PRIVACY NOTICE
Last updated
December 30, 2022
This privacy notice for
Koupka
(
"
Company
," "we," "us," or "our"
), describes how and why we might collect, store, use, and/or share (
"process"
) your information when you use our services (
"Services"
), such as when you:
-
Visit our website
at https://www.koupka.com , or any website of ours that links to this privacy notice
-
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy
rights and choices. If you do not agree with our policies and practices, please do not use our Services. If
you still have any questions or concerns, please contact us at
contact@mail.koupka.com
.
SUMMARY OF
KEY POINTS
This
summary provides key points from our privacy notice, but you can find out more details about any of these
topics by clicking the link following each key point or by using our table of contents below to find the
section you are looking for. You can also click here to go directly to our table of
contents.
What personal information do we process? When you visit, use, or navigate our Services, we
may process personal information depending on how you interact with
Koupka
and the Services, the choices you make, and the products and features you use. Click
here to learn more.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We do not receive any information from third parties.
How do we
process your information? We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process
your information for other purposes with your consent. We process your information only when we have a valid
legal reason to do so. Click here to learn more.
In what situations and with which
parties do we share personal information?
We may share information in specific situations and with specific
third parties. Click
here
to learn more.
How do we keep your information safe? We have
organizational
and technical processes and procedures in place to protect your personal information. However, no electronic
transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized
third parties will not be able to defeat our security and improperly collect, access, steal, or modify your
information. Click
here
to learn more.
What are
your rights? Depending on where you are located geographically, the applicable privacy law may mean
you have certain rights regarding your personal information. Click here to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out
our data subject request form available
here:
http://www.koupka.com
, or by contacting us. We will consider and act upon any request in accordance with applicable data protection
laws.
Want to learn more about what
Koupka
does with any information we collect? Click
here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
Personal information you disclose to
us
In
Short:
We collect personal information that you provide to
us.
We collect personal information that you voluntarily provide to us when you
register on the Services,
express an interest in obtaining information about us or our products
and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on
the context of your interactions with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the following:
-
names
-
email addresses
-
usernames
-
passwords
Sensitive Information.
We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases,
such as your payment instrument number, and the security code associated with your payment instrument. All
payment data is stored by
Stripe
. You may find their privacy notice link(s) here:
https://stripe.com/privacy
.
Social Media
Login Data. We may provide you with the option to register with us using your existing social
media account details, like your Facebook, Twitter, or other social media account. If you choose to register
in this way, we will collect the information described in the section called
" HOW DO WE HANDLE YOUR SOCIAL
LOGINS?
" below.
All personal information
that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such
personal information.
2. HOW DO WE PROCESS YOUR
INFORMATION?
In
Short: We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your
consent.
We process your personal information for a variety of reasons, depending on how you interact with
our Services, including:
-
To facilitate account creation and authentication and otherwise manage user accounts. We
may process your information so you can create and log in to your account, as well as keep your account in
working order.
-
To deliver and facilitate delivery of services to the user. We may process your
information to provide you with the requested service.
-
To send administrative information to you. We may process your information to
send you details about our products and services, changes to our terms and policies, and other
similar information.
-
To send you marketing and promotional communications. We may process the
personal information you send to us for our marketing purposes, if this is in accordance
with your marketing preferences. You can opt out of our marketing emails at any time. For
more information, see
" WHAT ARE YOUR PRIVACY RIGHTS? " below).
-
To save or protect an individual's
vital interest. We may process your information when
necessary to save or protect an individual’s vital interest, such as
to prevent harm.
3. WHAT
LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your personal information
when we believe it is necessary and we have a valid legal reason (i.e.
,
legal basis) to do so under applicable law, like with your consent, to
comply with laws, to provide you with services to enter into or
fulfill
our contractual obligations, to protect your rights, or to
fulfill
our legitimate business interests.
If you are located in the EU
or UK, this section applies to
you.
The General Data Protection Regulation
(GDPR) and UK GDPR require us to explain the valid legal bases we rely
on in order to process your personal information. As such, we may rely
on the following legal bases to process your personal
information:
-
Consent. We may process your information if you have
given us permission (i.e.
, consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
-
Performance of a Contract. We may process your
personal information when we believe it is necessary to
fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
-
Send users information about special offers and discounts on our
products and services
-
Legal Obligations. We may process your
information where we believe it is necessary for compliance
with our legal obligations, such as to cooperate with a law
enforcement body or regulatory agency, exercise or defend
our legal rights, or disclose your information as evidence
in litigation in which we are involved.
-
Vital Interests.
We may process your information where we believe it is
necessary to protect your vital interests or the vital
interests of a third party, such as situations involving
potential threats to the safety of any person.
If you are located in Canada, this section
applies to you.
We may process your information if you have given us specific
permission (i.e.
,
express consent) to use your personal information for a
specific purpose, or in situations where your permission can
be inferred (i.e.
,
implied consent). You can withdraw your consent at any time.
Click
here to
learn more.
In
some exceptional cases, we may be legally permitted under
applicable law to process your information without your
consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
-
For investigations and fraud detection and prevention
-
For business transactions provided
certain conditions are met
-
If it is contained in a witness
statement and the collection is necessary to assess,
process, or settle an insurance claim
-
For identifying injured, ill, or
deceased persons and communicating with next of
kin
-
If we have reasonable grounds to believe an individual has
been, is, or may be victim of financial abuse
-
If it is reasonable to expect collection and use with
consent would compromise the availability or the accuracy of
the information and the collection is reasonable for
purposes related to investigating a breach of an agreement
or a contravention of the laws of Canada or a province
-
If disclosure is required to comply with a subpoena,
warrant, court order, or rules of the court relating to the
production of records
-
If it was produced by an individual in the course of their
employment, business, or profession and the collection is
consistent with the purposes for which the information was
produced
-
If the collection is solely for journalistic, artistic, or
literary purposes
-
If the information is
publicly available and is specified by the
regulations
In Short:
We may share information in specific situations described
in this section and/or with the following
third parties.
We
may need to share your personal information in the
following situations:
- Business Transfers. We may share or transfer your 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.
In
Short: If you choose to
register or log in to our Services using a
social media account, we may have access to
certain information about
you.
Our Services offer
you the ability to register and log in using your
third-party social media account details (like
your Facebook or Twitter logins). Where you choose
to do this, we will receive certain profile
information about you from your social media
provider. The profile information we receive may
vary depending on the social media provider
concerned, but will often include your name, email
address, friends list, and profile picture, as
well as other information you choose to make
public on such a social media platform.
We will use the
information we receive only for the purposes that
are described in this privacy notice or that are
otherwise made clear to you on the relevant
Services. Please note that we do not control, and
are not responsible for, other uses of your
personal information by your third-party social
media provider. We recommend that you review their
privacy notice to understand how they collect,
use, and share your personal information, and how
you can set your privacy preferences on their
sites and apps.
6. HOW LONG
DO WE KEEP YOUR
INFORMATION?
In
Short: We keep your
information for as long as necessary to fulfill the
purposes outlined in this privacy notice unless
otherwise required by
law.
We will only keep
your personal information for as long as it is
necessary for the purposes set out in this privacy
notice, unless a longer retention period is
required or permitted by law (such as tax,
accounting, or other legal requirements). No purpose in
this notice will require us keeping your personal
information for longer than
the period of
time in which users have an account with us
.
When we have no
ongoing legitimate business need to process your
personal information, we will either delete or
anonymize such
information, or, if this is not possible (for
example, because your personal information has
been stored in backup archives), then we will
securely store your personal information and
isolate it from any further processing until
deletion is possible.
7. HOW DO WE
KEEP YOUR INFORMATION
SAFE?
In
Short: We aim to protect
your personal information through a system of
organizational and
technical security
measures.
We have implemented
appropriate and reasonable technical and organizational
security measures designed to protect the security
of any personal information we process. However,
despite our safeguards and efforts to secure your
information, no electronic transmission over the
Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise
or guarantee that hackers, cybercriminals, or
other
unauthorized third
parties will not be able to defeat our security
and improperly collect, access, steal, or modify
your information. Although we will do our best to
protect your personal information, transmission of
personal information to and from our Services is
at your own risk. You should only access the
Services within a secure environment.
8. DO WE
COLLECT INFORMATION FROM
MINORS?
In
Short: We do not knowingly
collect data from or market to children under
18 years of age
.
We do not knowingly
solicit data from or market to children under 18
years of age. By using the Services, you represent
that you are at least 18 or that you are the
parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we
learn that personal information from users less
than 18 years of age has been collected, we will
deactivate the account and take reasonable
measures to promptly delete such data from our
records. If you become aware of any data we may
have collected from children under age 18, please
contact us at
privacy@mail.koupka.com
.
9. WHAT ARE
YOUR PRIVACY
RIGHTS?
In
Short:
In some regions,
such as the
European Economic Area (EEA), United Kingdom
(UK), and Canada
, you have rights that allow you greater
access to and control over your personal
information.
You may review,
change, or terminate your account at any
time.
In some regions
(like the EEA,
UK, and Canada
), you have certain rights under applicable data
protection laws. These may include the right (i)
to request access and obtain a copy of your
personal information, (ii) to request
rectification or erasure; (iii) to restrict the
processing of your personal information; and (iv)
if applicable, to data portability. In certain
circumstances, you may also have the right to
object to the processing of your personal
information. You can make such a request by
contacting us by using the contact details
provided in the section "
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
" below.
We will consider and
act upon any request in accordance with applicable
data protection laws.
If you are located
in the EEA or UK and you believe we are unlawfully
processing your personal information, you also
have the right to complain to your local data
protection supervisory authority. You can find
their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located
in Switzerland, the contact details for the data
protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing
your consent: If we are relying
on your consent to process your personal
information,
which may be express and/or implied consent
depending on the applicable law, you
have the right to withdraw your consent at any
time. You can withdraw your consent at any time by
contacting us by using the contact details
provided in the section "
HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
" below
.
However, please note
that this will not affect the lawfulness of the
processing before its withdrawal nor, when applicable law
allows,
will it affect the processing of your
personal information conducted in reliance on lawful
processing grounds other than consent.
Opting out
of marketing and promotional
communications:
You can unsubscribe from our
marketing and promotional communications at any time
by clicking on
the unsubscribe link in the emails that we send,
or by contacting
us using the details provided in the section "
HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?
" below.
You will then be removed from the marketing lists.
However, we may still communicate with you — for
example, to send you service-related messages that
are necessary for the administration and use of your
account, to respond to service requests, or for
other non-marketing purposes.
Account
Information
If you would at any time
like to review or change the information in your
account or terminate your account, you can:
-
Log in to your account settings and update your user account.
Upon your request to
terminate your account, we will deactivate or delete
your account and information from our active
databases. However, we may retain some information
in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce
our legal terms and/or comply with applicable legal
requirements.
If you have questions or
comments about your privacy rights, you may email us
at privacy@mail.koupka.com
.
10. CONTROLS
FOR DO-NOT-TRACK
FEATURES
Most web browsers
and some mobile operating systems and mobile
applications include a Do-Not-Track ( "DNT" )
feature or setting you can activate to signal your
privacy preference not to have data about your
online browsing activities monitored and
collected. At this stage no uniform technology
standard for
recognizing and
implementing DNT signals has been finalized . As
such, we do not currently respond to DNT browser
signals or any other mechanism that automatically
communicates your choice not to be tracked online.
If a standard for online tracking is adopted that
we must follow in the future, we will inform you
about that practice in a revised version of this
privacy notice.
11. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes, if you are a
resident of California, you are granted specific
rights regarding access to your personal
information.
California Civil
Code Section 1798.83, also known as the "Shine The Light"
law, permits our users who are California
residents to request and obtain from us, once a
year and free of charge, information about
categories of personal information (if any) we
disclosed to third parties for direct marketing
purposes and the names and addresses of all third
parties with which we shared personal information
in the immediately preceding calendar year. If you
are a California resident and would like to make
such a request, please submit your request in
writing to us using the contact information
provided below.
If you are under 18
years of age, reside in California, and have a
registered account with Services, you have the
right to request removal of unwanted data that you
publicly post on the Services. To request removal
of such data, please contact us using the contact
information provided below and include the email
address associated with your account and a
statement that you reside in California. We will
make sure the data is not publicly displayed on
the Services, but please be aware that the data
may not be completely or comprehensively removed
from all our systems (e.g. ,
backups, etc.).
CCPA Privacy
Notice
The
California Code of Regulations defines a
"resident"
as:
(1) every individual
who is in the State of California for other than a
temporary or transitory purpose
and
(2) every individual
who is domiciled in the State of California who is
outside the State of California for a temporary or
transitory purpose
All other
individuals are defined as "non-residents."
If this definition
of "resident"
applies to you, we must adhere to certain rights
and obligations regarding your personal
information.
What
categories of personal information do we
collect?
We have collected
the following categories of personal information
in the past twelve (12) months:
Category | Examples | Collected |
A.
Identifiers
|
Contact
details, such as real name, alias, postal
address, telephone or mobile contact
number, unique personal identifier, online
identifier, Internet Protocol address,
email address, and account
name
|
|
B. Personal
information categories listed in the
California Customer Records
statute
|
Name,
contact information, education,
employment, employment history, and
financial information
|
|
C. Protected
classification characteristics under
California or federal
law
|
Gender and
date of birth
|
|
D.
Commercial
information
|
Transaction
information, purchase history, financial
details, and payment
information
|
|
E. Biometric
information
|
Fingerprints
and voiceprints
|
|
F. Internet
or other similar network
activity
|
Browsing
history, search history, online
|
|
G.
Geolocation data
|
Device
location
|
|
H. Audio,
electronic, visual, thermal, olfactory, or
similar information
|
Images and
audio, video or call recordings created in
connection with our business
activities
|
|
I.
Professional or employment-related
information
|
Business
contact details in order to provide you
our Services at a business level or job
title, work history, and professional
qualifications if you apply for a job with
us
|
|
J. Education
Information
|
Student
records and directory
information
|
|
K.
Inferences drawn from other personal
information
|
Inferences
drawn from any of the collected personal
information listed above to create a
profile or summary about, for example, an
individual’s preferences and
characteristics
|
|
We may also collect
other personal information outside of these
categories through instances where you interact
with us in person, online, or by phone or mail in
the context of:
- Receiving help
through our customer support
channels;
- Participation in
customer surveys or contests; and
- Facilitation in
the delivery of our Services and to respond to
your inquiries.
How do we
use and share your personal
information?
You may contact us
by email at
ccpa@mail.koupka.com
,
or by referring to the
contact details at the bottom of this
document.
If you are using an
authorized agent
to exercise your right to opt out we may deny a
request if the
authorized
agent does not submit proof that they have
been validly
authorized
to act on your behalf.
Will your
information be shared with anyone
else?
We may disclose your
personal information with our service providers
pursuant to a written contract between us and each
service provider. Each service provider is a
for-profit entity that processes the information
on our behalf.
We may use your
personal information for our own business
purposes, such as for undertaking internal
research for technological development and
demonstration. This is not considered to be "selling" of
your personal information.
Your rights
with respect to your personal
data
Right to request
deletion of the data — Request to
delete
You can ask for the
deletion of your personal information. If you ask
us to delete your personal information, we will
respect your request and delete your personal
information, subject to certain exceptions
provided by law, such as (but not limited to) the
exercise by another consumer of his or her right
to free speech, our compliance requirements
resulting from a legal obligation, or any
processing that may be required to protect against
illegal activities.
Right to be
informed — Request to
know
Depending on the
circumstances, you have a right to know:
- whether we collect
and use your personal information;
- the categories of
personal information that we collect;
- the purposes for
which the collected personal information is
used;
- whether we sell
your personal information to third parties;
- the categories of
personal information that we sold or disclosed
for a business purpose;
- the categories of
third parties to whom the personal information
was sold or disclosed for a business purpose;
and
- the business or
commercial purpose for collecting or selling
personal information.
In accordance with
applicable law, we are not obligated to provide or
delete consumer information that is de-identified
in response to a consumer request or to
re-identify individual data to verify a consumer
request.
Right to
Non-Discrimination for the Exercise of a
Consumer’s Privacy
Rights
We will not
discriminate against you if you exercise your
privacy rights.
Verification
process
Upon receiving your
request, we will need to verify your identity to
determine you are the same person about whom we
have the information in our system. These
verification efforts require us to ask you to
provide information so that we can match it with
information you have previously provided us. For
instance, depending on the type of request you
submit, we may ask you to provide certain
information so that we can match the information
you provide with the information we already have
on file, or we may contact you through a
communication method (e.g. , phone
or email) that you have previously provided to us.
We may also use other verification methods as the
circumstances dictate.
We will only use
personal information provided in your request to
verify your identity or authority to make the
request. To the extent possible, we will avoid
requesting additional information from you for the
purposes of verification. However, if we cannot
verify your identity from the information already
maintained by us, we may request that you provide
additional information for the purposes of
verifying your identity and for security or
fraud-prevention purposes. We will delete such
additionally provided information as soon as we
finish verifying you.
Other privacy
rights
- You may object to
the processing of your personal
information.
- You may request
correction of your personal data if it is
incorrect or no longer relevant, or ask to
restrict the processing of the information.
- You can designate
an
authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You may request to
opt out from future selling of your personal
information to third parties. Upon receiving an
opt-out request, we will act upon the request as
soon as feasibly possible, but no later than
fifteen (15) days from the date of the request
submission.
To exercise these
rights, you can contact us
by email
at
ccpa@mail.koupka.com ,
or by referring to the
contact details at the bottom of this document. If you
have a complaint about how we handle your data, we
would like to hear from you.
12. DO WE
MAKE UPDATES TO THIS
NOTICE?
In
Short: Yes, we will update this
notice as necessary to stay compliant with
relevant laws.
We may update this
privacy notice from time to time. The updated
version will be indicated by an updated "Revised" date
and the updated version will be effective as soon
as it is accessible. If we make material changes
to this privacy notice, we may notify you either
by prominently posting a notice of such changes or
by directly sending you a notification. We
encourage you to review this privacy notice
frequently to be informed of how we are protecting
your information.
13. HOW CAN
YOU CONTACT US ABOUT THIS
NOTICE?
If you have
questions or comments about this notice, you may
email us at
privacy@mail.koupka.com
14. HOW CAN
YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM
YOU?
This privacy policy was created using Termly's Privacy
Policy Generator.