Last Updated 18 Dec 2019
KLEQ is serious about protecting your online privacy. It is very important to us to be clear about what data we collect, why we collect it and how we use it. This Privacy Statement explains our views and practices concerning privacy, and how they may apply to you as a user of our website.
1.1. When we talk about 'us', we mean the entity detailed in the Schedule, we are the operator of www.kleq.com (Previously known as 10XPRO) and any subdomain ('website'). When we talk about 'you', we mean you as a participant or user of this website or services of this website.
1.2. 'Personal data' or 'personal information' is information that directly identifies you, such as your name and email address, or data that could be used, on its own or in combination with other data, to identify you.
2. Staying Anonymous
2.1. You can browse our website anonymously, although cookies may be collected. You will not be able to access our services anonymously. Once you access our services, including for example by requesting an invitation for a free trial, requesting a demo, requesting a seat in an on-line workshop or subscribing to our services, we will begin collecting your personal information in accordance with this policy.
3. Collection and Use of Data
3.1. We collect personal data about you when you give it to us for an agreed purpose. This generally occurs when you complete an online enquiry for a service, request information (for example a demo) or when you subscribe to a trial or full membership with us or place an order through our online services. We may use this information to contact you about the service and related services you have inquired about.
3.3. We collect and process the minimum amount of information required to deliver our requested services to you. We process this information to fulfill your request. This information includes:
• your first and last name
• your email address
• your phone number
• your residential and/or postal address (if required for billing purposes)
This is the type of information typically found on a business card. If you make a purchase, we will also store your IP address. We process this information for our legitimate business purpose of matching your IP address with your account. Unless stated otherwise in this policy, personal information will be held for our business purposes for a period of up to 3 years (unless you subscribe to our services for a longer period). After 3 years, we may still retain your personal information however if we do so, it will be in a form where personal details are de-identified. This means you will not be able to be identified once the data is made anonymous.
3.4. With your permission, we may use your email address to send you emails about new products, free and premium content and special events. These emails may contain links to blog posts, YouTube videos, reports/whitepapers etc. We process this information based on your consent. You may always withdraw your consent and unsubscribe to these emails by clicking on the unsubscribe link at the bottom of the email or by contacting us at [email protected]
3.5. If you interact with us via our blog or on social networking sites (Facebook, Twitter. Google+, Linkedin, Instagram), we may receive information about you. We may process this data as a legitimate business interest to properly administer our business and website and communications with users. You should be aware that personal information you disclose on those social media sites is publicly available.
3.7. Testimonials. If you provide us with a testimonial, you give us your consent to use on our website or other marketing material, your name together with your personal image and testimonial wording. You also give us permission to store this information in our secure records together with your email address and the year in which we provided you the services related to your testimonial. We will retain and use this information for it's intended purpose for a period of up to 7 years. We process this information based on your consent.
3.9. We also may share your personal information when required to do so by law or with our professional advisers to obtain advice, for instance if there is a breach of the terms and conditions, or to meet our accounting or compliance obligations.
4.1. We use a range of tools provided by third parties including search engine browsers and our web hosting company, to collect or view social media, app or website traffic information and to enable our website to function smoothly. For example, we use a log-in cookie so users do not have to enter their username and password each time they visit our site.
4.2. We use tracking pixels (for example Google Analytics) to aid in measuring and tracking where our website traffic is coming from and to track the performance of our site. We use these technical and functional cookies to do tasks such as to identify you when you visit our site, manage your log in, remember your preferences, for security purposes, for analysis and to generally improve your experience and manage your sessions on our website.
4.3. We use remarking pixels from Facebook and Google to aid in customised, targeted follow up advertising. These sites have their own privacy policies.
4.4. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Some website features may not function properly without cookies.
4.5. The information collected by these tools may include the IP address of the device you are using and information about sites that IP address has come from, the pages accessed on our site and the next site visited. We use the information, as a legitimate business interest, to help to track your use of our online services to improve your user experience and the quality of our services.
4.6. To find out how to opt out of tailored advertising please check the options available here - http://www.networkadvertising.org/choices/.
5. Storage and Security of Data
5.1. Our website is hosted using cloud hosting provided by Liquid Web (www.liquidweb.com) who apply appropriate security protocols. Liquid Web data privacy can be found here: https://www.liquidweb.com/about-us/policies/privacy-policy/
5.3. Depending on your location, your personal information may cross Country borders and may be stored in a jurisdiction with different privacy laws to where you live. By agreeing to this policy, you agree to such a transfer.
5.4. We are committed to ensuring your information is secure. To prevent unauthorised access or disclosure, we use third party hosting and storage providers with industry standard security. We also internally take reasonable precautions and aim for industry best practice to avoid mis-use, interference loss or unauthorised access, modification or disclosure of your personal information. While we do our best to ensure the security of your data, no storage is 100% secure and we cannot guarantee the safety of your data. If you feel this is not sufficient, please do not provide us with your personal information, or, if you have already provided personal information, please contact us and we will securely destroy it.
6. Collection of Data of Minors
6.1. Our website is not intended to be used by minors nor do we do not intend to collect the personal data of persons under the age of 13. If you are the guardian of a minor and suspect they may have provided us with their personal information, please contact us and request to have the minor's personal information destroyed (use the contact information in the schedule below).
7. Data Rights
7.1. You have the right to ensure:
• We process your data fairly and lawfully and within the purpose and/or consent it was provided to us.
• Your data is accurate.
• The data collected by us is not excessive.
• Your data is accurate.
To ensure this happens, you can:
• Have your data updated and amended if incorrect, out of date or incomplete.
• Restrict the level of processing or automated processing we do.
• Know how long we keep your data.
• Ask us to erase your data and be forgotten.
• Ask us to provide details of the personal data we hold.
To achieve this, at your request, and upon production of satisfactory identification, we will tell you what personal data about you is being processed (eg what information we have stored), on what basis, and by whom.
7.2. You may amend inaccurate, incomplete or outdated personal data at any time by applying directly to us using the contact information in the schedule below.
7.3. If you decide your data should not be processed for one or more purposes, you may withdraw your consent from using your data in that way. Please note that we will action your request as soon as practically possible however such a request will not take effect immediately and your data may still be used in the meantime.
7.4. You may request that all personal data we have collected about you be deleted from our records and erased from information stored by any third party organisations processing data on our behalf.
7.5. If data we have collected about you is processed using automated means, you have the right to receive that data in a structured, machine-readable format and to transmit it to another data controller without hindrance.
Notice To California Users
Pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), we are providing the following details regarding the categories of personal information about California residents we have collected or disclosed within the preceding 12 months.
We collected, including through service providers, and disclosed the following categories of personal information:
Identifiers, such as your name, email address, as well as IP addresses, device IDs, user IDs, and other similar identifiers;
Payment and financial information you provide when you purchase a Product, services, Subscription or use certain features of the Platform;
Characteristics about you like any information you choose to provide when you register an account on the Platform;
Commercial information, such as Subscription and other purchase or transaction information related to your use of the Platform;
Internet or other network activity information, including browsing and search history and other information about your use of the Platform, as well as information about how you interact with ads for KLEQ off the Platform;
Geolocation data derived from IP addresses;
Audio, visual, and other electronic information, such as video recordings, images, and comments;
We disclosed the categories of personal information above, including to our service providers and affiliates, for a range of operational business purposes, including:
+ To operate and maintain the Platform and your account;
+ To market and sell our products and services;
+ To provide personalized content and ads;
+ To perform research and development;
+ To perform data and business analytics;
+ To detect and prevent fraud or abuse;
+ To perform identity verification;
+ To process Product and Subscription payments;
+ To process user inquiries and requests;
+ To perform security and other risk testing;
+ To undertake quality assurance measures;
+ To maintain our systems and infrastructure;
+ To comply with law or exercise or defend legal claims;
+ To perform accounting, audits and other internal functions; and
+ To otherwise operate our business and achieve our business objectives
For purposes of CCPA, the disclosure of personal information to our advertising partners to provide you with personalized ads may constitute a "sale" in some instances. The personal information disclosed is limited to the following:
+ IP address and device ID
+ General location information
+ Inferred preferences based on your use of the Platform
We do not otherwise "sell" personal information.
Exercising Your California Privacy Rights
CCPA and other California law provides California residents with the additional rights listed below. You may exercise any of the rights described in this section through the Help Center or by contacting us at [email protected] Please note that we may ask you to verify your identity before taking further action on your request.
Right to Access: You have the right to know and access what data we have collected about you over the past 12 months, including:
+ The categories of personal information we've collected about you;
+ The categories of sources from which the personal information is collected;
+ The business or commercial purpose for collecting your personal information;
+ The categories of personal information about you which we shared and/or sold;
+ The categories of third parties we have shared or sold personal information to; and
+ The specific pieces of personal information we have collected about you.
Right to Delete: You have the right to request that we delete personal information we have collected from you (and direct our service providers to do the same). In some instances, however, we may decline to honor your request where an exception applies.
Right to Opt Out: You have the right to opt-out of any future "sale" of personal information about you by contacting us.
Other Rights: You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.
8. Contact Us
8.1. Please let us know if you have any requests, feedback or concerns regarding the way we manage your personal data. Use the contact details listed in the below schedule. We will respond to you within 30 days and take action, within reason, as quickly as possible.
8.2. If you are not happy with how we manage your concerns, you can contact your local data protection supervisory office. For example, in Europe, this would be the European Dara Protection Supervisor www.edps.europa.eu.
9. Changes to this Privacy Notice
9.1. It is important to us that our privacy notice is regularly reviewed and we will do so to keep it relevant and up to date with changing laws. We will notify you of any changes by posting the new policy on this page.
Our contact details If you have questions, require more information, have a complaint to register or details to amend, correct or delete in relation to your personal information, please contact our Privacy Compliance Officer via email at: [email protected]