I. IMPRESSUM (LEGAL DISCLOSURE)
Business Name: Creative Tech Solutions s. r. o.
Registered Seat: Hlavná 22, Štúrovo 943 01, Slovak Republic
ID No. (IČO): 55 760 287
Legal Form: Private Limited Liability Company
Registration: Registered in the Business Register of the City Court Nitra, Section: Sro, Insertion No.: 61367/N
Statutory Body (Managing Director): Ahmed Idris Awad (Human Executive Executor)
Note: Strategic direction is provided by John J. Astor V (AI CEO); legal liability is held by the statutory body.
Business Objects: * Computer services and services related to computer data processing.
- Digitalization, automation, and integration of AI systems.
- Development of custom software with AI support and CRM solutions.
- Administrative management services and services of an organizational and economic nature.
Hosting Provider: Namecheap, Inc. (4600 East Washington Street, Suite 305, Phoenix, AZ 85034, USA)
II. DATA PROTECTION POLICY (PRIVACY POLICY)
Version: 2.1 (Focus: GDPR, NIS2, EU AI Act)
1. INTRODUCTORY PROVISIONS
Creative Tech Solutions s. r. o. (hereinafter referred to as “CTS”) approaches data protection with zero tolerance for ambiguity. This document defines the standards for data processing in accordance with Regulation (EU) 2016/679 (GDPR), the NIS2 Directive, and the EU Artificial Intelligence Act (EU AI Act).
2. SCOPE AND PURPOSE OF PROCESSING
CTS processes data exclusively for the following purposes:
- Provision of Services: Development and implementation of AI software, CRM systems, and automation tools.
- Security (NIS2): Monitoring system integrity and preventing cyber incidents.
- Contractual Fulfillment: Management of business relationships and technical support.
3. ARTIFICIAL INTELLIGENCE AND TRANSPARENCY (EU AI ACT)
- Custom AI Software: Our systems are designed as “AI-motored” solutions. In compliance with the AI Act, we declare that our models undergo audits for transparency and security.
- Local Processing: Whenever technically feasible, CTS prioritizes on-premise data processing to minimize data transfer to third parties.
- Accountability: Every output generated by the AI CEO (John J. Astor V) is subject to validation by the Human Executive Executor (Ahmed Idris Awad).
4. CYBERSECURITY (NIS2)
As an entity providing digital services, CTS implements:
- Encryption of data at rest and in transit.
- Proactive threat monitoring by “Blackshield” agents.
- The obligation to report incidents to relevant authorities in accordance with the Cybersecurity Act.
5. SERVICE LIMITATIONS (BLOCKCHAIN DISCLAIMER)
All projects related to cryptocurrencies (CTSChain, Vaultum Wallet) are currently “ON PAUSE” (suspended). CTS does not perform the activities of a Crypto-Asset Service Provider (CASP), and these projects are currently not subject to the MiCA regulatory framework.
6. RIGHTS OF DATA SUBJECTS
Users have the right to access data, rectification, erasure (“right to be forgotten”), and data portability. Requests must be sent formally to the address of the company’s registered seat.
7. INTERNATIONAL DATA TRANSFERS
Due to the use of Namecheap, Inc. infrastructure, we use European (Amsterdam) Datacenters, technical metadata may be transferred to the USA. This transfer is covered by Standard Contractual Clauses (SCCs) in accordance with GDPR.
Approved by: Guardian Legal & Compliance Officer, CTS
Signed by: Ahmed Idris Awad Managing Director, Creative Tech Solutions s. r. o.