Ketch Kloud, Inc. (“Ketch”, “we”, or “us”) is a software company that sells tools for companies to understand, implement, and manage their privacy obligations to their consumers and to control how they store and process data to make compliance with those obligations easy.
We collect personal information (or personal data) and non-personal information (e.g., aggregated data or de-identified data) from you when you use our Services. As further described in this section, we may receive personal information about you that you submit through the Services or that is provided to us by a third party; we also may receive personal information about you automatically as you use the Services.
Information you Provide Us: We receive personal information about you that you choose to provide to us, including when you create an account; search for or purchase our offerings; configure settings; seek employment or business opportunities with us, communicate with us; or otherwise use our Services.
Information from our Customers: Our customers (“Customers”) may share information with us so that we can provide them with our Services. Each Customer chooses what information it shares, which may, for example, include personal information (“Customer Data”).
Usage and Log Data: When you interact with our Services, we may collect information from your device or web browser when you interact with the Services. For example, when you interact with the Services, we may log and store your IP address and technical information about your usage like your device ID, browser type, how you progressed through the Services, where you abandoned it, etc. We can use your IP address to determine your general location. This information is generally pseudonymous but is considered personal information in many places.
App Data: If you use a Ketch application, on mobile or other platforms, we may collect analytic information about your device, such as IP address, device ID, OS version, and clickstream. This information is also generally pseudonymous but is considered personal information in many places.
Information from Public Sources or Third Parties: We may receive additional information about you from public or third-party sources. For example, we may receive marketing, sales generation, and recruitment information from service providers or partners.
We collect, use, process, and store your personal information:
We will only share your personal information with third parties under the following circumstances:
We use and share your non-personal information in a variety of ways, including to improve the Services.
We use tracking technologies, such as cookies, local storage, and pixel tags as described further below.
Cookies may be set and accessed on your computer. Upon your first visit to the Services, a cookie will be sent to your computer that uniquely identifies your browser. "Cookies" are small files containing a string of characters that is sent to your computer's browser and stored on your device when you visit a website. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent; however, if you reject cookies, you may not be able to sign into the Services or take full advantage of our Services. Additionally, if you clear all cookies on your browser, you may need to reset any privacy settings in your browser which are stored in cookies.
Our Services use the following types of cookies for the purposes set out below:
Type of Cookie
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor, but rather enables us to count the number of unique visitors. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages that they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services works. You can find out more information about Google Analytics cookies here. You can find out more about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link. Please note that our transfer of information to Google might be deemed a sale in certain jurisdictions. Where applicable, we will provide you a notice of our transfer of information and provide you with the ability to opt-out of such sale or sharing of information.
These cookies are essential to provide you with services available through our Services and to enable you to use its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, remembering which polls you have voted in and in some cases, to show you poll results, and remembering the changes you make to other parts of our Services which you can customize. These cookies also enable us to identify you across various screens and devices as you login and use our Services, as well as enable us to work with partners to resolve your digital identities and personalize your experiences across our Services, our partners and customers, and across channels. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
A Flash cookie is a data file placed on a device via the Adobe Flash plug-in that is built into or downloaded by you onto your device. Flash cookies are used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. For more information about Flash and the privacy choices Adobe offers, visit this link. If you choose to adjust your Flash privacy settings on your device some features of the Services may not function properly.
We also use “pixel tags,” which are small graphic files that allow us and third parties to monitor the use of the Services and collect usage data. We may also insert pixel tags on third parties’ websites. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your computer. We use pixel tags to collect information about your visit, including the pages you view, the links you click, and other actions taken in connection with our sites and Services and use them in combination with our cookies to provide offers and information of interest to you. We may also use pixel tags to collect data related to a website visit. Similar functionality may be enabled in a mobile app through the use of an SDK (Software Development Kit). Pixel tags also enable ad networks to serve targeted advertisements to you when you visit the Services or other websites. Please note that our transfer of information to these third-party might be deemed a sale in certain jurisdictions. Where applicable, we will provide you a notice of our transfer of information and provide you with the ability to opt-out of such sale or sharing of information. In addition, we use a variety of other technologies that collect similar information for security and fraud detection purposes.
You can also find more information about cookies and how they work, what cookies have been set on your computer or mobile device and how to manage and delete them at http://www.allaboutcookies.org and http://www.youronlinechoices.com.
To stop receiving notifications or promotions, please click the unsubscribe link found at the bottom of each email. For purposes of this policy, we refer to data subjects located in the European Economic Area, United Kingdom, and Switzerland as “EEA” users. We only send marketing communications to users located in the EEA with your prior consent. Please see the section “GDPR: Information for EEA Users” below.
We use industry standard technical, administrative, and physical controls to protect your data. While we take reasonable precautions against possible security breaches, no website or internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss, or other breach will never occur. We will process and store your personal information only for the period necessary to achieve the purpose of the storage, or as permitted by law. The criteria used to determine the period of storage of information is the respective statutory retention period. After expiration of that period, the corresponding information is routinely deleted, as long as it is no longer necessary for the fulfillment of a contract or the initiation of a contract.
You can choose to deactivate your account so that you are no longer viewable on the Services. You can request deactivation through the Services or by sending a message to email@example.com.
The Services may contain links to and from third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies, which may differ substantially from ours, and that we do not accept any responsibility or liability for their activities or the content of their privacy policies.
Certain U.S. States (e.g., Connecticut, Colorado, California, Virginia, Utah) provide additional privacy protections for data subjects located within their jurisdictions, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete), c) the right to correct data we have about you, your computer or device, d) the right to opt-out of the sale or sharing of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales/sharing of your information), and e) the right to port such data to a different company. We do not discriminate against you if you exercise any of the above rights.
Please note that we may not be able to honor a right if doing so would otherwise violate applicable law. Applicable law in certain U.S. states (e.g., Colorado, Virginia) also provide you with the right to appeal to your attorney general’s office in the event that you disagree with how we honor the aforementioned rights.
Applicable law in certain U.S. states also provides you with the right to opt-out of the sale or sharing of your personal information, profiling and targeted ads. We do not transfer your personal information to third parties in exchange for money or engage in profiling or targeted ads, but we may share it with certain third parties for activities like targeted advertising, marketing, and analytics, and these may be deemed a "sale" under applicable law. You may opt-out of sale here if you are located in a place that requires such rights.
Personal Information We Collect and Disclose for a Business Purpose. Without limiting the description of the information we collect, we collect the categories of personal information about U.S. consumers identified in the chart below.
This information is required under California law, but we think it might be helpful to all readers of this policy as it provides a fair description of the types of information collected by Ketch in most places.
Categories of Personal Information
Collected in Prior 12 Months
A. Personal and online identifiers
A real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, and account name.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
We collect names, certain payment information from Customers and partners and (while not covered under this policy) social security and insurance information for our personnel.
C. Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
No, except as required pursuant to management of employment (covered under a different policy).
D. Commercial or transactions information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
We only collect this in connection with the Website.
G. Geolocation data
Physical location or movements.
H. Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information
Current or past job history.
Yes, only in an employment context, which is covered under a different policy.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Categories of Sources
We collect the personal information identified as collected in the chart above from the following categories of sources:
Why We Collect, Use, and Share Information from Data Subjects in California
These commercial and business purposes include, without limitation:
Recipients of Personal Information
We disclose, and have disclosed in the last 12 months, all of the categories of personal information identified as collected in the chart above to the categories of third parties listed below for business purposes:
Your California Rights Regarding Personal Information
Applicable law grants data subjects with certain rights with respect to the personal information collected by businesses. You may exercise the following rights regarding your personal information, subject to certain exceptions and limitations. For example, we tailor the rights made available to you based on applicable law in the place where our systems believe your computer or device is currently located:
To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:
Verification Process and Required Information
We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. For example, we may require you to provide, at a minimum, at least two data points that we determine to be reliable for the purpose of verifying your identity. We will then typically attempt to match the identifying information provided by you to the personal information already maintained by us to verify the request. If you have a password protected account on the Services, we may verify your identity through the existing authentication practices for your account, in which case we will require you to re-authenticate yourself before we disclose or delete your personal information.
You may designate an authorized agent to make a data subject request on your behalf by verifying your identity, as described above, and providing written permission for the authorized agent to act on your behalf.
Ketch will not discriminate against a user because the user exercised any of the user’s rights described above or afforded to it under applicable data privacy law.
Under Nevada law, Nevada residents may submit a request directing us not to make certain disclosures of personal information we maintain about them.
To exercise this right, please contact us:
Personal data collected through our Services will be transferred to and stored by us in the United States; therefore, your personal data will be processed outside your jurisdiction in a country that is not currently subject to an adequacy decision by the European Commission, and that may not provide the same level of data protection as your jurisdiction, such as the EEA. We ensure that the recipient of your personal data offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulator.
Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it 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.
In the context of an onward transfer, Ketch is responsible for the processing of personal data it receives under the DPF Principles and subsequently transfers to a third party acting as an agent on its behalf. Ketch shall remain liable under the DPF Principles if its agent processes such personal data in a manner inconsistent with the DPF Principles, unless the Ketch proves that it is not responsible for the event giving rise to the damage.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Data Privacy Framework Principles, Ketch commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DataPrivacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Ketch by email at firstname.lastname@example.org.
Ketch has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.
If your DPF complaint cannot be resolved through the abovechannels, under certain conditions, you may invoke binding arbitration for someresidual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.
The Federal Trade Commission has investigation and enforcement authority over our compliance with the DPF Principles.
If you believe we have not respected your rights or otherwise not handled data correctly, then we encourage you to contact us directly and wewill do everything possible to help.
However, where you still have a complaint, then you have theright to raise the matter with the Supervisory Authority (or data protection agency) in your country for resolution.
Individuals located in the EEA have certain rights in respect of your personal data, including:
As a Ketch user:
In some cases, Ketch may process personal data pursuant to a legal obligation or to protect your vital interests or those of another person.
Ketch will offer EEA, UK, Brazil and Swiss individuals whose personal data has been transferred to us the opportunity to choose whether the personal data we have received may be used or disclosed for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses or disclosures of their personal data by contacting us at email@example.com.
Ketch users may exercise their rights regarding their personal information as follows:
Alan Chapell is Ketch’s worldwide data protection officer; and he may be contacted at firstname.lastname@example.org.
VeraSafe has been appointed as Ketch's representative in the European Union and in the United Kingdom for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are unable to reach Ketch as otherwise described in this section, VeraSafe can be contacted on matters related to the processing of personal data under GDPR. To make such an inquiry, please contact VeraSafe using this contact form or via telephone at +420 228 881 031 (Netherlands) or +44 (20) 4532 2003 (UK).
Alternatively, VeraSafe can be contacted at:
VeraSafe Netherlands BV,
1017 DR Amsterdam,
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
If you have any questions about our privacy practices, or if you wish to make a request, please contact us at either:
Ketch Kloud, Inc.
23 Geary Street, Suite 600
San Francisco, CA 94108
We do not knowingly collect personal data about children. Our websites and systems are not designed for use by individuals under the age of 16, and in particular are not designed for children under the age of 13. If we learn we have collected or obtained personal data of someone under 13, we will delete that information from our database. If you believe that this has occurred, please contact us at email@example.com.