Privacy Policy & GDPR Compliance

Last updated: September 9, 2024

1. Introduction

This Privacy Policy explains how 4Square Innovations UAB ("we," "our," or "us"), a company registered in Lithuania and subsidiary of 4Square Capital Dubai, collects, uses, and protects your personal information when you visit our website, use our services, or interact with our AI products including AskDiana.ai and Genius².

2. Data Controller

4Square Innovations UAB acts as the data controller for personal data processed through our services.

3. Information We Collect

3.1 Personal Information

• Contact Information: Name, email address, phone number, company details
• Website Usage Data: IP address, browser type, device information, pages visited
• Investor Information: Financial and business information provided through our data room
• Communication Data: Messages, feedback, and support requests

3.2 Automated Data Collection

• Cookies and similar tracking technologies
• Analytics data through our AI platforms
• System logs and usage statistics
• Performance and security monitoring data

4. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

1. Consent: When you explicitly agree to data processing (e.g., marketing communications)
2. Contract: To fulfill contractual obligations with our clients
3. Legitimate Interest: For business operations, security, and service improvement
4. Legal Obligation: To comply with applicable laws and regulations

5. How We Use Your Information

• Provide and maintain our AI services (AskDiana.ai, Genius²)
• Process investor inquiries and manage data room access
• Improve our products and develop new features
• Communicate with users and provide customer support
• Ensure security and prevent fraud
• Comply with legal and regulatory requirements
• Send marketing communications (with consent)

6. Data Sharing and Disclosure

We may share your personal data with:

• 4Square Capital: Our parent company for business operations (Sharjah, UAE)
• Service Providers: Third-party vendors who assist our operations
• Legal Authorities: When required by law or legal process
• Business Partners: With your explicit consent for specific purposes

We never sell your personal data to third parties.

7. Your GDPR Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Revoke previously given consent

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

• Website Data: Up to 2 years after last interaction
• Customer Data: Duration of business relationship plus 7 years
• Investor Data: As required by financial regulations
• Marketing Data: Until consent is withdrawn

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption of data in transit and at rest
• Regular security audits and vulnerability assessments
• Access controls and authentication systems
• Employee training on data protection
• Incident response and breach notification procedures

10. International Data Transfers

Your data may be transferred to and processed in countries outside the EU/EEA, including:

• United Arab Emirates (4Square Capital, Sharjah)
• Countries with adequate protection decisions
• Countries under appropriate safeguards (Standard Contractual Clauses)

11. Cookies and Tracking

We use cookies and similar technologies to enhance your experience:

• Essential Cookies: Required for website functionality
• Analytics Cookies: To understand website usage
• Marketing Cookies: For targeted advertising (with consent)

You can manage cookie preferences through your browser settings.

12. Children's Privacy

Our services are not intended for children under 16. We do not knowingly collect personal data from children under 16 without parental consent.

13. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via email or website notice.

14. Contact Information

15. Supervisory Authority

You have the right to lodge a complaint with the Lithuanian Data Protection Authority:

16. Terms of Service

By using our website and services, you also agree to our Terms of Service, which govern the use of our AI platforms and business services.

16.1 Service Agreement

These terms apply to all users of 4Square Innovations services, including AskDiana.ai and Genius² platforms.

16.2 Intellectual Property

All content, software, and technology provided by 4Square Innovations remain our intellectual property. Users receive a limited license to use our services according to agreed terms.

16.3 Limitation of Liability

4Square Innovations provides services "as is" and limits liability to the maximum extent permitted by law. We are not liable for indirect, incidental, or consequential damages.

16.4 Governing Law

These terms are governed by Lithuanian law, with disputes resolved through Lithuanian courts or agreed arbitration procedures.

Document Version 1.1 - Effective October 22, 2025