Privacy Notice

The website located at https://klaro.cards (hereafter referred to as “Website”) and the Klaro application (hereafter referred to as “Application”) are the initiatives of:

Klaro App SRL (hereafter referred to as “Klaro App SRL” and “We”)
Chaussée De Chastre, 985140 Sombreffe, Belgium
VAT BE0698.790.176
info@klaro.cards
+32477245861

What is this Privacy Notice for?

Every visitor (hereafter referred to as “user”) who uses our Website or Application divulges a certain amount of personal information. This personal information allows us to identify the user directly or indirectly as a real person.

We collect and process your personal information in accordance with applicable legal regulations and laws, in particular the law of 30 July 2018 relative to the protection of privacy in the context of the processing of private data (“Privacy Law”) and the European regulation of 27 April 2016 relative to the protection of people in the context of the processing of personal information and the free circulation of this data: “GDPR”.

By using the Website or the Application, the user declares understanding of this Privacy Notice and expressly accepts the collection and processing of their personal data in the manner outlined in this document.

We reserve at any moment the right to modify our Privacy Notice. All major notification will always be clearly communicated to users. Nevertheless we advise regular consultation of this document.

Who processes your personal data?

Responsibility for processing

Klaro App SRL is responsible for processing data and determines, along or in collaboration with other parties, which personal data is collected, the purpose for which the data is collected and the manner in which the data is processed.

Sub-contractors

Klaro App SRL is free to use the services of sub-contractors. A sub-contractor processes personal information at the request and on behalf of the party responsible for processing data. A sub-contractor is obliged to assure the security and confidentiality of your data and always acts on instruction from the responsible party.

Klaro App SRL works with sub-contractors in the following categories:

• Software design and development (Enspirit SRL, On purpose SRL)
• Hosting of software solutions (Enspirit SRL, Google)
• Chat support system (CM.com)
• Secure electronic payment platform (Stripe)

Why do we process your data and what are our legal bases to do so?

Conforming to Privacy Law and GDPR, we process your personal information for the following purposes:

• To execute the agreement which you have entered into or contractual measures taken at your request in the use of our Website and Application and the provision of our services.
• To fulfil all our legal obligations in the management of contractual relationships, notably invoicing, tax, and accounting obligations.
• To fulfil our legitimate right to send information and newsletters to our clients.
• To respond to your requests, prevent abuse and fraud, monitor the regularity of our services, exercise, defend and preserve our rights, for example in case of disputes, as well as to provide evidence of any violation of our rights, manage and improve our relationship with you, continuously improve our website and our products/services, unless these interests are overridden by your interests or your freedoms and fundamental rights requiring the protection of your personal data.
• To send you promotional offers (marketing) or any other data processing if you have expressly consented to it.

What personal information is collected?

Processing of your personal data is limited to what is strictly necessary to attain goals set by Klaro App SRL. Listed below are the categories of data processed:

• Personal identification data (name, surname and login details)
• Contact details (telephone number and email address)
• Financial information (bank details, secured by Stripe)
• Electronic identification (IP address, localisation, cookies)
• Information supplied as part of your Klaro projects (card content, dimensions)
• Information about Klaro usage preferences (in your user profile)

This data is collected at the moment of registration or when the Website and Application are used. We may need your personal data in order to comply with our own contractual obligations (if we do not have such personal data, we may not be able to provide you with our services). Other personal information may be collected subsequently, for example in the context of our after-sales service. The quantity of collected data depends on your use of the Website and Application and their functions.

Among other things, we may use cookies to recognise users and offer them a personalised user experience, to memorise their technical choices (for example visibility options for boards) and to detect and correct possible errors on the Website and Application. We make best efforts to minimize the amount of tracking cookies in use in our website and application. For more information about our use of cookies, please consult our Cookie Policy.

Who receives your personal data?

Your personal data is collected exclusively for internal use. Aside from communication and processing by our authorized sub-contractors identified in the “Sub-contractors” section, your personal data is not sold, transmitted or communicated to third parties. Whenever possible and in the context of their service, we minimise the exposure of your data to sub-contractors, and we anonymise wherever possible.

In the event of a dispute, your personal data may be transmitted to a third-party responsible for managing disputes (law firm, collection company, etc.), which will also ensure compliance with the applicable legislation regarding this data.

How long is your data conserved for?

Your data is conserved for as long as necessary to attain the associated goals and in accordance with the law. It will be either deleted or anonymized from our database the moment when it is no longer necessary to achieve these goals, if you exercise your right to request and obtain deletion.

In general, such period of time is 10 years after the end of the business relationship.

The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Do we transfer your personal data outside the EEA (European Economic Area)?

Unless otherwise indicated, we do not transfer your personal data outside the European Union. If this happens, we would only transfer your data to a non-EU country if that country provides an equivalent level of protection of the European Union (for more information, see the following link: https://goo.gl/1eWt1V).

Some of our sub-contractors may transfer or host your personal data outside the EEA. Please refer to their own privacy policies for more information.

What are your rights?

Under data protection legislation and subject to our own rights and obligations, you have the following rights:

Guarantee of fair and legal data processing

Your personal information is always processed in accordance with clear goals expressed in the above section “What are the goals targetted by data collection?” Your information is collected and processed in a satisfactory, specific and non-excessive way, and it is not conserved longer than necessary to attain the specified goals.

Right of access

As long as you are able to prove your identity, you have the right request access to your personal data from us, free of charge, and to obtain a copy in an accessible format.

You have the right to know the purpose of this data processing, the categories of data concerned, the categories of parties to whom your data may be transferred, the criteria used to determine the length of conservation of data, and the rights that you have over the control of your data.

Right to correct

Erroneous or incomplete personal information may be corrected. In the first instance it is the user's responsibility to make the necessary corrections in their user account, but corrections may also be requested in writing.

Right to erasure (or “Right to be forgotten”)

You have the right to have your personal data erased in the following cases:

• Your personal data is no longer necessary to attain the specified goals.
• You have rescinded your consent for data processing and there does not exist another legal reason for data processing.
• You have exercised in a valid manner your right to object.
• Your data has been subject to illegal processing.
• Your information has to be deleted to respect a legal obligation.

Right to limit data processing

In certain cases you have the right to request a limit to the processing of your personal data, notably in the case where the accuracy of your data is contested, if the data is necessary in the context of a legal process or during the time it takes for Klaro App SRL to verify that you may exercise in a valid manner your right to erasure.

Right to object

You have the right to object at any moment to the processing of your personal data for direct marketing, profiling or for the legitimate goals of the party responsible for processing your personal data. Klaro App SRL will stop processing your personal data unless we can show a legitimate reason to continue processing your data that outranks your right to object.

Right of data portability

You have the right to obtain all the personal data that you have provided us in a structured format that is readily usable and readable by machine. At your request your data may be transferred to another service provider, unless technically impossible.

Right to retract your consent

At any moment you may retract your consent for the processing of your personal data, for example for the purpose of direct marketing.

How to exercise your rights?

To exercise your rights you have to send us a written request and proof of identity, by recorded delivery, to Klaro App SRL (Chaussée De Chastre, 985140 Sombreffe, Belgium) or by email to info@klaro.cards.

We will respond in good time, at the latest one (1) month following receipt of your request unless specific circumstances apply (e.g. in case of complex request which may take a longer time).

Ability to register a complaint

If you are not satisfied with the processing of your data by Klaro App SRL you have the right to register a complaint with the Authority for the Protection of Data (https://www.autoriteprotectiondonnees.be/).

Long trials do not benefit anyone. In the event of a dispute between us, we commit to give priority to dialogue and openness in the search for an amicable solution.

What happens in the event of a change to the privacy notice?

If we change this privacy notice, you will be notified through our website or by message. We recommend that you check this page regularly. The date of last amendment of this document is shown upstream of this document.