KLUE PRIVACY POLICY

This Privacy Policy (the “Policy”) applies to Klue’s public-facing website as well as the website through which our Customers access our Services (collectively, the “Website”). The Policy covers the information we collect about you and describes our data privacy and protection practices in the collection, processing, use, storage, transfer, and disclosure of personal and personally identifiable information in connection with the Services as such information may be defined under your applicable jurisdiction (“Personal Data”).

In this Policy:

“Contract” means an agreement between us and a Customer, pursuant to which the Customer acquires Services.

“Customer” means any entity who enters into a Contract.

“End Users” means the employees, contractors, or other representatives of a Customer or its affiliates to whom a Customer grants access to the Services under a Contract.

“Klue”, “we”, “us”, and “our” refers to Klue Labs, Inc.

“Services” means the services for which a Customer subscribes under a Contract with Klue.

“you” and “your” refers to both Customers and End Users.

Personal Data we collect:

We collect and/or store the following Personal Data about all End Users: work email address, username, job title/role, and encrypted password. We also automatically receive and record information about End Users on server logs from End Users’ browsers, including IP addresses, cookie information (described in more detail below), browser type, language preferences, device type, operating system, location, and interactions.

The Services will also store files, links or other material that you upload, including any Personal Data that you choose to upload. You may delete and remove any such material at any time.

We do not retain your home address, telephone number, age, or gender. We do not collect, or permit Customers to use the Services to collect, any special categories of Personal Data as defined in applicable data privacy legislation.

Personal Data processed by us about other individuals will vary based on (1) how the Customer and End Users elect to configure, implement and use the Services, and (2) what Personal Data Customers and End Users elect to search for, index, store, upload or otherwise use through the Services. Depending on what search terms you provide to the Services and what you choose to download from the Internet and store and index using the Services, the Services may process information about individuals whose Personal Data appears in publicly available articles published on the Internet or publicly available web pages on the Internet (such articles and websites “Publicly Available Sources” and Personal Data contained therein “Publicly Available Personal Data”).

How we Collect Personal Data:

When a Customer enters a Contract, we will process certain End User Personal Data in order to provide the Services. Some Personal Data will be provided directly to us by End Users, and some will be provided by the Customer.

As described above, the Services may also process Publicly Available Personal Data, but do not target the collection of Publicly Available Personal Data and are instead targeted at the collection of business information about Customers’ competitors.

How we use Personal Data:

We use Personal Data for the purpose of providing the Services and improving your experience in using the Services. We use Personal Data to verify End Users’ identity and, if necessary, to respond to security threats and address issues relating to compliance with your Contract.

Your administrators may configure the Services so that you receive Klue’s Intel Digest or other content updates via email or so that you receive email notifications when you are @mentioned on the Website. We may contact you occasionally to request feedback about the Services.

We also provide support for the Services. If you speak or otherwise engage with our Customer Success team, you will likely provide contact information along with information about the issue you’re experiencing so that we can assist in resolving it.

We include anonymized aspects of Personal Data as part of aggregated, anonymized reports that enable us to constantly improve the Services, in particular to improve our ability to recommend content relevant to our Customers. These reports are based upon aggregated, anonymous information about Personal Data in our system, but do NOT include Personal Data about identifiable End Users, Customers, projects, or companies.

We may use your Personal Data, including the fact that you are or have been an End User, to send you information, features updates, product developments and other related communications about us and our services for our legitimate business purposes, and/or to the extent you have provided your prior consent (please see “Your Data Protection Rights” for details on how you can control our processing of your Personal Data).

Lastly, if you have given us specific permission to do so, either in your Contract or otherwise, we may share testimonials or reviews of the Services for promotional purposes.

Legal bases for processing (for EEA users):

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. We collect and use your information where one or more of the following legally permitted bases for processing applies:

Consent: you’ve given us consent to use your information for a specific purpose;
Performance of a Contract: the information is needed to provide the Services we’ve agreed to provide under a Contract;
Legal obligation: we need to process your data to comply with a legal obligation that applies to us or the Customer, such as in response to a court order or a subpoena;
Vital Interest: we need to process your information to protect your vital interests or those of another person (such as in cases of suspected fraud, or potential threats to safety or security).
Legitimate interest: our use of Personal Data is reasonably necessary to achieve our legitimate business interests.

If you have consented to our use of information, you have the right to revoke your consent any time. If we are using your information based on the legitimate interest described above, you may object to that use, however, you may no longer be able to use the Services as a result.

How we transfer your Personal Data:

Third Party Service Providers: We rely on third-party service providers and contractors for certain hosting, storage, backup, storage, and other services. As part of this, these third-party providers may need to access or use information about you. If they do so, they will be subject to strict confidentiality and security requirements and will only be granted access to the extent necessary to provide the services in question.

Some of the third parties described above are based in other countries. If you are located in the European Economic Area, the UK, or Switzerland, and we transfer your Personal Data to a country that does not have equivalent standards, we rely on the European Commission-approved standard contractual data protection clauses to ensure the transfer is compliant with applicable laws.

Klue may participate in corporate transactions such as mergers and acquisitions. In that case, Personal Data may be shared in connection with those transactions. You will be notified via email or a prominent notice on our Website if Personal Data is transferred in this context and becomes subject to a different privacy policy.

Klue does not sell Personal Data to any third parties.

How we Store Personal Data:

We use a secure server hosting location, firewall protection, controlled access and standard secure data storage practices to protect Personal Data. We also limit access to Personal Data to those of our employees, service providers and contractors who reasonably need to come into contact with that information to provide Services to our Customers.

How long we keep your Personal Data:

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law.

When we no longer require your Personal Data for the purposes described in this Policy, we will destroy it.

Your Data Protection Rights

You are entitled to the following data protection rights:

The right to access – you can request copies of your personal data.
The right to rectification – you can request corrections to your Personal Data.
The right to erasure – you can request that we erase your Personal Data, subject to certain exceptions.
The right to restrict processing – you can request that we restrict the processing of your personal data, subject to certain exceptions.
The right to object to processing – you can object to us processing your Personal Data, subject to certain exceptions. Where we process your Personal Data for direct marketing purposes, you can exercise your right to object at any time without providing any specific reason for your objection.
The right to data portability – you can request that we transfer your Personal Data to another organization or directly to you, subject to certain exceptions.

If you make any of these requests, we will respond within one month. If you would like to exercise any of these rights, please contact us using the contact information listed at the end of this Policy.

The Services are intended for use by Customers and the End Users employed or otherwise engaged by Customers. In light of this, unless you are exercising your right to object to the processing of your Personal Data for direct marketing purposes (in which case please direct your request to us), please first direct your data privacy questions to the Customer on whose behalf you are accessing and using the Services, as your use of the Services will be subject to the Customer’s Contract with Klue. The Customer may have privacy and security practices that differ from ours, and Klue is not responsible for those policies.

Cookies

We use "cookies" to improve the experience of the Website and Services. A cookie is a text file that is placed on an End User’s hard disk by a web page server, often including an anonymous unique identifier.

Cookies cannot be used to run programs or deliver viruses to End Users’ computers.

Cookies are uniquely assigned to End Users and can only be read by a web server in the domain that issued the cookie to such End Users. We primarily use cookies to record current login information but do not use permanent cookies.

Other Websites

The Website or content stored or indexed on the Website may contain links to other websites. This Policy applies only to our Website, so if you click on a link to another website, you should read their privacy policy.

Changes to Our Privacy Policy

This Policy was last updated on the date referenced at the top of this page. If we make significant changes to this Policy, we will notify you via a general notice on our website, a pop-up notice, or some other appropriate method.

How to contact us:

If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: info@klue.com.

Or write to us at:

Klue Labs, Inc.

Suite 1600, 777 Hornby Street

Vancouver, BC V6Z 1S4

DoubleCheck Research

Concord, Massachusetts, United States