Markin AI, S.L. and its group affiliates ("Markin", "we" or "us") respect your privacy and are committed to securing and protecting any information we have about you. This policy (the "Privacy Policy") explains the collection, use, sharing and processing of personal data in connection with your use of Markin's website at markin.ai (the "Site"), the Markin platform, APIs, features and plug-ins ("Services") and any other digital service that links to this Privacy Policy. It also covers our interactions with you at meetings, events and other offline sales and marketing activities. For information on cookies and similar technologies used on the Site, see our Cookie Policy.
The terms "personal information" or "personal data" mean any information that relates to an identified or identifiable individual, such as name, business email, role, IP address or any information gathered through your interactions with us.
1. Scope of this Privacy Policy
This Privacy Policy applies when Markin is the data controller for personal data of:
- visitors and users of the Site and Services;
- attendees of Markin events, webinars and surveys;
- customers, prospective customers and their representatives;
- subscribers to Markin newsletters and updates; and
- suppliers, service providers, business partners and their representatives.
This Privacy Policy does not apply to input submitted to, output generated by, or data uploaded to the Services ("Subscriber Content"). We process Subscriber Content as a data processor on behalf of our enterprise customers (the controllers), governed by the applicable Data Processing Agreement. Rights requests concerning Subscriber Content will be forwarded to the relevant controller.
2. What information does Markin collect
2.1. Information you provide to us. Account information (name, business email, role, company, language, credentials), communication information (support tickets, demo requests, sales emails), survey and testimonial information, and marketing preferences.
2.2. Information we automatically collect. Log data (IP address, browser type, timestamps, pages viewed), device information (operating system, device identifiers), usage data (product events, features used, session duration) and cookies as described in the Cookie Policy.
2.3. Information from third parties. We may receive information about you from our customers, event organisers, security providers and marketing vendors, and combine it with information we collect from you.
2.4. Aggregated information. We may aggregate personal data and use it to analyse the effectiveness of the Services and to develop new features. Aggregated information does not identify you and may be shared with third parties.
3. How we use your personal data
Markin uses personal data for the following purposes and on the following legal bases under the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"):
- Provide and administer the Site and Services — performance of a contract (Art. 6(1)(b) GDPR) or legitimate interest (Art. 6(1)(f) GDPR).
- Respond to sales and demo requests — pre-contractual measures at your request (Art. 6(1)(b) GDPR).
- Analytics and product improvement — your consent where required (Art. 6(1)(a) GDPR) or legitimate interest (Art. 6(1)(f) GDPR).
- Marketing communications — your consent (Art. 6(1)(a) GDPR) or the soft opt-in for existing customers permitted under applicable e-privacy rules.
- Network and information security, fraud prevention — legitimate interest (Art. 6(1)(f) GDPR).
- Compliance with legal obligations — Art. 6(1)(c) GDPR.
4. Sharing your personal data
We share personal data with the following categories of recipients:
- vetted service providers acting as processors (cloud hosting, email delivery, analytics, CRM, customer support);
- other companies within the Markin group, under intra-group data protection commitments;
- professional advisers (lawyers, auditors, accountants) bound by confidentiality;
- public authorities, when required by law or to protect our legal rights.
The current list of subprocessors that support the Services is published at Subprocessors. We do not sell personal data.
5. International transfers
Where personal data is transferred outside the European Economic Area, we rely on the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914) together with any supplementary technical and organisational measures required following the case-law of the Court of Justice of the European Union. A copy of the relevant transfer mechanism is available on request at privacy@markin.ai.
6. Retention
We keep personal data only for as long as necessary for the purposes described above, plus any period required by law. Account data is retained for the duration of the customer relationship; marketing contact data is deleted or anonymised on opt-out; log and usage data is retained for up to 24 months; and data relating to the Services is governed by the retention terms of the DPA.
7. Your rights
You have the right, subject to the conditions of the GDPR and Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights ("LOPDGDD"), to (i) access your personal data, (ii) rectify inaccurate data, (iii) request erasure, (iv) restrict or object to processing, (v) data portability, and (vi) withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise these rights, contact privacy@markin.ai. You may also lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos, C/ Jorge Juan 6, 28001 Madrid, aepd.es).
8. Security
Markin applies technical and organisational measures aligned with SOC 2 and ISO/IEC 27001 controls, including encryption in transit and at rest, least-privilege access, network segmentation, continuous monitoring, penetration testing and secure software development practices.
9. Controller
The controller responsible for personal data processed under this Privacy Policy is Markin AI, S.L., with registered office in Barcelona, Spain. Contact for privacy matters: privacy@markin.ai.
10. Changes to this Privacy Policy
We will update this Privacy Policy when our practices change. Material changes will be notified in advance through the Site or by email before they take effect.