We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the RSI X AI website at rsix-ai.com (“Website”) and the related RSI X AI products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and RSI X Limited (doing business as “RSI X”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
Collection of information
We collect only the minimum data we need. The Website uses only privacy-friendly, cookieless analytics (see “Data analytics” below). It does not use advertising trackers or social media plugins, and the fonts it uses are hosted on the Website itself, so visiting it does not send your data to Google or other third parties for those purposes.
We process the following information in connection with the Website:
- Contact form. When you send the form, we receive the details you enter: name, work email, organization, event type, languages needed and your message, together with the language version of the site you used. We use them only to reply to your enquiry and to prepare a possible offer. Legal basis: steps taken at your request before entering into a contract, and our legitimate interest in answering business enquiries.
- Technical data. Like any website, our hosting provider receives technical information needed to deliver and protect the Website, such as your IP address, browser type and the pages requested, and may keep it in its server logs for a limited time. We do not use this information to identify you. Legal basis: our legitimate interest in operating a secure website.
- Cookie choice. Your answer to the cookie notice is stored in your own browser (local storage, key “rsix-consent”). It is not sent to us. See our Cookie Policy.
RSI X AI service. When an organization uses the RSI X AI interpretation and captioning service, the audio and text processed during its meetings and events are handled under the agreement with that organization, which acts as data controller while we act as its data processor. On our paid-tier setup, this audio is not used to train AI models, and retention follows the service settings agreed with the customer.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
Use and processing of collected information
We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information.
We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.
In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used to help us run and operate the Website and Services.
Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Disclosure of information
We do not sell your Personal Information and do not share it with third parties for their own marketing. We use the following service providers, who process data on our behalf and only for the purposes described here:
- GitHub, Inc. (GitHub Pages) - hosting of the Website, including the technical data described above. United States.
- Web3Forms, operated by Web3Creative (India) - receiving, spam-checking, storing and forwarding contact form submissions to our mailbox, under its Data Processing Agreement. Web3Creative uses its own sub-processors: Amazon Web Services (hosting, storage and email delivery), Cloudflare (network and security), Hetzner (infrastructure in Germany and Finland), and CleanTalk and Akismet (spam filtering, which receive the sender’s IP address and email address, United States).
- Umami Software, Inc. (Umami Cloud) - cookieless website statistics as described under “Data analytics”. Data stored in the European Union.
- Namecheap, Inc. (Namecheap Private Email) - hosting of our mailbox info@rsiexchange.com, where form submissions and correspondence are received and stored, under the Namecheap Data Processing Addendum. Data centre in Phoenix, Arizona, United States.
Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements, and receive only the information they need for their designated functions. We may also disclose information where required by law.
International transfers
RSI X Limited is based in Hong Kong, and our service providers process data in other countries, including India, the United States and the European Union. Where the law requires it, for example for data from the European Economic Area, the United Kingdom or Switzerland, these transfers are protected by appropriate safeguards: the European Commission’s Standard Contractual Clauses (Decision (EU) 2021/914) and, for the United Kingdom, the International Data Transfer Addendum, which are incorporated into the Web3Forms Data Processing Agreement, and the equivalent safeguards or adequacy decisions relied on by our other providers.
Retention of information
We keep contact form enquiries and our related correspondence for as long as needed to handle your request and any resulting business relationship, and for no longer than 24 months after our last contact, unless a longer period is required by law or needed to establish, exercise or defend legal claims. We have set Web3Forms to keep submissions in its dashboard for 7 days; under its retention design, any remaining copies on its systems expire after at most three years, and all data is deleted within 90 days after our account ends. Hosting providers keep server logs for their own limited retention periods. Your cookie choice remains in your browser until you change it or clear your browser data.
Once the retention period expires, Personal Information is deleted or anonymized. We may use anonymized, aggregated data that cannot identify you.
Cookies
The Website does not set its own cookies. It stores only your cookie choice in your browser’s local storage, which is strictly necessary to remember your decision. You can change your choice at any time via “Cookie settings” at the bottom of each page. For more detail, see our Cookie Policy.
Data analytics
We use Umami Cloud, provided by Umami Software, Inc., with data stored in its European Union region, to count visits and understand how the Website is used in aggregate. Umami does not use cookies or any other storage on your device, does not store your IP address and does not build profiles or track you across websites. It records the page visited, the referring website, the browser, operating system, device type, screen size, language and approximate country (derived from your IP address, which is then discarded). We rely on our legitimate interest in understanding and improving the Website (Article 6(1)(f) GDPR). Because no information is stored on or read from your device for analytics, no consent is required. Statistics are kept in aggregate form for as long as our Umami account is active.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. The Website and Services do not track its visitors over time and across third-party websites. However, some third-party websites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Social media features
The Website does not include social media plugins or share buttons that collect data. Links to other websites are ordinary links: those websites only receive data from you if you choose to visit them.
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
Data breach
In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the top of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
Your rights
Depending on where you live, including under the GDPR, the UK GDPR, the Swiss Federal Act on Data Protection and the Hong Kong Personal Data (Privacy) Ordinance, you may have the right to access your Personal Information, to have it corrected or deleted, to restrict or object to its processing, to data portability, and to withdraw your consent at any time without affecting earlier processing. To exercise these rights, contact us at the address below; we respond within one month. You also have the right to lodge a complaint with your local data protection authority.
Contacting us
The data controller for the Website is RSI X Limited, 132 Luk Tei Tong Village, Mui Wo, Lantau, Hong Kong SAR. If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.