Last updated 04.01.2022.

Welcome to Grithut!

Abilitics OOD, a company registered in Bulgaria under company number 200131838 ("Abilitics", "we", "us" and/or "our") operates the Grithut platform (all versions) under the name Grithut, which is a personal development platform.

We are committed to protecting your privacy. This Privacy Policy describes how we collect, store, use and distribute information through our Services in terms of the General Data Protection Regulation (GDPR). Please read this Privacy Policy carefully. By starting to use our Services, you consent to this Privacy Policy.

We care about the protection and confidentiality of your data. We therefore only process your data to the extent that:

• It is necessary to provide you with services you are requesting,
• You have given your consent to the processing, or
• We are otherwise authorised to do so under the data protection laws.

Conversations with the Grithut chatbot may only be shared with the owner of this website/platform if this is not Abilitics. We will never sell your personal data or conversation history.

By using or accessing the services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you at this moment consent that we will collect, use, and share your information in the following ways.

Remember that your use of Grithut's services is always subject to the Terms of Service, which incorporate this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in Terms of Service.

If you have any questions, suggestions or comments about privacy or protection and confidentiality of your data, please contact us at office@abilitics.com.

1. What personal data we collect and process

Here we list all the types of personal data we collect and store throughout your experience with Grithut. Some of this information may be shared with service providers who help us deliver your experience with Grithut, each of such service is explained below.

We neither rent nor sell your information to anyone. If Grithut is used by our client or partner, the latter will control the processing of your personal data.

We DO NOT knowingly collect or store special categories of personal data under GDPR, including medical information or Health Information (HI), defined under the Bulgarian law as personal data related to the health status, the physical and psychological development of individuals, as well as any other information contained in medical prescriptions, recipes, records, certificates and other medical documentation. We discourage you from communicating this information to Grithut through text or voice chat so that this information does not become part of your chat history. However, our partners or our clients/third parties, that embedded Grithut on their websites, mobile environment or other resources on the Internet, may intend or envisage processing of special categories of personal data, including medical information or HI. If this is the case, the respective third parties will be controllers of your personal data processed through Grithut. They will be responsible for concerning all your requests relating the processing of your personal data.

We collect information you intentionally provide through the Services (such as your profile information that you provide upon registration or content you share), as well as some technical information coming from your mobile device or web browser.

1.1. What personal data you provide

When you start using Grithut and throughout your experience with our Services we may collect, and you may provide your personal data. The following table covers the types of personal data that you may provide and we may collect:

Personal data	Why we need the data	When we collect the data	Is it ever shared?
Email	To enable you to register and log in on our platform using your email and restore password in case you forget it. We also collect your Email if you register or log in with your Microsoft, LinkedIn, Google or Facebook account. If you provide your Email in conversation with Grithut, we will use it to send you a verification email. We will also process your Email when you use the contact form on our website. When you consent to obtain our newsletter, we will process your Email to send it.	When you create an account; use the Chatbot; contact us through the contact form on our website or consent to obtain our newsletter.	Yes, we use an external service to deliver automated emails to you (for example, in case you forgot your password).
Other profile information	We may use personal data from your Microsoft, LinkedIn, Google or Facebook account, like your name and profile picture.	When you edit your profile	No
Photos, articles, presentations you shred on the platform	To enable you share content with the other users of Grithut; to enable you to train your chatbot	When you share the content on the platform	No
Text messages you send to Grithut	To display your chat history in in your web browser and sync the history across all your devices and to train Grithut machine learning models and improve the quality of your text chat experience.	In text chat with Grithut	No
Usage data	We collect and store your usage data, such as button clicks or search queries, to track and analyze product metrics and to better understand and serve the users of the Services.	When you interact with Grithut or our website	Yes, we use an external service to track and visualize de-identified usage data.

1.2. Device information

As described below, we collect certain information from and about the computers, phones, and other web-connected devices that you access Grithut from. We combine this information across different devices you use.

The device information also helps us conduct user research across our customer demographics, interests and behavior. We use this information to elaborate aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes. None of these aggregated statistics may identify you personally.

Device information	Description
Device attributes	Information such as the operating system, hardware, and software versions, browser type.
Identifiers	Unique identifiers, such as your device ID.
Data from device settings	Information you allow us to receive through device settings you turn on, such as access to your camera, microphone or photos.
Network and connections	Information such as the name of your mobile operator or ISP, language, time zone.
Cookie data	Data from cookies stored on your device, including cookie IDs and settings. Learn more about how we use cookies in the "Cookies" section.

1.3. Cookies

In operating the Services, we may use a technology called "cookies." A cookie is a small text file that our website stores on your computer or mobile device when you visit our website.

Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately.

We may also allow third party service providers to use cookies or similar technologies to collect information about your activities on our website or in our mobile apps following your use of the Services.

In all cases in which we use cookies, we will not collect Personal Data except with your permission. In addition, you may restrict the cookies from the settings of your web browser. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off.

In the table below you can find what cookies we store on your device and how long we keep them:

Name of Cookie	Purposes	Expiration
.AspNet.ApplicationCookie	Created when the user is registered	Expires after 1 month - if the user has selected "Remember" me Expires after Session end - without Remember me
cookieconsent_status	Used to save if the used have accepted cookie consent. So that second time - we don't show them the "agree with cookies" message	Expires after 1 year
userIdentifier	Holds an unique user identifier for the anonymous users. This is used so that if the same anonymous user accesses the site second time, we can load the same history with the chatbot. This cookie can be removed.	Expires after 1 year
_fbp	Used by Facebook Pixel tracking	Expires after 3 months
_ga	Used by Google Analytics tracking	Expires after 2 years
_hjid	Used by HotJar tracking	Expires after Session end

2. With whom we share your personal data

We may pseudonymize or anonymize your personal data so that you are not individually identified to improve our services or provide that information to our partners. We also may combine your de-identified information with that of other users to create aggregate de-identified data that may be disclosed to third parties who may use such information to understand how often and in what ways people use our services, so that they, too, can provide you with an optimal experience.

For the purposes of complying with legislative requirements, court acts or other public authorities instructions, we may need to access, read, preserve, and disclose any information; we can do that if we reasonably find it necessary to apply our Terms of Service and other agreements; or protect the rights, property, or safety of Grithut, our employees, our users, or others. Subject to applicable law, you will be duly notified of such processing activities.

3. How we secure and protect your information

We use a variety of industry-standard security technologies and procedures to help protect your data from unauthorized access, use, or disclosure. However, while we use reasonable commercial efforts to protect the data, no technology, data transmission or system can be guaranteed to be 100% secure. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your data, we will notify you as soon as we spot the issue.

4. Where we store your data

Our services are operated in Bulgaria. If you are located in another jurisdiction, please be aware that the information you provide will be stored within the European Union. While operating Grithut we do not transfer your personal data outside the European Economic Area. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

5. Data retention

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we retain your data until you decide to delete your account.

6. Your data protection rights

As a Grithut registered user, you have the following data protection rights, depending on the circumstances of the specific case. You can exercise your rights by sending us a request at the following email: office@abiltics.com.

• Access: you have the right to receive information about your personal data processed by us and to request access to your personal data and/or copies of these data. This includes information on the purpose of use, the category of data used, its recipients and authorized persons and, if possible, the planned duration of data storage or, if this is not possible, the criteria for determining this duration.
• Rectification, erasure or restriction of processing: you may request the rectification, erasure or restriction of the processing of your personal data, If (i) the data are incomplete or incorrect, (ii) they are no longer necessary for the purposes for which they were collected, (iii) the consent on which the processing was based has been revoked, or (iv) you have successfully exercised your right to object to data processing; in cases where data is processed by third parties, we will forward your requests for correction, deletion or limitation of the processing to these third parties, unless this proves impossible or involves a disproportionate effort.
• Opposition to the processing: you may object to the processing for reasons arising from your particular situation.
• Withdrawal of consent: when we process your personal data on basis of your prior consent, you have the right to withdraw your consent to the processing of your personal data at any time without affecting the lawfulness of data processing prior to the withdrawal.
• Automatic decisions : you may require that you be subject to a decision based exclusively on automated processing only in the exceptional cases provided by law, if that decision has legal effect against you or significantly affects you in a similar manner; should such an automated decision take place in exceptional cases, you have the right to obtain information on the logic involved and the scope of the intended effects.
• Right of appeal: you may communicate to us any concerns you have regarding processing of your personal data. You also have the right to lodge a complaint with a supervisory authority, if necessary.

7. How to delete your data

You can delete all your account information and content shared by deleting your account in the platform.

8. Use of Grithut by minors

We do not knowingly collect Personal Data from children under the age of 14. If you are under the age of 14, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 14 has provided Personal Data to us through the Services, please contact us, and we will endeavor to delete that information from our databases.

9. We may change this Privacy Policy

Grithut and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.