Privacy Policy

Last updated: March 28, 2025

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1. Identity of the Data Controller

Icarus Ai Ltd
4 Princess Street
W1B 2LE Mayfair, London
United Kingdom
Email: support@replyer.io

Replyer AI is the data controller responsible for processing your personal data collected through this website.

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2. What Personal Data We Collect

We collect and process the following categories of personal data:

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Personal information submitted via forms:

  • First name
  • Last name
  • Email address
  • Phone number

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ROI calculator inputs (linked to personal data):

  • Annual ticket volume
  • Number of agents
  • Annual in-house customer service team cost
  • Annual BPO team cost (optional)
  • Average order value
  • Annual help desk cost

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These inputs are linked to personal identifiers and are therefore treated as personal data.

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3. Legal Bases and Purposes for Processing

Purpose Legal BasisResponding to contact or demo requestsConsent / Legitimate InterestROI calculation and follow-up communicationConsentImproving our servicesLegitimate InterestCompliance with applicable lawsLegal Obligation

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4. Data Sharing and International Transfers

We do not sell your personal data.

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We use Webflow to host our website. Webflow acts as a data processor and may store your personal data outside the EU, including in the United States. Webflow has signed a Data Processing Agreement (DPA) and includes Standard Contractual Clauses (SCCs) to safeguard international transfers in compliance with GDPR.

We may also share your data with:

  • Internal employees or contractors (bound by confidentiality)
  • Approved subprocessors for functionality and maintenance purposes

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5. Data Retention

We only retain personal data for as long as necessary for the intended purposes:

  • Contact form and ROI calculator submissions: up to 24 months after last contact
  • Analytics or anonymized usage data: may be stored indefinitely (non-identifiable)

You can request deletion at any time (see section 6).

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6. Your Rights Under the GDPR

a) Right of Access (Article 15 GDPR)

You have the right to obtain confirmation from Replyer AI as to whether or not personal data concerning you is being processed, and if so, access to that personal data and the following information:

  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients or categories of recipients to whom your data has been or will be disclosed (especially recipients in third countries or international organisations)
  • Where possible, the intended period of data retention or, if not possible, the criteria used to determine that period
  • The existence of your rights (listed below)
  • The right to lodge a complaint with a supervisory authority
  • Where personal data is not collected directly from you, any available information about the source
  • The existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and expected consequences of such processing for you

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We will provide a copy of your personal data free of charge. For any additional copies requested, we may charge a reasonable fee based on administrative costs.

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b) Right to Rectification (Article 16 GDPR)

You have the right to request the rectification of inaccurate personal data concerning you without undue delay. You also have the right to have incomplete personal data completed, including by providing a supplementary statement.

If we have shared your personal data with third parties, we will inform them of the rectification where possible. You may also request information about these recipients.

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c) Right to Erasure – “Right to be Forgotten” (Article 17 GDPR)

You have the right to request the deletion of your personal data under certain conditions, including when:

  • The data is no longer necessary for the purposes for which it was collected
  • You withdraw your consent and there is no other legal basis for processing
  • You object to processing and there are no overriding legitimate grounds
  • The data has been unlawfully processed
  • The data must be erased to comply with a legal obligation

Please note, we may refuse deletion in certain cases, such as:

  • To exercise freedom of expression and information
  • To comply with a legal obligation
  • For reasons of public interest
  • For the establishment, exercise or defence of legal claims

If data has been disclosed to others, and erasure is required, we will take reasonable steps to inform recipients of your request.

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d) Right to Restriction of Processing (Article 18 GDPR)

You have the right to request the restriction of processing where one of the following applies:

  • You contest the accuracy of the data (for a period enabling us to verify it)
  • The processing is unlawful but you oppose erasure and request restriction instead
  • We no longer need the data but you require it for legal claims
  • You have objected to processing (pending verification of whether our legitimate grounds override yours)

If processing is restricted, we will only store your data, unless further processing is necessary for legal claims, protecting others' rights, or for reasons of important public interest.

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e) Right to Data Portability (Article 20 GDPR)

You have the right to receive your personal data that you have provided to us in a structured, commonly used, machine-readable format and to transmit that data to another controller, where:

  • Processing is based on your consent or on a contract, and
  • Processing is carried out by automated means

Where technically feasible, you have the right to request that we transfer your data directly to another controller.

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f) Right to Object (Article 21 GDPR)

You have the right to object at any time to processing of your personal data that is based on:

  • Our legitimate interests, or
  • The performance of a task carried out in the public interest

We will stop processing your data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise or defence of legal claims.

You also have the right to object at any time to the processing of your personal data for direct marketing purposes. If you object, we will immediately stop processing your data for those purposes.

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g) Automated Individual Decision-Making (Including Profiling) – Article 22 GDPR

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similar way.
This does not apply if:

  • It is necessary for a contract between you and us
  • It is authorised by EU or Member State law
  • It is based on your explicit consent

Replyer AI does not currently engage in automated decision-making or profiling that falls under this category.

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h) Right to Withdraw Consent (Article 7 GDPR)

If processing is based on your consent, you have the right to withdraw it at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

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i) Right to Lodge a Complaint (Article 77 GDPR)

If you believe your data is being processed unlawfully, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or the supervisory authority in your country of residence.

Dutch DPA website: https://autoriteitpersoonsgegevens.nl

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7. Data Security

We apply appropriate technical and organizational security measures to protect your data. However, no system is completely immune to risks. Users are responsible for keeping their own access credentials secure.

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8. Cookies and Tracking

We currently do not use cookies or tracking technologies that store personal data.

If this changes in the future, we will update this policy and request explicit consent from users where required.

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9. Consent

By submitting personal data via our website, you give explicit and informed consent for your data to be processed in accordance with this Privacy Policy.

You may withdraw consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

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10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect legal or operational changes. The “last updated” date at the top will always indicate the latest version.

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11. Contact

If you have any questions or concerns regarding this Privacy Policy, please contact:

Replyer AI
Email: support@replyer.io

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