1. Introduction

Technovate N.V. (“Technovate”, “we”, “us” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with our websites, products, and services. We primarily operate in Suriname and the Caribbean, with occasional clients in the US and EU. We comply with applicable data protection laws in Suriname and align with international standards such as the EU General Data Protection Regulation (GDPR)[1] to ensure your personal data is handled responsibly. By using our services, you agree to the collection and use of information as described in this policy. If you do not agree, please discontinue use of our services.

2. Personal Data We Collect

We may collect various types of personal data from you in the course of operating our business:

• Information You Provide: When you create an account, sign up for services, or contact us, we collect information such as your name, email address, telephone number, billing address, shipping address (for any hardware deliveries), company name (if applicable), and any other details you provide.
• Account and Authentication Data: Login credentials (such as username and password) and security information (like security questions or multi-factor authentication tokens) for accessing our hosting or other services.
• Service Usage Data: When you use our websites or services, we automatically collect technical data including your IP address, browser type, device identifiers, pages viewed, actions taken on our site, and the dates/times of access. For example, we may log how you interact with our AI agents or AR/VR applications for service improvement.
• Cookies and Tracking Technologies: We use cookies and similar technologies to enhance user experience and analyze usage of our websites. This includes third-party cookies from services like Google Analytics and the Facebook Pixel, which may track your interactions with our site and ads (see our Cookie Policy below for details).
• Payment Information: If you purchase a service, we (or our payment processors) collect payment details necessary to process transactions (e.g. credit card number, payment account details). We do not store full credit card numbers on our servers; payments are handled securely via compliant third-party processors.
• Communications: Records of our correspondence with you, including support inquiries, feedback, or customer service communications (which may include email addresses and any information you choose to share).

We do not intentionally collect any sensitive personal data (such as government-issued IDs, health information, or biometric data) unless it is necessary for a specific service and you have explicitly provided it or consented (for example, if an AR solution involves health or ergonomic data, we will inform you separately). We also do not target or knowingly collect personal data from children under 16 without parental consent, and our services are generally intended for business use by adults.

3. How We Use Your Personal Data

We use the personal data collected for the following purposes:

• To Provide and Maintain Services: We process your data to set up and administer your account, provide the digital services you requested (such as hosting your website, deploying AI agents, designing a solution, or shipping hardware/software bundles), and ensure those services function as intended. For instance, our systems use your login data to authenticate you and your contact data to communicate about your account.
• Service Improvements and Development: Usage data and analytics help us understand how our services are used, enabling us to troubleshoot issues, monitor performance, and improve features. For example, we may analyze how users interact with Augmentify (our AR/VR platform) or RxAgent (our AI agents) to refine their reliability and user experience.
• Communication and Support: We use contact information (email, phone) to send service- related announcements (e.g. service updates, security alerts, maintenance notifications), respond to your inquiries or support tickets, and provide customer care. We may also send administrative emails about your account status, invoices, or changes to policies.
• Marketing and Updates: With your consent where required, we may send newsletters or promotional communications about new features, services, or events that Technovate offers. You can opt out of marketing emails at any time by using the unsubscribe link or contacting us. We do not sell your personal data to third-party marketers.
• Analytics and Advertising: We use analytics tools (like Google Analytics) to collect information about your use of our website, which helps us understand website traffic and improve our content. We also use the Facebook Pixel and similar technologies to deliver tailored advertisements about our services on third-party platforms (such as showing Technovate ads on Facebook or Instagram to people who have visited our site). These tools may enable third parties (including Facebook/Meta) to collect information about your online activities over time and across different websites, for the purpose of measuring ad effectiveness and providing targeted ads. (See Cookie Policy below on how we use cookies and how you can control advertising preferences.)
• Legal and Security: We may process personal data as necessary to comply with legal obligations (e.g. accounting records, responding to lawful requests by authorities) and to enforce our agreements or policies. We also process data to detect, prevent, and address fraud, abuse, security risks, and technical issues. For example, IP addresses may be used to monitor for suspicious login attempts, and we may use your information to verify identity if we suspect fraudulent activity.

We will only use your personal data for the purposes above or for compatible purposes. If we need to use your data for a new purpose that is not compatible with the original reason it was collected, we will seek your consent or provide you with an appropriate legal notice.

4. Legal Bases for Processing (GDPR Purposes)

For individuals in the European Economic Area (EEA) or other jurisdictions that require a legal basis for processing personal data, Technovate processes your information under the following legal bases:

• Performance of a Contract: Many data processing activities are performed to provide our services as agreed with you. For example, when you sign up for web hosting or an AI agent service, we need to use your data to create and manage your account, deliver the service, and bill you. This is necessary for the performance of the contract between you and Technovate.
• Legitimate Interests: We process certain data as needed for our legitimate business interests, in a way that is proportionate and respects your privacy. For instance, we have a legitimate interest in understanding how our customers use our products (analytics)[2], improving functionality, securing our services, and marketing to existing customers. We will always consider your rights and objections in relation to such processing.
• Consent: Where required by law (for example, before setting non-essential cookies or sending marketing communications in certain jurisdictions), we will rely on your consent. You have the right to withdraw consent at any time, which will not affect the lawfulness of processing already carried out.
• Legal Obligation: In some cases, we have a legal obligation to process personal data, such as retaining transaction records for tax/regulatory purposes or responding to official legal requests.

5. Disclosure of Your Information

We treat your personal information confidentially and do not share it with third parties except in the following circumstances:

• Within Technovate NV: Access to personal data is restricted to authorized personnel and departments on a need-to-know basis (for example, the support team can view contact details to assist you, but they cannot view your payment information which is handled by the billing department).
• Service Providers: We may share data with trusted third-party vendors who perform services on our behalf, such as payment processors, cloud infrastructure providers, email service platforms, or analytics and advertising partners (e.g. Google Analytics, Meta for Facebook Pixel). These providers are contractually bound to process your data only for our purposes and to protect it in accordance with this policy and applicable law. For example, we might use a third-party data center for web hosting; that provider could have access to the server where your data resides, but only to the extent needed to keep the service running.
• Business Transfers: If Technovate is involved in a merger, acquisition, restructuring, or asset sale, your personal data may be transferred to the successor or acquiring entity. In such cases, we will ensure the confidentiality of personal data is maintained and give affected users notice before personal data becomes subject to a different privacy policy.
• Legal Requirements and Protection: We may disclose your personal data if required to do so by law or in the good-faith belief that such action is necessary to (a) comply with a legal obligation, court order, or regulatory request; (b) enforce our Terms & Conditions or other agreements; (c) investigate or defend against third-party claims or allegations; (d) prevent or halt illegal, fraudulent, or unethical activity (such as a cyber-attack or misuse of our services); or (e) protect the rights, property, and safety of Technovate, our users, or the public. This includes exchanging information with law enforcement or other companies and organizations for fraud protection and credit risk reduction, as permitted by law.

We do not sell or rent your personal information to third-party data brokers or marketing companies. Any sharing of data is solely for the purposes outlined above.

6. International Data Transfers

By using our services, you acknowledge that your personal data may be transferred to and processed in Suriname or other jurisdictions outside of your home country. Technovate is based in the Republic of Suriname, which as of now does not have an enacted comprehensive data protection law[3]. We take steps to ensure that your data is afforded protection consistent with this Privacy Policy wherever it is processed. If you are located in the EEA or another region with data transfer restrictions, we will implement appropriate safeguards for transfers of personal data out of your region. These may include:

• Contractual Clauses: We may incorporate standard contractual data protection clauses (Standard Contractual Clauses, SCCs) approved by the European Commission into agreements with our service providers or partners when personal data from the EEA is processed in a country not deemed “adequate” by the EU. This obligates recipients of the data to protect it according to EU standards.
• Consent and Necessity: In some cases, we rely on your consent to transfer data or the necessity for the performance of our contract with you. For example, if you are an EU customer who requests services that we provide exclusively from Suriname, the transfer of your data is necessary to fulfill that contract.
• Adequacy and Other Mechanisms: If in the future Suriname or any country we operate in is recognized as providing adequate data protection by relevant authorities, we will rely on that decision. Otherwise, we continue to monitor legal developments and will adapt our practices to remain compliant with cross-border data protection requirements.

You have the right to request more information about our international data transfer safeguards by contacting us at [email protected].

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Retention periods will vary depending on the type of data and the context in which it was collected:

• Account Information: Your account data and profile information are kept as long as you maintain an account with us. If you terminate your relationship with Technovate, we will delete or anonymize your personal data within a reasonable time after closure of your account, except for data we are required or permitted to retain by law (for example, records of transactions for tax or audit purposes may be kept for a number of years as required by Surinamese commercial law).
• Communications: If you contact us via email or support tickets, we may retain those communications (and any attached information) for a period necessary to address your inquiry, provide support, and for training or quality assurance. Typically, routine support records are purged periodically unless they form part of our business records.
• Analytics Data: Data collected via Google Analytics, Facebook Pixel, and similar tools may be retained as governed by those services’ default retention settings or our configuration. We generally review aggregated analytics data over time, but personal identifiers in analytics are either not stored by us or are removed/obscured (for instance, we might keep aggregated traffic volumes but not raw IP addresses after a short period).
• Backup Copies: Due to the nature of our digital backup and recovery services, copies of your data might be stored in encrypted backups. If we delete data from our live systems, it may still persist in secure backups for some additional time until those backups cycle out. We maintain strict access controls on any backup data.
• Legal Holds: In the event of a legal dispute or investigation, we may retain specific information for longer if we are under a duty to preserve evidence.

When data is no longer needed for its intended purpose or required retention period, we ensure it is securely deleted or anonymized so that it no longer can be associated with you.

8. Your Rights and Choices

We respect your rights to your personal data. Depending on your jurisdiction (for example, if you are an EU/EEA resident under GDPR or a resident of a country with similar laws), you may have some or all of the following rights:

• Access and Portability: You have the right to request a copy of the personal data we hold about you, and to obtain it in a commonly used, machine-readable format. This helps you to verify the information and potentially transfer it to another service.
• Rectification: If any of your personal data is inaccurate or incomplete, you have the right to request that we correct or update it. You can also update basic account information by logging into your account settings.
• Erasure: You can request that we delete your personal data if it is no longer necessary for the purposes for which it was collected, or if you have withdrawn consent (where applicable) or objected to processing and we have no overriding legitimate grounds to continue. We will honor valid deletion requests and also instruct our processors to delete data, subject to any legal obligations to retain information.
• Restriction of Processing: You have the right to ask us to suspend the processing of your personal data if you contest its accuracy, prefer to restrict its use rather than have us erase it, or if you need us to preserve it for legal claims.
• Objection to Processing: You may object to our processing of your data when we rely on legitimate interests, including any profiling based on those interests. We will evaluate your objection and cease processing unless we have compelling legitimate grounds that override your rights or the processing is needed for legal reasons. Where your personal data is used for direct marketing purposes, you have an absolute right to object at any time.
• Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. For example, you can opt out of marketing emails by clicking the unsubscribed link or contacting us. Withdrawing consent will not affect the lawfulness of processing before the withdrawal.
• Lodge a Complaint: If you believe we have infringed your privacy rights, you have the right to complain to a supervisory authority. For EU residents, this would typically be your country’s data protection authority. For Suriname, you may contact any relevant data protection oversight body once established (Suriname’s Privacy and Personal Data Protection Bill provides for a Data Protection Commissioner[4][5], though at present the law is still pending). We would appreciate the chance to address your concerns directly before you approach a regulator, so we encourage you to contact us first.

To exercise any of these rights, please contact us at [email protected] with a clear description of your request. We may need to verify your identity before fulfilling certain requests (to protect your data from unauthorized access). We will respond to your request within a reasonable timeframe and in accordance with applicable law (GDPR requires us to do so within one month for most requests). Please note, some rights may not be absolute and may be subject to exceptions; for example, we might refuse a request for erasure if retaining the information is necessary to comply with a legal obligation.

9. Security of Your Data

We take the security of your personal data seriously. Technovate employs a range of technical and organizational measures to safeguard information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: Sensitive data (such as passwords and any confidential personal details) is stored encrypted at rest. Communications between your browser and our websites are protected by HTTPS encryption. For any payment transactions, we use secure encryption and comply with PCI-DSS standards via our payment processors.
• Access Controls: Personal data is accessible only by authorized staff who require access to perform their duties. We enforce role-based access control and use strong authentication methods for our internal systems. Administrative access to servers is logged and restricted.
• Monitoring and Testing: Our IT team monitors systems for possible vulnerabilities and attacks. We regularly update our software and infrastructure and conduct security testing or audits where appropriate. We also maintain intrusion detection systems and firewalls to protect our network.
• Employee Training and Policies: All Technovate employees and contractors are bound by confidentiality obligations. They receive training on data protection best practices and are required to follow our internal security policies, including proper data handling and incident response procedures.
• Data Minimization: We limit the personal data we collect and store to what is necessary for the purposes outlined. By reducing the volume and sensitivity of stored data, we reduce the impact of any potential incident.

Despite our efforts, no security measure is foolproof. The transmission of information via the internet is not completely secure, so we cannot guarantee absolute security of data sent to our site. However, we strive to use commercially acceptable means to protect your personal data. In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant authorities as required by law.

10. Cookies and Tracking Technologies

For details about how we use cookies and similar technologies, please see our Cookie Policy in Section 5 of this document. In summary, we use cookies to enhance site functionality (e.g., keeping you logged in), to analyze site usage via tools like Google Analytics, and to support advertising/retargeting via Facebook Pixel and similar technologies. You have choices in managing cookies, such as adjusting your browser settings or using opt-out tools. Our Cookie Policy provides more information on these choices and on the specific cookies in use.

11. Third-Party Websites and Services

Our website and services may contain links to third-party websites or integrate third-party services (for example, social media sharing buttons, or APIs for payment processing). This Privacy Policy does not apply to information collected by those third-party websites or services, which have their own privacy policies. We encourage you to review the privacy policies of any third-party sites or services before providing your personal data to them. Technovate is not responsible for the content or privacy practices of external sites. However, if you have concerns about a third-party integration on our site, we welcome you to contact us so we can address it or provide more information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to evolving legal, technical, or business developments. When we update it, we will revise the "Last Updated" date at the top of the policy. If changes are significant, we may provide a more prominent notice (such as by email notification or a banner on our website) to obtain your consent if required by law. We encourage you to review this page periodically for the latest information on our privacy practices. Your continued use of our services after any changes to this Privacy Policy constitutes acceptance of those changes.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how Technovate handles your personal data, please contact us:

• By Email: [email protected]
• By Mail: Technovate N.V. – Privacy Office, [Address], Paramaribo, Suriname (please insert the appropriate mailing address)

For general inquiries unrelated to privacy, you can reach us at [email protected]. We are committed to resolving any issues or questions you may have and to protecting your privacy.