ANNEX IIb: DESCRIPTION OF PROCESSING -PERSONAL CHAMPION

Categories of data subjects whose personal data is processed

The data subjects under this agreement will consist of the data controller’s employees who are users of Personal Champion.

Categories of personal data processed

In addition to the categories of personal data described in Annex IIa, the data processed in connection with Personal Champion will include behavioural data of Users, comprising: (i) usage data (relating to Users' activity on the Relesys Platform); (ii) engagement data (relating to Users' engagement with tasks and content); and (iii) interaction data (relating to Users' interactions with Personal Champion's AI-powered features).

The data controller and the data processor have agreed that sensitive data will not be processed under this Annex. The Data Controller commits to omit sensitive data from the platform.

Nature of the processing

The nature of the processing consists of collection of usage, engagement, and interaction data generated through the data subject's use of the Relesys Platform and Personal Champion, structuring and analysis of that data within Personal Champion's AI-powered features, and storage of the data for the purposes set out below.

The data will be stored until the data controller has notified the data processor that the data must be deleted or returned to the data controller.

If the data is to be returned to the data controller, the data processor must ensure that all copies of the data will be deleted, unless it is required under the law of an EU Member State to store the data.

Purpose(s) for which the personal data is processed on behalf of the controller

The purpose of the data processing is to give the data subjects access to Personal Champion, an AI-powered capability within the Relesys Platform, including its conversational assistant, AI-generated communications tools, and natural language reporting features.

Additionally, the purpose is to train and improve the AI models underlying Personal Champion. Such training will only be performed on data that has been anonymized and/or aggregated so that it no longer constitutes personal data, solely to develop and enhance such AI-powered features for the benefit of the Client and its data subjects. Such processing shall not be used for any purpose beyond the improvement of services provided to the Client.

Duration of the processing

The processing of personal data described in this Annex will take place during the contractual relationship between the parties, or for as long as Personal Champion remains enabled.

For clarity, any data used to train or improve the AI models underlying Personal Champion is anonymized  prior to such use, as set out above, and therefore does not constitute personal data. Accordingly, this duration of processing provision does not require deletion of such anonymized or aggregated data, or of any resulting improvements to the AI models.

‍

‍