Privacy Policy

1. The General Data Protection Regulation

The General Data Protection Regulation 2016 (GDPR) is one of the most significant pieces of legislation affecting the way that Telemore AI LLC carries out its information processing activities. Significant fines are applicable if a breach is deemed to have occurred under the GDPR, which is designed to protect the personal data of citizens of the European Union. It is Telemore’s policy to ensure that our compliance with the GDPR, The California Consumer Privacy Act (CCPA), and other relevant legislation is clear and demonstrable at all times.

2. Definitions

There are a total of 26 definitions listed within Article 4 – Definitions of the GDPR, and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:

Personal data: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
Processing: “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”
Controller: “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.”

3. Principles relating to processing of personal data

Personal data shall be:

Processed lawfully, fairly, and in a transparent manner in relation to the data subject (‘lawfulness, fairness, and transparency’).
Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’).
Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’).
Accurate and, where necessary, kept up to date (‘accuracy’).
Kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’).
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).
The controller shall be responsible for, and able to demonstrate, compliance with all these principles (‘accountability’).

Telemore AI LLC must ensure that it complies with all these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems. The operation of an information security management system (ISMS) that conforms to the ISO/IEC 27001 international standard is a key part of that commitment.

4. Rights of the individuals

The data subject also has rights. These consist of:

The right to be informed.
The right of access.
The right to rectification.
The right to erasure.
The right to restrict processing.
The right to data portability.
The right to object.
Rights in relation to automated decision-making and profiling.

“To protect the integrity and security of our internal systems, we may limit access to specific details about how your data is processed, where such disclosure would compromise proprietary methods or allow for system manipulation. We are committed to balancing transparency with the need to maintain secure and reliable services.”

Each of these rights must be supported by appropriate procedures within Telemore AI LLC that allow the required action to be taken within the timescales stated in the regulations.

Unless it is necessary for a reason allowable in the regulations, consent must be obtained from a data subject to collect and process their data. In the case of children below the age of 16 (Note – this age may be lower in individual EU member states), parental consent must be obtained. Transparent information about our usage of their personal data must be provided to data subjects at the time that consent is obtained, and their rights regarding their data explained, such as the right to withdraw consent. This information must be provided in an accessible form, written in clear language, and free of charge.

If the personal data are not obtained directly from the data subject, then this information must be provided within a reasonable period after the data are obtained and definitely within one month.

6. Privacy by design

Telemore AI LLC has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more privacy (also known as data protection) impact assessments.

The privacy impact assessment will include:

Consideration of how personal data will be processed and for what purposes.
Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s).
Assessment of the risks to individuals in processing the personal data.
What controls are necessary to address the identified risks and demonstrate compliance with legislation.

Use of techniques such as data minimization and pseudo-anonymization will be considered where applicable and appropriate.

7. Transfer of personal data

Transfers of personal data outside the European Union/USA must be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgment as to the adequacy of the safeguards for personal data applicable in the receiving country, and this may change over time.

8. Data protection officer

A defined role of Data Protection Officer (DPO) is required under the GDPR if an organization is a public authority, if it performs large-scale monitoring, or if it processes particularly sensitive types of data on a large scale. Based on these criteria, Telemore AI LLC does not require a Data Protection Officer to be appointed.

9. Breach notification

It is Telemore’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours.

The following actions are undertaken to ensure that Telemore AI LLC complies at all times with the accountability principle of the GDPR:

The legal basis for processing personal data is clear and unambiguous.
Rules regarding consent are followed.
Privacy by design is adopted for all new or changed systems and processes.
Relevant technical and organizational controls are in place.

These actions are reviewed regularly as part of the information security management process.