Privacy policy

Article 1. Purpose and scopeCopy Anchor Link

1.1. Purpose. This privacy policy (the "Policy") informs data subjects, in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (the "GDPR"), of the processing of personal data carried out by iAdvize as part of the AI Shopping Assistant v3 pilot (the "Service"), a free evaluation phase governed by the terms of use.

1.2. Processing for which iAdvize is responsible. The Policy covers the processing for which iAdvize determines the purposes and means, and for which it is the controller within the meaning of Article 4(7) GDPR. It concerns:

• people who visit the iAdvize website (the "Visitors");
• people who use a v3 test account, namely the dashboard, the playground, the REST API and the MCP server, on behalf of the company that employs them (the "Users").

This processing relates to visits, accounts, sign-in, security, the change log, product emails and feedback sent from the dashboard.

1.3. Processing carried out on behalf of the company. Operations a User performs on the data of the company that employs them, such as tests in the playground or the pages of its site, are carried out on behalf of that company, which is the controller. iAdvize acts as a processor within the meaning of Article 4(8) GDPR. This processing is described in Article 5, for information.

1.4. Excluded processing. The Policy does not apply to conversations between a shopper and an assistant on a merchant's site. The merchant determines the purposes and means of that processing and is its controller; iAdvize acts as a processor, on the merchant's instructions. Information for the shopper is primarily a matter for the merchant's own privacy policy; the processing carried out by iAdvize is described in the data-use notice for shoppers. The same applies to conversations held on a hosted assistant page that iAdvize serves on behalf of a merchant.

Article 2. Controller and data protection officerCopy Anchor Link

2.1. The controller is iAdvize SAS, a French simplified joint-stock company (société par actions simplifiée) whose registered office is at Euronantes Gare, Le Berlingot bât. B, 9 rue Nina Simone, 44000 Nantes, France. Its full details appear in the legal notice.

2.2. Any question about the processing of personal data, including the exercise of the rights in Article 11, may be sent to the iAdvize data protection officer, appointed in accordance with Article 37 GDPR, at privacy@iadvize.com or by post to the registered office.

Article 3. Processing relating to VisitorsCopy Anchor Link

3.1. No advertising and no profiling. iAdvize runs no advertising script, sets no advertising cookie and does not profile Visitors.

3.2. Technical request data. iAdvize's servers and infrastructure providers process technical request data (requested address, browser characteristics, IP address) to serve the page and protect the Service against abuse. This processing is based on iAdvize's legitimate interest in operating a website that works and is protected against misuse (Article 6(1)(f) GDPR).

3.3. Audience and performance measurement. iAdvize's hosting provider measures the audience and performance of every page of the website and the dashboard, except the notice for shoppers. It counts visits and records how quickly the page loads and responds on the Visitor's device. This measurement is served from iAdvize's own domain and sets no cookie. Before anything leaves the browser, the part of the page address after ? or # is removed. Visits are told apart by a value computed from the request, which the hosting provider deletes after twenty-four (24) hours; no identifier is kept beyond that and no profile is built.

3.4. Objecting to measurement. The Visitor may object to measurement from the menu of the assistant panel on the documentation and changelog pages. Neither of the two measurements is then sent from that browser, on any iAdvize page. The objection is recorded only in that browser: it does not extend to other devices and stops having effect if the site data is cleared. The assistant script still reports that it has loaded to iAdvize's servers, with the browser's user-agent string, which is written to the technical logs.

3.5. Assistant on the documentation and changelog pages. The documentation and changelog pages carry the assistant iAdvize sells, so that iAdvize uses it itself. It is an AI system whose answers, generated by a model, may be wrong, which it tells the Visitor as soon as it opens. On these pages, the assistant works under the same conditions as on a customer's site, and iAdvize is the controller.

3.6. Data processed during a visit.

3.7. Retention and control. The session key is erased from the browser when the tab is closed. The measurement it produces is kept for 24 months, and the conversation for 12 months after its last message. The Visitor may delete their conversation from the assistant panel and object to measurement from that panel's menu, in the same way as a shopper on a customer's site, as described in the notice for shoppers. That notice is written for a customer's site: where it names the store as controller, on its own pages iAdvize is the controller.

3.8. Conversation labeling. After the conversation, a model reads it to label it: type of request, whether it was answered, accuracy of the answers, signals and objections expressed (for example purchase intent or hesitation over price). This labeling involves no individual score, no linking of conversations and no targeting. Labels are stored with the conversation and deleted with it.

3.9. Page-view counting. As on a customer's site, views of each page are counted per day, without any identifier, and kept for 90 days.

Article 4. Processing relating to UsersCopy Anchor Link

4.1. Source of the data. The User has an account because the company that employs them takes part in the Service pilot. Where they were invited by a colleague, their email address was given to iAdvize by that colleague (Article 14 GDPR); iAdvize passes it to its identity provider, which sends the invitation. The audience and performance measurement described in Article 3.3 also applies to the dashboard pages.

4.2. Legal basis. The processing below is based on the legitimate interest of iAdvize and of the User's employer in providing the Service the employer has subscribed to, to the people the employer gives access to (Article 6(1)(f) GDPR). As the User is not a party to the contract between iAdvize and their employer, that contract is not the legal basis for processing their data.

The change log is also made available to the organization, on its behalf, under Article 5.5. Messages typed in the playground are processed on behalf of the employer, under Article 5.1.

The User is asked not to include personal data in their feedback, in particular data taken from shopper conversations.

4.3. Mandatory data. Providing an email address is necessary to create an account; without it, the account cannot be created. The other data result from using the Service.

4.4. Support access. At the User's request, or to investigate a security incident, an authorized iAdvize administrator may sign in to the dashboard in place of the User's account, through the identity provider. Each session is limited to sixty (60) minutes and logged by the identity provider, with the administrator's identity and the stated reason.

4.5. No automated decision-making. iAdvize takes no decision based solely on automated processing that produces legal effects concerning the User or similarly significantly affects them, within the meaning of Article 22 GDPR.

Article 5. Processing carried out on behalf of the companyCopy Anchor Link

The processing described in this Article is carried out by iAdvize as processor, on the instructions of the company that is the controller and in accordance with the applicable processing terms (DPA). It is described for information.

5.1. Playground messages. Messages are sent, through the hosting provider's gateway, to a model provider that processes them in the European Union; the gateway may however process the request in transit in a region outside the European Union. iAdvize configures every call to an AI model so that the provider keeps none of its content and does not use it to train its models, except for requests flagged by its abuse-detection systems, which may be retained outside the European Union, as set out on the sub-processors page. Where the agent being tested has web search or page fetching enabled, a query derived from the conversation, or the address of the page to fetch, is sent to iAdvize's search provider. Where the agent allows dictation, the voice is transcribed by the browser, under its vendor's terms and not iAdvize's. Where the organization has connected its own tools to the agent, the data sent to those tools falls under the agreements between the organization and their vendors.

5.2. Labeling of playground conversations. After each conversation, a model reads it to label it: type of request, whether the need was met, accuracy of the answers and their compliance with the agent's instructions, signals and objections raised, missing information. Labels are stored with the conversation and deleted with it.

5.3. Pages of the company's site. iAdvize keeps, in the company's page list, the addresses of pages found by importing the sitemap, added manually or visited by shoppers. A page is fetched at the company's request, or automatically once it reaches the view threshold set in the site's automation settings. If the site refuses iAdvize's reader, the fetch is handed to the search provider, which receives only the page's public address. Automatic reading is on by default and can be turned off in those settings.

From a page that has been read, iAdvize keeps an excerpt of the text, the title, the language and the content structured into sections, product attributes and questions and answers, as well as a limited number of shopper reviews published on the page, without their authors' names. The assistant uses this content to answer shoppers. A model provider uses it to write starter questions, at the company's request or automatically if the company has enabled it, under the conditions that apply to every model call. The questions are saved to the company's library and stay disabled until the company enables them.

iAdvize also keeps a record of each read and each generation: the page path (without the part after ?), the result and internal usage figures. A review may mention a person even without its author's name; the company may ask for any stored page containing personal data to be deleted.

5.4. Page views on the store. Views are counted per page and per day, from the page address (without the part after ?). No shopper identifier is attached to this count: no cookie, no session or visitor identifier, no IP address. The counts are used to show the most-viewed pages and to choose which pages to read. A shopper who has objected to measurement is not counted. The company may turn counting off in its site's automation settings. This counting is carried out on behalf of the merchant, as controller, with iAdvize acting as processor.

5.5. Change log. The log referred to in Article 4.2 is made available to the organization so that it can see who made each change to its configuration. For that purpose, iAdvize keeps it on behalf of the organization, which is the controller.

Article 6. Cookies and other trackersCopy Anchor Link

6.1. Principle. Every cookie iAdvize sets on its website and dashboard exists only to make a feature work. None is used for advertising or profiling, or shared with third parties.

6.2. Cookies.

6.3. Browser local storage.

6.4. Exemption from consent. None of these trackers requires the prior consent provided for in Article 82 of French law no. 78-17 of 6 January 1978. No banner is therefore displayed. In line with the CNIL guidelines, the following are exempt: trackers used for authentication and account security, trackers strictly necessary to provide a service expressly requested, such as the conversation with the assistant, trackers that store the objection choice, and trackers that personalize the interface where that personalization is an expected part of the service: language and time zone, theme, profile photo, last site viewed, state of the navigation and reports. The User may nevertheless block these trackers in their browser settings; the dashboard will then no longer be able to keep them signed in.

Article 7. RecipientsCopy Anchor Link

7.1. iAdvize relies on a small number of service providers to operate the Service. Each is named, with its role and location, on the sub-processors page.

7.2. Each provider, the search provider included, is bound by processing terms that meet the requirements of Article 28 GDPR. The search provider performs a search or fetches a page during a conversation only for agents on which that feature has been enabled, and it is disabled by default. It also fetches, for all sites, any page that refuses iAdvize's reader; only the page's public address is then sent to it.

7.3. Data is neither sold nor disclosed to anyone for their own purposes.

Article 8. Data location and transfers outside the European Economic AreaCopy Anchor Link

8.1. Main location. iAdvize's database, file storage and job queue are hosted in the European Union, in Frankfurt.

8.2. Processing located outside that region.

• Sign-in identity, name, profile photo, language and time zone, sessions, multi-factor settings and, for the organizations concerned, a copy of the configuration change log are held by the identity provider, in the United States.
• Contact email address, email preferences, service emails and their delivery records are held by the email provider, in the United States.
• Messages typed in the playground are processed by a model provider in the European Union, after passing through the hosting provider's gateway, which may process them in a region outside the European Union; requests flagged by a model provider's abuse-detection systems may be retained outside the European Union.
• Search queries and page addresses sent to the search provider are processed, under that provider's data processing agreement, in the European Union by default.
• During the site analysis at onboarding, the site's name and address and the queries derived from them are processed in the United States by a web search provider called through the hosting provider's gateway.
• Uploaded images, including the User's profile photo, are stored in Frankfurt but served by the hosting provider's global content delivery network and cached at its points of presence.
• On every request, session handling is performed by the hosting provider's routing layer in its region closest to the user; its control plane and backups are also global.
• Audience and performance measurement is processed by the hosting provider outside the region iAdvize pins; as no storage region is published for it, it may be processed in the United States.

The sub-processors page details these items provider by provider.

8.3. Safeguards. Transfers outside the European Economic Area are covered:

• for the hosting provider and the email provider, by the adequacy decision on the EU-US Data Privacy Framework and by the European Commission's standard contractual clauses;
• for the identity provider, by the standard contractual clauses.

Model calls and the web searches made during site analysis go through the hosting provider, with its credentials: the providers concerned act as sub-processors of the hosting provider, under its data processing agreement. The search provider's default processing region is the European Union, and it relies on the standard contractual clauses for its own providers outside the European Economic Area. A copy of these clauses can be obtained on request from privacy@iadvize.com (Article 13(1)(f) GDPR).

Article 9. Retention periodsCopy Anchor Link

9.1. Applicable periods.

9.2. End of an account or organization. The User may leave an organization from the dashboard, unless they are its last member or last administrator. During the pilot, an account or organization is otherwise closed on request sent to privacy@iadvize.com, handled within one month.

At the end of the pilot or when an account is closed, access to the dashboard, the playground and the MCP server is withdrawn. In accordance with Article 10.4 of the terms of use, the organization may still retrieve its conversations through the REST API for three (3) months. At the end of that period, iAdvize deletes the personal data held for the account within thirty (30) days, unless the law requires it to be kept or it is needed to establish, exercise or defend legal claims. Deleted data may remain for up to thirty-five (35) additional days in the database backups, until they are overwritten.

9.3. Proof of acceptance of the terms of use. As an exception, iAdvize keeps, for five (5) years from the closure of the organization, the record of which version of the terms of use the organization accepted, when, and the account identifier of the person who accepted them, as proof of the agreement.

Article 10. SecurityCopy Anchor Link

In accordance with Article 32 GDPR, all traffic to iAdvize's website, dashboard and APIs is encrypted in transit. Each organization's data is kept separate from every other organization's on every request. Changes to an organization's configuration are logged, and every User can protect their account with a second authentication factor.

Article 11. Rights of data subjectsCopy Anchor Link

11.1. Rights. Every data subject has the right of access, rectification, erasure, restriction of processing and, where the law provides for it, portability of their data (Articles 15 to 20 GDPR), as well as the right to set instructions on the retention, erasure and disclosure of their data after their death (Article 85 of French law no. 78-17 of 6 January 1978). Where processing is based on consent, it can be withdrawn at any time; for product emails, it can be withdrawn from any message received, without any further step. Some operations can be carried out directly by the person: changing their name, removing their profile photo, leaving an organization, deleting their conversation with the assistant on the documentation and changelog pages.

11.2. Right to object. Every data subject may object at any time, on grounds relating to their particular situation, to any processing based on iAdvize's legitimate interest (Article 21 GDPR). iAdvize then stops the processing, unless it has compelling legitimate grounds that override the person's interests, rights and freedoms, or the data is needed to establish, exercise or defend legal claims.

11.3. How to exercise these rights. Requests are sent to privacy@iadvize.com. Before acting on a request, iAdvize may ask for it to be confirmed from the email address of the account, to verify the requester's identity. iAdvize replies within one month. That period may be extended by up to two months, given the complexity or number of requests; the person is then informed within the initial one-month period (Article 12(3) GDPR).

11.4. Requests that concern the employer. Where a request concerns the employer's account rather than the requester's own data, iAdvize tells the requester so and refers the request to the employer.

11.5. Complaint. Anyone who considers that the processing of their data breaches the applicable rules may lodge a complaint with the French data protection authority (CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, cnil.fr), or with the supervisory authority of their habitual residence or place of work (Article 77 GDPR).

Article 12. Changes to the PolicyCopy Anchor Link

Any change to the Policy updates the version date at the top of it. Any change that significantly affects the processing carried out is communicated directly to the people concerned.