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Privacy Policy

02/05/2023

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 8 Rue Dunois 75013 Paris 1, France.  Where we decide the means or purpose of processing your personal data, we are the data "controller."

What’s this policy about?

 

Kaspr respects your privacy and is committed to protecting your personal data. 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 keep our privacy policy under regular review. [This version was last updated on 02/05/2023. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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 you have any concerns about our use of your personal information, you can make a complaint 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:

  • Your right of access - You have the right to ask us for copies of your personal information. 
  • Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
  • Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
  • You can ask us to restrict, stop processing, or delete your data
  • You can object to the use of your personal data for direct marketing
  • Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete
  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 
  • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances

 

If we rely on consent to process data, or send any direct marketing, you can withdraw consent by contacting us using the email to the address above.

 

WHAT WE MAY NEED FROM YOU

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You are not required to pay any charge for exercising your rights. If you make a request, we try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Please contact us using the details above if you wish to exercise any of your rights.

 

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) includes:

  • Name
  • Location and contact details
  • Other personal data you send to us as part of enquiries.

How long we keep this: 6 years

We collect and 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 additional 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. 

How long we keep it

We keep your account data for 6 years from when our relationship with you ends.

We collect and 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.

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 including 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 additional 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). For information on how they use and process your data, please visit their privacy policy on their website.

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 collect and 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 contacting us using the details outlined above, or by 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 collect and 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 we collect and process about how you 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:

  1. 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):
  2. 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;

(c) the interests of people in our database, in receiving more information relevant to B2B products and services;

(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

Our Services uses cookies to distinguish you from other users of our Services. This helps us to provide you with a good experience when you browse our website and Services, and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly Necessary Cookies. These are cookies that are required for the operation of our website and Services. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose.]

Cookies, pixels and other technologies store and access data on your device to help websites and apps work.  The table below explains the individual cookies we use, the purposes for which we use them, how long they last, and who else can access their data.  We get your consent to use these technologies. However, if you do not consent to the Strictly Necessary cookies, you may not be able to access parts or all of our website and/or Services. 

Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet Explorer | Opera | Apple Safari. However, if you use your browser settings to block all cookies (including Strictly Necessary Cookies) you may not be able to access all or parts of our website and/or Services.

Other settings to disable certain similar technologies: Windows Advertising ID | iOS and Mac OS Ad Tracking | Google Analytics | Your Ad Choices. However, if you use your browser settings to block all cookies (including Strictly Necessary Cookies) you may not be able to access all or parts of our website and/or Services.

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).

This cookie is essential for our site to OR enables us to:

 Recognise you when you return to our site.

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

axeptio_all_vendors

12 months

Cookies preferences

Cookies preferences

axeptio_authorized_vendros

12 months

Cookies preferences

Axeptio

cookiefirst-consent

30 days

This cookie saves your cookie preferences for this website. You can change these of withdraw your consent easily

Cookie First

cookiefirst-id

permanent

This cookie contains your unique ID so CookieFirst can identify unique visitors to this websits.

Cookie First

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

messagesUtk

6 months

Marketing / tracking = Track visitors identity

Hubspot

Prism_* 1 month Marketing / tracking Active Campaign
_hstc 6 months Marketing / tracking = track visitor session Hubspot

_hssrc

1 hour

Marketing / tracking = track visitor source

Hubspot

_hssc

1 hour

Marketing / tracking = track visitor campaign

Hubspot

mutiny.user.session

1hour

Marketing / tracking = track visitor session

Mutiny

mutiny.user.token

12 month

Marketing / tracking = track visitor session

Mutiny

sbjs_current

6 months

Marketing / tracking = track visitor source

Source Buster

sbjs_current_add

6 months

Marketing / tracking = track visitor source

Source Buster

sbjs_first

6 months

Marketing / tracking = track visitor session

Source Buster

sbjs_first_add

6 months

Marketing / tracking = track visitor session

Source Buster

sbjs_migrations

6 months

Marketing / tracking = track visitor session

Source Buster

sbjs_session

1 hour

Marketing / tracking = track visitor session

Source Buster

sbjs_udata

6 months

Marketing / tracking = track visitor session

Source Buster

_hjAbsoluteSessionInProgress

30 minutes

This cookie is being set by Hotjar for performance and analytics purposes.

Hotjar

_hjFirstSeen

30 minutes

This cookie is being set by Hotjar for performance and analytics purposes.

Hotjar

_hjSession_******

30 minutes

A cookie that holds the current session data. This ensues that subsequent requests within the session window will be attributed to the same Hotjar session.

Hotjar

_hjSessionUser_******

12 months

Hotjar cookie that is set when a user first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.

Hotjar

hjActiveViewportIds

Permanent

This item is being set by Hotjar for performance and analytics purposes.

Hotjar
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

In_or

1 day

Marketing / tracking / advertising

Linkedin ads

 

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.