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Belay AI – Website Privacy Notice

Effective Date: September 22, 2025

1. Who We Are

Belay AI AS is the data controller for personal data collected through our website www.belay.ai. We are committed to protecting your privacy in accordance with the EU General Data Protection Regulation (GDPR).

Contact
Belay AI AS
Oslo, Norway
Company Registration Number: 932 740 575
Email: privacy@belay.ai

2. What Personal Data We Collect

When you use our website, we may collect:

• Technical Data: IP address, browser type, device information, date/time of access, and usage logs.
• Cookies: Small files placed on your device to support site functionality, analytics, and (if applicable) marketing.
• Contact Forms / Newsletter Sign-Up: Name, email, and any information you choose to provide.
• Comments: Data entered in comment fields, plus IP address and browser user agent for spam detection.
• Media Uploads: Uploaded images or files (users should avoid including location data in uploads).
• Job Applications: Name, email, LinkedIn profile, motivation letter, resume (including employment history, education, and other details you choose to share).

We do not collect or process climbing session data or app usage data through the website. For that, please see our App Privacy Policy.

3. How We Use Your Data

We use website data to:

• Provide and maintain website functionality.
• Respond to inquiries submitted through forms.
• Process job applications and manage recruitment.
• Improve website performance and user experience (analytics).
• Detect spam, fraud, or security risks.
• Send newsletters or marketing updates (only if you opted in).

4. Legal Basis for Processing

We rely on the following legal bases under GDPR:

• Consent (Art. 6(1)(a)): For cookies, analytics, newsletters, and storing applications for future roles.
• Contract (Art. 6(1)(b)): When responding to inquiries or processing job applications as steps toward an employment contract.
• Legitimate Interests (Art. 6(1)(f)): For site security, performance monitoring, recruitment process management, and essential cookies.
• Legal Obligations (Art. 6(1)(c)): Where required to comply with applicable laws.

5. Cookies

We use:

• Essential Cookies: Required for core functions (e.g., login sessions).
• Analytics Cookies: To understand usage patterns (only with your consent).
• Marketing Cookies (if any): Only with your explicit consent.

You can manage or disable cookies in your browser settings, or via our cookie banner.

6. Data Sharing and Subprocessors

We do not sell your personal data. We may use trusted third parties to help operate the website, including:

• Hosting Provider: WP Engine (servers located in the EEA).
• Analytics Tools: [Google Analytics / Matomo / other, if applicable].
• Spam Detection Services: e.g., Akismet for comments.
• Recruitment Tools / HR Service Providers: If we use them to help manage job applications.

All subprocessors are contractually required to comply with GDPR.

7. Data Storage & Transfers

• Data is stored on secure, encrypted servers within the European Economic Area (EEA).
• If accessed from outside the EEA (e.g., by service providers), we ensure appropriate safeguards such as EU Standard Contractual Clauses (SCCs).

8. Retention Periods

• Comments: Retained indefinitely unless deleted.
• Contact Forms: Retained for up to 12 months unless required longer for business purposes.
• Newsletter Data: Retained until you unsubscribe.
• Technical Logs: Retained for up to 90 days for security monitoring.
• Job Applications: Retained for up to 6 months after recruitment ends, unless law requires longer. With your consent, we may keep applications on file for up to 24 months for future opportunities.

9. Job Applications

If you apply for a role with Belay AI through our website, we will process the personal data you provide (name, contact details, LinkedIn, motivation letter, resume).

• Purpose: To assess your qualifications, manage recruitment, and contact you during the process.
• Legal Basis: Contract (Art. 6(1)(b)), Legitimate Interest (Art. 6(1)(f)), and Consent (Art. 6(1)(a)) if you ask us to keep your application for future roles.
• Retention: 6 months post-recruitment, or 24 months with your consent.
• Sharing: Limited to Belay AI’s internal hiring team and trusted HR providers under GDPR-compliant contracts.

10. Your Rights under GDPR

You have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request erasure of your personal data.
• Restrict or object to processing.
• Receive your data in a portable format.
• Withdraw consent at any time (e.g., unsubscribe, cookie preferences, job application storage).

You can exercise these rights by contacting us at privacy@belay.ai. You also have the right to lodge a complaint with the Norwegian Data Protection Authority (Datatilsynet) or your local supervisory authority.

11. Link to App Privacy Policy

If you use the Belay AI Technique App, please see our separate App Privacy Policy for details on how we process session videos, climbing analytics, and account data.

12. Changes to This Policy

We may update this notice to reflect changes in our practices or legal requirements. The effective date at the top of this notice will always show the latest version.