Privacy Policy
Privacy Policy
This Privacy Policy explains how PixelFaerie Limited collects, uses, stores, and protects personal data in connection with our website and the Saije platform. It applies to prospective clients, registered clients (whether Subscription Clients or Retainer Clients), and visitors to our website at www.pixelfaerie.com.
This Policy should be read alongside our Terms of Service and the Saije Software Licence, Subscription & Managed Presentation Services Agreement (“Full Agreement”), both available at www.pixelfaerie.com/legal/agreement.
If you have any questions about this Policy, contact our data protection contact at dataprotectionofficer@pixelfaerie.com.
1. Who We Are
1.1 Data Controller. PixelFaerie Limited (“PixelFaerie”, “we”, “us”, “our”) is a private limited company incorporated in Ireland (Company No. 409258) with its registered office at Broomfield West, Midleton, Co. Cork, Ireland. PixelFaerie is the data controller in respect of personal data we collect and process for our own purposes (including account management, billing, and marketing), within the meaning of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
1.2 Data Processor Role. Where you submit content containing personal data to the Saije Platform for the purpose of receiving Managed Services, PixelFaerie acts as your data processor — processing personal data on your instructions as the data controller. This processing relationship is governed by the GDPR Article 28 Data Processing Agreement set out in Schedule 1 of the Full Agreement, available at www.pixelfaerie.com/legal/agreement.
1.3 Contact. Our data protection contact can be reached at: dataprotectionofficer@pixelfaerie.com, or by post at: PixelFaerie Limited, Broomfield West, Midleton, Co. Cork, Ireland. For general legal enquiries, contact legal@pixelfaerie.com.
1.4 Applicable Law. We process personal data in accordance with the GDPR and the Irish Data Protection Acts 1988–2018, as amended.
2. What Personal Data We Collect
2.1 Account and Registration Data. When you register for Saije or enquire about our services, we collect: your name; work email address; company name and address; telephone number; job title; and any other information you provide in the registration or enquiry form.
2.2 Billing and Transaction Data. We collect billing name and address, VAT registration number (where applicable), and payment records. We do not store payment card numbers — card payments are handled by our third-party payment processor subject to their own PCI-DSS compliance.
2.3 Platform Usage and Service Data. When you use the Saije Platform, we collect: log data (access timestamps, IP address, browser/device type, pages visited); session identifiers; Service Request metadata (submission dates, turnaround times, feature usage); and anonymised, irreversibly aggregated performance telemetry used to improve Platform functionality and security. We do not use individual-level usage data to build behavioural profiles beyond what is necessary for service delivery and security.
2.4 Client Content. As part of providing Managed Services, you submit presentation materials, brand assets, data, instructions, and other content to the Platform (“Client Content”). Client Content may incidentally contain personal data (for example, names or contact details of individuals referenced in your presentations). Where it does, PixelFaerie processes it solely as your data processor in accordance with the Full Agreement. See Section 6 (Our Role as Data Processor) below.
2.5 Communications Data. We retain records of communications between you and PixelFaerie (emails, support tickets, messages sent through the Platform) for service delivery, support, legal compliance, and dispute resolution purposes.
2.6 Website Analytics Data. Our website at www.pixelfaerie.com may use analytics tools (such as Google Analytics) to collect anonymised or pseudonymised information about how visitors use the site. This is subject to separate cookie consent in accordance with the ePrivacy Regulations 2011 (Ireland). We do not rely on acceptance of this Privacy Policy as consent for non-essential cookies — a separate active consent mechanism is provided on our website.
2.7 Marketing Preferences. Where you have opted in, we may process your contact details to send you product updates, service announcements, and other communications about PixelFaerie and Saije. You may withdraw consent at any time as described in Section 8.
3. How and Why We Use Your Personal Data (Legal Bases)
3.1 We process personal data only where we have a lawful basis to do so under Article 6 GDPR. The table below sets out the purposes for which we process personal data and the legal basis we rely on for each.
| Purpose | Categories of Data | Legal Basis |
|---|---|---|
| Registering your account and onboarding you as a client | Account and registration data | Performance of contract (Art. 6(1)(b)) |
| Providing Managed Services through the Saije Platform | Client Content (as processor); account data; service data | Performance of contract (Art. 6(1)(b)) |
| Billing and invoice management | Billing and transaction data | Performance of contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) |
| Communicating with you about your account and Services | Account data; communications data | Performance of contract (Art. 6(1)(b)) |
| Providing customer and technical support | Account data; communications data; service data | Performance of contract (Art. 6(1)(b)) |
| Improving Platform performance and security using anonymised telemetry | Anonymised aggregated usage data | Legitimate interests (Art. 6(1)(f)) — we have a legitimate interest in improving the security and functionality of the Platform, and this processing does not involve individual-level profiling |
| Complying with legal and regulatory obligations (including tax, data protection, and financial record-keeping) | Billing data; account data; communications data | Legal obligation (Art. 6(1)(c)) |
| Establishing, exercising, or defending legal claims | All categories as necessary | Legitimate interests (Art. 6(1)(f)) |
| Sending marketing communications (product updates, new features, service announcements) | Account data (email, name) | Consent (Art. 6(1)(a)) — you may withdraw consent at any time |
| Portfolio use — referencing your name or logo as a client | Account data; portfolio materials (with your consent) | Consent (Art. 6(1)(a)) — see Section 2.6 of the Terms of Service and Section 10.5 of the Full Agreement |
3.2 AI Training Prohibition. We will not use your personal data, Client Content, or Deliverables to train, fine-tune, or improve any artificial intelligence or machine-learning model without your express prior written consent.
3.3 Legitimate Interests. Where we rely on legitimate interests as the legal basis, we have assessed that our interests are not overridden by your rights and freedoms. You may contact us to request a copy of our legitimate interests assessment.
4. Who We Share Your Personal Data With
4.1 Sub-Processors. We engage third-party service providers (“sub-processors”) to assist us in operating the Platform and providing Managed Services. Sub-processors may process personal data on our behalf. A current list of sub-processors can be provided upon written request. We will notify you at least 14 days before adding a new sub-processor as described in Schedule 1, DPA 4.2 of the Full Agreement.
4.2 Categories of Sub-Processors. Sub-processors typically include: cloud hosting and infrastructure providers; email and communications platforms; billing and payment processors; analytics providers (processing anonymised data only); and security monitoring services. All sub-processors are contractually required to process personal data only on our instructions and to maintain security standards equivalent to those in the Full Agreement.
4.3 Professional Advisers. We may share personal data with our legal advisers, accountants, and auditors on a confidential basis where reasonably necessary.
4.4 Regulatory and Legal Disclosure. We may disclose personal data to regulatory authorities, law enforcement agencies, or courts where required by law or legal process. Where legally permitted, we will notify you before making such a disclosure.
4.5 Business Transfers. In the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred to the relevant third party as part of that transaction, subject to equivalent confidentiality and data protection obligations.
4.6 No Sale of Data. We do not sell, rent, or trade personal data to any third party for marketing purposes.
5. International Transfers
5.1 PixelFaerie is based in Ireland and primarily processes personal data within the European Economic Area (“EEA”).
5.2 Where personal data is transferred to a country outside the EEA, we ensure an adequate level of protection by relying on one or more of the following: (a) a European Commission adequacy decision in respect of that country; (b) Standard Contractual Clauses approved by the European Commission (Article 46(2)(c) GDPR); or (c) another appropriate safeguard permitted under Chapter V GDPR.
5.3 Details of the safeguards applicable to transfers by our sub-processors are available on request.
6. Our Role as Data Processor (Client Content)
6.1 When you use the Saije Platform to submit Client Content for Managed Services, and that Client Content contains personal data, PixelFaerie acts as your data processor and you act as the data controller of that personal data.
6.2 In this capacity, PixelFaerie processes personal data only on your documented instructions (as set out in the Full Agreement and any Service Request you submit), and not for any other purpose.
6.3 The full terms governing PixelFaerie’s processing of personal data in Client Content are set out in Schedule 1 (Data Processing Agreement — Article 28 GDPR) of the Full Agreement, available at www.pixelfaerie.com/legal/agreement. That Schedule includes provisions on: subject matter, nature, and purpose of processing; sub-processor authorisation; security measures; personal data breach notification (48 hours); data subject rights assistance; and deletion/return of data on termination.
6.4 Your Responsibilities as Data Controller. Where you submit personal data to the Platform, you are responsible for: ensuring you have a valid legal basis for that processing; providing all required privacy notices to data subjects whose data you submit; obtaining any necessary consents; and ensuring the transfer of data to PixelFaerie is lawful. Full details are in Section 10.4 of the Full Agreement.
6.5 Prohibited Data. You must not submit to the Platform: special-category personal data under Article 9 GDPR (including health, biometric, racial/ethnic origin, political, religious, sexual orientation data); criminal offence data; or payment card numbers or social security/PPS numbers — unless PixelFaerie has expressly agreed to handle such data in a separate written agreement. See Section 10.7 of the Full Agreement.
7. Retention of Personal Data
7.1 We retain personal data only for as long as necessary for the purposes set out in this Policy, having regard to the nature and sensitivity of the data, applicable legal obligations, and the need to defend legal claims.
7.2 Account and Billing Data. We retain account registration data for the duration of your engagement with PixelFaerie and for seven (7) years following termination or expiry of your agreement, to comply with Irish tax and commercial record-keeping obligations and to exercise or defend legal claims.
7.3 Client Content (as Processor). Following termination or expiry of the Full Agreement, PixelFaerie makes Client Content and Deliverables available for download for thirty (30) days, after which it is deleted from live systems. Backup copies may be retained for up to ninety (90) days thereafter, subject to ongoing confidentiality obligations, before deletion. PixelFaerie may retain data for longer where required by Applicable Law.
7.4 Communications and Support Records. We retain records of material communications for up to seven (7) years for legal compliance and dispute resolution purposes.
7.5 Anonymised Telemetry. Anonymised and irreversibly aggregated usage data may be retained indefinitely as it no longer constitutes personal data.
7.6 Marketing Data. Where you have consented to marketing communications, we retain your details until you withdraw consent or we receive a valid erasure request.
8. Your Rights Under GDPR
8.1 Overview. Under the GDPR and the Irish Data Protection Acts, you have the following rights in respect of personal data we hold about you as data controller:
- (a) Right of access — to receive a copy of the personal data we hold about you and information about how we use it (Article 15 GDPR).
- (b) Right to rectification — to ask us to correct inaccurate or incomplete personal data (Article 16 GDPR).
- (c) Right to erasure (“right to be forgotten”) — to request deletion of your personal data in certain circumstances, for example where the data is no longer necessary for the purpose for which it was collected (Article 17 GDPR).
- (d) Right to restriction of processing — to ask us to restrict processing of your personal data in certain circumstances, for example while a complaint is being investigated (Article 18 GDPR).
- (e) Right to data portability — to receive a copy of personal data you have provided to us in a structured, commonly used, machine-readable format, or to have it transferred directly to another controller, where processing is based on consent or contract and carried out by automated means (Article 20 GDPR).
- (f) Right to object — to object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will stop processing your data for that purpose immediately (Article 21 GDPR).
- (g) Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing (Article 7(3) GDPR).
- (h) Right not to be subject to automated decision-making — not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects (Article 22 GDPR). We do not carry out such automated decision-making.
8.2 How to Exercise Your Rights. To exercise any of the rights above, contact us at: dataprotectionofficer@pixelfaerie.com, or by post at: PixelFaerie Limited, Broomfield West, Midleton, Co. Cork, Ireland. We will respond within one month of receiving your request. We may need to verify your identity before acting on a request.
8.3 Rights in Relation to Client Content (Processor Role). Where PixelFaerie processes personal data in Client Content as your data processor, data subject rights requests relating to that data should be directed to you as the data controller. We will assist you in responding to such requests in accordance with Schedule 1 of the Full Agreement.
8.4 Complaints. If you are not satisfied with how we have handled your personal data, you have the right to lodge a complaint with the Irish Data Protection Commission (“DPC”) at www.dataprotection.ie, or with the supervisory authority in the EU member state where you are habitually resident, work, or where an alleged infringement occurred. We encourage you to contact us first at dataprotectionofficer@pixelfaerie.com — most concerns can be resolved quickly.
9. Cookies and Tracking Technologies
9.1 Our website at www.pixelfaerie.com uses cookies and similar tracking technologies. Cookies are small text files placed on your device that help us understand how visitors use our site, remember your preferences, and where you have consented, to deliver relevant analytics.
9.2 Cookie Consent. In accordance with the ePrivacy Regulations 2011 (Ireland) (implementing the EU ePrivacy Directive), we obtain your active, informed consent for any non-essential cookies before they are placed. Acceptance of this Privacy Policy, the Terms of Service, or the Full Agreement does not constitute consent to the use of non-essential cookies. Cookie consent is managed through a separate cookie consent tool displayed when you visit our website.
9.3 Cookie Categories. We use the following categories of cookies:
- Strictly necessary cookies — required for the Platform to function and cannot be disabled.
- Analytics cookies — help us understand site usage through anonymised or pseudonymised data (e.g. Google Analytics). Placed only with your consent.
- Preference cookies — remember your settings and preferences. Placed only with your consent.
- Marketing cookies — used to deliver relevant communications (if applicable). Placed only with your consent.
9.4 Managing Cookies. You can withdraw cookie consent or manage your preferences at any time through our cookie consent tool. You may also configure your browser to refuse or delete cookies, although this may affect the functionality of our website. For information on how to manage cookies in your specific browser, please consult the browser’s help documentation.
10. Security
10.1 PixelFaerie implements appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include: encryption of personal data in transit and at rest; access controls and multi-factor authentication; regular security assessments; incident response procedures; and staff training.
10.2 Personal Data Breaches. In the event of a personal data breach affecting personal data for which PixelFaerie is the data controller, we will notify the Irish Data Protection Commission without undue delay and, where feasible, within 72 hours of becoming aware, where the breach is likely to result in a risk to your rights and freedoms. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay.
10.3 In the event of a security incident affecting Client Content processed as data processor, PixelFaerie will notify you without undue delay and in any event within 48 hours, as provided in Schedule 1, DPA 6 of the Full Agreement and in Section 11.5 of the Full Agreement.
11. Links to Third-Party Websites
11.1 Our website and the Saije Platform may contain links to third-party websites, including Microsoft’s platform and related services. PixelFaerie is not responsible for the privacy practices or content of those websites. We encourage you to read the privacy policies of any third-party websites you visit.
11.2 The Saije add-in operates within Microsoft PowerPoint. PixelFaerie’s processing of personal data is as described in this Policy. Microsoft’s processing of data through its platform is governed by Microsoft’s own privacy policy and terms.
12. Children
12.1 Saije is a business and professional-use platform and is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data without parental consent, please contact us at dataprotectionofficer@pixelfaerie.com and we will take steps to delete such data.
13. Changes to This Policy
13.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons.
13.2 Material changes (affecting your rights or how we use your data) will be notified to you by email at least 30 days before taking effect. Minor or administrative changes will be notified at least 14 days in advance.
13.3 The current version of this Policy is always available at www.pixelfaerie.com/legal/privacy. A version history is maintained at www.pixelfaerie.com/legal/agreement/versions.
13.4 Continued use of the Platform after the effective date of any change constitutes acceptance of the updated Policy, subject to your rights to object or withdraw consent as described in Section 8.
14. Governing Law
14.1 This Privacy Policy and any non-contractual obligations arising from it are governed by the law of the Republic of Ireland. Any disputes relating to this Policy shall be subject to the exclusive jurisdiction of the courts of Ireland.
15. Contact Us
15.1 For any questions, concerns, or requests relating to this Privacy Policy or our data protection practices, please contact:
Data Protection Contact
General and Legal Enquiries
15.2 For complaints, contact the Data Protection Commission (Ireland): www.dataprotection.ie.