Klaar Digital Solutions Private Limited (Registered Private Limited Company in India), hereafter referred to as "Klaar", "we", "our", "us" and its derivates, provides a software-as-a-service solution for its customers, which can be used in organizations and (or) their work teams to manage multiple aspects of work such as but not limited to performance management, goals and okrs, talent development such as mentoring, coaching, 360 degree feedback, and employee engagement.

This Privacy Policy explains how Klaar collects, stores and processes  Personal Information of its customers and end users. This Privacy Policy is referenced in our Terms of Service and forms a part of the same. Before you use our service or submit any personal information in our service, please review this Privacy Policy carefully and contact us if you have any questions. By using our service you agree to the practices outlined in this Privacy Policy. If you do not agree to this privacy policy, please do not use our service.

This Privacy Policy describes how we collect, store and process to the following types of Personal Information at Klaar
1. Customer Data - data we collect, generate, process and analyze of the end users on our customer's behalf which is essential to deliver the service to our customer
2. Usage Data - data we college, generate, process and analyze for improving Klaar's services
3. Website visitor data - data we collect, generate, process and analyze from visitors of https://www.klaarhq.com. and any sites owned and operated by us (hereafter referred to as "Sites"), participants at our physical and virtual events, physical and virtual forums and communities, users who interact with ads, content, emails or any other communication which is created and (or) governed by us.

We will outline our practices based on the following points:
1. Data Collection & Processing
2. Data Use
3. Data Retention
4. Use of cookies
5. Data Security
6. Data Subject Rights
7. All additional points/notices

Data Collection
Customer Data: We collect and generate following types of personal information for our customers and end users (users who our customer have authorized to use our service in their context).
User account - email, hashed password
profile information - name, title, team, work experience and any additional information and media submitted by end users, their organization or their co-workers
usage information such as connectivity, IP address, type and operating system of device and other data from device, activity logs
content created by end users such as goals, OKRs, survey responses and any other content created by the end user through the use of our services
direct communication with us - recording and transcripts of communication with us for support queries and user enablement activities
Usage Data: We collect and generate all the same types of data mentioned above.

Data Processing and Use
We process, analyze and use the Usage Data (including email address) and Website visitor data for the following purposes:
As needed to deliver our Services
To authenticate our customers and end-users
To comply with our legal and contractual obligations
To maintain and improve our Services e.g. to understand how our Services are used, how we can improve the quality of our Services
For marketing and selling our Services
For providing customer service, technical support and implementation services
For protecting and securing the data
To train our customer support and other user-facing staff so that they can provide a higher quality of service to our customers and end-users
To obtain additional information of users through third party sources which would enable us to provide a higher quality of service and increase customer satisfaction
To contact our customers and end-users for service related messages and other messages related to our offerings
To create aggregated statistical data and or anonymized or pseudonymized data for the purpose of analysis by us or our partners and improving our services
To comply with any legal requests as mandated by law
We do not sell any personal information from Customer Data, Usage Data or Website visitor data.

Data Location
We and our service providers and sub-processors store and process personal information in the United States of America primarily and in any other location which are reasonably required to deliver our Services with adequate levels of performance or as may be required by law.



Data Retention
We will retain Customer Data on behalf of our customers and in compliance with any instructions we have received from them.
We will retain Usage Data and Website visitor data for as long as it is necessary for the uses described above, in order to comply with our legal and contractual obligations and to protect ourselves form any disputes and legal issues.

Data Sharing
We may share the personal information included in Customer Data, Usage Data and Website visitor data only under the following circumstances:
A legal compliance request in the form of a search warrant, court order, subpoena, or any other similar legal process.
Service Providers - our Sites and Services use service providers. Such service providers include web hosting, CDNs, billing and payment processing, helpdesk, e-mail and messaging distribution, product walkthroughs, usage analytics and others.
With Customers and other end-users: The personal information that is generated by our end-users use of our Services can be shared with the Customer who has authorized that end user to use our Services. Such data can also be shared with other end-users who are part of the same Customer's account. This is necessary for the delivery of our services for e.g. a goal created by a user would be shown to their co workers and manager based on the options chosen by the goal creator.
Change in control or ownership: In the eventuality that Klaar undergoes a change in control or ownership by any means all kinds of data would be transferred to the parties which have control or ownership after the change. However, Klaar will inform all Customers in advance about such an event.
In addition to above we may share Personal Information from Usage data and Website visitor data, in other ways, after explicit approval from the Customer or Website visitor, or if we are legally obligated to do so, or if the said Personal Information has been modified to render it non-personal, non-identifiable and anonymous. We may use non-personal, non-identifiable, anonymous data at our discretion without the need for further approval.

Use of cookies
We may share the personal information included in Customer Data, Usage Data and Website visitor data only under the following circumstances:
A legal compliance request in the form of a search warrant, court order, subpoena, or any other similar legal process.
Service Providers - our Sites and Services use service providers. Such service providers include web hosting, CDNs, billing and payment processing, helpdesk, e-mail and messaging distribution, product walkthroughs, usage analytics and others.
With Customers and other end-users: The personal information that is generated by our end-users use of our Services can be shared with the Customer who has authorized that end user to use our Services. Such data can also be shared with other end-users who are part of the same Customer's account. This is necessary for the delivery of our services for e.g. a goal created by a user would be shown to their co workers and manager based on the options chosen by the goal creator.
Change in control or ownership: In the eventuality that Klaar undergoes a change in control or ownership by any means all kinds of data would be transferred to the parties which have control or ownership after the change. However, Klaar will inform all Customers in advance about such an event.
In addition to above we may share Personal Information from Usage data and Website visitor data, in other ways, after explicit approval from the Customer or Website visitor, or if we are legally obligated to do so, or if the said Personal Information has been modified to render it non-personal, non-identifiable and anonymous. We may use non-personal, non-identifiable, anonymous data at our discretion without the need for further approval.

Data Security
We and our service providers including our primary hosting service (AWS) ensures that adequate safeguards are in place to protect and secure your personal information, to minimize the risk of data loss, unauthorized access and (or) theft of your personal information.

Data Subject Rights
You may request the following from us
1. Access your data, including receiving a machine-readable copy of the same
2. Rectify your data
3. Erase your data

Additional Information
Updates - We may update and amend this Privacy Policy at any time and the updated policy would be posted to this same page with the data from which it is effective. The updated policy shall be deemed to have been accepted by you if you continue to use our Services and Sites after the new Privacy Policy comes into effect.

Use of our services by children under the age of 13 - Our Services and Sites are not designed in any way to attract users who are below the age of 13. We also do not knowingly collect any data from users who are under the age of 13. If we become aware of any usage of our Services and Sites by users below the age of 13, we will attempt to block such usage whenever possible and make our best efforts to delete all data collected from such users promptly. If you become aware of any usage of our Services and Sites by users below the age of 13 please write to us at support@klaarhq.com.

Contacting us - We are reachable at support@klaarhq.com to answer any comments or questions regarding our Privacy Policy.

The following Privacy Policy governs the online information collection practices of Klaar (“Klaar Digital Solutions Private Limited”, “Klaar Digital Solutions Inc”, “we,” “us,” “our”). It outlines the types of information that we gather about you while you are using our website https://www.klaarhq.com/ and the ways in which we use this information. 

Klaar provides a software-as-a-service solution for its customers, which can be used in organizations and (or) their work teams (“User(s)”) to manage multiple aspects of work such as but not limited to performance management, goals and okrs, talent development such as mentoring, coaching, 360 degree feedback, and employee engagement. It allows (“User(s)”) to share their relevant information, and files (“Content”) and analyze their pre-existing customers, prospective customers and third parties (“Viewer(s)”) on the basis of the content viewed by them. The viewers are the non-registered users of the web-services and product offerings (“Service(s)”) provided by Klaar. We process your data in accordance with the applicable laws and regulations following industry best practices.

PURPOSE AND SCOPE 

The Privacy Policy applies primarily to information that we collect online; however, it may apply to some of the data that you provide to us offline and/or through other means, as well (for example, via telephone or through the mail).

The Privacy Policy documents and describes the manner in which our organization collects information from all our users/viewers of our services. While providing our services on behalf of our registered users, we collect information related to viewers. The use of information collected on behalf of our users is governed primarily by our contract for the engagement with them and the privacy policies governing their organization. We are not accountable for the privacy policies and practices undertaken by our users or any other third parties.

HOW WE COLLECT DATA ABOUT YOU

We may collect different data from or about you depending on how you use the sites.

Data provided by registered users: 

Account creation and login When you create an account or login into your account, we collect personal information such as first name, last name, email address, and password.

Data provided by non-registered users: 

Access pre-existing user’s content When you request to view a pre-existing user’s content, the user may ask for personal information such as email address in order to open a Klaar’ link. Klaar collects and stores this personal information on behalf of its users. When you provide this personal information, you do so in accordance with that user’s privacy practices and policies. Klaar is not responsible for the privacy practices of its users and only processes this information in accordance with the applicable agreement it has with each user. For any issues pertaining to the processing of such personal information, please contact the user directly.

Data collected through automated means: 

System data Technical data about your computer or device, like device type, operating system, and IP address. This data helps us improve the delivery of our web pages and to measure traffic on the site. The collection of data will also depend on the individual settings of your device and software. It is recommended to refer to the policies of your device manufacturer or software provider to learn about information they might share with us.

User Generated Data: 

Account Creation, log in, and Usage as a viewer We collect information and material (user-generated content) provided to us voluntarily by our users or the viewers to publish and process on our platform. The user-generated content is inclusive of text, photos & videos associated with the accounts/ emails used to create an account with Klaar or to access links as viewers.

Data Collected from Third Parties: 

Integration of Third Parties such as Google Drive, OneDrive, Dropbox, Box When you connect your existing cloud storage such as Google Drive, we access your account on your behalf to get information about your files & folders. When you choose to create a Google Drive file link in Klaar, we download the selected file(s) from your Google Drive and store it in our own storage for reliability purposes.

Integration of Third Parties such as Google Drive, OneDrive, Dropbox, Box

When you connect your existing cloud storage such as Google Drive, we access your account on your behalf to get information about your files & folders. When you choose to create a Google Drive file link in Klaar, we download the selected file(s) from your Google Drive and store it in our own storage for reliability purposes.

Data collected during transactions:

Transactional Data

On the basis of types of services requested, Klaar also collects information such as:

  1. type of service that has been requested
  2. order details for such a request
  3. payment & transaction information (such as merchant’s name, payment method, and chargeable amount for the service)
  4. date and time the service was provided

For the purpose of promotion codes, name of the person associated with such a code will also be collected

Some information is collected through the use of cookies, web beacons, and tracking technologies. Please refer to the Cookie Policy for more details on the type of cookies being used.   

THE TYPES OF INFORMATION WE COLLECT AND STORE

We may collect personal and sensitive personal information about you and store this information in connection with the provision and fulfillment of our services to you. Personal information may include:

  • First name and last name
  • Email address
  • Location
  • IP Address

HOW WE USE YOUR PERSONAL INFORMATION

The above personal information may be used for the following purposes:

  • To provide you with information about our offerings and/or our periodic newsletters;
  • To respond to your requests;
  • For creation or development of business intelligence or data analytics in relation to the offerings provided by us (for this purpose we may share the personal information with certain software or tools available online);
  • To manage our relationship with you;
  • For internal record keeping;
  • To provide you with authorization to login and use your user account;
  • To verify your identity;
  • To maintain correct and up-to-date information about you;
  • To identify you as a contracting party;
  • To improve our website;
  • To enable automated handling of the subscriptions;
  • To otherwise be able to provide the services to you and
  • To comply with our legal or statutory obligations.

WHO HAS ACCESS TO YOUR DATA WITHIN OUR ORGANIZATION?

Within our organization, access to your data is limited to those who require access to provide you with the products and services you purchase from us, to contact you, and to respond to your inquiries, including refund requests. Those staff members may be on teams, such as marketing, events, development, executive, and customer support. Employees only have access to relevant data to their team on a ‘need to know’ basis.

WHO DO WE SHARE YOUR DATA WITH OUTSIDE OUR ORGANIZATION, AND WHY?

Processors

We may use service providers & third parties for operating and improving the sites, to assisting with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, third-party solutions for marketing and analytics, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, through the execution of Data Processing Agreements or Addenda. 

Authorities

We may access, preserve, and disclose information about you to third parties, including the content of messages if we believe disclosure is in accordance with or required by applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, the Company or others.

Transfer of business

If we (or our assets) are acquired, or if we go out of business, enter bankruptcy or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.

WHY AND FOR HOW LONG DO WE STORE THE INFORMATION WE COLLECT FROM YOU?

We retain certain information collected from you while you are a member on the site, and in certain cases where you have deleted your account, for the following reasons:

  • So that you can use our sites;
  • To ensure that we do not communicate with you if you have asked us not to;
  • To provide you with a refund, if entitled;
  • To better understand the traffic to our sites so that we can provide all members with the best possible experience;
  • To detect and prevent abuse of our sites, illegal activities and breaches of our Terms of Service; and
  • To comply with applicable legal, tax or accounting requirements. 

We retain user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data. 

SECURITY

We implement a variety of administrative, managerial, and technical security measures to help protect your personal information. Our Company has various internal control standards which relate specifically to the handling of personal information. These include certain controls to help safeguard the information we collect online. Our employees are trained to understand and comply with these controls, and we communicate our Privacy Policy practices and guidelines to our employees. However, while we strive to protect your personal information, you must also take steps to protect your information. We urge you to take every precaution to protect your personal information while you are on the Internet.

YOUR RIGHTS UNDER THE GDPR 

You have certain rights if you are within the EU. This includes 

  • Right to access. This right allows you to obtain a copy of your personal data, as well as other supplementary information. 
  • Right to restrict processing. You have the right to restrict the processing of your personal data in certain circumstances.
  • Right to rectification. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Right to object to processing. The right to object allows you to stop or prevent us from processing your personal data. This right exists where we are relying on a legitimate interest as the legal basis for processing your personal Data. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Right to erasure. You have the right to ask us to delete or remove personal data when the personal data is no longer necessary for the purpose which you originally collected or processed. 
  • Right to Data Portability. You have the right to receive the personal data which you have provided with us, in a way that is accessible and machine-readable.

To exercise your rights, you can contact us at support@klaarhq.com

YOUR RIGHTS UNDER THE CCPA

Users who are California residents have certain rights under the California Consumer Privacy Act (CCPA). Included in these rights are

  • Right to know. You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
  • Right to deletion. You have the right to request the deletion of personal information that we have collected about you.
  • Right to non-discrimination. If you choose to exercise any of your rights under CCPA, we will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
  • Right to opt out. You have the right to opt out of the sale of your personal information. We do not sell personal information. However, the service providers we partner with (for example, our advertising partners) may use technology on the service that "sells" personal information as defined by the CCPA. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below. Please note that any opt-out is specific to the browser you use. You may need to opt-out on every browser that you use.

To exercise any of these rights under CCPA, please email support@klaarhq.com.

OUR POLICY CONCERNING CHILDREN & THEIR DATA

Our Sites are not directed to children under the age of sixteen, and we do not knowingly collect personally identifiable information from children or distribute such information to third parties. We screen users who wish to provide personal information in order to prevent children from providing such information. If we become aware that we have inadvertently received personally identifiable information from a child, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children.

LINKS TO OTHER WEBSITES

Our sites may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the Privacy Policy of every site you visit. 

Third parties are under no obligation to comply with this Privacy Policy with respect to personal data that you provide directly to those third parties or that those third parties collect for themselves. We do not control the third-party sites that may be accessible through our services. Thus, this Privacy Policy does not apply to information you provide to third-party sites or gathered by the third parties that operate them.

CHANGES TO THIS POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. If we make any material change/s to the Policy, we will notify you via email, through a notification posted on the Services, or as required by applicable law. You can see when the Policy was last updated by checking the date at the bottom of this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective from when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy, you can contact us at support@klaarhq.com

CONTACT DETAILS OF OUR DATA PROTECTION OFFICER

Atri Roy

Data Protection Officer

Klaar Digital Solutions Private Limited

HD- 019, WeWork Embassy TechVillage, Block L,, Devarabisanahalli, Outer Ring Road, Bellandur, Bengaluru (Bangalore) Urban, Karnataka, 560103

E-mail : atri@klaarhq.com

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