KAYRROS PRIVACY POLICY

Last update: May 25th, 2018

KAYRROS is careful about the personal information (i.e., all information that is about any individual, or from which any individual is identifiable) we may collect about our users ("You") through the performance of our services, such as our website and application, as described below.

KAYRROS complies with the General Data Protection Regulation (GDPR (EU) 2016/679) and any national law within the European Union that is applicable to the protection of privacy and personal information.

The following Privacy Policy explains KAYRROS’s position regarding personal information protection, i.e., how we collect, store, process, transfer, share and use personal information. This Privacy Policy is part of our Terms of Use.

  1. Who is the controller of your personal information?

    KAYRROS SAS is a French simplified share company, having its registered office at 1 rue François 1er, 75008 Paris, France, with a share capital of € 175,109.00, registered under number 818 399 651 at the Paris Registre du Commerce et des Sociétés (EU VAT number: FR52818399651) ("KAYRROS" or "We").

    KAYRROS is the controller of the personal information that is collected through the website www.kayrros.com, the application app.kayrros.com, and the performance of our services.

  2. What is the information We collect?

    KAYRROS collects information in three different ways: information You provide to us, information collected automatically, and information collected from outside sources.

    • Information You personally consent to share with us:

      You can share personal information with KAYRROS though our website, our application or by directly contacting us by email. For example, through the “get in touch” page of KAYRROS’s website, You are able to share the following information with us: your name, your email address and your phone number, and You are able to send us a message. Only your name and email address are mandatory to enable KAYRROS to reply to You. The same information is shared with us through our application app.kayrros.com if You become a subscriber to our products. This information enables KAYRROS to provide and improve our services and to answer any query from its subscribers.

      Please note that You are never compelled to provide your personal information to KAYRROS. However, if You decide not to provide us with your personal information, We might not be able to conclude a contractual relationship with You and to fulfill our contractual obligations towards You.


    • Information We collect automatically:

      • Cookies: Cookies are text files that may be recorded on your terminal’s hard drive or internal memory during your visit to KAYRROS’s website and application. Cookies are used to improve your online experience and to help KAYRROS make its website and application more efficient. KAYRROS uses two types of cookies, each one having its own purpose:

        • Session cookies: These cookies store a single token to identify the user and keep his or her session active. KAYRROS will use these types of cookies to identify your terminal and recognize it when You decide to come back to the website or application. These cookies are necessary for an effective use of the website or application and to assure the security of your connection, especially to your subscriber account. You can always decide to turn the cookies off, but the navigation tool might not perform as well.

        • Google Analytics cookies: These cookies are used to collect information about how visitors use KAYRROS’s website and application. We use the information to compile reports and to help us improve our website and application. The cookies collect information in an anonymous form, including the number of visitors to the website, where visitors have come to the website from, and the pages they visited. You may choose to turn these cookies off by using this tool.

      • Logs: During your visit to our website or application, We may collect logs regarding the way You interact with our online tools. The logs are used for statistical purposes but also to detect or investigate any suspicious activity related to our website or application.

    • Information We collect from outside sources:

      KAYRROS may get information about individuals who are not yet subscribers, such as a mailing address, from third-party service providers which We may use, for example, for marketing purposes such as mailers advertising our services. KAYRROS always makes sure that such third-party service providers comply with the GDPR and our Privacy Policy.

  3. Why do We collect your personal information?

    KAYRROS collects information about You only if there is a valid reason to do so – for example, to provide our services to subscribers, to communicate with You, to recruit candidates, or to monitor the use of our services.

    KAYRROS makes sure your personal information is collected for a permissible purpose. That might be, with the consent of the person whose information is collected, to perform our obligations under an agreement, or to pursue a legitimate business interest in using the information – for example, to improve the effectiveness of our online tools or to market our products, to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

    The personal information We collect about You will help us to perform our services for You and to send you e-mails about our services. It also may help us to improve our services in general (such as our website or application).

    Your personal information will never be used by us for profiling purposes or other purposes that are not explained in either this Privacy Policy or our Terms of Use.

  4. How do We make sure that the information We process is accurate and limited?

    KAYRROS makes every reasonable effort to ensure that the personal information that We process is limited to the personal information reasonably required for the purposes set out in this Privacy Policy (including the performance of our services to You).

    Moreover, KAYRROS makes every reasonable effort to ensure that the personal information We process is accurate and that any personal information that is inaccurate is erased or rectified without delay. From time to time, we may ask You to confirm the accuracy of your personal information.

  5. How long do We store your personal information?

    KAYRROS only keeps your personal information as long as We need it to achieve the purpose for which it was collected. We generally discard information about You if We no longer need it or if We do not have a legal obligation to keep it.

    Each type of information has its own retention period. For example:


    • We keep the logs for a period of 3 (three) months, and in no case for longer than 13 (thirteen) months.

    • The information shared by candidates who apply for positions within KAYRROS is stored for a period of 12 (twelve) months from receipt of the application.

    • We store the personal information related to our subscribers for a period of 5 (five) years after termination of the relevant agreement.
  6. How do We share the personal information We collect?

    KAYRROS does not sell the personal information collected in the course of our business activities.

    We share the information about You in limited circumstances – for example, with our subsidiaries, employees and independent contractors, or with third-party service providers who need to know your information in order to help us provide our services and perform our obligations.

    If KAYRROS engages a third-party processor to process your personal information, We will enter into a data processing agreement with such third-party processor that will require it to: (i) only process the personal information in accordance with our prior written instructions; and (ii) take measures to protect the confidentiality and security of the personal information.

    We may have to share your personal information with a law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights, or any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties.

  7. What about transfers of personal information outside the EU?

    KAYRROS’s products and services are offered worldwide. That means that some of your personal information might be processed or shared outside the European Union ("EU") and transferred to other countries that may have lower standards for data protection than the EU.

    Before transferring your personal information outside the EU, We make sure that the recipients agree to comply with this Privacy Policy and that all measures are taken to ensure the protection of your information. To that end, when We transfer your personal information to other countries, We do so, where required, on the basis of standard contractual clauses as approved by the European Commission.

  8. What security measures do We take to protect your personal information?

    KAYRROS employs effective technical and organizational measures to protect your personal information against loss, destruction, alteration or access by unauthorized persons. For example, we regularly monitor our online tools to identify potential vulnerabilities and attacks.

    You are responsible for ensuring that any personal information that You send to us is sent securely.


  9. Your rights regarding your personal information and how to enforce them:

    If your personal information is processed by KAYRROS, You have the following rights:


    • to access your personal information;

    • to request the correction, modification or deletion of your personal information;

    • to request the limitation of the processing of your personal information;

    • to object to the processing of your personal information or to withdraw the consent You gave for the processing of your personal information;

    • to request the portability of your personal information (subject to technical feasibility); and

    • to file a complaint regarding the processing of your personal information with a supervisory authority such as the CNIL “Commission Nationale Informatique et Libertés” (the French administrative body dealing with personal data regulation).

    To enforce these rights, You can email us at contact@kayrros.com. We will respond as soon as possible, and in no case more than 30 (thirty) days after receipt of your request.

  10. How do we update this Privacy Policy?

    KAYRROS may update or change this Privacy Policy to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this Privacy Policy the date when this Policy was last updated.

    Please review this Privacy Policy every time You access or use our website and application to make sure that You have reviewed the latest version.