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PRIVACY POLICY

09/09/2022

I.I Introduction Who are we? We are KASPR SAS a limited company registered in
France. Our company registration (SIREN) number is 843898396 and our registered
office is at 38 Rue Dunois 75013 Paris , France.  Where we decide the means or
purpose of processing your personal data, we are the data “controller.”
What’s this policy about?

 

This policy explains how we process your personal data as a data controller when
we provide you with access to our website or to our other online services (the
“Services”).  
 
This policy also explains how we process personal data about you which may be
included within the business profiles we make available to our users (this is
described at section 3 of this policy).
 
You can opt-out at any time from our sharing your information with our clients,
by completing this form: opt-out.
We update this policy from time to time so please check back in.
How do you contact us?
(if you have questions about this policy or to exercise your rights)
Write to us at: privacy@kaspr.io.
 
If we can’t resolve your issue, and you are in the UK you can also get in touch
with the Information Commissioner’s Office: https://ico.org.uk/concerns. Or, if
you are in France, with CNIL: https://www.cnil.fr/. If you are based in another
country, you may also be able to liaise with your local regulator.
What are your rights?

You have the following rights, although these rights may be limited in some
circumstances:

 * Ask us to send a copy of your data to you or someone else 
 * Ask us to restrict, stop processing, or delete your data
 * Object to our processing of your data
 * Object to use of your personal data for direct marketing
 * Ask us to correct inaccuracies 

If we rely on consent to process data, or send direct marketing, you can
withdraw consent by email to the address above.

 

I.2. Personal Data and how we use it (for ou website visitors and users)

Your data How we use it Sources and recipients
Enquiry data (information we receive when you get in touch) including:
 * Name
 * Location and contact details
 * Other personal data you send to us as part of enquiries.

We process this information to respond to your support and other enquiries.
 
Legal basis
We may process this data in accordance with the terms of our contract with you
(where we need this information to provide Services to you) or to take steps at
your request prior to entering into a contract.
We also use this to pursue our legitimate interests, including: (a) our interest
in responding to enquiries to ensure smooth operation of our business and
services; and (b) to understand our customers and improve our website and
Services, by taking on-board your feedback.
 
More information
You may be required to provide us with certain information for us to respond to
your enquiries.
Sources
 * We collect this information from you

Recipients
We may store this information with our suppliers, including, in particular,
HubSpot Inc. and Userback Pty Ltd.  

Account data

(information we receive when you set-up and use your account via our Services)
including:

 * Username

 * Name

 * Preferences (such as language, features, and other settings) 

 * Email, phone, employer, and address details

 * Billing information (amounts, invoices, billing frequency, records of
   payment)

 * If you choose to connect your social media accounts to our Service, we may
   collect basic information from that social media platform such as your name &
   location. 

 * If you choose to connect your Google accounts to our Service, we may collect
   store and uses your informations to provide our service.

How long we keep it

We keep your account data for 6 years from when our relationship with you ends.

We process this information to set-up, maintain, administer and manage your
account and the Services, to process and fulfil your orders, to communicate with
you regarding purchases, support, feedback and enquiries, to let you know about
security, privacy & other announcements relating to the Services, for billing
purposes, and to respond to your enquiries. Google user data are use to provide
you an engagement tool and to improve your experience in Kaspr

Legal basis

We process this information in accordance with the terms of our contract with
you (where we need this information to provide Services to you) or to take steps
at your request prior to entering into a contract.

We process certain billing information to comply with our legal obligations
include our accounting and tax obligations.

We also use this information to pursue our legitimate interests in responding to
enquiries, detecting & preventing fraud and unlawful activity which may
jeopardise or negatively affect the Services, enforcing our rights and the
rights of others, and to understand our customers and improve our Services (for
example for testing, research, and statistical analysis). 

More information

You may be required to provide us with certain information for us to respond to
your enquiries. 

Sources

 * We collect this information from you

Recipients

We may store this information with OVH Limited and  MongoDB (a Group including
MongoDB, Inc., MongoDB Limited, and MongoDB Serviços de Software No Brasil
LTDA).

We do not process payment data (such as your card, PayPal or other payment data)
directly, this is instead processed by our payment processor (Stripe).

Marketing

We process the following information about you to send you emails to let you
know about news and updates relating to us and our Services: 

 

 * Name
 * Contact information (such as email address)

How long we keep it

Until you have opted-out of marketing communications.

We process this information to send you marketing communications.

Legal basis

We process your personal data for this purpose where either: (a) we have your
consent; or (b) where you are a corporate subscriber or decide not to opt-out of
such marketing in the course of registering with the Services, in pursuit of our
and your legitimate interests in ensuring you find out about new features, news
and updates, to help you make the most of the Service.

More Information

You can withdraw consent or opt-out at any time by dropping us a line or
clicking on the unsubscribe link in our emails.

Sources

We collect this information from you.

Recipients

We may use Active Campaign LLC and Sendinblue to manage our email marketing.

Referrals

We process the following information about you to send you emails inviting you
to register for our Services: 

 

 * Name
 * Email address

How long we keep it

We store your email address until you have opted-out, and offer you the ability
to easily opt-out when we send you the invitation.

If one of our customers wants to refer their contacts to our Services, they can
provide us with your name & email and we will send you an email invitation to
visit our website.

Legal basis

We process your personal data for this purpose in pursuit of our and your
contact’s legitimate interests in inviting you to use our Service.

Sources

We collect this information from the contact who refers you.

Recipients

We may use Active Campaign LLC and Sendinblue to manage our email marketing.

Analytics

(data about how users interact with our Services which might (but not always) be
associated with a unique ID) including:

 * browser type and version, IP address, approximate location and time zone,
   access logs, device type and settings, operating system, & other information
   provided by browser or device;
 * use you make of our Services, including the URLs and content you visit,
   actions and clickstream to, through and from our website and Service, date
   and time, page response times, errors, length of visits to website pages,
   interaction (such as scrolling, clicks and mouse-overs) data, details of the
   website which directed you to our Services. 

How long we keep it

After 26 months underlying data is deleted, but we may retain anonymous,
aggregated statistics generated from that data.

We use our Services, HubSpot and Google to collect data about visitors to our
website and Services, to understand how many people visit, where they come from,
and how they interact with our Services and website, and to help us improve and
maintain our Services and address bugs.

Legal basis

We may process website analytics data which uses cookies or similar technologies
with your consent (if you give it).

If we undertake analytics without storing or accessing information on your
device (for example by reviewing log information on our servers which explain
how our Services have been used) then we do this in pursuit of our legitimate
interests in understanding how people use our Services, and improving them. 

More information

You can find out more about how Google uses data by reviewing their privacy
policy here.

You can withdraw your consent for Google analytics by using the following
link: Google Analytics. 

Sources

We use HubSpot and Google’s services to collect this data and otherwise collect
it from you.

Recipients

Google and HubSpot in the USA collect and process analytics data on our behalf.

Where explicit retention periods are not described above, we hold data for as
long as necessary bearing in mind the purpose for which it was collected. To
determine the appropriate period, we consider the amount, nature, and
sensitivity of the data, the potential risk of unauthorised access, and legal
requirements.

 

I.3 Personal data and how we use it (Business contacts in our Database) Your
data How we use it Sources and recipients

Profile data:

 * Name
 * Contact information (including email, telephone number, social media profile
   URL)
 * Employer/company
 * Job title & information about skills which may be published through
   professional networking services & other sources
 * Approximate location of employer or workplace (e.g. country or city)

How long we keep it

We hold data for as long as necessary to provide our Services, to comply with
legal obligations, or to enforce our policies or resolve disputes, bearing in
mind the purpose for which it was collected.  To determine the appropriate
period, we consider the amount, nature, and sensitivity of the data, the
potential risk of unauthorised access, and legal requirements.

We collect business profile information from trusted business partners and
various public sources, to enhance and maintain our database, and to keep it
current and up to date, so we can provide our Services.

We make our database available to our registered customers for the following
purposes:

 1. to enable our clients to find contact, job title & employer information
    relating to sales leads, for use predominantly in B2B marketing campaigns,
    recruitment purposes, and for the purpose of assisting those clients to
    verify information supplied by their own customers as described at (b):
 2. certain clients compare data from our database with information supplied by
    their own customers, to help ensure those customers are who they claim to
    be.

For more detailed information about the way this personal data is used, please
get in touch by writing to privacy@kaspr.io.

Legal basis

We process this data to pursue legitimate interests, including:

(a) our interests carrying on our business and providing our Services; 

(b) the interests of our clients in obtaining information for business marketing
purposes, and to help detect and prevent fraud, misuse of their services and
money laundering;

(c) the interests of people in our database, in receiving more information
relevant to B2B products and services;

(d) the interests of the public in preventing fraud, misuse of services and
money laundering.

More information

You can opt-out at any time from our sharing your information with our clients,
by filling out this form: opt-out.

Sources

We collect this data from public sources, business directories & our data
partners from time to time.

Recipients

Information in our database is made available to our registered customers.

 

I.4 Cookies analytics and similar technologies

Cookies, pixels and other technologies store and access data on your device to
help websites and apps work.  This table explains their purpose, how long they
last, and who else can access their data.  We get your consent to use them
unless they’re essential for our sites, apps or services.

Most browsers allow control over cookies, for more information: Google
Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet
Explorer | Opera | Apple Safari.

Other settings to disable certain similar technologies: Windows Advertising
ID | iOS and Mac OS Ad Tracking | Google Analytics | Your Ad Choices.

Cookie/data

Duration 

Purpose

Access

Access_token

24 months

Authentication – To deliver our Services and third party services which may be
embedded into our own Services (such as social media network connectivity).

Kaspr

__stripe_mid

12 months

Payment: Set for fraud prevention purposes and helps us assess the risk
associated with an attempted transaction.

Stripe 

Preferences – To remember information about your preferences such as your
preferred language and configuration.

Axeptio_cookies

12 months

Cookies preferences

Axeptio Analytics – To help us understand how you use our Services, such as how
often, so we can improve Services and deliver a better experience and for us to
carry out research and statistical analysis to help us develop new content,
products and services. _ga

24 months

Marketing / tracking

Google Analytics

Hubspotutk 6 months Marketing / tracking = Track visitors identity Hubspot
Prism_* 1 month Marketing / tracking Active Campaign _hstc 6 months Marketing /
tracking = track visitor session Hubspot Advertising – To help us deliver
in-Service advertising to you (which may be served by, or facilitated by, third
parties). These are also used to help us and our partners and vendors measure
the effectiveness of advertising and whether it was actually served to you. _fbp

3 months

Marketing / tracking / advertising

Facebook pixel

_gcl_au

3 months

Marketing / tracking / advertising

Google adsense

_ga_*

24 months

Marketing / tracking / advertising

Google Adwords

 

1.5 Transfers and Disclosure

Transfers

Your data is generally stored in the UK or European Economic Area.     Where we
use data processors outside the UK and European Economic Area and transfer
personal data to a country which does not provide an adequate level of
protection, we use contracts approved by the Information Commissioner’s Office
and/or European Commission which give personal data protection similar to that
which it has in the UK or Europe.  For more information drop us a line using the
contact details at the start of this policy.

Disclosure

Other than as set out above, we may disclose your personal data:

 * Where required by law, government, competent authorities or the courts or to
   establish, exercise or defend our legal rights, and for the purposes of
   preventing crime and fraud (for example, we may share personal data with our
   professional advisors, investigators, or credit reference agencies).
 * With members of our corporate group, suppliers and subcontractors, as
   necessary for the purposes set out in this policy.
 * If involved in an investment, merger, acquisition, or sale of our
   organisation or assets, personal data we hold may be shared on the basis of
   the legitimate interests of us, our shareholders, customers and other parties
   to a transaction, unless those interests are outweighed by prejudicial
   impacts upon you.

 

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