EU Privacy Policy

Date Published: March 18, 2020

This privacy policy explains how Kandji, Inc. (“Kandji”, “we”, “us”) collects, stores, shares, and uses your personal information if you are located in the European Economic Area [“EEA”]. This privacy policy applies to scenarios where Kandji is acting as a “data controller” under the General Data Protection Regulation (GDPR) in its position as a company seeking new corporate customers or interacting with current customers. If you are a user of our service via a corporate account, please see section one below.

If you are a user of the Kandji service and wish to request information or exercise your privacy rights under the GDPR, please contact the company under which you have an account. Kandji is a vendor for the company, and all requests should be routed through that company. We will then respond to any requests submitted directly from the company.

We've organized this privacy policy as follows:

1. Individuals Users of The Service
2. What Information We Collect As A Controller
3. How We Use Information We Collect As A Controller
4. How We Share Information We Collect As A Controller
5. How We Transfer Information Across Borders As A Controller
6. Cookies.
7. Exercising Your Data Rights.
8. California Privacy Rights
9. Contact Us
10. Updates

1. Authorized Users

Kandji is a provider of mobile device management services to companies who wish to employ our services. We process the personal information of users of devices ("authorized devices") in the accounts of these corporate customers at the direction of our corporate customers. We do not own or control this data, and corporate customers are responsible for complying with any regulations or laws that require providing notice, disclosure, or obtaining consent before the collection or transfer of personal data of users of authorized devices directly with you.

If you are a user of one of these devices, we collect personal information from you to the extent it is associated with a device designated in a corporate account. We collect and process this personal information under the direction and instruction of our corporate customers. Our contractual agreements with our corporate customers prohibit us from using the personal information of users of authorized devices in any manner other than provided for in the contract between us, as required by law, and as detailed in this EU privacy policy. Should a corporate client stop using our service, we will delete or return to the corporate customer all personal information associated with users of authorized devices in the account of that corporate customer.

If another company acquires Kandji or our assets through an acquisition, merger, bankruptcy, or other transaction, the personal data of all users of authorized devices would be included in that transaction, and you agree to such transfer. Kandji reserves the right to use or disclose the personal information of users if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect the safety of you or others, investigate a crime or fraud, or comply with a law, court order, or legal process.

We may provide links or access to the sites or services of third parties. We are not responsible for the collection, use, monitoring, storage, or sharing of any personal information of users of authorized devices by such third parties, and we encourage you to review those third parties' privacy notices and policies. In accessing such third party sites or services, you expressly agree to their applicable Terms documentation.

We automatically collect metrics and information about how you interact with our service. We use this information to develop and improve the service, and to inform our sales and marketing strategies. We may share or publish this service data with third parties in an aggregated and anonymous manner that cannot be used to identify you or other users of authorized devices.

2. What Information We Collect As A Controller

When we communicate with you as a potential corporate client or interact with you as a current corporate client, we collect personal information you voluntarily provide to us when you contact us such as your name, business email address, and the relevant corporate entity. You may also ask us questions through a pop-up on the webpages of our site, and we collect any personal information you might provide through it. We also collect personal information you provide when you sign up for our service, contact us, and exchange communications with us.

We also automatically collect specific information about you in relation to your visit to our website such as your IP address, location in the world, what pages you view on our website, where you came from, browser type, and other analytical data that helps us evaluate our website and service.

Should you sign-up for our service, we will have access to personal information associated with the person making the payment for our services. We use a third-party vendor to process payments, and that vendor is PCI-compliant.

We receive messages and posts through social media platforms that may contain personal information. We decide upon how to manage the personal information depending upon the nature of the message or post. When contacting Kandj through a social media platform, we suggest you also familiarise yourself with the privacy information of that platform.

Our service is intended for use by corporate customers and their adult authorized users. We do not collect personal information from individuals under the age of 16. Our website and service are directed at adults, not directed at individuals under the age of 16 nor do we have any actual knowledge of use by individuals under 16. Please contact us should you learn of a person using our service who is under the age of 16.

3. How We Use Information We Collect As A Controller

We use the personal information we collect from you as detailed in this Privacy Policy. We use your personal information that you voluntarily provide us to communicate with you about our service, answer any questions, provide a demonstration of our services, process payment should you become a corporate client, and to provide general customer service to your company as needed. We may also use your personal information to facilitate and deliver the service as follows:

• To set-up and facilitate the syncing of authorized devices with Kandji.
• To present our service for use.
• To provide information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between us.
• To notify you about changes to our service.
• To bill you for the service, if needed.
• To market new or additional services to you.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

In the case of automatically collected personal information such as your IP address, we use this information to analyze our website and marketing efforts so that we can provide more value to visitors and improve our marketing efforts.

As for personal data we collect when you provide payment for our services, we and our third-party payment processor collect this personal information to facilitate the payment for our services. Our payment processor is PCI-compliant.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use, Acceptable Use Policy, and other agreements between us.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ourselves, our customers, or others. This includes exchanging information with other companies, organizations, and payment processors for fraud protection and credit risk reduction.
• We may disclose aggregated, anonymized, or deidentified information about our users, and information that does not directly or indirectly identify any individual, without restriction.

a. Lawful Basis for Collection

When you voluntarily provide us with personal data such as contact us for a demonstration of our service, we have a legitimate interest in using the information to respond to your request and provide the demonstration. Data that we collect automatically from you is done with your consent, which is obtained when you first visit us through a pop-up banner asking for consent. You may block tracking via your browser or revoking your consent. The legal basis for the collection of your payment information is to facilitate the entering of a contract via the providing of consideration by you to us.

We provide links to third-party platforms such as LinkedIn or Facebook on our website. These features may employ a cookie or similar piece of code to track you. This privacy policy does not apply to these third party operations and you should review their privacy policies prior to using any such functionality. You may also opt-out of such tracking by using this free service.

b. Data Retention and Security

Kandji uses reasonable security measures to store your personal data. We do not store your data permanently. Instead, we retain your personal data for a period of time depending on your commercial relationship with us. If you become a client, we will retain your personal data for as long as you remain a corporate customer with Kandji whether that is one year or ten. Automatically collected personal data is stored and maintained for specific periods which you can see in our Cookies Policy. If you provide personal information, such as your name on a corporate credit card, when making payment for our services, we will maintain information sufficient to identify the payment for 48 months from the data of payment for tax purposes, but not your credit card number.

We reserve the right to anonymize or deidentify your data for further use. Should we exercise this right, we will remove any personal data or identifiers that can be used to associate the resulting data with you.

c. Changes to Kandji.

Should we decide to sell, merge, or otherwise transfer the ownership of all or part of our company, company assets, or the website at some point in the future, your personal information will be included as an asset in the transfer and you agree to such transfer.

d. Take Control

We strive to provide you with choices regarding the personal information you provide to us:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of service may then be inaccessible or not function properly.
• You can choose to opt-out of tracking by many third parties, including Google, by visiting these links – http://www.networkadvertising.org/choices/ and http://www.aboutads.info/consumers/ and https://tools.google.com/dlpage/gaoptout.
• You may stop receiving email marketing by clicking the opt-out link available in each message.

4. How We Share Information We Collect As A Controller

We will share your personal information with third party vendors we retain to assist us in the operation of our company and service. For example, we use a third-party payment processor to charge your payment resource instead of collecting and holding your credit card information ourselves. The payment processor is PCI-DSS compliant, which means your personal data is more secure than if we handled the transactions on our own. Data processors contractually agree with us not to use your data in any manner other than as contracted with us. We change processors from time-to-time, but our current list can be found here.

5. How We Transfer Information Across Borders As A Controller

Kandji is located in the United States and we will import data into the country if you or users of authorized users in your corporate account are located in another country. When we move such data, we do so pursuant to standard contract clauses approved by the European Commission and employ those security measures required by the country in question to secure the data. We work with third-party vendors from time-to-time and require those parties to meet these same standards. We do not currently participate in the Privacy Shield program.

6. Cookies

Cookies are text files placed on your computing device to collect standard Internet log and visitor behavior information. For further information, visit allaboutcookies.org. When you visit our website, we and our third-party vendors may collect information from you automatically through cookies or similar technology. You can review our Cookies Policy to learn more about how we use cookies, the types of cookies we use, and how you can manage cookies.

7. Exercising Your Data Rights

If you have contacted us on behalf of a corporate entity or interact with us as a representative of a corporate client, then you may exercise your data rights as detailed below. However, if you are a user of an authorized device only, you must contact the company that is giving you access to our service to exercise your data rights.

You may exercise the following rights:

• The right to access – You have the right to request Kandji produce copies of your personal data it has collected. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that Kandji correct any information you believe is inaccurate or add any additional information you feel is warranted.
• 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 Kandji's processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that Kandji transfer the data that we have collected to another organization, or directly to you, under certain conditions.

We have one month to respond to you if you exercise any of these rights. You can submit requests to us via the following:

Email us at legal@kandji.io

Call us at (855) 877-1866

Or write to us:

c/o Mark DaughtersKandji, Inc.101 W. Broadway, Ste. 1130San Diego, CA 92101

You can contact us at legal@kandji.io if you have any questions or complaints regarding our privacy policies or practices. If, after contacting us, you feel a privacy issue has not been resolved, you have the right to file a complaint with a Supervisory Authority. We suggest the Data Protection Commissioner of Ireland.

8. California Privacy Rights

a. California Consumer Privacy Act. We comply with the California Consumer Privacy Act. You can view our California Privacy Notice separately.

9. Contact Us

Mark Daughters, Privacy RepresentativeK
andji, Inc.
101 W. Broadway, Ste. 1130
San Diego, CA 92101
(855) 877-1866
legal@kandji.io

10. Modifications and Updates

We reserve the right to update our EU Privacy Policy and other privacy-related documents if required due to changes in the law, changes to our service, for new products we offer, or other reasons that involve privacy issues. We will provide notice of such changes on our site and in an email message forwarded to corporate clients.

Please contact us at legal@kandji.io if you have any questions about this privacy policy.