Last updated: February 12, 2022
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You for the purpose of creating legally binding documents. Personally, identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data is collected automatically when using Klokbox’s Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information Collected while Using the Klokbox Application While using Our Application, in order to provide features of Our Application, We may collect, with your prior permission:
- Information regarding your location
- Information from your Device’s phone book (contacts list)
- Pictures and other information from your Device’s camera and photo library
We use this information to provide features of Our Service and to improve and customize Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device.
You can enable or disable access to this information at any time, through Your Device settings.
When You choose to use Klokbox services, we strictly follow the Customer’s instructions in collecting and processing data. The User is considered as the data controller and Klokbox is considered as a data processor, in relation to the processing of Your personal data.
Who is Your Data Controller and Data Protection Officer
Klokbox PLC is your Data Controller and is responsible for your Personal Data.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Processing Data on behalf of a Controller and Processors’ responsibility to you. In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
- Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
- Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
- Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
- Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
- Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
- Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
- Maintain a record of all categories of processing activities carried out on behalf of a Controller;
- Cooperate, on request, with the supervisory authority in the performance of its tasks;
- Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
- Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
- Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority; and
- Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain their expert knowledge;
Use of Your Personal Data
Klokbox PLC may use Personal Data for the following purposes:
- To provide and maintain our Service: including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You: with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service, products, services, marketing, and your experience.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures, and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
We allow a 12-month data recovery period, from the date of release, the infringed account can be recovered for 365 days and repopulated using the Recovery code. Once data passes as time capsules, it becomes the property of the new user. We keep data for up to a year after the subscription elapses.
If a Keyholder tries to release a Klokbox and the subscription has elapsed, and it’s still within the 12-month retention period, then the Keyholder should have the ability to pay the arrears, thus allowing the data to be released.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
Some parts of the Service are available as an upgraded service and are billed (“Subscription(s)”).
The cost of this monthly subscription is clearly displayed at the time of upgrade, currently $89/year (subject to change). You will be billed in accordance with this subscription in advance on a recurring and periodic basis (“Billing Cycle”). Billing cycles are currently set on a monthly basis.
At the end of each Billing Cycle, your Subscription will automatically renew under the exact same conditions unless you cancel it or we at Klokbox cancel it for breach of contract.
You may cancel your Subscription renewal at any time, either through your online account with the App Store (through its management page) or by contacting our customer support team.
No refund will be made for services already provided and cancellation will be effective immediately.
Access to your data will be available at all times following cancellation, however, data releases will become immediately disabled and thereby become ineffective upon cancelling your subscription.
Klokbox PLC follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this as part of hosting services’ analytics. The information collected by log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
When you access the Service by or through a mobile device, we may collect certain information automatically including (but not limited to) the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other statistics (“Log Data”).
In addition, we may use third-party services such as Google Analytics that collect, monitor, and analyze this type of information in order to increase our service functionality. These third-party service providers have their own privacy policies addressing how they use such information.
Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.
We use “cookies” to collect information.
You yourself can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
We may employ third-party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Communications and Data Protection Act
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Compliance With The Law
We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.
If Klokbox is involved in a merger, acquisition, or asset sale your Personal Information may be transferred.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Your information including Personal Information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. We currently host all data within the European Union.
If you are located outside Ireland and choose to provide information to us please note that we transfer the information, including Personal Information to Ireland and process it there.
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Advertising Partners Privacy Policies
Note that Klokbox PLC has no access to or control over these cookies that are used by third-party advertisers.
Third-Party Privacy Policies
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
CCPA Privacy Rights (Do Not Sell My Personal Information)
Under the CCPA, among other rights, California consumers have the right to.
Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business deletes any personal data about the consumer that a business has collected.
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
GDPR Data Protection Rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
Data Location and Transfer
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Klokbox PLC has facilities. We are currently storing data in the EU and so, by using Klokbox PLC, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
Customer support system
Our customer support and email services are hosted primarily in the EU. Any information you choose to send us through email or our customer support system may pass through and be stored on a variety of intermediate services.
Third-Party Data Processors
Your data is held by third-party data processors, who provide us with hosting and other infrastructure services. In many cases (but we cannot promise that this will always be the case) even Service data held by these entities is encrypted with keys held only by us.
Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from children aged under 13. If you are a parent or guardian and you are aware that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.