1. PURPOSE

1.1 General Commerce maintains a strong commitment to privacy. Trust is essential when our services are used, and the privacy of clients is a top priority in our operations and technology decisions.

1.2 We provide a range of professional consulting services. “Services” means the professional services offered by General Commerce, including but not limited to development, consulting, management, and information technology services. Advanced artificial intelligence (AI) technologies may be used to ensure efficiency and results. The scope of each Service is determined by mutual agreement with the client (“Client”).

1.3 We take extensive measures to keep processed data private and secure. Data collection within the scope of our Services is conducted to deliver the best results and personalized experiences.

1.4 This policy applies to the collection, use, and disclosure of personal data related to our Services, marketing, sales, client relationships, and website operation.

1.5 Depending on context, General Commerce acts as a data controller or data processor under the General Data Protection Regulation (EU 2016/679).


2. DATA SUBJECTS AND CATEGORIES OF PERSONAL DATA

2.1 Personal data is collected through various means depending on the assignment and data subject. Categories include:

(a) Basic information such as name, title, address, relationship to a represented company, and contact details.

(b) Relationship data including service details, contracts, billing, and payment information.

(c) Data from website use and analytics tools (e.g., IP address, browser type, website engagement metrics).

(d) Client-provided data, including CRM entries, meeting records, and communications.

(e) Other data collected with consent, as defined case by case.

2.2 Data about clients’ customers or potential customers may also be collected to support personalized services.

2.3 Information from public sources may be combined with client-provided or third-party data to enhance accuracy and relevance.

2.4 Aggregated, anonymized data may be used for analytical or statistical purposes.