Privacy Policy

INTRODUCTION

Welcome to Mila, an AI chatbot service provided by AC Goldman Solutions & Services GSS Ltd ("we," "our," or "us"). We respect your privacy and are committed to protecting your personal data in compliance with:
•   General Data Protection Regulation (GDPR) (EU) 2016/679
•   Data Protection Directive (95/46/EC)
•   ePrivacy Directive (2002/58/EC, as amended by 2009/136/EC)
•   Cyprus Commissioner for Personal Data Protection (CCPDP) regulations

This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you interact with Mila.

DATA CONTROLLER INFORMATION

The data controller responsible for your personal data under this Privacy Policy is:

AC Goldman Solutions & Services GSS Ltd
Diogenous 1, Block A, 4th floor, 2404 Engkomi, Nicosia, Cyprus
info@milabots.com
+357 99 668702

If you have any questions about how we handle your data, you can contact our Data Protection Officer (DPO) at info@milabots.com.

WHAT DATA WE COLLECT

When you interact with Mila, we may collect the following types of personal data:

A. Data You Provide Voluntarily

If you explicitly consent to the collection of your data, we may process the following personal information:

Identifiers: Your name, email address, phone number (if applicable).
Chat Content: Any personal information you voluntarily share in conversations with Mila.

Your Consent Rights:

You can withdraw your consent at any time without affecting the lawfulness of prior processing.
Mila will not collect, process, or store this data without your explicit opt-in consent in accordance with Article 6(1)(a) of GDPR and CCPDP regulations.
If you withdraw consent, all previously collected personal data will be deleted or anonymized, unless retention is required by law.

To withdraw consent, contact us at info@milabots.com.

B. Data We Collect Automatically

IP address and device identifiers.
Browser type and operating system.
Chat logs and timestamps.
Cookie identifiers and tracking data (where applicable, in compliance with the ePrivacy Directive and CCPDP requirements).

C. Special Category Data

We do not intentionally collect sensitive personal data (e.g., health, racial, religious, or biometric data). If you voluntarily provide such data, it will be handled in compliance with Article 9 of the GDPR and Cyprus data protection regulations.

PURPOSE AND LEGAL BASIS FOR PROCESSING

We process personal data based on:

Purpose of Processing Legal Basis
Providing chatbot responses Contractual necessity (Article 6(1)(b) GDPR)
Improving chatbot functionality Legitimate interest (Article 6(1)(f) GDPR)
Analytics & user experience enhancement Legitimate interest (Article 6(1)(f) GDPR)
Marketing communications (if opted-in) Consent (Article 6(1)(a) GDPR and ePrivacy Directive)
Compliance with legal obligations Legal obligation (Article 6(1)(c) GDPR and CCPDP guidelines)

We do not use personal data for automated decision-making or profiling without explicit user consent.

USE OF COOKIES AND TRACKING TECHNOLOGIES

Mila does not use cookies except when obtaining the user's initial consent for data collection, in compliance with the ePrivacy Directive and Cyprus Commissioner for Personal Data Protection (CCPDP) guidelines.

We ensure that:

A single, temporary cookie is used only once to store the user's consent preference.
The cookie expires automatically after the session or a short period necessary for compliance.
No tracking, analytics, advertising, or third-party cookies are used.
Users have the right to manage or withdraw their consent at any time.

For more details, please see our Cookie Policy.

DATA SHARING AND THIRD PARTIES

We do not sell personal data. However, we may share personal data with:

Service providers (processors): Cloud hosting, AI processing, analytics providers (subject to strict data protection agreements).
Legal authorities: If required by law, regulatory obligation, or to protect our rights.
Partners (only with user consent): If integrating Mila with third-party services (e.g., CRM, helpdesk solutions).

All third-party data processing complies with GDPR Article 28, ensuring security and contractual safeguards.

DATA SECURITY AND RETENTION

We apply robust technical and organizational measures to safeguard personal data, including:

Encryption of stored and transmitted data.
Access control to limit unauthorized access.
Regular security audits and risk assessments.

Data Retention

Chat logs: Stored for [insert duration], then anonymized or deleted.
Account data: Retained as long as the account is active.
Marketing preferences: Stored until consent is withdrawn.

Data will not be retained longer than necessary, per GDPR Article 5(1)(e) and CCPDP regulations.

YOUR RIGHTS UNDER EU AND CYPRUS LAW

Under the GDPR (Articles 12-23) and CCPDP regulations, you have the following rights:

Your Rights How to Exercise Them
Access your data Request a copy of your data
Rectification Correct inaccurate or incomplete data
Erasure ("Right to be Forgotten") Request deletion of personal data
Restriction of Processing Limit how we use your data
Data Portability Receive your data in a structured format
Object to Processing Stop processing for direct marketing or legitimate interests
Withdraw Consent Opt-out of marketing communications or cookies

To exercise these rights, contact us at info@milabots.com. You also have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection (CCPDP).

INTERNATIONAL DATA TRANSFERS

If we transfer personal data outside the European Economic Area (EEA), we ensure:

Adequacy decisions (e.g., for UK, Switzerland).
Standard Contractual Clauses (SCCs) approved by the European Commission.
Additional safeguards, such as encryption and pseudonymization.

We do not transfer personal data to countries without adequate data protection safeguards.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect regulatory changes or improvements to Mila. If material changes occur, we will:

Notify users via email or chatbot notification.
Provide at least 30 days' notice before changes take effect.

Please check this page periodically for updates.

CONTACT INFORMATION

For questions, concerns, or to exercise your data rights, contact:

AC Goldman Solutions & Services GSS Ltd

Diogenous 1, Block A, 4th floor, 2404 Engkomi, Nicosia, Cyprus

info@milabots.com

+357 99 668702