of legitimate interest is evidenced.

5.2 In any case, We will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

6. THE PURPOSE OF PROCESSING

6.1 The Data concerning You is collected to allow Us to provide Our Service, comply with Our legal obligations, respond to enforcement requests, protect Our rights and interests (or those of Our users or third parties), detect any malicious or fraudulent activity, as well as the following: Registration and authentication, Location-based interaction, Analytics and Mobile Identifiers, Advertising, Device permissions for Personal Data access and Data transfer outside the EU.

6.2 We have set out below, in a table format, a description of all the ways we plan to use Your Personal Data, and which of the legal bases We rely on to do so. We have also identified what Our legitimate interests are where appropriate.

7. CHANGE OF PURPOSE

7.1 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 Us.

7.2 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.

7.3 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.

8. RETENTION TIME

8.1 Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• (a) Personal Data collected for purposes related to the performance of a contract between Us and You shall be retained until such contract has been fully performed.
• (b) Personal Data collected for the purposes of Our legitimate interests shall be retained as long as needed to fulfil such purposes. You may find specific information regarding the legitimate interests pursued by Us within the relevant sections of this Privacy Policy or by contacting Us.
• (c) We may be allowed to retain Personal Data for a longer period whenever You have given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
• (d) Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

9. PROTECTION OF PERSONAL DATA

9.1 With the purpose of securing the personal data BRIEFD has adopted technical and organizational measures to ensure the compliance with GDPR and to prevent accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed which may in particular lead to physical, material or non-material damage.

10. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

10.1 BRIEFD will not give, send, sell, share of disclose Personal Data to any third country except if such process is outlined in this Privacy Policy.

10.2 However, as our business partner ActiveCampaign (https://www.activecampaign.com/?_r=UQER3868 ) is based outside the EU, the processing of certain Personal Data involves the transfer of Personal Data outside the EU. As a result, we may share the following Personal Data with those business partners for the purpose described:

• (a) we share your email address with a third party outside the EU for the purpose of sending you email about changes to Our Application / Website or about new functionalities on the Application / Website. Our cooperation with ActiveCampaign enables us to send emails safely and securely, which prevents mass and unnecessary sending of emails to the users of the Website and/or the Application, however, users may still be adequately informed about changes, updates and other new functionalities of the App/Website. ActiveCampaign’s Privacy Policy is available at https://www.activecampaign.com/legal/privacy-policy.

11. YOUR RIGHTS

11.1 You may exercise certain rights regarding their Data processed by Us. In particular, You have the right to do the following:

• (a) Withdraw their consent at any time. You have the right to withdraw consent where You have previously given Your consent to the processing of their Personal Data.
• (b) Object to processing of their Data. You have the right to object to the processing of Your Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• (c) Access their Data. You have the right to learn if Data is being processed by Us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
• (d) Verify and seek rectification. You have the right to verify the accuracy of Your Data and ask for it to be updated or corrected.
• (e) Restrict the processing of Your Data. You have the right, under certain circumstances, to restrict the processing of Your Data. In this case, We will not process Your Data for any purpose other than storing it.
• (f) Have their Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of Your Data from Us.
• (g) Receive Your Data and have it transferred to another controller. You have the right to receive Your Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on Your consent, on a contract which You are part of or on pre-contractual obligations thereof.
• (h) Lodge a complaint. You have the right to bring a claim before their competent data protection authority.

11.2 Details about the right to object to processing. Where Personal Data is processed for a public interest, in the exercise of an official authority vested in Us or for the purposes of the legitimate interests pursued by Us, You may object to such processing by providing a ground related to their particular situation to justify the objection. You must know that, however, should Your Personal Data be processed for direct marketing purposes, You can object to that processing at any time without providing any justification. To learn, whether We are processing Personal Data for direct marketing purposes, You may refer to the relevant sections of this Privacy Policy.

11.3 How to exercise these rights. Any requests to exercise Your rights can be directed to Us through the contact details provided in this Privacy Policy. These requests can be exercised free of charge and will be addressed by Us as early as possible and always within one month.

12. ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

12.1 Reliability. You are responsible for backing up, to Your own computer or other device, any important data stored or accessed via this Application. We do not guarantee or warrant that any content You may store or access through the Application will not be subject to inadvertent damage, corruption, or loss.

12.2 Security. We will use commercially reasonable efforts to safeguard the confidentiality of Your Data. However, We cannot be held liable for any loss of or disclosure of Data or any losses or damages incurred due to errors in transmission or unauthorized or unlawful acts of third parties or Your decision to disclose Your Personal Data. No system can be 100% secure, and despite Our efforts, there is always a risk of unauthorized access to Your Data. By using this Application, You assume this risk.

12.3 Legal action. Your Personal Data may be used for legal purposes by Us in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. You declare to be aware that We may be required to reveal personal data upon request of public authorities.

12.4 Additional information about Your Personal Data. In addition to the information contained in this Privacy Policy, this Application may provide You with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

12.5 System logs and maintenance. For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application. (System logs) use other Personal Data (such as the IP Address) for this purpose.

12.6 Information not contained in this Privacy Policy. More details concerning the collection or processing of Personal Data may be requested from Us at any time. Please see the contact information at the beginning of this Privacy Policy.

12.7 How “Do Not Track” requests are handled. This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

12.8 Changes to this Privacy Policy. We reserve the right to make changes to this Privacy Policy at any time by notifying You on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to You via any contact information available to Us. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the Your consent, We shall collect new consent from You, where required.

12.9 Legal information. This Privacy Policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This Privacy Policy relates solely to this Application, if not stated otherwise within this Privacy Policy.

Latest update: 19. 2. 2026