• INTRODUCTION
• WHAT INFORMATION DO WE COLLECT?
• HOW DO WE USE THE INFORMATION WE COLLECT?
• WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?
• WHAT RIGHTS DO YOU HAVE REGARDING YOUR INFORMATION?
• NOTICES FOR CALIFORNIA RESIDENTS
• NOTICE FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA
• ADDITIONAL POLICIES

INTRODUCTION

This privacy policy is designed to inform users of our website about how we gather and use personal information collected by us in connection with our website. We will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with applicable U.S. laws. In this policy, "user," “your” or "you" refers to any individual or entity using the website, whether by browsing the website, registering with us by creating an account, or participating in any other activities available through the website.  

This Privacy Policy does not apply to the data Kyruus processes on behalf of our customers (Customer Data) in our capacity as a processor. Your use of the KyruusOne Platform as a customer of Kyruus, including use of our associated mobile applications (Mobile Apps), is covered under the KyruusOne Platform Product Privacy Policy.

WHAT INFORMATION DO WE COLLECT?

KYRUUS WEBSITE VISITORS

You are free to explore our website without providing any Personal Information about yourself. When you visit our website or register for more information, we request that you provide Personal Information about yourself, and we collect Navigational Information.

"PERSONAL INFORMATION"

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Website, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.

INFORMATION WE COLLECT FROM THIRD PARTIES

From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.

NAVIGATIONAL INFORMATION

We may collect web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the website efficiently and to collect data related to your usage of and interaction with the website. Such collected data ("Navigational  Information") may include the address of the websites you visited before and after you visited the website, your geographic location, the search terms you used, the date and time of your visit, the type of browser you are using, your Internet Protocol (IP) address, what pages in the website you visit and what links you clicked on, and whether you opened email communications we send to you. If you use a mobile device to access our website, we may also collect information about the geographical location from which you accessed the website. 

In order to collect Web Tracking Information and to make your use of the website more efficient, we may store cookies on your computer. These cookies will be stored (1) until the user closes the browser, (2) until the user logs off the website, or (3) until they expire.  For more information about cookies, visit www.allaboutcookies.org. 

We may also use web tracking technologies that are placed in web pages on the website or in email communications to collect information about actions that users take when they interact with the website or such email communications. Navigational Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the website, but this may affect the performance of the website. Likewise, most mobile devices allow you to disable the ability for geo-location to be collected from your mobile device, but this may also affect the performance of the website. 

HOW DO WE USE THE INFORMATION WE COLLECT?

WE NEVER SELL PERSONAL INFORMATION

We will never sell your Personal Information to any third party. 

PERSONAL INFORMATION

We will use and store Personal Information for the purpose of delivering the website content, and to analyze and enhance the operation of the website.

We may use the Personal Information you provide or that we collect about you, as well as non-personally identifiable information, to fulfill your requests for our products, programs, and services, to respond to your inquiries about our offerings, and to offer you other products, programs or services that we believe may be of interest to you.  We sometimes use this information to communicate with you.

NAVIGATIONAL INFORMATION

We use Web Tracking Information to administer the website and to understand how well our website is working, to store your user preferences, to develop statistical information on usage of the website, and to analyze the productivity of users of the website. This allows us to determine which features visitors like best to help us improve our website, to personalize your user experience, and to measure overall effectiveness.

You may disable the collection and use of your location data through browser-, operating system- or device-level settings. Consent concerning location data may be withdrawn at any time by emailing: privacy@kyruus.com.

LEGAL EXCEPTION

Notwithstanding the above, we may in any event use Personal Information, and any other information collected through the website to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy and the Terms of Use) with you, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.

EMAIL COMMUNICATIONS

If you register and provide your email address, we will send you updates and promotional emails, including newsletters. If you wish to opt out of newsletters and promotional emails, you may do so by following the "unsubscribe" instructions in the email.

WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?

PERSONAL INFORMATION

We will not disclose your Personal Information to any third parties except as follows:

(i) to third party contractors engaged to provide services on our behalf ("Contractors"), such as analyzing data and usage of the website, operating the website or providing support and maintenance services for the website, performing marketing support, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us; and

(ii) when we have your consent to share the information.

Aggregated and De-identified Data – 

As noted above, this Policy addresses the collection and sharing of Personal Information, that is, information that can reasonably be connected with a particular user.  We may occasionally de-identify and/or aggregate Personal Information – to the extent permitted by law – to the point that it can no longer be associated with a particular user.  When that occurs, such information is no longer Personal Information.

Use, Sharing, and/or Sale of Non-personal Information – We may aggregate data on user behavior with respect to the Site and/or Service.  This data does not enable identification of individual users and is not Personal Information as defined by this Policy.  As such, our use, sharing, and/or sale of Non-personal Information is not restricted by this Policy.

WEB TRACKING INFORMATION

We disclose Web Tracking Information to Contractors, in order to analyze the performance of the website and the behavior of users, and to operate and improve the website. Certain Web Tracking information that is not correlated to individual user Personal Information, such as the popularity ranking of certain pages of the website, may be published on the website and so disclosed to all users of the website. Kyruus may disclose to its institutional and corporate subscribers how the users of the website affiliated with the subscriber use the website.

ADDITIONAL DISCLOSURES

We may share information with businesses that are legally part of the same group as the Company, or that become part of that group.  We reserve the right – in the event of a business transition such as a merger – to transfer Personal Information to a new business owner, on the condition that such Personal Information must be treated in accordance with this Policy. We reserve the right to disclose any information we collect in connection with the website, including Personal Information to any successor to our business as a result of any merger, acquisition, asset sale or similar transaction.

We will also share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary and in our legitimate interests to:

• comply with a legal obligation, process or request;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (i.e., exchanging information with other companies and organizations for the purposes of security and/or fraud protection).

WHAT RIGHTS DO YOU HAVE REGARDING YOUR INFORMATION?

PRIVACY SETTINGS/OPT OUT

If you would like your Personal Information or geographical location data permanently removed from our database, please contact us at support@kyruus.com. We will delete your account and you will no longer receive marketing email from Kyruus. Your removal from the mailing list or database will not remove records of past transactions or delete information stored in our data backups and archives. If you opt-out of allowing Kyruus to collect geographical location data, the performance of the website may be affected, and you may not be able to access certain applications within the website.  Please note that this opt-out process may take some time to complete, consistent with applicable law.

ACCESS AND UPDATING OF INFORMATION

Kyruus is happy to allow you to review or amend your email address, contact details at any time. Please contact us by sending an email to: support@kyruus.com.

NOTICES FOR CALIFORNIA RESIDENTS

THE CALIFORNIA CONSUMER PRIVACY ACT

The California Consumer Privacy Act (“CCPA”) went into effect on January 1, 2020.  The law gives California residents certain rights to access and delete their “Personal Information,” and to opt out of the sale of their Personal Information.  The CCPA also requires businesses to disclose in their privacy policies information about how they collect, use, and share Personal Information.  This section of the privacy policy contains the disclosures Kyruus is required to make and summarizes the rights that California residents have under the CCPA.

For purposes of this section, the term “Personal Information” means Personal Information under Cal. Civ. Code 1798.140(o).  To the extent that any other provision of this Privacy Policy conflicts a provision of this section, the provision in this section controls as to California residents. 

a. Categories of Information Collected, Disclosed, and Sold in the Past 12 Months

The below table discloses the categories of Personal Information that Kyruus has collected in the past 12 months from the effective date of this privacy policy.  For each category of Personal Information, the table identifies: (i) whether Kyruus has sold to a third party, or disclosed for a business purpose, the category of Personal Information; and (ii) the categories of third parties to whom the information was disclosed or sold.  The table does not include Personal Information provided to us by providers or other customers in a business-to-business context. 

b. Summary of California Residents’ CCPA Rights 

California residents may:

• Request that we delete their Personal Information (a “Request to Delete”).
• Opt-out of the sale of their Personal Information (a “Request to Opt-Out”).
• Request information about our collection, use, and sharing of their information (a “Request to Know”), including:
• the categories and specific pieces of Personal Information we have collected about them;
• the categories of sources from which we have collected their Personal Information;
• the business or commercial purpose for collecting or selling their Personal Information;
• the categories of their Personal Information that we have sold; and
• the categories of third parties with whom we have shared, disclosed for a business purpose, or sold their Personal Information, and which categories of Personal Information we have sold to which categories of third parties.

Consistent with the anti-discrimination protections provided by the CCPA, we will not discriminate against users for exercising these rights.  Consistent with Cal. Civ. Code 1798.125, we may charge users different prices, or provide different levels or quality of goods or services, if the difference is reasonably related to the value of their data.  We may also offer financial incentives for the collection, sale, or deletion of your Personal Information.

California residents, such as providers, who share their Personal Information with Kyruus in their capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency have the right to submit a Request to Know but do not have the right to submit a Request to Delete.

c. Submitting “Requests to Know”

California residents may submit a Request to Know by filling out the form found at https://www.kyruus.com/data-subject-access-request.

California residents may submit two types of Requests to Know: (1) a request for the specific pieces of Personal Information that Kyruus has collected about you in the past twelve months; or (2) a request for the categories of Personal Information that Kyruus has collected about you in the past twelve months.  Depending on the type of request you submit, we will need to verify your identity to a reasonable degree of certainty or a reasonably high degree of certainty. 

• If you are not a Kyruus accountholder, we will attempt to verify your identity by matching information that you provide to us with information that we have on file for you. This may include your name, email address, country and state of residence and photo.  For Requests to Know the specific pieces of information that Kyruus has collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the request. 

If Kyruus is able to verify your identity, we will respond to your Request to Know by:

(a) providing the requested information; or (b) explaining why the CCPA does not require us to provide the requested information.  If Kyruus is unable to verify your identity, Kyruus will respond by explaining why it cannot verify your identity.

We will confirm receipt of your Request to Know within 10 business days and will respond to your request within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.  If the CCPA requires us to provide the information requested, we will provide the information free of charge and in a readily useable portable format.  We have no obligation to provide Personal Information to you more than twice in a 12-month period.  If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

d. Submitting “Requests to Opt-Out”

California residents may opt out of the sale of some or all of their Personal Information by clicking the “Do Not Sell” link in our cookie management tool located on our home page or you may filling out the form found at https://www.kyruus.com/data-subject-access-request. 

Within 15 business days of receiving a Request to Opt-Out, Kyruus will:

• Not sell your Personal Information unless and until you subsequently provide express authorization for the sale of your Personal Information.
• Notify any third parties to whom we sold your Personal Information after we received your Request to Opt-Out but before we complied with the request, and instruct them not to sell your Personal Information.
• Not ask for permission to sell your Personal Information for 12 months after receiving the Request.

California residents who have opted out of the sale of their Personal Information may opt back into the sale of their Personal Information by filling out the form found at https://www.kyruus.com/data-subject-access-request.

e. Submitting “Requests to Delete”

California residents may submit a Request to Delete by filling out the form found at https://www.kyruus.com/data-subject-access-request.  You may request that we delete all or some of your Personal Information.

We will confirm submission of your Request to Delete within 10 business days.  When you submit a request, we will need to verify your identity to a reasonable degree of certainty or a reasonably high degree of certainty depending on the type of Personal Information we have collected about you.

• If you are not a Kyruus account-holder, we will attempt to verify your identity by matching information that you provide to us with information that we have on file for you.  This may include your name, email address, country and state of residence and photo ID.
• If Kyruus is able to verify your identity, we will respond to your request by (a) deleting your Personal Information and, if applicable, directing any of our service providers to delete your Personal Information; or (b) explaining why the CCPA does not require us to delete your Personal Information.  Kyruus may choose to delete Personal Information by de-identifying, aggregating, or completely erasing the information.  We will specify the manner in which we delete your Personal Information. 

If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

f. Authorized Agents

California residents may submit Requests to Know, Requests to Opt-Out, and Requests to Delete through an authorized agent.  Unless the agent provides Kyruus with a power of attorney executed by the California resident, Kyruus may require the California resident to verify their identity with Kyruus and/or to provide Kyruus with written confirmation of the agent’s authority to make the request.

g. Minors

Kyruus does not have actual knowledge that it sells the Personal Information of minors under 16 years of age.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT NOTICE

On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like Kyruus to disclose how they respond to "Do Not Track Signals"; and whether third parties collect personally identifiable information about users when they visit Kyruus.

(1) Kyruus does not respond to "do not track" signals.

(2) Kyruus does not authorize the collection of personally identifiable information from Kyruus users for third party use through advertising technologies without separate member consent.

NOTICE FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA

We do not market our services to residents in Europe, nor do we have a place of business in Europe.  We are thus not subject to Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of Personal Information and free movement of such Information, known as the General Data Protection Regulation (“GDPR”).

If you reside in the European Economic Area (EEA), please be aware that if you voluntarily provide us any personal information, that information will be transferred from the EU to data centers located in the United States for processing.

Although we are not subject to the GDPR, nevertheless we will honor your data privacy rights upon request.  If you are a resident of the EEA, you have the right, as applicable under the GDPR, to the following:

• Request an accounting of Personal Information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
• Request that we correct or update Personal Information that pertains to you.
• Request that we delete Personal Information that pertains to you.
• Fully or partially withdraw your consent to the collection, processing, and/or transfer of your Personal Information.

If you believe we are unlawfully possessing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find contact details here: https://edpb.europa.eu/about-edpb/board/members_en.

To request an accounting of your Personal Information, a correction or update to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your Personal Information, please fill out the form found at https://www.kyruus.com/data-subject-access-request. Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are legitimate grounds for further processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

ADDITIONAL POLICIES

SECURITY

We have put in place appropriate physical, electronic, and managerial procedures and security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures.

THIRD PARTY ACTIVITY (INCLUDING LINKS AND COOKIES

The website may contain links to other websites, cookies or other materials from, or which may be operated by, parties other than Kyruus, whose information practices may be different than ours. Kyruus is not responsible for the privacy practices, the content or the actions of those third parties. This Privacy Policy applies solely to information collected by Kyruus in connection with the website.  Please refer to the Kyruus Cookie Policy for further information about how Kyruus uses cookies.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information in accordance with the appropriate statutory limitation periods as provided by local law, or in other cases, for as long as such personal data is needed for the following reasons:

• as required by law or court order;
• as needed to defend or pursue legal claims;
• in line with industry codes of practice; and/or
• as required for legitimate business purposes.

AMENDMENTS

Kyruus may modify or amend this policy from time to time. If we make any material changes, as determined by Kyruus, in the way in which Personal Information or Web Tracking Information is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you at the website. Notwithstanding any modifications we may make, any Personal Information and Web Tracking Information collected by Kyruus from you will be treated in accordance with the privacy policy in effect at the time information was collected, unless we obtain your consent otherwise.

COMPLAINTS

In the event that you wish to make a complaint about how we process your Personal Information, please contact us in the first instance at support@kyruus.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with a relevant supervisory authority in the country in which you live or work, where you think we have infringed information protection laws.

ACCESSIBILTY

Any person with a disability that prevents or restricts them from accessing this Privacy Policy through the Apps or through Kyruus’s website may request a copy of the Privacy Policy in an alternative format by contacting Kyruus at support@kyruus.com or 617.419.2060.