Data protection policy
Konplik Health, Inc.—1007 North Orange Street, 4th Floor #100, Wilmington, DE 19801
Information We Collect and Use
Konplik uses information we collect to operate, maintain and provide you the features and functionality of the Service, to analyze how the Service is used, diagnose service or technical problems, maintain security, personalize content, remember information to help you efficiently access your account, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track content and users as necessary to comply with the Digital Millennium Copyright Act, EU GDPR (General Data Protection Regulation) and other applicable laws.
Information You Provide
You may be providing us information about yourself, such as your name and e-mail address, if you register for an account with the Service, including by connecting with the Service via a third-party service, or by “following,” “becoming a fan,” adding the Konplik application, etc., on a third party website or network. We may use your email address to send you Service-related notices (including any notices required by law, in lieu of communication by postal mail). We may also use your contact information to send you marketing messages. If you don’t want to receive these messages, you can opt out by following the instructions in the message. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. If you choose to use our invitation service to invite a friend to the Service, we will ask you for that person’s email address and automatically send an email invitation. Konplik stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation service.
You also may be providing us information in the content you post to the Service. Konplik can, but has no obligation, to monitor the content you post on the Service. We can remove any information you post for any reason or no reason. We have implemented encryption or other appropriate security controls to protect your personal information when stored by Konplik. Konplik and Konplik employees will not view your content except: (i) to maintain, provide or improve the Service; (ii) to help you and resolve your support requests; or (iii) as Konplik believes, in its sole opinion, is necessary to comply with or avoid the violation of applicable law or regulation or to cooperate with law enforcement.
Our communications with you
Users of the Konplik Service: as part of our service, Konplik will contact you to inform you of any circumstance that you need to know and necessary for the provision of such service: of operation, maintenance or billing incidents, launch of new products or new versions of existing ones, replacement or discontinuation of products, etc. To unsubscribe from the contents necessary for the provision of the service, it is necessary to unsubscribe from the service itself. Users registered to receive marketing communications: if you have registered to receive our marketing communications, you can receive information on the following topics:
- Product news: launch of new products or new versions of existing ones, substitution or discontinuation of products, training events, use tutorials, etc.
- Invitations to events and other content of interest for your position or industry: conferences, webinars, white papers, customer cases, etc.
- Periodical Newsletter: an updated summary about Konplik and its industry (product news, new clients, events, presence in media, etc.)
You can control your subscription to all these types of content through our Communications Preference Center.
When you use the Service, we may send one or more “cookies” – a small data file – to your computer to uniquely identify your browser and let Konplik help you log in faster and enhance your navigation through the site. A cookie may convey anonymous information about how you browse the Service to us. A persistent cookie remains on your hard drive after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled. Konplik website can use the following types of cookies:
|Necessary||Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.|
|Antispam||Antispam cookies are used to prevent automated attacks (by bots) to the website.|
|Statistics||Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.|
|Marketing||Marketing cookies are used to track visitors across websites. The intention is to build a profile of your behavior and interests so that more personalized experiences and content can be offered to you.|
Disabling cookies in your browser
You can easily disable cookies from being installed on your machine, by configuring your browser settings. These are instructions for the most common browsers:
- Google Chrome
- Mozilla Firefox
- Microsoft Internet Explorer
- Apple Safari
When you use the Service, our servers automatically record certain information sent by your web browser. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, mobile carrier, and other such information.
Clear Gifs Information
When you use the Service, we may employ clear gifs (also known as web beacons) which are used to track the online usage patterns. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened by recipients. The information is used to enable more accurate reporting and make Konplik better for our users.
When you use the Service by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey information about how you browse the Service to us. Location data does not collect or share any personally identifiable information about you. Location data may be used in conjunction with personally identifiable information. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
When you access the Service by or through a mobile device, we may access, collect, monitor and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device and are used to enhance the Service. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information about how you use the Service to us. A device identifier does not collect or share any personally identifiable information about you. A device identifier may be used in conjunction with personally identifiable information. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers are impaired or disabled. Konplik may access, collect and/or store device identifiers upon enabling Konplik’s Services.
Third Party Tools
We will display your Personal Information in your profile page. You can review and revise your profile information at any time. We may also share or disclose your information with your consent, for example if you use a third party application to access your account (see below).
Service Providers, Business Partners, and Others
As we develop our business, we may buy or sell assets or business offerings. Customers, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution.
Third Party Services
Compliance with Laws and Law Enforcement Requests; Protection of Konplik’s Rights
Konplik may disclose your personal information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Konplik’s rights or property.
Non-Personally Identifiable Information
We may disclose your non-private, aggregated, or otherwise non-personally identifiable information, such as anonymous usage data, platform types, etc., with interested third parties to help them understand the usage patterns for certain Konplik Services.
How We Protect Your Information
Your Choices About Your Information
You may, of course, decline to submit personally identifiable information through the Service, in which case Konplik may not be able to provide certain services to you. You may update or correct your account information at any time by logging in to your account.
Konplik Blog & Community
Our Service offers publicly accessible community services including blogs, and forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account.
Protecting the privacy of young children is especially important. Our Service is not directed to persons under 13. Konplik does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register with the Service. If we become aware that we have collected personal information from a child under age 13 without verification of parental consent, we take steps to remove that information. If you believe that we might have any information from or about a child under 13, please contact us at email@example.com.
Links to Other Web Sites
International Data Transfer
Konplik Health, Inc. (“Konplik”) has adopted this policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that Konplik obtains from Individual Customers located in the European Union and Switzerland and to personal data received in the U.S. from other Data Subjects in the EU and Switzerland, including EEA Employees of Konplik.
Konplik complies with the European Union legislation, and in particular with:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons 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, GDPR), available at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=EN(Accessed: September 29th, 2020).
The EU Court of Justice (CJEU) delivered on Thursday July 16, 2020 a ruling in the case known as Schrems II (C-3111/18), in which the mechanisms for personal data transfers between the EU and US was challenged based on the argument that US law cannot adequately ensure protection of EU personal data. With that decision, the CJEU struck down the Privacy Shield, one of the most widely used mechanisms allowing US commercial companies to transfer and store EU personal data in the US.
As the European Commission has ruled that Standard Contractual Clauses (SCCs) offer sufficient safeguards to protect personal data that’s transferred internationally, Konplik has adopted this mechanism to comply with Regulation (EU) 2016/679 regarding the processing of data from Customers in the European Union. You can download Konplik’s EU Standard Contractual Clauses.
The term “Individual Customers” needs to be interpreted in a broad sense: these are actual (paying or not) users of Konplik’s products, but also prospective customers that register with Konplik and opt-in to attend its events or download its contents. Konplik stores and processes their data to keep these people informed about its products and services.
All Konplik employees in the U.S. who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.
For the full terms and conditions governing your use of the Konplik service, please see our Terms and Conditions.
Please also review our full Data Protection Policy (https://konplik.health/privacy-policy).
This Policy applies to the processing of Individual Customer Personal Data that Konplik receives in the United States concerning Individual Customers located in the European Union and Switzerland. Konplik provides products and services to businesses and consumers. The term “Individual Customers” designates actual (paying or not) users of Konplik’s products, but also prospective customers that register with Konplik and opt-in to attend its events or download its contents. This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
2. RESPONSIBILITIES AND MANAGEMENT
Konplik has designated the Legal Department to oversee its information security program, including its compliance with the EU regulation. The Legal Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to firstname.lastname@example.org. Konplik will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Konplik personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Konplik has undertaken to protect Personal Data.
Konplik will prepare an internal verification statement on an annual basis.
3. COLLECTION AND USE OF PERSONAL DATA
Konplik provides various solutions to its Individual Customers who purchase its products. Konplik collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, Konplik Individual Customers may choose to seek live support or post to a message board. The Personal Data that we collect may vary based on the Individual Customer’s interaction with our website and request for our services. As a general matter, Konplik collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person’s name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Individual Customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals. When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website. The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer. Konplik uses Personal Data that it collects directly from its Individual Customers for the following business purposes, without limitation:
- maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing analysis requests, reporting, invoices, renewals, and other operations related to providing services to a Individual Customer);
- satisfying governmental reporting, tax, and other requirements (e.g., import/export);
- storing and processing data, including Personal Data, in computer databases and servers located in the United States;
- verifying identity (e.g., for online access to accounts);
- as requested by the Individual Customer;
- for other business-related purposes permitted or required under applicable local law and regulation;
- and as otherwise required by law.
Konplik does not disclose personal information to third parties other than its parent company (MeaningCloud Europe SL), its subsidiaries and their agents, with the same restrictions stated above. Should this change in the future, we will provide individuals with the option to opt-out, or opt-in for sensitive data, for any personal information so disclosed. Konplik provides an individual opt-out choice, or opt-in for sensitive data, before we use your personal information for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
4. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Except as otherwise provided herein, Konplik discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. For operational reasons, Konplik may disclose personal information to its parent company (MeaningCloud Europe SL), its subsidiaries and their agents, with the same restrictions stated above. Such recipients must agree to abide by confidentiality obligations. Konplik may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Konplik may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Konplik and they must either:
- comply with the EU legislation or any mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Data;
- or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;
Konplik also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that Konplik may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Konplik is liable for appropriate onward transfers of personal data to third parties. Konplik’s accountability for personal data that it receives in the United States and subsequently transfers to a third party is described in the Konplik’s EU Standard Contractual Clauses. In particular, Konplik remains responsible and liable if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the clauses, unless Konplik proves that it is not responsible for the event giving rise to the damage.
5. SENSITIVE DATA
Konplik does not collect Sensitive Data from its Individual Customers.
6.DATA INTEGRITY AND SECURITY
Konplik uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Konplik has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Konplik’s electronic information systems requires user authentication via password or similar means. Konplik also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data. Further, Konplik uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
8. ACCESSING PERSONAL DATA
Konplik (and its parent company and its subsidiaries) personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
9. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
Right to Access. Individual Customers and other Data Subjects have the right to know what Personal Data about them is included in the databases in the United States and to ensure that such Personal Data is accurate and relevant for the purposes for which Konplik collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Konplik policies. Upon reasonable request, Konplik allows Individual Customers and other Data Subjects access to their Personal Data, in order to correct, amend, or delete such data where inaccurate or collected in a manner inconsistent with the EU legislation. Individual Customers may edit their Personal Data by logging into their account profile or by contacting Konplik by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local Konplik office.
B. Requests for Personal Data. Konplik will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Konplik receives a request for access to his/her Personal Data from a Data Subject, then, unless otherwise required under law or by contract with such Data Subject, Konplik will refer such Data to the Data Subject.
C. Satisfying Requests for Access, Modifications, and Corrections. Konplik will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
10. CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the EU legislation and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
11. QUESTIONS OR COMPLAINTS
In compliance with the EU legislation, Konplik commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States. European Union and Swiss individuals with privacy inquiries or complaints should first contact Konplik by email at firstname.lastname@example.org.
12. ENFORCEMENT AND DISPUTE RESOLUTION
Konplik is committed to cooperate with EU supervisory authorities about unresolved privacy complaints. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the web site of the European Data Protection Supervisor for more information and to file a complaint. This service is provided free of charge to you. If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and Konplik does not address it satisfactorily, Konplik commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Contact details for the EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en.
13. DEFINED TERMS