Privacy Policy
This Privacy Policy explains how Causa Prima Inc. ("Causa Prima", "we", "us") processes personal data in connection with our corporate website at causaprima.ai (the "Website").
This policy covers the Website only. Personal data processed within the Causa Prima product/Service (accounts, content you upload, and processing on behalf of customers) is handled by Causa Prima Germany GmbH under the applicable Terms of Service and Data Processing Agreement, and is described in the Service's own privacy information. For our other products (Byll, Scribo) please see the privacy policies on those products' own websites.
1. Controller
Causa Prima Inc.
1111B S Governors Ave # 44267, Dover, DE 19904, USA
EIN (US Tax ID): 41-4651484
E-mail: security@causaprima.ai
We have not appointed a data protection officer; data-protection questions reach us at the e-mail address above.
2. Categories of personal data we process
Depending on how you interact with the Website, we may process:
- Contact and enquiry data — the name, business e-mail and any message you submit through a contact, information-request or sign-up form on the Website (collected via our forms provider — see §4).
- Communication data — e-mails and other correspondence you send us, and our replies.
- Website-visit data — pages viewed, referrers, approximate location (country/city derived from IP), device/browser metadata, cookies and similar identifiers (see §8).
We do not intentionally process special categories of personal data (Art. 9 GDPR) through the Website. Providing your details in a Website form is voluntary — without them we cannot respond to your enquiry. Analytics and marketing data are not required and you can decline non-essential cookies via the cookie banner.
3. Purposes and legal bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Operating, securing and analysing the Website (hosting, request logs) | Art. 6(1)(f) — legitimate interests in running a secure website |
| Handling contact / information-request form enquiries and replying to you | Art. 6(1)(b) — pre-contractual steps; or Art. 6(1)(f) — legitimate interest in responding |
| Direct B2B marketing to business contacts who requested information | Art. 6(1)(f); §7 UWG where applicable |
| Use of cookies and similar technologies on causaprima.ai | §25 TDDDG and Art. 6(1)(a) where consent is required; see the Cookie consent page |
4. Recipients
We share personal data with the following categories of recipients:
- Website service providers (causaprima.ai) — for our public website we use: Tally (Tally BV, Belgium) for contact and sign-up forms; PostHog (EU) for website analytics (where you submit a form, your e-mail may be associated with your analytics profile); Usercentrics / Cookiebot (Denmark) for cookie-consent management; Google (Google Tag Manager and, subject to your consent, Google Analytics, Google Ads and the LinkedIn Insight Tag); and Vercel (Vercel Inc., USA) for website hosting.
- Tax and statutory authorities — where we are legally required to disclose.
- Professional advisers — lawyers, auditors, accountants, where necessary and under confidentiality obligations.
- Acquirers — in connection with a merger, reorganisation or sale of all or substantially all of our assets.
We do not sell personal data and do not disclose personal data to advertising networks for cross-site targeting beyond the consent-based tags described on the Cookie consent page.
5. Transfers outside the EEA
Some recipients are established outside the European Economic Area (EEA), in particular in the United States (e.g. Google, LinkedIn, Vercel). For each such transfer we rely, in order of preference, on:
(a) an adequacy decision of the European Commission, where available;
(b) the EU–US Data Privacy Framework, where the recipient is certified;
(c) the EU Standard Contractual Clauses 2021/914 in the appropriate module, supplemented by a transfer impact assessment.
6. Retention
We retain personal data only as long as necessary for the purposes set out in §3, and in any event:
- Website contact / enquiry data — until your enquiry is resolved, then up to 12 months unless it leads to a contract.
- Website analytics data — typically up to 14 months.
- Server and security logs — typically 12 months; longer where required to investigate a specific incident.
- Support correspondence — typically 24 months after closure of the matter.
7. Your rights
Under the GDPR you have the rights to:
- access your personal data (Art. 15);
- rectification (Art. 16);
- erasure / "right to be forgotten" (Art. 17);
- restriction of processing (Art. 18);
- data portability (Art. 20);
- object to processing based on legitimate interests (Art. 21);
- withdraw consent at any time, where processing is based on consent (Art. 7(3)) — withdrawal does not affect the lawfulness of processing before withdrawal.
To exercise these rights, contact us at security@causaprima.ai. We will respond without undue delay and in any event within one month.
You also have the right to lodge a complaint with a data-protection supervisory authority, including the authority in the EU member state of your habitual residence or place of work.
8. Cookies and similar technologies
Cookies and similar technologies on causaprima.ai are governed by our Cookie consent page, accessible via the cookie banner on each visit. Strictly necessary cookies (e.g. session, security, load-balancing) are set on the basis of §25(2) TDDDG; all others are set only with your prior consent under §25(1) TDDDG.
9. Changes to this Policy
We may update this Privacy Policy from time to time. The current version is indicated by the "Last updated" date at the top. Material changes will be communicated through the Website where appropriate.