Data Privacy Policy

1. Demo request and demo access (Information pursuant to Art. 13 GDPR)

1.1 Categories of personal data

When you request demo access, we process the following personal data:

• Name

• Business E-Mail address

• Date and time of registration

1.2 Purposes of processing

We process your data for the following purposes:

• to process your demo request and provide access to the demo environment.

• to communicate with you regarding the demo (e.g., questions, support).

• to contact you in relation to the demo (sales contact: Jakob Mucke, j.mucke@reply.de).

1.3 Legal basis

• Art. 6(1)(b) GDPR (processing necessary to take steps at your request prior to entering a contract / to provide the requested demo access).

• Where applicable and limited to the context of your request: Art. 6(1)(f) GDPR (legitimate interest in responding to enquiries and business communication).

1.4 Recipients and categories of recipients

Your data is accessible only to authorized personnel who need it to process your demo request.

Where we use technical service providers for hosting/operations (e.g., cloud infrastructure), these providers act as processors and are contractually bound under Art. 28 GDPR.

1.5 International data transfers

If personal data is transferred to countries outside the EEA, this will only take place in accordance with the requirements of Chapter V GDPR (e.g., adequacy decision or appropriate safeguards such as Standard Contractual Clauses), where applicable.

1.6 Retention and deletion

We apply a deletion concept based on the principle of storage limitation (Art. 5(1)(e) GDPR):

• Demo access period: We grant demo access for three months. The demo account is automatically deactivated after that period, or after thirty days of inactivity.

• Support retention: After deactivation/expiry, we retain your demo user data and the content created in the demo environment for six months to handle follow-up post-trial support/clarification.

• Deletion / anonymization: After the retention period, we delete or anonymize the data unless statutory retention obligations or other legal requirements justify longer storage.

• If no customer relationship is established, we will delete or anonymize demo lead/contact data as soon as it is no longer necessary for the purposes stated and in accordance with the principle of storage limitation (Art. 5(1)(e) GDPR). The retention period is determined based on necessity and will be communicated or made available as part of our information duties (Art. 13(2)(a) GDPR). You may request erasure at any time; where the legal requirements are met, we will erase the data without undue delay (Art. 17 GDPR). Where processing is based on legitimate interests, you may also object (Art. 21 GDPR). Any longer retention applies only where required by law or for the establishment, exercise or defense of legal claims (Art. 17(3) GDPR).

1.7 Requirement to provide data

Providing your name and business email address is necessary to process your demo request and provide demo access. If you do not provide this data, we cannot provide demo access.

1.8 No newsletter / no marketing opt-in

Submitting the demo form does not subscribe to a newsletter. We do not send marketing emails based on the demo form without a separate, explicit opt-in.

2. Joint Controllers (Art. 26 GDPR) and Data Protection Officers

2.1 Joint Controllers

The processing activities described in section 1 may be carried out under joint controllership within the Reply S.p.A. in accordance with Art. 26 GDPR.

As joint controllers, we have determined in an arrangement how the respective responsibilities for compliance with data protection obligations are allocated, in particular regarding the provision of information and the handling of data subject rights.

2.2 Data Protection Officer (DPO) contact details

• DPO UK: dpo.uk@reply.com

• DPO Italy: dpo.it@reply.it

• DPO Germany: dpo.de@reply.de

3. Data subject rights (Chapter III GDPR) and contact points

3.1 Your rights

Subject to the legal requirements, you have the following rights:

• Right of access (Art. 15 GDPR)

• Right to rectification (Art. 16 GDPR)

• Right to erasure (Art. 17 GDPR)

• Right to restriction of processing (Art. 18 GDPR)

• Right to data portability (Art. 20 GDPR)

• Right to object (Art. 21 GDPR)

• Right to withdraw consent at any time where processing is based on consent (Art. 7(3) GDPR)

3.2 How to exercise your rights (contact details)

You may request erasure of your personal data at any time by contacting us via E-mail at info@parhelia.ai. We will respond without undue delay and in any event within one month of receipt of your request; where necessary, this period may be extended by two further months, in which case we will inform you within one month and provide reasons. We will confirm the action taken at your request.

• ITALY: privacy@reply.com or Reply S.p.A., Corso Francia 110, Turin

• UK: privacy@reply.com or Reply Ltd, 38 Grosvenor Gardens, London SW1W 0EB

• GERMANY: DSB@reply.de or Reply AG, Bartholomäusweg 26, D-33334 Gütersloh

• POLAND: privacy@reply.com or Hermes Reply Polska Sp. z o.o., Ul. Gliwicka 6/2, 44-079 Katowice

3.3 Right to lodge a complaint

You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement (Art. 77 GDPR).