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:

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):
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;

(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.