Privacy Policy

Uncle Louis's Services are offered to companies and/or other legal entities for professional use (our "Subscribers"). Our subscriber agreements govern the delivery and use of the Services ("Subscriber Agreements").

This Privacy Policy applies when Uncle Louis is the data controller responsible for processing personal data. It does not apply to any input submitted to, output generated by, or documents uploaded to our Services ("Content") - including tax filings, financial statements, contracts, correspondence and any other materials processed through our AI Services. We process Content as a data processor on behalf of our Subscribers (the data controllers), and our processing of Content is governed by the relevant Subscriber Agreement and the data processing agreement (verwerkersovereenkomst) concluded with the Subscriber. Any queries related to personal data included in Content should be directed to our Subscribers. If we receive any rights requests concerning instances where we act as data processor, we will forward them to the relevant Subscriber.

Uncle Louis may maintain links to other websites, and other websites may maintain links to the Online Services. This Privacy Policy only applies to unclelouis.app and app.unclelouis.app (and any other official Uncle Louis domains listed at sign-up), and not to other websites accessible from Uncle Louis or websites that you use to access Uncle Louis.

2.1 Information you provide to us

We collect personal data provided to us if you create an account to use our Services or communicate with us as follows:

User account information: We require everyone with access to our Services to have an account with us. When you or your employer creates an Uncle Louis account for you, we collect personal data including your name, email address, role, language preferences and account credentials.

Communication information: When you contact us for customer support, feedback, or inquiries, we collect your name, email address, phone number, and any other information you provide to assist you or resolve your issue. Uncle Louis may monitor and record phone conversations or email communications between you and Uncle Louis employees for training and quality assurance purposes. We may receive a confirmation when you open or click on content in an email from us, which helps us make our communications more useful and relevant.

Social media information: We have accounts on social media sites such as LinkedIn, YouTube and X ("Social Media"). When you interact with our Social Media, we collect personal data that you elect to provide to us, such as your contact details, and the third parties that host our Social Media may provide us with aggregate information and analytics regarding your use of our Social Media.

Survey and contest information: We may provide you the opportunity to participate in surveys on our Site to measure customer satisfaction. If you participate, we may request certain personally identifiable information from you. Participation is completely voluntary, so you choose whether to disclose this information. The requested information typically includes name, email address, and mailing address.

Testimonial and review information: We may display personal testimonials or reviews from satisfied users if you have consented to it. If you wish to update or delete your testimonial or review, you can contact us.

2.2 Information we automatically collect

When you visit, use, and interact with our Services, we collect certain information about your visit, use, or interactions ("Technical Information") indirectly, including through automated means from your computer or device, including the following:

Log data: Whenever you visit the Online Services, your browser automatically sends us your IP address, browser type and settings, the date and time of your request, and how you interacted with the Online Services.

Device information: We automatically collect information about the device you use to access the Online Services, including the name of the device, operating system, browser, referring/exit pages, date/time stamps, and clickstream data. The information collected may depend on the type of device you use and its settings.

Usage data: We automatically collect information about your use of our Services, including name, email address, the features you use, actions you take, your time zone, location, the dates and times of access, the amount of time spent within the Services, and the types and volumes of queries you submit. We will, however, never collect or store any data directly related to your Content other than in accordance with the applicable Subscriber Agreement.

Cookies: A cookie is a small string of information that websites you visit transfer to your computer for identification purposes. Cookies can be used to follow your activity on the website, and that information helps us understand your preferences and improve your experience. Cookies are also used for activities such as remembering your access credentials for our Services. In addition to the cookies used by Uncle Louis and our service providers, some cookies are placed by third parties such as Google (for analytics, described below). Uncle Louis uses cookies for the following purposes:

• Essential Cookies: these are essential to enable you to move around the website and use its features, such as accessing secure areas of the website.
• Performance and Analytics Cookies: these include Google Analytics, Plausable analytics and keep track of the pages you visit and the content you access, so we can determine which content is most popular and improve the performance of our website. These cookies primarily record aggregate and anonymous statistical data, but may capture a minimal amount of identifiable information.
• Functional Cookies: these cookies remember the choices you make, such as language options or your region. They help make your visit more personal and are deleted automatically when you close your browser or the session expires.

You can turn off all cookies if you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options, you must adjust your browser settings (such as Chrome, Safari, Firefox, Edge, or another browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies you may limit the features and functionality of our Services.

2.3 Information collected from third parties

We may collect information about you from third parties, such as security partners, marketing vendors and event organisers. Our Subscribers may give us information about you, such as your contact details, in order to facilitate our provision of the Services. We may combine this information with information we collect from you and use it as described in this Privacy Policy.

2.4 Publicly available information

We provide access to publicly available information (for example, judgments, decisions, legislation and regulatory guidance) within our Services. Some of this information may relate to individuals and can, in some jurisdictions, be considered personal data. Personal data included in publicly available information is only processed so that our Services can provide more accurate and relevant responses. It is not provided to intentionally identify individuals.

Uncle Louis also collects publicly available information about Subscribers and prospects, including name, email address, phone number and other contact details.

2.5 Aggregated information

Uncle Louis may aggregate personal data and use the aggregated information to analyse the effectiveness of our Services and to improve and add features to our Services. From time to time, we may analyse the general behaviour and characteristics of users of our Services and share aggregated information, such as general user statistics, with third parties, publish such aggregated information, or make it generally available. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy.

Uncle Louis may use your personal data for the following purposes:

• to provide, administer, maintain, and/or improve our Services;
• to provide you with support services, resolve issues, or reply to your queries;
• to manage and remember your preferences and customise the Services;
• to communicate with you, including to send you information or marketing about our Services and events;
• to analyse and study the effectiveness of our Services and to develop new features and services;
• to verify your identity, prevent fraud and criminal activity, and ensure the security of our IT systems, architecture, and networks;
• to prevent misuse of the Services and enforce our legal terms;
• to comply with legal obligations and legal processes; and
• to protect Uncle Louis's rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

The following disclosures provide additional information about the categories of personal data we collect (as defined above), the type of data, and how we use each category. These disclosures do not limit our ability to use or disclose information as described above.

In certain circumstances, we may share your personal data with third parties without further notice to you, unless legally required, including without limitation in the situations below:

Affiliates: Uncle Louis may share your personal data with other entities within the Uncle Louis corporate group (our "affiliates"). Our affiliates will only use the personal data we share with them in a manner consistent with this Privacy Policy.

Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share your personal data with vendors and service providers, including providers of hosting services, cloud service providers and other information technology providers, event management services, email communication and newsletter services, advertising and marketing services, and web analytics services. Pursuant to our instructions, these parties will access, process, or store personal data in the course of performing their duties to us.

Third-party Websites and Services: Our Services may contain links to other websites not operated or controlled by Uncle Louis, including social media services ("third-party sites"). The information you share with third-party sites is governed by the specific privacy policies and terms of service of those sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the third-party sites directly for information on their privacy practices and policies.

Other users: When you use the collaboration features within Uncle Louis, certain actions you take may be visible to other users of our Services.

Plug-Ins: When you use third-party applications and choose to connect your Uncle Louis account with such external applications (for example to use our Microsoft Word plug-in), the providers of those services or products may receive information about you from Uncle Louis or others. When you use third-party sites or services, their own terms and privacy policies will govern your use. Please contact the supplier of such applications directly for information on their privacy practices and policies.

Business changes: If we are involved in strategic transactions (such as a sale, merger, reorganisation, liquidation, or transition of service to another provider), your personal data and other information may be shared in the diligence process with counterparties and others assisting with the transaction, and transferred to a successor or affiliate as part of that transaction along with other assets.

Legal Requirements: Uncle Louis may also share your personal data if required to do so by law or in the good-faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (v) protect against legal liability.

Uncle Louis always strives to process your personal data as close to you as possible. By using our Online Services, however, you understand and acknowledge that your personal information will be transferred from your location to our facilities and servers in the EU/EEA.

In certain situations, such as when we share your information within the Uncle Louis corporate group or with a supplier or subcontractor, your personal data may be transferred outside the EU/EEA. Uncle Louis always ensures that the same high level of protection applies to your personal data under the relevant data protection laws, even when the data is internationally transferred. Your rights in respect of your personal data (described in detail in Section 6) are not affected when data is internationally transferred. You will find more information about the recipients with which Uncle Louis shares your data in Section 4.

Safeguards Uncle Louis uses when conducting international transfers

Countries outside the EU/EEA or your country of residence may have laws that allow public authorities to request access to personal data stored in the country for the purpose of combating crime or safeguarding national security. Regardless of whether we or any of our providers process your personal data, we will ensure that a high level of protection is guaranteed when transferring that data and that appropriate protection measures have been taken, in accordance with applicable data protection requirements (such as the GDPR). Such appropriate safeguards include, but are not limited to:

Adequacy decisions: where the relevant authority (e.g. the EU Commission) has decided that the country to which your personal data are transferred has an adequate level of protection corresponding to the level afforded by the relevant data protection laws. This means, for example, that the personal data is still protected from unauthorised disclosure and that you may still exercise your rights with regard to your personal data.

Standard Contractual Clauses: where the relevant authority's standard clauses have been entered into between Uncle Louis and the recipient of the personal data. The recipient guarantees that the level of protection afforded by the relevant data protection laws still applies and that your rights are still protected. In these cases we also assess whether there are laws in the recipient country that affect the protection of your personal data and, where necessary, take technical and organisational measures so that your data remains protected during the transfer.

Derogations: in limited circumstances, we may rely on an exception, or "derogation", under the applicable data protection laws to transfer your personal data despite the absence of an adequacy decision or standard contractual clauses, such as relying on your explicit consent or because the transfer is necessary for the establishment, exercise or defence of legal claims (including regulatory, administrative or out-of-court procedures, and seeking advice).

Data Privacy Framework: where the transfer is covered by a relevant data privacy framework, such as the EU-US Data Privacy Framework, which is an opt-in certification scheme for US companies administered by the US Department of Commerce. Such frameworks include sets of enforceable principles and requirements to which a company must certify, ensuring that your data is still sufficiently protected.

You have several rights under the applicable data protection laws (including the GDPR) related to your control over your personal data and to receive information directly from us on how we process personal data about you. These rights are set out below.

Right to information and access: You have the right to be informed of how we process your personal data, which we do through this Privacy Policy and by answering your questions. You can request information regarding whether we are processing your personal data and ask to receive a copy of your personal data (a "data extract"). Through the data extract you will receive information about what personal data Uncle Louis holds about you and how we process it.

Right to rectification: If you believe that your personal data is inaccurate or incomplete, you have the right to ask for it to be corrected or completed.

Right to restriction: If you believe that your personal data is inaccurate, that our processing is unlawful, or that we do not need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. You may also request that we stop processing your personal data while we assess your request. If you object to our processing (see below), you may also request that we restrict processing while we make our assessment.

Right to object: You have the right to object to the processing of your personal data which is based on our legitimate interest (Article 6(1)(f) GDPR) by referencing your personal circumstances. If we cannot demonstrate compelling and legitimate grounds to continue processing, we must cease it. You can also always object to our processing of your personal data for direct marketing purposes; if you do, we will turn off marketing for you and stop sending it.

Right to be forgotten: In some cases, you have the right to have us delete personal data about you - for example, personal data that we (i) no longer need for the purpose it was collected for, or (ii) process based on your consent where you revoke that consent. There are situations where Uncle Louis is unable to delete your data, for example where it is still necessary to process the data for the purpose for which it was collected, where Uncle Louis's interest in processing overrides your interest in deletion, or where we have a legal obligation to keep it.

Right to data portability: If we process your personal data to fulfil a contract or on the basis of your consent, you may, in certain cases, obtain the personal data for use elsewhere - e.g. by obtaining a copy in a machine-readable format and transmitting it to another data controller.

Right to withdraw consent: Where we process your personal data based on your consent, you have the right to withdraw your consent at any time. When you withdraw your consent, we will stop any processing that is based on it.

Right to lodge a complaint: If you have objections or concerns about how we process your personal data, you have the right to contact, or lodge a complaint with, the relevant supervisory authority for data protection. In the Netherlands, this is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority), www.autoriteitpersoonsgegevens.nl.

To exercise your rights, please contact us at any time. We reserve the right to limit our facilitating such requests to that which is required by applicable law.

In order to protect your personal data from unauthorised access or deletion, we may require you to verify your identity before we process any request to know or delete personal data. If we cannot verify your identity (and, where applicable, proof of residency) to our satisfaction, we will not provide or delete your personal data. You may submit a request through an authorised agent; such an agent must present signed written authority to act on your behalf and must be able to verify your identity (and, where applicable, proof of residency) to our satisfaction.

We will not discriminate against you for making any such request. Your right to access and delete your personal data is important to us, and we will take reasonable steps to verify and process your request promptly. Please be aware that even if we delete your personal data, certain residual data may remain in our backups or archives for a limited period in accordance with our data retention policies and applicable laws. If you have any questions or concerns about this process or our data deletion practices, please contact us.

We take significant and appropriate steps to protect your personal data in an effort to prevent loss, misuse, and unauthorised access, disclosure, alteration and destruction. We use appropriate technical and organisational measures to protect your personal information, which may include physical access controls, encryption, intrusion detection and network monitoring, depending on the nature of the information and the scope of processing. For more information regarding our security measures, please view our Security Policy.

Uncle Louis retains your personal information for as long as necessary to fulfil the purposes for which we collected it, or longer if required under applicable law:

• If you are an Uncle Louis user covered by a Subscriber Agreement between your employer and Uncle Louis, we will delete your data in accordance with that Subscriber Agreement.
• Personal data that Uncle Louis is under a legal obligation to retain - for example under anti-money laundering or bookkeeping laws (such as the 7-year fiscal retention obligation under the Dutch Algemene wet inzake rijksbelastingen and the 5-year retention obligation under the Wet ter voorkoming van witwassen en financieren van terrorisme) - is retained for the required periods under applicable law (generally 5 or 7 years).
• Personal data which is not used for the purposes of a contractual relationship, and where Uncle Louis does not have a legal obligation to retain the data, is only retained as long as necessary to fulfil the respective purpose for our data processing (usually 3 months).

More information can be found in the table in Section 3.

In some limited cases, the personal data may need to be stored for a longer period in order for Uncle Louis to protect its legal rights. Where we do not have a legal obligation to retain the personal data, we instead assess whether we may require it in order to protect Uncle Louis from legal claims. Please note that the fact that we have a legal obligation to store your personal data does not mean we are permitted to use that data for any other purpose.

When we no longer need your personal data, we will delete or anonymise it in accordance with our data retention policies and applicable laws or, if this is not possible (for example, because your personal data has been stored in backup archives), we will securely store it and isolate it from any further processing until deletion is possible.

We may update this Privacy Policy from time to time. When the Privacy Policy is updated, we will post an updated version on this page, unless another type of notice is required by applicable law or contractual agreement. By continuing to use our Online Services, or by providing us with personal data after we have posted an updated Privacy Policy or notified you by other means, you consent to the revised Privacy Policy.

If you have any questions about our Privacy Policy or any other privacy-related issue, please contact us at privacy@unclelouis.app or by mail.

Controller's contact information:

Uncle Louis B.V.

KvK number: 98343300

Establishment number (vestigingsnummer): 000063515539

Prins Hendrikkade 21 E, 1012 TL Amsterdam

The Netherlands