kasitoko’s Privacy Commitment
kasitoko has worried about customer and user privacy since its creation, The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not. This policy is unfortunately longer than we would like, but we must unambiguously address all the relevant cases. We will try and keep the language simple and direct as much as possible.
Part I – Information kasitoko collects and controls
This part deals with how kasitoko collects and uses information about website visitors, potential customers, users of kasitoko’s products and services, and others who contact kasitoko through forms or email addresses published on or linked to our websites.
Part II – Information that kasitoko processes on your behalf
This part deals with how kasitoko handles data that you entrust to kasitoko when you use our products and services, or when you share any personal or confidential information with us while requesting customer support.
Part III – General
Part I – Information kasitoko collects and controls
What information kasitoko collects
We collect information about you only if we need the information for some legitimate purpose. kasitoko will have information about you only if (a) you have provided the information yourself, (b) kasitoko has automatically collected the information, or (c) kasitoko has obtained the information from a third party. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.
Information that you provide us
i. Account signup: When you sign up for an account to access one or more of our services, we ask for information like your name, contact number, email address, company name and country to complete the account signup process. You’ll also be required to choose a password for accessing the created account. You may also provide us with more information such as your photo, time zone and language, but we don’t require that information to sign up for an account.
ii. Event registrations and other form submissions: We record information that you submit when you (i) register for any event, including webinars or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in order to download any product, whitepaper, or other materials, (iv) participate in contests or respond to surveys, or (v) submit a form to request customer support or to contact kasitoko for any other purpose.
iii. Payment processing: When you buy something from us, we ask you to provide your name, contact information, and credit card information or other payment account information. When you submit your card information, we store the name and address of the cardholder, the expiry date and the last four digits of the credit card number. We do not store the actual credit card number. For quick processing of future payments, if you have given us your approval, we may store your credit card information or other payment information in an encrypted format in the secured servers of our Payment Gateway Service Providers.
iv. Testimonials: When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org
v. Interactions with kasitoko: We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.
Information that we collect automatically
i. Information from browsers, devices and servers: When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.
iii. Information from application logs and mobile analytics: We collect information about your use of our products, services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our products. This information includes clicks, scrolls, features accessed, access time and frequency, errors generated, performance data, storage utilized, user settings and configurations, and devices used to access and their locations.
Information that we collect from third parties
i. Signups using federated authentication service providers: You can log in to kasitoko Services using supported federated authentication service providers such as Facebook. These services will authenticate your identity and give you the option to share certain personal information with us, such as your name and email address.
ii. Referrals: If someone has referred any of our products or services to you through any of our referral programs, that person may have provided us your name, email address and other personal information. You may contact us at email@example.com to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.
iii. Information from our reselling partners and service providers: If you contact any of our reselling partners, or otherwise express interest in any of our products or services to them, the reselling partner may pass your name, email address, company name and other information to kasitoko. If you register for or attend an event that is sponsored by kasitoko, the event organizer may share your information with us. kasitoko may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.
iv. Information from social media sites and other publicly available sources: When you interact or engage with us on social media sites such as Facebook, Twitter, Google+ and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. We must tell you that once collected, this information may remain with us even if you delete it from the social media sites. kasitoko may also add and update information about you, from other publicly available sources.
Purposes for using information
In addition to the purposes mentioned above, we may use your information for the following purposes:
- To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;
- To ask you to participate in surveys, or to solicit feedback on our products and services;
- To set up and maintain your account, and to do all other things required for providing our services;
- To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;
- To provide customer support, and to analyze and improve our interactions with customers;
- To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of kasitoko, kasitoko’s users, third parties and the public;
- To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;
- To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;
- To monitor and improve marketing campaigns and make suggestions relevant to the user.
Legal bases for collecting and using information
Legal processing bases applicable to kasitoko: If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of kasitoko or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.
Withdrawal of consent: Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.
Legitimate interests notice: Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.
Your choice in information use
Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.
Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
Optional information: You can choose not to provide optional profile information.. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.
Who we share your information with
Third-party service providers: We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
Reselling partners: We may share your personal information with our authorized reselling partners in your region, solely for the purpose of contacting you about products that you have downloaded or services that you have signed up for. We will give you an option to opt out of continuing to work with that partner.
Other cases: Other scenarios in which we may share the same information covered under Parts I and II are described in Part III.
Your rights with respect to information we hold about you as a controller
If you are in the European Economic Area (EEA), you have the following rights with respect to information that kasitoko holds about you. kasitoko undertakes to provide you the same rights no matter where you choose to live.
Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information’s source, purpose and period of processing, and the persons to whom the information is shared.
Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure: You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Right to complain: You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.
Retention of information
Part II – Information that kasitoko processes on your behalf
Information entrusted to kasitoko and purpose
Information provided in connection with services: You may entrust information that you or your organization (“you”) control, to kasitoko in connection with use of our services or for requesting technical support for our products. This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for technical support or other services.
Information from mobile devices: When you elect to allow it, some of our mobile applications have access to the camera, contact information, photo library, and other information stored on your mobile device. Our applications require such access to provide their services. Similarly, when you elect to provide access, location-based information is also collected for purposes including, but not limited to, locating nearby contacts or setting location-based reminders. This information will be exclusively shared with our mapping providers and will be used only for mapping user locations. The data stored on your mobile device and their location information to which the mobile applications have access will be used in the context of the mobile application, and transferred to and associated with your account in the corresponding services (in which case the data will be stored on our servers) or products (in which case the data will remain with you unless you share it with us).
(All the information entrusted to kasitoko is collectively termed “service data”)
Ownership and control of your service data
We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, and (ii) request export or deletion of your service data.
How we use service data
We process your service data when you provide us instructions through the various modules of our services. For example, when you generate an invoice, information such as your name and address ?will be used to generate the invoice; and when you use our campaign management service, the email, phone or addresses of the persons on your campaign list will be used for sending the campaign information.
Who we share service data with
kasitoko group and third party sub-processors: In order to provide services and technical support for our products, the contracting entity within the kasitoko group engages other group entities and third parties .
Employees and independent contractors: We may provide access to your service data to our employees and individuals who are independent contractors of the kasitoko group entities involved in providing the services (collectively our “employees”) so that they can (i) identify, analyze and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify campaigns that you submit to us. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the kasitoko group.
Collaborators and other users: Some of our products or services allow you to collaborate with other users or third parties. Initiating collaboration may enable other collaborators to view some or all of your profile information.
Other cases: Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.
Retention of information
We hold the data in your account as long as you choose to use kasitoko Services. Once you terminate your kasitoko user account, your data will eventually get deleted from active database during the next clean-up that occurs once in 6 months. The data deleted from active database will be deleted from backups after 3 months.
Data subject requests
If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.
Part III – General
Children’s personal information
Our products and services are not directed to individuals under 16. kasitoko does not knowingly collect personal information from children who are under 16 years of age. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you believe that a child under 16 years has provided personal information to us, please write to firstname.lastname@example.org with the details, and we will take the necessary steps to delete the information we hold about that child.
How secure is your information
At kasitoko, we take data security very seriously. TWe have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. If you have any concerns regarding the security of your data, we encourage you to write to us at email@example.com with any questions.
Data Protection Officer
Locations and international transfers
We share your personal information and service data within the kasitoko Group. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where kasitoko operates. Such transfer is subject to a group company agreement that is based on EU Commission’s Model Contractual Clauses.
Data processing addendum
To enable you to be compliant with the data protection obligations under the General Data Protection Regulation, we are prepared to sign a Data Processing Addendum (DPA) that is based on Standard Contractual Clauses. You can request a DPA from kasitoko by by sending an email to firstname.lastname@example.org. Once we get your request, we’ll forward the DPA to you for your signature.
Do Not Track (DNT) requests
Some internet browsers have enabled ‘Do Not Track’ (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don’t wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.
External links on our websites
We offer publicly accessible blogs on our websites. Please be aware that any information you provide on these blogs may be used to contact you with unsolicited messages. We urge you to be cautious in disclosing personal information in our blogs. kasitoko is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your account with kasitoko. To request the removal of your information from our blogs you can contact us at email@example.com
Social media widgets
Our websites include social media widgets such as Facebook “like” buttons and Twitter “tweet” buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.
Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.
Enforcement of our rights
We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.
We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.
Notification of changes