KL-IMAGINE Privacy Policy
Posted: JAN 26, 2024
Effective: JAN 26, 2024
Thanks for using KL-IMAGINE Memory On Cloud App! Here we describe how we collect, use, and handle your personal data when you use our websites, software, and services (“Services”).
What & Why
We collect and use the following information to provide, improve, protect, and promote our Services.
Account information. We collect, and associate with your account, the information you provide to us when you do things such as sign up for your account, upgrade to a paid plan, and set up two-factor authentication (like your name, email address, phone number, payment info, and physical address).
Your Stuff. Our Services are designed as a simple and personalized way for you to store your photos and videos (“Your Stuff”), and work across multiple devices.
Usage information. We collect information related to how you use the Services, including actions you take in your account (like viewing photos and videos, and buying packages). We use this information to provide, improve, and promote our Services, and protect users.
Device information. We also collect information from and about the devices you use to access the Services. This includes things like IP addresses, and device you use. Your devices (depending on their settings) may also transmit location information to the Services. For example, we use device information to detect abuse and identify and troubleshoot bugs.
Cookies and other technologies. We use technologies like cookies and firebase analytics to provide, improve, protect, and promote our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information.
Google analytics. When you use the Google Analytics portion of our Services to view content, we collect information including your identifying and device information, such as email addresses, IP addresses, and device identifiers of devices you use to view the content. We also collect information on how you interact with the viewed content, such as the date and time you view the content, the number of times and length of time you view the content, and which portions of the content you view.
Marketing. We give users the option to use some of our Services free of charge. These free Services are made possible by the fact that some users upgrade to one of our paid Services. If you register for our Services, we will, from time to time, send you information about upgrades when permissible. Users who receive these marketing materials can opt out at any time. If you don’t want to receive a particular type of marketing material from us, click the ‘unsubscribe’ link in the corresponding emails
We may also collect information from you if you interact with KL-IMAGINE representatives at an event, download marketing or educational materials from our website, or contact a KL-IMAGINE representative. We may use the information you provide to send you additional marketing materials.
We sometimes contact people who don’t have a KL-IMAGINE account. For recipients in the EU, we or a third party will obtain consent before reaching out. If you receive an email and no longer wish to be contacted by us, you can unsubscribe and remove yourself from our contact list via the message itself.
Bases for processing your data. We collect and use the personal data described above in order to provide you with the Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs. To the extent we process your personal data for other purposes, we ask for your consent in advance or require that our partners obtain such consent.
For more details on the categories of personal information that are included in the information above.
With Whom
We may share information as discussed below, but we won’t sell it to advertisers or other third parties.
Others working for and with KL-IMAGINE. We uses certain trusted third parties (for example, providers of customer support and IT services) for the business purposes of helping us provide, improve, protect, and promote our Services.
Law & Order and the Public Interest. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of KL-IMAGINE or our users.
Stewardship of your data is critical to us and a responsibility that we embrace. We believe that your data should receive the same legal protections regardless of whether it’s stored on our Services or on your home computer’s hard drive. We’ll abide by the following Government Request Principles when receiving, scrutinizing, and responding to government requests (including national security requests) for your data:
How
Security. We have a team dedicated to keeping your information secure and testing for vulnerabilities. We continue to work on features to keep your information safe in addition to things like two-factor authentication, encryption of files at rest, and alerts when new devices and apps are linked to your account. We deploy automated technologies to detect abusive behavior and content that may harm our Services, you, or other users.
User Controls. You can access, amend, download, and delete your personal information by logging into your account and going to your account settings page.
Retention. When you sign up for an account with us, we’ll retain information you store on our Services for as long as your account exists or as long as we need it to provide you the Services. If you want to delete your account, send us mail over privacy@kl-imagine.com and we’ll initiate deletion of this information after 30 days. But please note: (1) there might be some latency in deleting this information from our servers and back-up storage; and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
Use of Data from Google APIs. KL-IMAGINE use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Where
Around the world. To provide you with the Services, we may store, process, and transmit data in the United States and locations around the world—including those outside your country. Data may also be stored locally on the devices you use to access the Services.
Data Transfers. When transferring data from the European Union, the European Economic Area, the United Kingdom, and Switzerland, KL-IMAGINE relies upon a variety of legal mechanisms, such as contracts with our customers and affiliates, Standard Contractual Clauses, the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, the Swiss-U.S. Data Privacy Framework, and the European Commission's adequacy decisions about certain countries, as applicable.
Data Privacy Frameworks. KL-IMAGINE complies with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks, as well as the UK Extension to the EU-U.S. Data Privacy Framework, as set forth by the U.S. Department of Commerce regarding the processing of personal data transferred from the European Union, the European Economic Area, the United Kingdom, and Switzerland to the United States. KL-IMAGINE has certified to the U.S. Department of Commerce that it adheres to the Principles of these Data Privacy Frameworks with respect to such data, but this does not include the DocSend or Formswift portions of the Services. If there is any conflict between this Privacy Policy and the Data Privacy Framework Principles, the Principles shall govern. In accordance with the Principles, KL-IMAGINE shall remain liable for onward transfers if a processor processes personal data in a manner inconsistent with the Principles. To learn more about the Data Privacy Framework, and to view our certification, visit https://www.dataprivacyframework.gov.
KL-IMAGINE is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Data Privacy Framework compliance—free of charge to you. We ask that you first submit any such complaints directly to us via privacy@kl-imagine.com. If you aren’t satisfied with our response, please contact JAMS at https://www.jamsadr.com/dpf-dispute-resolution. In the event your concern still isn’t addressed by JAMS, you may be entitled to a binding arbitration as set forth in Annex I of the Data Privacy Framework Principles.
Your Control and Access of Your Data
You have control over your personal data and how it’s collected, used, and shared. For example, you can:
If you would like to submit a data access request or object to the processing of your personal data, please email us at privacy@kl-imagine.com.
Changes
If we’re involved in a reorganization, merger, acquisition, or sale of our assets, your data may be transferred as part of that deal. We’ll notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.
We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.
Contact
Have questions or concerns about KL-IMAGINE, our Services, and privacy? Contact our Data Protection Officer at privacy@kl-imagine.com. If they can’t answer your question, you have the right to contact your local data protection supervisory authority.