Our Privacy Policy

Last modified September 16, 2022 with an effective date of September 16, 2022

This privacy policy ("Policy") informs you of practices when handling your Information through the Services (both as defined below). In this Policy, "Kairn", "we" or "us" refers to Kairn Inc., a company registered in Delaware with its registered address located at Corporation Trust Center, 1209 Orange Street, Wilmington, DE 19801, United States. We are the data controller under the applicable privacy laws.

For the purpose of this Policy, "Information"means any information relating to an identified or identifiable individual. This includes Information you provide or generated when you use: (a) our apps ; and (b) kairn.app and any other dedicated Kairn websites which link to this policy ("Website"and together with the "Apps" the "Services"). When you use the Services, you accept and understand we collect, process, use and store your Information as described in this Policy. If you do not agree with this Policy, you must not use any of the Services. If you change your mind in the future, you must stop using the Services and you may exercise your rights in relation to your Information as set out in this Policy.

Who are the data subjects?
We process personal data from:
- our users;
- our suppliers' representatives;
- candidates for employment with us;
- visitors to our Website and work premises; and
- other data subjects, (the "data subjects", "you/your").
This privacy policy (the "Policy") applies to any processing of your personal data by us.

1. Information we collect
We will collect and use the following Information about you:

Information you provide to us
Registration information
: for example, when you create an account on the Website, you will be asked to provide your name, email, and password.

Information collected via voluntary activities: for example, when you communicate with us via email, or participate in surveys, we ask you to provide your email address and any Information you choose to provide to allow us to assist you. The Information we collect from you varies depending on the survey, but we typically ask you questions about your interests and habits, your opinion about different products and services and what you‘d like to be offered in the future. We also collect your ratings, opinions, preferences, questions, pictures, and responses associated with that survey.

Information we automatically collect or is generated about you when use the Services
- Identifiers, such as your IP address, device ID, and device information (such as model, brand and operating system).
- Cookies: we use cookies and other similar technologies ("Cookies") to enhance your experience when using the Services. For more information about our Cookies policy, see below How We Use Cookies and Similar Technologies section.
- Information you generate when using the Services: You may provide Information as part of your use of the Services, including any information you provide when sending messages through the Services. Also, if you choose to share and collaborate on a task with your co-workers or friends, we will collect the email address of your co-workers or friends.Please make sure you have permission from your co-workers or friends before sharing Information referring to your co-workers or friends with us.
- Information regarding your use of the Services, such as app use information, interactions with our team, and transaction records.

Information received from third parties.
- Information we receive from third party platforms: when you register through a third party account (such as Apple or Google) or when you connect other apps to our Services (such as Slack and Notion), we receive Information which may include your username, email address, and profile picture.
- Information from platforms our Services relies on, such as for transaction information and payment verification.
- Concerning our calendar integration with gCal from Google. A gCal User may connect their calendar with Kairn. Our calendar integration is designed to help users better prioritise their days by seeing in Kairn how much time they spend in meetings and doing their tasks. We compute a score per day to help them better prioritise time. Concerning data usage in this integration:
>> We never store information from the integration, the data collection is streamed directly to the user.
>> Our integration has access to meetings information on gCalendar but we  only use the following information:the time spent in meeting given the following rules: >>> the type of meeting, we only look at meetings that are not “out of office” or “focus time”;
>>> the number of attendees, we only look at meetings where the user is not alone;
>>> the overlap of meetings, when two hours of meetings overlap we consider them as one hour;
>> among others, we do not use the following information: who the user is meeting with, their email address, the meeting title, or any other details about the appointments.

Our Services are not targeted at children, and we do not knowingly collect Information from children under the age of 13. If you learn that a child has provided us with Information in violation of this Policy, please contact us as indicated below.

2. How we use your personal information
We undertake to use our best efforts to bring our personal data processing activities into compliance with applicable data protection law including Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the "GDPR") and the Belgian Law of 30 July 2018 on the protection of individuals with regard to the processing of personal data, as amended, supplemented or replaced from time to time (the "Applicable Data Protection Law").

We use your Information to: Provide you with the Services. We will use your Information to perform our contractual obligation towards you to allow you to create an account and use the Services. The Information we process when doing so includes your registration information, information you provide to us when using the Services, identifiers, information you generate when using the Services, and information regarding your use of the Services such as transaction information. We also use your Information when you activate certain features of the Services.

-Improve and monitor the Services. It is in our legitimate interests to improve our Services for our customers. When doing so, we may collect information we automatically collect or is generated about you when you use the Services, as well as non-personal information about your device such as device manufacturer, model and operating system.
- Provide you with support and to respond to your requests or complaints. If you reach out to us for support, we will use your Information to respond to and resolve your queries and complaints and facilitate support (e.g. bug reports, feature requests). When doing so, we perform our contractual obligation towards you. The Information we process when doing so includes your registration information, your identifiers, and any other information about you collected via our customer support channels.
- Conduct analytics. It is in our legitimate interests to analyse the use of, and any other interaction or interest in our Services. When doing so we will process information we automatically collect or is generated about you when you use the Services to create anonymised and aggregated data regarding your App usage.
- Send you newsletters about product news, tips and tricks, productivity reports that may be of interest to you. We will send you emails with daily reports, opt-in newsletters with product news, and tips and tricks to use our Services. When doing so, we process your registration information. Your consent can be withdrawn at any time by following the unsubscribe mechanism at the bottom of each communication.
- Prevent fraud, defend Kairn against legal claims or disputes, enforce our terms and to comply with our legal obligations. It is in our legitimate interest to protect our interests by (1) monitoring the use of the Services to detect fraud or any other user behaviour which prejudices the integrity of our Services, (2) taking steps to remedy aforementioned fraud and behaviour, (3) defending ourselves against legal claims or disputes, and (4) enforcing our terms and policies. When doing so, we will process the Information relevant in such a case, including information you provide us, information we automatically collect about you, and information which is provided to us by third parties.
- Conduct surveys. From time to time, we may ask you to participate in surveys we conduct which are in our legitimate interest because they help us understand our userbase and improve the Services. If you participate, we process your registration information and any other information collected through the survey questions.
- If you are a representative of one of our suppliers, we process your personal identification data, professional identification data and contact data for the management of our commercial relationship with our suppliers.
- If you are a candidate for employment with us, we process your personal identification data, professional identification data, contact data, data relating to your professional life (skills, qualifications, experience, etc.) and personal data contained in your curriculum vitae to assess your profile in relation to our recruitment needs.
- We may also process some of your personal data for the following purposes:conduct operations to restructure our activities;carry out internal and external audits;manage disputes with data subjects and where processing is necessary for the establishment, exercise or defence of a legal claim.
- We do not subject the data subjects to decisions based exclusively on automated processing that produces legal effects concerning them or that affect them in a similarly significant way.

In what capacity do we process your personal data?
We process your personal data in a capacity of controller. In this context, we determine the purposes and means of the processing of your personal data.

On which basis do we process your personal data?
- The provision of your personal data may be necessary:
> for the performance of a contract to which the data subject is a party or for the performance of pre-contractual steps taken at your request (for example, in the event of a request to work with us);
> for compliance with a legal obligation applicable to us (e.g. accounting, taxation, etc.);
> to pursue our legitimate interests (or those of a data recipient) provided that these interests prevail over your fundamental rights and freedoms.

- We ask for your prior, free and informed consent before processing some of your personal data (for example, whenever the processing of your data involves a transfer of your image rights).

- The provision of some of your personal data (e.g. your personal identification data, etc.) may be a condition to enable us to provide you with our services or perform our activities.

- The possible consequences of not providing your personal data may include our inability to provide you with our services or perform our activities or a breach by us of one or more obligations under applicable laws (e.g. accounting and tax laws).

3. How we use cookies and similar technologies
Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer‘s hard drive.
Our Services uses Cookies to collect information about your browsing activities and to distinguish you from other users of our Services. This aids your experience when you use our Services and also allows us to improve the functionality of our Services.

We use the following cookies:
- Strictly necessary cookies: Some cookies are strictly necessary to make our Services available to you; for example, to perform your login functionality and for user authentication and security. We cannot provide you with the Services without this type of cookies.
- Functional 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).
- Analytical or performance cookies. We also use cookies for analytics purposes in order to operate, maintain, and improve our Services. We use third party analytics providers, including Google Analytics and Mixpanel, Hotjar, and June, to help us understand how users engage with the Services. Such services uses cookies to track user interactions which helps show how users use our Services. This information is used to compile reports and to help us improve our Services.
You can block cookies by setting your internet browser to block some or all cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to use our Services.

4. Who we share your personal information with
We do not sell your information to any third parties or disclose it in exchange for money or other valuable consideration. We do not share your Personal Data with others except as indicated within this Notice, or when we inform you and give you an opportunity to opt-out of having your Personal Data shared.

We share your Information with selected third parties, including:
- Other users who will see your profile information and any other information you choose to share with them through the Services;
- Vendors and service providers we rely on for the provision of the Services , for example: Authentication services such as Auth0 - Okta Inc, based in the U.S. to securely authenticate users;
- Cloud service providers who we rely on for data storage, including Google Cloud Services;
- Customer support solution providers, who help us manage and respond to our customer questions and complaints. This includes Intercom Inc., which is based in Ireland;
- Analytics providers. We work with a number of analytics, segmentation and measurement service providers who help us understand our userbase. This includes among others Google LLC, which is based in the U.S. You can learn about Google‘s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout;
- Third Parties Service Integrations. When you connect third party apps to the Apps, you authorize us to share designated information and data created and/or uploaded by you to our server with these third party services of your choice on your behalf;
- Communications platform providers, who help us manage and send newsletters to you in relation to the Services. This includes SendGrid, and Intercom which are based in the U.S and Ireland;
- Law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection);
- Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

We have taken reasonable steps to help protect the personal information we collect. Although we have in place security measures to maintain the privacy and integrity of your Information, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimise the Information we process. For example, when we use Auth0 for secure authentications. Additionally, we are not responsible for how third party integration services may collect, use or share the Information you send from the Apps. Please review the privacy policy of such third party integration partners before connecting those services to the Apps.

Who has access to your personal data?
The following recipients may receive or have access to some of your personal data (only if necessary for the performance of their tasks):
- the members of our staff tasked with technical, commercial and administrative follow-up have access to all the data mentioned in article 4.1;
- the members of our staff tasked with monitoring our suppliers have access to personal identification data, professional identification data and contact data of our suppliers' representatives;
- our legal advisors and lawyers have access to certain personal data of data subjects in the context of the restructuring of our activities or litigation.

We entrust the processing of some of your personal data to processors only to the extent necessary to carry out their tasks and in accordance with our written instructions and with Applicable Data Protection Law. In the case of a restructuring of our activities (e.g. a financing operation), we may transfer certain personal data concerning a limited number of data subjects to a third party involved in the operation (e.g. a bank) in accordance with Applicable Data Protection Law.

5. Where we store your information
Your Information will be processed by our employees and service providers in the E.U. We take steps to ensure all transfers are protected by adequate safeguards, including the standard contractual clauses approved by the European Commission.

6. How long we store your information
Your Information is kept for as long as necessary to achieve the purposes set out above. Generally, it is stored for as long as you are registered and using our Services, and then for up to 6 years from the date you stop using the Services, or promptly following a valid erasure request (see below _ Your Rights: Erasure _ section). Some information we collect will be stored for longer where we have an overriding legitimate interest to retain such information (for example, information on suspicious behaviour of certain users of our Services and transaction records).
When deleting Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently.

7. Your rights
If you are based in the EEA, you have certain rights in relation to your Information. You will find more information below on when which rights can apply. To exercise your rights, please contact us at hello@kairn.app

- Access. You have the right to access Information, and to receive an explanation of how we use it and who we share it with. Please ask us at hello@kairn.app. The right to access is not absolute. For example, we cannot reveal trade secrets, or give you Information about other individuals.

- Erasure. You have the right to delete your account and erase your Information and upon deleting your account, all your Information will be removed from our production systems. At any moment you can delete your account directly on your profile page. You can also contact us at hello@kairn.app to ask for a delete. We reserve the right to retain some of your Information where there are valid grounds for us to do so under data protection laws. For example, for the defence of legal claims, respect freedom of expression, or where we have an overriding legitimate interest to do so. Note that where the Information is held by a third party data controller, we recommend you contact them directly in accordance with their own privacy policies to ensure your personal data is erased.

- Objection. You may have the right to object to our processing of your Information. This is the case where we process such Information on the basis of our legitimate interests (see above under _ How we use your personal information _ section), or where the Information is used for direct marketing purposes. You may exercise this right as follows:To stop receiving marketing newsletters: You may withdraw your consent through the unsubscribe mechanism at the bottom of each communication.To stop our cookies being placed for either advertising or analytics purposes: please change your device or browser settings.To object to all other processing based on our legitimate interests, please contact us at hello@kairn.app Please note that we may have an overriding legitimate interest to keep processing your Information, but we will let you know where this is the case.

- Portability. You have the right to receive a copy of Information.

- Correction. You have the right to correct any Information held about you that is inaccurate.

- Restriction. You have a right in certain circumstances to stop us processing Information other than for storage purposes.

- To withdraw consent. If you have given us your consent for the processing of your personal data, you have the right to withdraw it at any time.

- To be informed. You have the right to obtain clear, transparent and understandable information about how we process your personal data and how to exercise your rights. This information is contained in the Policy. If such information is not clear enough, we invite you to contact us (via our contact details set out in the Policy).

Please forward any request relating to the exercise of your rights regarding your personal data that we process in our capacity as controller to our contact person for data protection matters using his or her contact details as set out in the Policy. We undertake to respond to your request as soon as practically possible and always within the timeframes set forth by Applicable Data Protection Law. Please note that we may retain your personal data for certain purposes when required or permitted by law. Finally, please note that we may, in the event of doubt as to your identity, ask you for proof of identity in order to prevent any unauthorised access to your personal data.

8. Contact & complaints
We welcome questions, comments and requests regarding this Policy. For additional details feel free to contact us at hello@kairn.app.
If you wish to make a complaint about how we process your Information, please contact us at hello@kairn.app and we will endeavour to deal with your complaint as soon as possible. This is without prejudice to your right to launch a claim with a data protection authority.

9. Changes
If we make any material changes to this Policy, we will post the updated Policy here and notify our users through the Services and/or newsletters. Please check this page frequently to see any updates or changes to this Policy.