Supplemental Privacy Notice
California Residents
Scope of This Notice
This Supplemental Privacy Notice supplements the information in our Privacy Policy and applies solely to California residents. It applies to Personal Data we collect as a business; it does not apply to Personal Data we collect or otherwise process as a service provider.
Kloü as a "Business" and a "Service Provider"
California law makes a distinction between organizations that process Personal Data for their own purposes (known as "businesses") and organizations that process Personal Data on behalf of other organizations (known as "service providers"). Depending on the circumstances, Kloü may act as either a business or service provider with respect to your Personal Data. If you have a question or a complaint about how your Personal Data is handled, these should always be directed to the relevant business since they are the ones with primary responsibility for your Personal Data.
Summary of Information We Collect
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your "personal information" and "sensitive personal information" as defined in the California Consumer Privacy Act (CCPA).
Throughout our Privacy Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we share it. Under the CCPA, we also have to provide you with the "categories" of personal information we collect and disclose for "business purposes" (as those terms are defined by applicable law). Those categories are:
- Identifiers (such as name, address, and email address)
- Commercial information (such as transaction data)
- Financial data (such as credit card and other financial account information)
- Internet or other network or device activity (such as IP address)
- Geolocation information (general location)
- Inference data about you
- Physical characteristics or description (such as when you voluntarily submit a photo)
- Other information that identifies or can be reasonably associated with you
The categories of sensitive personal information are: account login, financial account information, and password or other credentials allowing access to your account. If you choose to respond to a survey, you may elect to provide additional categories of personal information.
We collect the above categories of personal information from the following sources: (1) directly from you; (2) through your use of the Services; (3) agents/service providers; (4) affiliates; and (5) third parties such as social networks, marketing partners and credit reporting agencies.
Business and Commercial Purposes
We or our service providers may collect and disclose the above categories of information for the following business and commercial purposes (as those terms are defined in applicable law):
- Our or our service provider's operational purposes.
- Auditing consumer interactions on our site (e.g., measuring ad impressions).
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity.
- Bug detection and error reporting.
- Customizing content that we or our service providers display on the Services (e.g., contextual ads).
- Providing the services.
- Improving our existing services and developing new services (e.g., by conducting research, developing and training automated systems, algorithms, and machine learning models).
- Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third-party partners.
- Other uses for which we notify you.
We may also use the above categories of Personal Data for compliance with applicable laws and regulations, and we may combine the information we collect ("aggregate") or remove pieces of information ("de-identify") to limit or prevent identification of any particular user or device.
Disclosure of Personal Information
We describe our information disclosure practices in our Privacy Policy. We may disclose certain categories of personal information to third parties (as defined by the CCPA) for the business purposes described above. For example, we may disclose any of the categories described above to our parent companies, subsidiaries, or affiliates. We may also disclose identifiers, commercial information, and general location to organizers. If you connect your Kloü account with social media services, interact with social media plugins or links on the services, or contract or integrate with third parties, we may disclose identifiers, commercial information, internet or other network or device activity, or general location with those social media services and third parties.
Your California Rights
If you are a California resident, you may have certain rights under the CCPA. California law may permit you to request that we:
- Provide you the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, "selling," or "sharing" your personal information; the categories of third parties to whom we disclose or "sell," or with whom we "share," personal information; and the categories of personal information we "sell."
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
- Correct inaccurate personal information that we maintain about you.
You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.
How to Exercise Your Rights
You can download a copy of your personal information or delete your personal information by emailing us at gabe@klou.app. You may correct your personal information by making changes in your Kloü account profile. You may also exercise your California consumer rights by emailing us at gabe@klou.app.
You will be required to verify your identity before we fulfill your request. To do so, you will need to demonstrate that you have access to the email address used to create your account or provide us with certain account information, such as the full name and email address you used to create your account and your most recent event or ticket purchase.
You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization for the agent to act on your behalf. You will still need to verify your identity directly with us.
Sale and Sharing of Personal Information
The CCPA requires businesses that "sell" personal information to provide an opt-out from such sales. Some interpretations of the CCPA take the position that when a website uses third parties' cookies or similar technology for its own analytics or advertising purposes, the website is engaged in a "sale" if the third parties have some ability to use, disclose or retain the data to improve their service or to take steps beyond the most narrowly drawn bounds of merely providing their service to the website/app.
As part of these analytics and advertising services, these technologies may access identifiers (like IP addresses), internet or other electronic network activity information (like information regarding an individual's browsing interactions on our Site), and commercial information to those sorts of companies. You can opt out of this activity by contacting us at gabe@klou.app or using the "Do Not Sell or Share My Personal Information" controls available in the App.
The CCPA also requires businesses that "share" personal information to provide an opt-out from such sharing. Under the CCPA, "sharing" is defined as the targeting of advertising to a consumer based on that consumer's personal information obtained from the consumer's activity across websites. We "share" information for these purposes to provide more relevant and tailored advertising to you regarding our Services.
As part of this advertising, we may "share" identifiers (like IP addresses and email addresses), internet or other electronic network activity information, and commercial information with advertising platforms and advertising networks. To opt out of such "sharing," please contact us at gabe@klou.app.
We do not knowingly "sell" or "share" the personal information of individuals under 18.
Retention of Your Personal Information
Please refer to the "Information We Collect and How We Collect It" section in our Privacy Policy for details on how long we retain personal information.
California Shine the Light
We do not share personal information with third parties for their direct marketing purposes.