Privacy Policy 

This Privacy Policy was last updated February 2022

This Privacy Policy describes the information that we gather on, or through, our Services and how we use and process such information. For each processing purpose we will articulate the reason for requiring the data, what data we will process, the legal basis for processing the data and how long we will keep the data. Where the legal basis of consent is to be used, this will be gathered freely, and we will use clear, plain language that is easy to understand, and you will be able to remove your consent at any point.

References in this Privacy Policy and on our platform to “we”, “our” or “us” are references to Kloo Finance Limited, company number 13727633.

References to “you” and “your” means each natural or legal person who uses our platform or the associated services.

1. What Information do w e collect about you and how do we use it?

We collect/process information so that we can provide the best possible experience when you utilise our Services. This section of the policy will describe the purpose for processing your Personal Data, the legal basis to do so and how long we will keep your data.

“Personal Data” has the meaning given to it in the Data Protection Laws.

“Data Protection Laws” means any and all laws, statutes, enactments, orders or regulations or other similar instruments of general application and any other rules, instruments or provisions in force from time to time relating to the processing of personal data and privacy applicable to the performance of this Agreement, including where applicable the Data Protection Act 1998, the Data Protection Act 2018, the Regulation of Investigatory Powers Act 2000, the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) and the GD PR (Regulation (EU) 2016/679), as amended or superseded. 

1. Our Product / Service
   If you choose to use our Services, including access to the platform, email notifications, newsletters and product/service updates, you must provide us with some Personal Data so that we can provide our Services to you; this will include your name, email address, phone number, job title/role, address, location/country, personal bank accounts and IP address.
   
   Other non-mandatory Personal Data may also be gathered.
   
   We will process data using two legal rationales:
1. if you are an individual and not associated with a contracted client we will use contracted based upon our Terms and Conditions;
2. if you are associated with a contracted client we will use legitimate interest as the legal basis to process the data, as we may not have a direct relationship with you as the data subject.
3. Our ability to retain the Personal Data will be determined by account activity, if the account is not used for over two (2) years we will delete your data. Accounts associated with contracted clients will be deleted on termination of the contract.
2. Our use of Productivity Tools
   If you choose to use our Service, Personal Data items such as name, email address, telephone number, job title/role, address, location/country and other non-mandatory Personal Data may be stored in our corporate cloud application platform, corporate email platform and our help desk platform.
   
   We will process Personal Data using two legal rationales:
   1. if you are an individual and not associated with a contracted client we will use contracted based upon our Terms and Conditions;
   2. if you are associated with a contracted client we will use legitimate interest as the legal basis to process the data.
      
      Our ability to retain the Personal Data will be determined by account activity, if the account is not used for over two (2) years we will delete your data. Accounts associated with contracted clients will be deleted on termination of the contract.
3. Our Marketing Site
   If you choose to use our site, including receiving email notifications, newsletters and product/service updates, or attending webinars, you must consent to provide us with some Personal Data so that we can provide these services to you; this will include your name, email address and IP address. Other non - mandatory Personal Data may also be gathered if you choose to provide it.
   
   We will only process your personal data where we have a lawful basis for doing so. In general, unless we have your consent, our lawful basis will be one or more of the following:
   
   
   • that the processing is necessary for the performance of a contract;
   • that the processing is necessary for compliance with our legal obligations;
   • that the processing is necessary for the purposes of pursuing our legitimate interests (this includes carrying out the business of providing products and services and pursuing our general business interests);
   • that the processing is necessary for the establishment, exercise or defence of legal claims;
     
     Sometimes we may process personal data on the basis that you have provided your consent, however you have the right to change your mind which you can do by getting in touch with us using the contact details below. You may also opt- out of receiving marketing emails from us by following the instructions outlined in the email.
     
     We will retain Personal Data for active customer leads or site users for a period of up to two (2) years. A lead will be active under the following circumstances:
     
     
   • An email sent by our organisation has not received an unknown account bounce back
   • An email or contact us form has been sent to us from the data subject
     
     
4. Marketing
   We would like to send you information about new or existing products and services, or content resources of ours which may be of interest to you. You have a right at any time to stop us from contacting you for marketing purposes. To distribute our marketing information we may use personal data such as names, addresses, email addresses, employer details, job titles, telephone numbers and LinkedIn profiles.
   
   If you request or consent to be added to our mailing or marketing lists, we will use consent as the legal basis to process your Personal Data.
   
   If you haven’t requested to be added to our m ailing or marketing lists, we will process Personal Data using the following legal rationale to send marketing information: if your role within an organisation is associated with any of:
   
   
   • finance
   • Leadership & management
   • business change & transformation
   • sustainability
     
     then we will use legitimate interest as the legal basis to process the data. W e use this legal basis after completing a legitimate interest assessment process. The assessment states we will only send low volume, customised messages to business email addresses who, based on their job role, would have a legitimate interest in developing their employees and may find our product useful. If you do not want us to contact you, we will provide an unsubscribe facility within the emails or you can email us at dp@ kloo.co.
     
     We will retain Personal Data for active customer leads for a period of up to two (2) years, a lead will be active under the following circumstances:
     
     
   • An email sent by our organisation has not received an unknown account bounce back
   • An email has been sent to us from the data subject
     
     
5. Cookies
   Like many platforms and apps, we use cookies and similar technologies to collect additional platform or app usage data and to improve our Services. Platform usage information is collected using cookies to monitor aggregate site usage metrics such as total number of visitors and pages viewed . W e will store the cookie values on our platform to allow us to perform our analysis, however this will not be used for any marketing analysis and is essential to deliver our reporting service.
   
   We will process data under the legitimate interest legal basis as we only use the data to perform aggregated tracking analysis and will not target individuals based upon this analysis. You will also need to accept our cookie policy to allow us to process the data. We will retain active cookie data for a period of up to one (1) year, a cookie will remain active if a user re-visits our platform.
   
   Learn more about how we use cookies by visiting our cookie policy on the platform.
   

2. Updating This Policy

We may change or update this Privacy Policy at any point so that it accurately reflects our Services, if we believe it does not fundamentally change your data privacy rights. If we believe your rights have been affected we will contact Users 30 days before we implement the change. If you continue to use the Service once the Privacy Policy has been updated or amended, you will be bound by the updated Privacy Policy. If you do not want to agree to any updated or amended Privacy Policy, you can request an account deletion.

3. Your Rights

1. Accessing or Rectifying your personal data
   In most circumstances before w e are able to invoke your rights we may need to verify you as the data subject, therefore we will request data from you and this will be checked against our records before we can proceed. W e want to make sure that your personal information is accurate and up to date and you have the right to request a copy and update the Personal Data that we hold about you. You may ask us to correct or remove information you think is inaccurate. If you would like to invoke this right, please email or write to us at dp@getkloo.com or DP - Kloo, Scale Space, 58 Wood Lane, London, W 12 7RZ.
   
   
2. Deletion
   Based upon the retention periods described above we will remove your Personal Data from our platforms.
   
   
3. Object, Restrict or Withdraw Consent
   You may wish to object to or restrict our ability to process your Personal Data, this can be done either via email or in writing, using the contact details below. Further context may need to be requested to ensure we can carry out the relevant tasks on our platforms to perform the request.
   
   
4. Portability
   You may wish to p ort your Personal Data to another platform. If you would like to invoke this right, please email or write to us at dp@getkloo.com or DP - Kloo, Scale Space, 58 Wood Lane, London, W12 7RZ.

4. Who We Are And How To Contact Us

This Privacy Policy is issued on behalf of the Kloo group of companies so when we mention “Kloo”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the group responsible for processing your data. If you are an individual and not associated with a contracted client we are the Data Controller and are responsible for defining and managing how your personal data is processed. If you are associated with a contracted client we are a Data Processor and the contracted client will be responsible for defining and managing how your personal data is processed (as the Data Controller).

Our company name is: Kloo Finance Limited

Our company address is: Scale Space, 58 Wood Lane, London, W 12 7RZ.

Our email address is: info@getkloo.com

5. To Whom We Disclose Information

Except as described in this Privacy Policy, we will not intentionally disclose the Personal Data that we collect or store on the Service to third parties without the consent of the data subject. W e may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

Unrestricted Information

Any information that you voluntarily choose to include in a public area of the Service, such as a public profile page, will be available to any visitor or User who has access to that content.

6. Service Providers

We work with third party service providers who provide email hosting, core corporate applications, web hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data as part of providing those services for us. W e limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information. An up to date list of our service providers can be found at the end of this Privacy Policy.

1. Overseas transfers
   If you are a User based in the UK or the European Economic Area (EEA), the information you provide may be transferred to countries outside the UK or EEA that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information, you consent to these transfers for the purposes specified above.
   
   We may transfer your personal information to our service providers located outside of the UK or EEA as specified in the list of service providers which can be found at the end of this Privacy Policy.
   
   All of our International service providers have each provided the information to demonstrate they have appropriate technical and organisational measures in place to safeguard Personal Data, and it shall be processed to at least the same standards as set out by the General Data Protection Regulations (GDPR). Each organisation has entered into Standard Contractual Clauses with Kloo Finance Limited , which is accepted by the European Commission as evidence that an adequate level of protection exists for the Personal Data in the country, territory, or organisation where it is being transferred .
   
   
2. Non -Personally Identifiable Information
   We may make non-personally-identifiable information available to third parties for various purposes. This data may be automatically-collected and would be analysed to create an aggregated view of the data, ensuring the reported information was anonymous
   
   
3. Law Enforcement, Legal Process and Compliance
   We may disclose Personal Data or other information if required to do so by law or in the good -faith belief that such action is necessary to comply with applicable laws, in response to a valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
   
   
4. Service Providers
   We work with third party service providers who provide email hosting, core corporate applications, web hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data as part of providing those services for us. W e limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information. An up to date list of our service providers can be found at the end of this Privacy Policy.
   
   
5. Change of Ownership
   Information ab out data subjects, m ay be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the Personal Data commits to a privacy policy that has terms substantially consistent with this Privacy Policy.

7. Our Data Security

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way.

The following security procedures, and technical and organisational measures to safeguard your personal information have been put in place:

• In cases where Personal Data is being processed in third countries or third parties, a rigorous data protection impact assessment is being performed to ensure that your data is always secured.
• Our application platform is hosted in an ISO 27001 certified secure data centres in the UK.
• Firewalls, intrusion detection and prevention, anti-virus and anti-malware and backup and disaster recovery are in place to prevent data loss or deletion.
• 24/7 security guard, closed circuit television and a door access control system to authorized personnel secures our offices and data centres
  
  Service providers
  
• Our applications are engineered by following industry standards to minimise security vulnerabilities and updates on a regular basis.
• Anti-malware and anti-virus software is deployed to all of our servers and regularly scan and update with the latest anti-malware and virus signatures.
• We regularly apply critical, security patches and firmware updates to operating systems and physical hardware to minimise the risk of vulnerabilities.
• Our employees undergo background screening and selection processes, with a restricted list of employees having access to secure areas of the applications, databases and physical infrastructure. The access to the secure areas are logged and auditable.
• W e will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
• We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
• We also have procedures in p lace to deal with any suspected data security breach. W e will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
• Our employees receive regular Security and Data Privacy awareness training

8. Complaints

If you are not happy with this privacy policy, or you wish to speak to a supervisory authority, you can contact the ICO on 0303 123 1113 or via their website www.ico.org.uk.

9. CCPA

• W e do not sell any personal information
• We do not offer any financial incentive for your personal information
• You will not receive any discriminatory treatment by our business for exercising your privacy rights
• We will not charge you for exercising your privacy rights
• Upon receiving a request to know or a request to delete, we will confirm receipt of the request within 10 business days and provide information about how the business will process the request.
• We will respond to requests to know and requests to delete within 45 calendar days.
• We shall not disclose in response to a request to know a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics.
• We are able to provide the information and classification of information when responding to a Request to Know request
• We are able to delete the personal information in relation to a Request to Delete request

This Privacy Policy was last updated February 2022

In order to provide the best service to our customers, this list may change.