This Privacy Policy describes how Kloosive jsc. and its affiliates (collectively, Kloosive, “Company”, “our”, “we”, or “us”) collects, uses and discloses information, and what choices you have with respect to your information. This Privacy Policy applies to Kloosive’s website available at www.kloosive.com ( “Website”), and any other communication between an individual (“you” or “User(s)”) and the Company with regards to the access or use of the Kloosive widget and/or the Website (collectively  “Services”). 

This Privacy Policy is incorporated by reference to the Kloosive Terms of Service or any other separate agreement that you have executed with Kloosive that governs your access and use of the Services (“Terms”). Capitalized terms that are not defined herein, shall have the meaning ascribed to them in the Terms. 

The term “Personal Information” as used in this Privacy Policy means information that relates to an identified or identifiable individual. 

Please read this Privacy Policy carefully and make sure that you fully understand and agree with it. If you do not agree to the provisions of this privacy policy, do not access or use the Services, the Website, or any other content, service, or software that we provide or make available.

You are not legally required to provide us with any Personal Information, but please keep in mind that without it we may not be able to provide you with the full range of Services or with the best user experience when using the Services.

Information we Collect and Receive

We collect various types of information, including Personal Information, when each customer or individuals acting on their behalf, or an individual that visits the Website or accesses and uses certain Services as specifically set forth in this Privacy Policy.

Information You Provide

1. Account Information. When you register and create (or update) an account that enables you to access and use the Kloosive Solution, for your benefit or for the benefit of a Customer, we collect certain Personal Information including your full name, email address, and phone number. Your account may also include additional information you provide to us, such as domains (i.e., where the Kloosive Solution will be used). In addition, when you purchase a license to use the Kloosive Solution, you provide us (or our third-party payment processor) with your billing information such as credit card information, banking information, and/or billing address. The Personal Information that is part of your account comes directly from you and may as set forth above include your Personal Information or the relevant Customer Personal Information. You may edit certain elements of your Personal Information at any time via your account or by sending us an email to hello@kloosive.com requesting such edits.
2. Device and Technical Information. We collect information about the devices used to access the Website, including the following: IP Address, referring URL and domain, device type, operating system and version, browser type and version, and screen resolution.
3. Support Information. When you interact with us via support email or to provide us with feedback, we will collect certain Personal Information generated by your use of the Website or Personal Information that you choose to share with us. We may, in accordance with applicable law, document your communication with our support team or with other similar contact channels.

Information Collected from Other Sources

1. Marketing Communication. When you sign up to receive a demo or any other marketing communication from us including news regarding the Services, we will collect and process your name, email address, and phone number, in order to comply with your request. We may also collect additional information such as your role or job title at the company you work for and details about the company you work for.
2. Log Information. Our servers automatically collect information when you access or use the Website and record it in log files. The log information we collect may include your IP Address, the address of the web page visited before using the Website, browser type and settings, and cookie data.
3. Cookies. We use cookies and similar technologies in order to operate and improve the Website, serve and measure the effectiveness of advertising campaigns, and analyze the Website traffic and trends. We may share non-identifiable/aggregated extracts of such information with our partners for our legitimate business purposes.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

We use Persistent Cookies to remember your log-in details and make it easier for you to log in the next time you access the Website. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Website’s features and tools. 

Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Website.

Information from Social Media. We also collect social media handles, content, and other data posted on our official social media pages (such as feedback, reviews, email address, and other information). If you submit any such information (including Personal Information), note that we may (at our discretion) store and present such information to other users of the Services. If you wish to remove such information, please contact us at hello@kloosive.com.

Data obtained through analytics tools. We use analytics tools (e.g., Google Analytics) and others to collect data about the use of the Website. Analytics tools collect data such as IP Address, how often Users visit the Website, which pages they visit and when, and which website, ad, or e-mail message brought them there.

Information We Collect from Third Parties. We may collect information about you from other sources that may include your Personal Information. These sources may include the following: (i) third parties providing your information in connection with any affiliate program; (ii) third parties requesting services for or on your behalf; (iii) third parties providing information in connection with any claims or disputes; (iv) our Service Providers (as defined below), such as third-party payment processors and social media services; (v) publicly available sources; and (vi) marketing service providers. We may combine the information collected from third parties as set forth above with other information which is in our possession.

Information Collected in Accordance with Applicable Law. We will also collect the Information we are required or otherwise authorized to collect under applicable laws to authenticate or identify you or to verify the information you have provided, or we have collected from you via the Services.

Communications.

We may contact you, via email or phone about changes to the Services, updates to your account, billing issues, and important notices related to the Services, such as security notices or notices regarding your account with us. You may not opt-out of these communications. In addition, we may from time to time send you newsletters, updates on new features, offerings, events, special opportunities, and other marketing or promotional emails. You may opt-out of receiving these emails by clicking on the unsubscribe link, which is part of the emails you receive, or by sending us an email to hello@kloosive.com requesting to no longer receive such communications.

How We Use Your Information

We use the information that we collect in accordance with the Terms; your instructions; or for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how the Services are used, optimizing our marketing, customer service, and support operations, and protecting and securing our Users, ourselves and members of the general public.

If you reside or are using the Services in a jurisdiction governed by privacy laws which determine that “consent” is the only legal basis for the processing of Personal Information (in general, or specifically with respect to the types of Personal Information you choose to share via the Services) your acceptance of the Terms and of this Privacy Policy will be deemed as your consent to the processing of your Personal Information for all purposes detailed in this Privacy Policy. If you wish to withdraw such consent, please contact us at hello@kloosive.com

Specifically, we use Personal Information to:

1. provide, maintain and update the Services (including your account), and any other products or services we may offer. For example; to provide you with the Services in accordance with the Terms, address/prevent any errors in the Services, or to provide you with assistance and support in relation to the Services;
2. to authenticate the identity of our Users, and to allow them to access and use the Services.
3. communicate with you. For example; when you send us an email, make a request or inquiry, or share a comment or concern;
4. send you service, technical, updates, administrative messages, and other types of communications such as marketing and advertising communications relating to our products or services;
5. improve and optimize the Services. For example; improving the features of the Services based on historical usage;
6. detect, investigate and prevent fraud, security risks, any misuse of the Services, violations of this Privacy Policy or the Terms and other illegal activities;
7. to create aggregated statistical data, inferred non-personal information or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services;
8. billing, account management, and other related matters. For example; to contact you about an invoice or rejected payment method;
9. respond to court orders, lawsuits, subpoenas, and government requests, and as required to comply with applicable law and our legal obligations; and
10. carry out any other purpose readily apparent to you or described to you at the time the information is collected.

How your Personal Information is Shared

1. Service Providers. We may engage selected third-party companies and individuals to perform services complementary to our own (collectively, “Service Providers“). Our Service Providers may have access to Personal Information, depending on each of their specific roles and purposes in facilitating and enhancing the Services, and may only use the information for such limited purposes as determined in our agreements with them.
2. Customer. We may share Personal Information with our Customer when you are using the Website on behalf of such a Customer.

For the avoidance of doubt, we may share Personal Information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such Information non-personal, non-identifiable and anonymous.

How Long we Retain your Information

We will retain your Personal Information related to your account for as long as your account is active, in accordance with the Terms, to resolve disputes, and comply with applicable law. After you request, by email, to have your account be closed, or if relevant, the Customer’s account, we may retain your Personal Information for up to thirty (30) calendar days to allow us a reasonable time to properly close your account (or, if longer retention of certain data is required under law, we will retain such data for such longer period of time). After such period, we may retain certain Personal Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy, including without limitation, to conduct audits, comply with our legal obligations, resolve disputes, and enforce the Terms. If you do not have an account, we will retain your Personal Information to comply with our legal obligations, resolve disputes, enforce the Terms, all as required or otherwise permitted under applicable law, whichever is shorter. Once this period has expired, we will delete your data. If we use your Personal Information in an aggregated anonymous format, for business purposes, it will not be deleted. You will not be identifiable from this data.

How We Protect Your Information

The security of your Personal Information is important to us. We have deployed appropriate security measures to protect the Personal Information we collect from misuse, damage, or unauthorized access. The measures we use take into account the applicable industry standards, the available technology, and the Personal Information we collect. However, while we take steps to safeguard your Personal Information, we cannot guarantee complete protection and security for information transmitted over the internet, information that is stored on our servers or that is in our or any third party’s possession.

Your Rights

You may exercise any of your applicable legal rights in connection with your Personal Information collected by Kloosive as detailed in this Privacy policy. In order to do so, kindly contact us at hello@kloosive.com

• The consent you provided to Kloosive in connection with the collection, use and processing of your personal information may be withdrawn at any time.
• Request to receive confirmation of whether your Personal Data is being processed.
• Request to receive a copy of your Personal information that you provided to Kloosive
• Request that Kloosive correct the specific Personal information that Kloosive is holding
• Request that Kloosive erase Its Personal information
• You have the right to complain to a Data Protection Authority if you believe that your rights have been violated.

Modifications to this Privacy Policy and to the Services

Kloosive reserves the right, at its sole discretion, to change or modify or to add or remove portions of the Privacy Policy at any time (“Updates“). You will be deemed to have accepted any Update by continuing to use Kloosive.

Additional Information and Contact Details

While the Services may contain links to other websites or services, we are not responsible for their privacy practices and encourage you to pay attention and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to the Services.

Suppose you are subject to the GDPR and not satisfied with our response or you believe that we are not processing your Personal Information in accordance with applicable law. In that case, you have the right to lodge a complaint with your local Data Protection Authority. You can find the contact information for your local Data Protection Authority here. 

Controller/Processor roles

Under the GDPR, there is a distinction between the “controller” and the “processor” of personal data (as defined under these laws). In general: (a) we act as an independent data controller with respect to Customer account data, and the applicable Customer acts as a data controller with respect to its account data, (b) we act as a data controller with respect to personal data of the Website visitors, and (c) we act as a data processor with respect to Customer user data, and the applicable Customer acts as a data controller with respect to its user data.  Please note that where we act as data processors with respect to your personal data, you must contact the relevant Customer who acts as the data controller with respect to your personal data, to exercise your rights.