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Kumbu Privacy Policy – May 25th 2018

Our role in your privacy

If you are a Kumbu customer or subscriber, or just visiting our website, this policy applies to you. It applies to our website, web applications, browser extension and mobile apps.

Our responsibilities

If you are a registered Kumbu customer or a visitor to our website we act as the data controller of personal data. This means we determine how and why your data are processed.

Your responsibilities

  • Read this Privacy Policy
  • If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Privacy Policy.

When and how we collect data

From the first moment you interact with Kumbu, we are collecting data. Sometimes you provide us with data, sometimes data about you is collected automatically.

Here’s when and how we do this:

Data you give us

  • You signup for Kumbu
  • You use Kumbu
  • You chat with us for support
  • You send us a nice email about Kumbu

Data we collect

  • You visit our website
  • You signup for Kumbu
  • You use Kumbu
  • You chat with us for support
  • You send us a nice email about Kumbu
  • You connect the Kumbu API to a third party

Types of data we collect

  • Contact details : Your email address when you signup for Kumbu
  • The memories you store in Kumbu : those are encrypted and stored in Kumbu. We don’t look at them, but we know there here.
  • Data that identifies you : IP Adress, Browser version, Timezone, Operating System. We use that to figure out who’s using Kumbu.
  • Data on what pages are viewed on the website. We use that to figure out if people find our stuff interesting.
  • Data on how you use Kumbu : what features are used, what are the response time, are there any bugs. We use that to make Kumbu better.
  • What about sensitive data ? We don’t collect any "sensitive data" about you (like racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data about your sexual life or orientation, and offences or alleged offences)
  • What about children’s data ? Kumbu is intended to be used by adults - we don’t target Kumbu at children, and do not knowingly collect any personal data from any person under 16 years of age.

How and why we use your data

Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. Here are the reasons for which we process your data:

  • Keeping Kumbu running : making sure you can login, making sure the servers are up
  • Improving Kumbu: Testing features, managing landing pages, optimising our traffic
  • Customer Support: Notifying you of any changes to our service, solving issues via live chat support, phone or email including any bug fixing.
  • Marketing Purposes (with your consent): Sending you emails and messages about new features, products and services, and content.

Your privacy choices and rights

  • You can choose not to provide us with personal data : If you choose to do this, you can continue to use the website and browse its pages, but you will not be able to have a Kumbu account
  • You can turn off cookies in your browser by changing its settings You can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use the website and browse its pages, but Kumbu and certain services (like Intercom) will not work effectively.
  • You can ask us not to use your data for marketing We will inform you (before collecting your data) if we intend to use your data for marketing and if third parties are involved. You can opt out from marketing by emailing us at support@getkumbu.com

Your rights

You can exercise your rights by sending us an email at support@getkumbu.com .

You have the right to access information we hold about you

This includes the right to ask us supplementary information about:

  • the categories of data we’re processing
  • the purposes of data processing
  • the categories of third parties to whom the data may be disclosed
  • how long the data will be stored (or the criteria used to determine that period)
  • your other rights regarding our use of your data

We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of other (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason.

You have the right to make us correct any inaccurate personal data about you

You can object to us using your data for profiling you or making automated decisions about you

We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behaviour). Otherwise, the only circumstances in which we will do this is to provide the Kumbu service to you.

You have the right to port your data to another service

We will give you a copy of your data in CSV or JSON so that you can provide it to another service. If you ask us and it is technically possible, we will help transfer the data to the other service with you.

You have the right to be ‘forgotten’ by us

You can do this by asking us to erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of Kumbu.

You have the right to lodge a complaint regarding our use of your data

Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the French Data Protection Agency here

How secure is the data we collect?

We have physical, electronic, and managerial procedures to safeguard and secure the information we collect. We use encryption throughout Kumbu to make sure only you can access your data.

And please remember:

  • You provide personal data at your own risk: unfortunately, no data transmission is guaranteed to be 100% secure
  • You are responsible of your Kumbu password: keep it secret and safe!
  • If you believe your privacy has been breached, please contact us immediately on support@getkumbu.com

Where do we store the data?

The personal data we collect is processed at our offices in Paris and Bordeaux and in any data processing facilities operated by the third parties identified below.

By submitting your personal data, you agree to this transfer, storing or processing by us. If we transfer or store your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

How long do we store your data?

As long as you have a Kumbu account, we keep PII such as your email adress, as well as your memories of course. If you ask us to delete your Kumbu account, we delete all your personal information within a week (7 days). Personal information residing in our backups may take up to a year to be rotated out of backups.

Third parties who process your data

Tech businesses often use third parties to help them host their application, communicate with customers, power their emails etc. We partner with third parties who we believe are the best in their field at what they do.

When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Privacy Policy.

Here are the details of our main third-party service providers, and what data they collect or we share with them, where they store the data and why they need it.

Infrastructure

Service provider
Data collected or shared
Purpose
Place of processing
Amazon Web Services, Inc.
Privacy Policy
Data that identifies you
This is a storage provider. We use it to store souvenirs
EU and US
Digital Ocean
Privacy Policy
- Data that identifies you
- Data on how you use Kumbu
This is where our processing servers are hosted
US
Papertrail
Privacy Policy
Data on how you use Kumbu
This is where our log and error messages go
US
- Data that identifies you
- Data on how you use Kumbu
We receive slack notifications from the above services when significant events occur or when you try to contact us
US

Analytics

Service provider
Data collected or shared
Purpose
Place of processing
Google Analytics
Privacy Policy
- Data that identifies you
- Cookies
Google Analytics is a web analytics service: we use it to track your use of the website, and prepare reports on website activity. We do NOT use google analytics on the Kumbu app or service.
US

Comms & support

Service provider
Data collected or shared
Purpose
Place of processing
Mailgun, Inc.
Privacy Policy
Contact details
We use this service for sending transactional emails such as resent password emails
US
Mailchimp
Privacy Policy
Contact details
We use this service to send you updates about Kumbu features
US
Intercom, Inc.
Privacy Policy
- Contact details
- How you use Kumbu
- Cookies
We use this service for customer communications, user interaction and helpdesk assistance
US
Google, Inc.
Privacy Policy
Contact details
We use Google G-Suite to handle our @getkumbu.com email
EU and US

Cookies

We use cookies. Unless you adjust your browser settings to refuse cookies, we (and these third parties) will issue cookies when you interact with Kumbu. These may be ‘session’ cookies, meaning they delete themselves when you leave Kumbu, or ‘persistent’ cookies which do not delete themselves and help us recognise you when you return so we can provide a tailored service.

How can I block cookies?

You can block cookies by activating a setting on your browser allowing you to refuse the setting of cookies. You can also delete cookies through your browser settings. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully. In some cases, our website may not be accessible at all. Please note that where third parties use cookies we have no control over how those third parties use those cookies

Which specific cookies do we use?

Service provider
Key cookies
Purpose
Google, Inc.
NID
_ga
_gid
_gat
_gat_gtag_UA_XXXXX_X
Google Analytics uses cookies allows us to see information on the activities of visitors to our website only (It is not used on the Kumbu Service or App), including page views, source and time spent on the website. The information is depersonalized and is displayed as numbers, meaning it cannot be tracked back to individuals. This will help to protect your privacy.
To opt out of being tracked by Google Analytics across all websites click here.
Intercom, Inc.
_mkra_ctxt
intercom-id-XXXXXX
Intercom uses cookies to recognise Kumbu users who have interacted with Intercom through Kumbu previously. You may refuse the transmission of your Information by opting out (contact them direct for more information), however please note that we use Intercom to provide you customer support, and it might be more complicated to do so (but you can still email us of course!)

Help us Improve this policy

Well done for getting to the bottom of this policy. We have designed it with inspiration from other beautiful privacy policies to be as transparent, useful and engaging as possible and we would love to hear your feedback on how we can make it even better - please contact us at support@getkumbu.com

Please don’t make this the last time you read it as we will post any changes on this page - significant changes will of course be notified to you by email.

Previous Versions of this Policy:

  • May 2018 (current version) : We’ve clarified wording, third party usage and complied with GDPR
  • October 2017 : Clarified usage of mobile apps too