Privacy Policy

Kumulos is committed to protecting the privacy of those involved in its business. This Privacy Notice is meant to help you understand, among other things, what personal data we collect, why we collect it, and what we do with it.

PRIVACY NOTICE

Kumulos and its affiliated companies and subsidiaries (“Kumulos,” “we” or “us”) are committed to protecting the privacy of visitors of the Kumulos website(s), individuals who register to use the products and services, individuals who register to attend the Company’s corporate events, and business partners (“Customers”). This Privacy Policy (“Privacy Policy” or “Policy”) describes our privacy practices in relation to the use of Kumulos websites (including any customer portal or interactive customer website), its software, services, solutions, tools, and related applications, services, and programs, including attendance of corporate events and research and marketing activities, offered by Kumulos (the “Services”) as well as your choices regarding use, access and correction of personal information.

This Privacy Policy describes how we collect, use, disclose and otherwise process personal data collected related to our Services and otherwise in the course of our business activities, including the information practices of the websites that link to this Privacy Policy (“Sites”).

This Privacy Policy does not apply to information collected about Kumulos employees, applicants, or other personnel.

The Kumulos Sites may contain links to other websites; and information practices and/or the content of such other websites shall be governed by the privacy statements of such other websites.

Data Relating to Our Customers and Users of Our Sites

Kumulos collects information as part of its normal business operations and in the administration of its relationship with Customers and Prospects, which may include personal information.

Business Contact and Customer Relationship Management. We collect and maintain information about our Customers, which may include company name, business contact name and title, phone number, email and other contact details. We may also collect billing address, financial account, credit card information, order details, subscription and license information, and usage details.

Data Submitted on Sites. In order to access or use certain portions of the Sites, to enjoy the full functionality of the Sites, or to conduct or seek to conduct business with us, you may be prompted to provide certain personal data to us, including in the following ways:

• by filling in forms (for example, a “Contact Us” form) on our Sites or at a trade show or anywhere else we conduct business;
• by downloading or accessing the Kumulos Services;
• by downloading documentation like Whitepapers from our Sites;
• by subscribing to newsletters or other communications; or
• by corresponding with us by phone, e-mail or otherwise using our contact details.

Typically, the personal data you give us may include name, business affiliation, business address, telephone number, and email address, and any personal details required to resolve any enquiries or complaints.

Third Parties. We may also obtain personal data about Customers from third parties, such as LinkedIn and other publicly accessible sources.

Customer Support and Service. When Customers contact us for support or other customer service requests, we maintain support tickets and other records related to the requests, including any information provided by Customers related to such support or service requests.

Usage Details. We collect information about Customers’ usage of our Services, including IP address, Customer ID, email address, and other usage statistics. We do not collect PII usage details about Customer end users, except as necessary for support or to provide the Services requested by Customers (in which case we are a data processor of such data).

When you visit our Sites, our server automatically collects certain browser or device generated information, which may in some cases constitute personal data, including but not limited to:

• your domain;
• your IP address;
• your date, time and duration of your visit;
• your browser type;
• your operating system;
• your page visits;
• information from third parties;
• other information about your computer or device; or
• Internet traffic.

Our API service may collect:

• Anonymised device identifiers for iOS installs of your app
• Randomly generated GUIDs for Android installs of your app

Use of Personal Data

The following is an overview of our purposes for using personal data that we process as a data controller. Additional details on how we process your personal data may be provided to you in a separate policy, contract or our terms and conditions.

For individuals in the European Union, our processing (i.e. use) of your personal data is justified on the following legal bases:

• the processing is necessary to perform a contract with you or take steps to enter into a contract at your request;
• the processing is necessary for us to comply with a relevant legal obligation;
• the processing is in our legitimate interests, subject to your interests and fundamental rights, and notably our legitimate interest in using applicable data to conduct and develop our business activities; or
• you have consented to the processing.

We use the personal data we collect to:

• conduct and develop our business with you and with others;
• process, evaluate and complete certain transactions involving the Sites, and more generally transactions involving Kumulos’ Services;
• operate, evaluate, maintain, improve and develop the Sites (including by monitoring and analyzing trends, access to, and use of the Sites for advertising and marketing);
• evaluate, improve and develop our Services generally;
• customize our Sites to users’ needs;
• engage you about events, promotions, the Sites and Kumulos Services;
• provide you with documentation or communications which you have requested;
• correspond with users to resolve their queries or complaints;
• provide you with any Services you request;
• send you marketing communications, where it is lawful for us to do so;
• manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations.

Disclosures

• Law Enforcement or National Security. In accordance with our legal obligations, we may also transfer Customer Data, subject to a lawful request, to public authorities for law enforcement or national security purposes.
• Additional Disclosures. We may also disclose Customer Data (including any personal data), where otherwise required by law.

Children

• The Sites, Services and Portal are not for use by children under the age of 16 years and Kumulos does not knowingly collect, store, share or use the personal data of children under 16 years. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the Sites to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify Kumulos and Kumulos will delete all such personal data.

Marketing

Where lawful to do so, and subject to your consent where required, we may communicate with Customers (and related business contacts) about our Services. If you wish to unsubscribe from receiving marketing communications, please use the Unsubscribe Link contained the email communication or contact us at [email protected] to request that we will stop sending you communications. We will then do so immediately.

Security

Kumulos aims to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and Kumulos utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no environment is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by Kumulos are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control.

Retention of Your Personal Data

We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances, we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

In specific circumstances, we may also retain your personal data for longer periods of time corresponding to a statute of limitation, so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

External Links

The Sites may contain links to third party sites. Since Kumulos does not control nor is responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third party sites. This Policy applies solely to personal data collected by our Sites or in the course of our business activities.

Your Rights

Subject to applicable law, you may have some or all of the following rights available to you in respect of your personal data

• to obtain a copy of your personal data together with information about how and on what basis that personal data is processed;
• to rectify inaccurate personal data (including the right to have incomplete personal data completed);
• to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);
• to restrict processing of your personal data under certain circumstances
• to port your data in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you;
• to withdraw your consent to our processing of your personal data (where that processing is based on your consent); and
• to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization.

• We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
• You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to 1 Bash Street, Dundee, DD1 1LQ, Scotland, UK.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us [email protected] as soon as possible at the above address. We will promptly correct any information found to be incorrect.

If you contact us regarding Customer Data for which we are a data processor, we will attempt to refer your request to the relevant Customer, and data controller for your personal data.

If you have any questions or concerns about the information in laid out in this Policy please contact us at [email protected]ulos.com