Privacy Policy

Last updated: August 2026

• Introduction
• Data We Collect
• How We Collect Your Personal Data
• How We Use Your Personal Data
• The Legal Basis for Processing Your Personal Data
• Automated Decision-Making and Profiling
• How We Share Your Personal Data
• How Long We Will Hold Your Information
• Your Rights Regarding the Information We Hold About You
• Aggregate Information About Demand AI Online Visitors and Daarwyn Platform Users
• Use of Cookies
• Complaints
• Security
• Other Websites
• Internet-based Transfers
• Do Not Track
• Changes to Our Policy
• Children's Information
• Contact Us

1. Introduction

At Demand AI we take your privacy seriously. This Privacy Policy (this “Policy”) states our policy and practices regarding the collection and use of personal data you submit to us, or which we collect via various channels (including our websites; through written correspondence, including e-mail; or through any of our offices or websites globally).

We aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency (or equivalent under applicable data protection laws) under the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR.

Please read this Policy carefully to understand our policies and practices regarding your data and how we will treat it. This Policy explains how and why we process personal data and the rights available to you; it is not itself the legal basis for that processing, which is set out below. This Policy may change from time to time and where required by law we will notify you of material changes.

2. Data We Collect

We collect personal data from four groups: our employees/contractors, customers, our subscribers, and business contacts whose data we process on behalf of our customers. “Personal data” means information that personally identifies someone or that relates to an identified or identifiable person.

i. Business Customer Data – When we enter a relationship with our business customers, we collect the personal data that we need to provide services to them, including name; business contact information, phone number, email address, and mailing address; company name; job title; and billing information. We may also collect additional information provided by our customers when they communicate with us.

ii. Subscriber Data – We collect certain data about individuals when they subscribe to our content, including name; business contact information, phone number, email address, and mailing address; company name; and job title. This information may be publicly available or provided directly to us, such as by our customers or other third-party providers, as permitted by applicable law. This data may include potential subscribers or other parties that have demonstrated an interest in our services or that have registered to attend our corporate events, both digital and physical.

iii. Business Contact / Lead Data – Separately from our customers and subscribers, we process only business contact data belonging to individuals whose details we source (i) from verified third-party data providers, engaged under a Data Processing Agreement, and (ii) from publicly available sources, for the purpose of marketing our customers' products, services, or events to them in a professional capacity. This processing is governed by our Fair Processing Policy, which sets out in detail where this data comes from, the legal basis we rely on, and how long we retain it. If you have received a marketing communication from us and are not a Demand AI customer or subscriber, the Fair Processing Policy — rather than the general terms below — is the primary policy that applies to you.

3. How We Collect Your Personal Data

i. Our Websites – Both customers and leads may access our websites and/or communicate with us. In general, you can visit Demand AI sites without identifying yourself or revealing any personal data. However, you may choose to provide us with personal data. Within these sites, you can make requests for information, register to receive materials, and in some cases, order products or services.

ii. From You – You may provide us additional personal data, such as when you contact us by phone or mail, or when you register for or attend our events. In these cases, we will collect your contact information as well as information regarding your communications with us.

iii. From Other Sources – We may collect information, including personal data, from publicly available sources or from other third parties. To the extent that we collect your personal data from these sources, we will treat it in accordance with this Policy (and, where applicable, our Fair Processing Policy), and we will honour your rights regarding your personal data as outlined in this Policy.

iv. Through Your Browser or Device – We also collect certain data automatically when you use our websites. For more information, see our Cookie Policy.

4. How We Use Your Personal Data

The information you provide voluntarily will only be used in connection with your business relationship with Demand AI. All personal data will only be processed and used for lawful and legitimate business purposes specified below.

• To present our websites and their contents to you.
• To provide the services, products, or information you request.
• Provide customer support.
• Communicate with you about our products, services, offers, and promotions.
• To better understand your needs and to provide better service.
• To plan and host events and to populate online profiles for attendees.
• From time to time, to contact you for market research or to provide you with marketing information we think would be of particular interest. At a minimum, we will always give you the choice to opt-out of receiving such direct marketing or market research contact.
• To carry out our obligations and enforce rights arising from any contracts entered between you and us.
• To protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users.
• To notify you about changes to our websites, products, or services.
• To comply with applicable legal requirements and industry standards.

Otherwise with your consent or as described to you when you provide the data.

5. The Legal Basis for Processing Your Personal Data

This Section is only applicable to you if you are located in the European Economic Area (“EEA”), Switzerland or the UK.

The main grounds that we rely upon in order to process personal data of customers, leads, other users of our websites, and event attendees are the following:

i. Necessary for entering into, or performing, a contract – In order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data.

ii. Necessary for compliance with a legal obligation – We are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency.

iii. Necessary for the purposes of legitimate interests – Either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and inquiries from you or a third party, optimising our websites and customer experience, our market research, informing you about our or our customers' products and services, and ensuring that our operations are conducted in an appropriate and efficient manner. Our legitimate interests also include the following activities:

• building datasets by collecting professionals' contact information from a variety of sources, including publicly available information where permitted, so that we can market events, products and services, run surveys or research projects on behalf of our customers and share that collected data with our customers as necessary;
• verifying and/or enriching our existing datasets;
• sending promotional emails to a carefully selected campaign database of business contacts on behalf of our customers; and

iv. Consent – We may also ask for your consent to process your personal data in a particular way.

6. Automated Decision-Making and Profiling

As part of providing services to our customers, Demand AI's Daarwyn platform uses automated tools, including AI-driven models (in accordance with the EU AI Act where applicable), to score and prioritise business contacts based on publicly available information and campaign-engagement data, in order to help our customers identify contacts who may be more likely to be interested in their products or services. This scoring activity constitutes a form of profiling under the GDPR.

This automated scoring informs which contacts are presented to our customers; it does not, on its own, produce legal effects or similarly significantly affect you, and outreach decisions based on this scoring remain subject to review by our customers or their representatives. If you believe a decision has been made about you based solely on automated processing that produces legal or similarly significant effects, or if you would like more information about the logic involved in this scoring, you may contact us using the details in the Contact Us section below to request human review or further explanation, or to exercise your right to object as set out in the section on your rights below.

We keep this processing under ongoing review, including through our internal data protection impact assessment programme, and will update this section if the nature or effect of this processing changes.

7. How We Share Your Personal Data

Personal data will be kept confidential but, subject to the provisions of any applicable law, may be provided to the third parties specified below (“Third Parties”). Third Parties may be located outside of your jurisdiction and, as a result, such disclosures may involve the transfer of personal data outside of your jurisdiction. Customer data provided as a suppression list, target account or uploaded into Demand AI’s Daarwyn Platform IS NEVER SHARED and is used only for the purpose of providing the requested service.

• To Demand AI affiliates – We may share it with Demand AI both inside and outside the EEA. For more information regarding our affiliate locations, please see our locations information at the bottom of this policy.
• To third-party service providers and contractors – We will only share your personal data with trusted third parties where we have retained them to support our business and who are bound by contractual obligations to maintain the same standards under the GDPR or equivalent data protection obligations to use it only for the purposes for which we disclose it to them. To the extent you are located in the EEA and personal data is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will use approved frameworks, including, with respect to any transfers outside of the EEA or access to the information as above, entering into standard contractual clauses as approved by the European Commission. A current list of our sub-processors is maintained internally and is available on request by contacting us using the details below.
• To our customers – We may share certain lead information with our customers in accordance with applicable law to allow our customers to connect with potential leads for their products or services.
• As required by law – We may disclose your personal data as required by applicable law, regulation or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other applicable laws, we may disclose certain personal data to such bodies or agencies.

Where we disclose personal data to Third Parties, we do so:

• To fulfil the purpose for which you provide it.
• To carry out our obligations and enforce rights arising from this Policy and any other contracts entered into between you and us; or
• Otherwise with your consent or as described to you when you provide the data.

We also reserve the right to transfer your personal data to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all our assets, equity or similar transaction. Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use your data in a manner that is consistent with this Policy.

8. How Long We Will Hold Your Information

Unless otherwise required to do so under applicable law, we will retain your personal data for the time necessary to provide the services we perform for you or fulfil the purposes outlined in this Policy, and you can always request that we stop processing or delete your personal data (if you are located in the EEA). The next section sets out more information on your rights.

If your personal data is processed under our Fair Processing Policy, specific retention periods and suppression rules — including our 24-month inactivity review and how objection or erasure requests are handled — are set out in full in that policy, which takes precedence over this general statement for that category of data.

9. Your Rights Regarding the Information We Hold About You

Depending on where you are located, you have certain rights in relation to personal data we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

i. Right of Access – You have the right at any time to ask us for a copy of the personal data about you that we hold. Where we have good reason, and as permitted by law, we can refuse your request for a copy of your personal data, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so. To exercise this right, please contact us using the details in the “Contact Us” section below.

ii. Right of Correction or Completion – If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. To exercise this right, please contact us using the details in the “Contact Us” section below.

iii. Right of Erasure – In certain circumstances, you have the right to request that personal data we hold about you is erased, e.g., if the data is no longer necessary for the purposes for which it was collected or processed or our processing of the data is based on your consent and there are no other legal grounds on which we may process the personal data. To exercise this right, please contact us using the details in the “Contact Us” section below.

iv. Right to Object to or Restrict Processing – In certain circumstances, you have the right to object to our processing of your personal data, for example, if we are processing your data on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal data for direct marketing purposes. You may also have the right to restrict our use of your personal data, such as in circumstances where you have challenged the accuracy of the data and during the period where we are verifying its accuracy. To exercise these rights, please contact us using the details in the “Contact Us” section below.

v. Right of Data Portability – In certain instances, you have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that data to you or directly to a third-party organisation. This right exists only in respect of personal data that: you have provided to us previously; and is processed by us using automated means. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to personal data of others without their consent. To exercise this right, please contact us using the details in the “Contact Us” section below.

vi. Right to Withdraw Consent – To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time going forward. To exercise this right, please contact us using the details in the “Contact Us” section below.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your right.

10. Aggregate Information About Demand AI Online Visitors and Daarwyn Platform Users

Websites We gather information and statistics collectively about all visitors to our websites, for example:

• which area users access most frequently,
• which services users access the most,
• the type of operating system and browser software,
• the geographical location of browsers,
• broad demographic information, and
• to monitor mouse clicks and movements and scrolling activity.

We only use such data in the aggregate form. The information and statistics we collect help us determine what is most beneficial for our users and how we can continually improve our online services to create a better overall experience for our users. Although such data may be shared with third parties, such as advertisers, the underlying data is not shared with anybody else. See Use of Cookies section below.

Daarwyn Platform We use Aggregated Data to operate, maintain, develop, improve and benchmark the Daarwyn Platform to improve service quality and user experience for all customers. We rely on Legitimate Business Interest for this processing.

11. Use of Cookies

We and our service providers automatically collect certain information about your behaviour while visiting our sites, using cookies and similar technologies, in order to measure our website's performance, understand user traffic, improve its design and functionality, and for other internal management purposes. The full details of the cookies we use — including their names, purpose, and duration, and how to manage your preferences — are set out in our Cookie Policy. Please note that without certain cookies you may not be able to take full advantage of our website.

12. Complaints

If you are unhappy about our use of your personal data, you can contact us using the details in the “Contact Us” section below.

You also have the right to lodge a complaint with the relevant supervisory authority.

Irish Data Protection Commission (DPC)

The DPC is the lead supervisory authority for DEMAND AI under the GDPR. You may contact the DPC by visiting their website:

https://www.dataprotection.ie/en

UK Information Commissioner's Office (ICO)

If you are based in the United Kingdom. You may contact the ICO by visiting their website:

https://ico.org.uk/

You also have the right to lodge a complaint with the supervisory authority in your own country of residence or work, in addition to the DPC.

13. Security

We maintain an information security programme, including administrative, technical, and organisational measures aligned with recognised industry frameworks, designed to protect the personal data we hold against unauthorised or unlawful access, disclosure, alteration, loss, or destruction. This programme covers, among other things, access control, encryption of data both in transit and at rest, network and database security measures, continuous monitoring, and a documented incident response process.

Personnel with access to personal data receive periodic security awareness training, and our security controls are reviewed on an ongoing basis. In the event of a personal data breach affecting your information, we will notify the relevant supervisory authority and, where required by applicable law, affected individuals, in accordance with our incident response procedures and applicable legal timeframes.

No security programme can guarantee absolute security, and we cannot guarantee the security of data transmitted to us over the internet or stored on our systems; however, we take reasonable and appropriate steps designed to protect your personal data from unauthorised disclosure and/or access. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Demand AI websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

14. Other Websites

Please note that clicking on links and banner advertisements on our websites can result in your browser accessing a third-party website, where data privacy practices are different to that of Demand AI. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you, such as your IP address, pages you visit, and when you view a page or open an email in which a tag is embedded. We do not control these third parties' tracking technologies or how they may be used. The information practices of these third parties are governed by their own privacy policies and are not covered by this Policy. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

We are not responsible for, and have no control over, data that is submitted to or collected by these third parties, and if you have any questions about their privacy practices, you should consult their privacy policies.

15. Internet-based Transfers

Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately, the transmission of data via the Internet is not completely secure. Although we take commercially reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to our websites via third party networks. Any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

16. Do Not Track

Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, our websites do not respond to the preferences you may have set in your web browser regarding such collection of your information, and our websites may continue to collect information in the manner described in this Policy

17. Changes to Our Policy

It is our policy to post any changes we make to our policy on this page. If we make material changes to how we treat our users' personal data, we will notify you by email to the primary email address specified in your account or through a policy on the Demand AI websites. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our websites and this Policy for any changes.

18. Children's Information

Our services are not directed to, and Demand AI does not knowingly collect or solicit personal data from, children under the age of 16 (or the legal minimum age under the relevant jurisdiction) (“Minimum Age”). If we learn we have collected or received personal data from a child under the Minimum Age, we will delete that information. If you believe we might have any information from or about a child under the Minimum Age, please let us know by contacting us at privacy@demandai.co.

19. Contact Us

If you have any enquiries or if you would like to contact us about our processing of your personal data, including to exercise your rights as outlined above, please contact us centrally by any of the methods below. When you contact us, we will ask you to verify your identity.

Contact name: Privacy Team

Email: privacy@demandai.co

Data Protection Officer: dpo@demandai.co

Our Office Locations

NORAM

EMEA

APAC