I. CONTACT US
For all enquiries regarding data protection, please contact us at legal@withkrew.com.
II. INFORMATION WE COLLECT AND PROCESS
We collect and process “Non-Personal Information” and “Personal Information.” Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Personal Information includes your email address, the name of your company, and your role within that company, which you submit to us through the registration process at the Site.
The processing of such information is limited to data that is required to operate a functional website and for the provision of content and services. The processing of personal data of our EU-based users is based on the purposes agreed or on a legal basis according to the European General Data Protection Regulation (GDPR). We only collect personal data that is necessary to implement and process our tasks and services or if you provide data voluntarily.
1. Information collected via technology
To request to be put on the waitlist for the Company’s proprietary software you do not need to submit any Personal Information other than your email address, the name of your company, and your role within that company. However, in an effort to improve the quality of the Service, we track information provided to us by your browser or by our software application when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you.
We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis.
The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser.
If you do not wish to use cookies, you can change the settings in your browser accordingly. You will then be notified whenever your browser attempts to create a cookie and you can decide whether you want to allow the cookie.
However, please note that a deactivation of cookies may result in a limited user experience and you may not be able to use every function of our website.
The legal basis is consent according to Art. 6 Para. 1 lit. a of the GDPR and legitimate interest according to Art. 6 Para. 1 lit. f of the GDPR. For example, it is in our legitimate interest to improve our website and design it more user-friendly. The declaration of consent can be revoked at any time, whereby this does not affect data which has already been transmitted.
This website uses cookies which transfer personal data to the following servers:
- Hubspot uses so called non-essential cookies to understand and save your preferences for future visits and to compile aggregate data about site traffic and site interaction.
Since Hubspot is a participant in the EU-U.S. Data Privacy Framework as well as the UK Extension to the EU-U.S. Data Privacy Framework, the data transfer to the USA is compliant with the GDPR and its UK counterpart due to an adequate level of protection of your personal data in the USA.
With the consent of setting cookies, the following personal data are transferred: first-party cookies, data related to the device/browser, IP address, and on-site activities.
The cookies are stored for a period of 6 months.
2. Information you provide us
(A) Registering for an account
In addition to the information provided automatically by your browser when you visit the Site, to become a subscriber to the Service you will need to create a personal profile. You can create a profile by registering with the Service and entering your email address, and creating a user name and a password.
For non-EU users: by registering, you are authorizing us to collect, store and use your email address in accordance with this Privacy Policy.
The data provided will be stored in our database for twelve months for the purpose of processing the request and in case of follow-up questions.
The data processing is based on Art 6 para 1 lit a and lit b GDPR.
(B) Contacting us
To ensure adequate information and system security and to detect malware, we store log data on e-mail traffic. When you send an e-mail to one of our addresses, the following data is logged: E-mail and IP address of the recipient and the sender, number of recipients, subject, date and time of receipt by the server, file name of any attachments, size of the message, risk classification for spam and delivery status. In a first step, e-mails are checked purely automatically. Only in the case of suspicion of a threat to the security of the IT systems are individual e-mails checked manually by responsible persons.
In addition, we process your personal data in connection with e-mails, where necessary, for the duration of the entire business initiation and beyond that in accordance with the statutory retention and documentation obligations.
The data mentioned above are saved for a maximum time period of 90 days.
The data processing is based on your consent according to Art 6 para 1 lit a and on our legitimate interest according to Art. 6para 1 lit f GDPR.
(C) Contractual Relationships
In order to fulfill our contractual relationship with you, we may collect and process your name and contact information such as your home and/or business address, e-mail address and telephone number.
We may collect your personal data, or you may provide it to us, by telephone, post, e-mail or other forms of electronic communication as well as any other provision in the normal course of providing professional services.
We use your personal data to provide our services.
We will retain your personal data for as long as is necessary to fulfil the purposes set out in the Privacy Policy. In many cases this will mean that we retain your personal data for the same period as we retain your files or a copy of your files. Usually this will not be less than 10 years from the date that the relevant matter ended. Longer retention periods may be appropriate, for example to exercise or defend our legal rights. If there is no longer a legal reason for storing the data, we will delete personal data securely, or in some cases anonymize it.
(D) Newsletters
We may use your contact details to send you (by post or electronically) newsletters, event invitations and other mail promoting our Services. We do this on the basis of our legitimate interests or your consent (as appropriate to the communication in question). You can always unsubscribe from these mailings by contacting us at legal@withkrew.com.
The legal basis is consent according to Art. 6 Para. 1 lit. a of the GDPR and legitimate interest according to Art. 6 Para. 1 lit. f of the GDPR. It is in our legitimate interest to inform you of changes relating to Krew and our range of services.
3. Children’s privacy
The Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at legal@withkrew.com.
III. HOW WE USE AND SHARE INFORMATION
1. Personal information:
Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We do share Personal Information with vendors who are performing services for the Company, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy.
In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.
We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.
2. Non-personal information
In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site.
For US-based users: This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion. In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy.
If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.
IV. HOW WE PROTECT INFORMATION
We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology.
However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.
V. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION
You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by unsubscribing, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.
You have the right to request information about any of your personal data we process. In particular, you have the right to request information about the purpose of the processing, the categories of personal data, the categories of recipients who will have access or were disclosed with your data, the duration periods for saving the personal data, whether there is a right to adjust/correct, erase, restrict or object, transmission of data, the source of your data if not collected through us and if we use automatic decision-making technologies including profiling.
Additionally, you have the right to rectification or deletion, the right to restriction of processing, the right to object to processing and the right to data portability.
Further, you have the right to revoke a previously granted consent to use your personal data at any time. The revocation can be sent informally by e-mail to legal@withkrew.com.
If you believe that the processing of your personal data is inconsistent or contradicts the applicable data protection laws you have the possibility to lodge a complaint with your data protection office.
VI. LINKS TO OTHER WEBSITES
As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.
VII. CHANGES TO OUR PRIVACY POLICY
The Company reserves the right to change this policy and our Terms of Service at any time. We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.
