Privacy Policy
Last update: May 29, 2024
This Privacy Policy describes how your personal data is collected, used and deleted while you (hereinafter you) visit our Platform website https://kulg.io/, register an account, and use Services provided via the website and its subdomains.
The controller of your personal data is Kulgio OÜ, registry code 16874304 (Estonia), address Harju maakond, Tallinn, Põhja-Tallinna linnaosa, Valgevase tn 11a/2-10, 10414 (hereinafter KULG, we, or us).
Any references or links to third-party websites, services or products are subject to separate privacy policies and terms that KULG does not control nor is responsible for. Please read third-party policies additionally to understand their scope. KULG never knowingly adds any references or links to third parties that have a negative impact on your privacy, but we cannot take responsibility for their actions if those third parties are not our service providers.
1.General Provisions
1.1. KULG ensures that the processing of personal data is in accordance with the legislation regarding the protection and security of personal data (including the General Data Protection Regulation of the European Union, GDPR), other personal data protection legislation, and good business practices.
1.2. KULG considers the privacy of individuals and the protection of their data important and makes the best efforts to ensure the security and protection of the information system and other data carriers.
2. Definitions
2.1. Coach means a third-party service provider providing coaching services to you and acting independently of KULG.
2.2. Services mean the information society services provided by KULG via the Platform.
2.3. Summaries mean content the Platform generates using automated decision-making processes, analysing, aggregating, and summarising the training data you entered, uploaded, and/or imported to provide feedback, recommendations, and guidelines for increasing training efficiency.
2.4. Platform means the subscription-based training analytics services platform provided by KULG and/or the data processors.
2.5. Processing of personal data means viewing, collecting, saving, storing, altering, transmitting, or receiving personal data and other activities related to personal data.
3. Purpose and Legal Basis for Processing Personal Data
3.1. KULG only processes personal data necessary to provide the Services.
3.2. In general, the legal basis for such a purpose is carried out in accordance with: Article 6(1)(a) of the GDPR (you have consented to the specific data processing), Article 6(1)(b) of the GDPR (necessary for the performance of the contract or taking steps at your specific request prior to entering into a contract), Article 6(1)(c) of the GDPR (processing is necessary for compliance with a legal obligation), or Article 6(1)(f) of the GDPR (necessary for legitimate interests provided that those interests are not outweighed by your rights and interests).
3.3. KULG is processing the following personal data:
| Processing activity | Data categories | Purpose | Legal basis |
|---|---|---|---|
| Account Creation | Account, First name and Last name, Avatar, Phone number, E-mail address, Country | To register on the platform and create individual user accounts that allow access to the Platform | Contractual obligation |
| Generating Summaries | Account, First name and Last name, Health data and performance data | To generate and provide you access to the Summaries | Consent. Each time you upload a dataset to generate a Summary, the consent extends to generating that specific Summary, whereas the consent can be withdrawn for each generated Summary |
| Data regarding billing | Financial data, Pricing plan data | Accounting law obligations | Legal obligation |
| Website and related product maintenance and quality | IP address, Device information such as the type and operation system, Browser information such as browser name and version, Geolocation | Providing the Platform and functionalities | Contractual obligation |
| Web visitor analytics | Online identifiers (including cookie identifiers and IP addresses) | Website visitor statistics | Consent |
| User communication and request resolving | Name, E-mail, User request content and communication | Client support | Contractual obligation |
| Newsletters and offers | User Name, Phone number, E-mail address | Marketing | Consent. You can opt-out of our marketing emails at any time |
4. How We Collect Personal Data
4.1. The personal data we process is provided to us directly by you in order to register yourself as our Platform user with your account (either a separate platform account or via Google, Apple, Facebook, or similar third-party account) and to use our Services, such as generating and viewing Summaries. If you upload data for generating Summaries from a third-party service provider, separate terms and privacy policies may apply. KULG is not responsible for your compliance with those terms and privacy policies.
4.2. In addition, we may also collect your personal data indirectly. When visiting our Platform, we and our service providers may collect certain data using tracking technologies like cookies, web beacons and similar technologies. The use of web cookies is described on our website in the cookie banner.
4.3. Indirectly collected data may fall under the terms of third-party privacy policies while they act as independent data controllers. Please read those separately.
5. Disclosure of Personal Data
5.1. KULG employees and business partners have access to personal data to the extent necessary for the performance of their work duties and are covered by confidentiality obligations. Any data you provide will not be publicly displayed or shared with third parties unless you have authorised a specific Coach to access your data, in which case the Coach as the recipient of the data is responsible for keeping the data confidential, as necessary.
5.2. KULG engages third-party service providers to provide, run, and maintain the Platform on our behalf. These service providers have access to your personal data only to the extent necessary to perform their services, and they are contractually obligated to maintain the confidentiality and security of your information.
5.3. We may disclose your personal data if required to do so by law or in good faith belief that such action is necessary to comply with legal obligations, such as platform exchange of tax information or anti-money laundering obligations.
5.4. We share your personal data with:
| Categories of Recipients | Reason for Sharing | Territory |
|---|---|---|
| Service providers | We work with service providers that work on our behalf which may need access to certain personal data to provide their services to us. These companies include those we have hired to operate the technical infrastructure that we need to provide service and assist in protecting and securing our systems and services as well as for business management and marketing.
AWS – Hosting Mailchimp - Emails and campaigns Google analytics – Data analytics Tag Manager – Data analytics Hotjar - Behavioural analytics MS Clarity - Behavioural analytics Squarespace - Website hosting |
EEA |
| Coaches | If you enable a Coach with access to some or all data you have uploaded to the Platform or Summaries that have been generated, you agree that we disclose that data to the designated Coach. The access is valid until you withdraw the access within the Platform. | EEA |
| Payment providers | For payment services we use Stripe. Payment service providers process your data separately as data controllers and thus their privacy policy applies. | EEA |
| Advertising partners | We work with advertising partners to enable us to customize the advertising content you may receive. These partners help us deliver more relevant ads and promotional messages to you, which may include interest-based advertising, contextual advertising, and generic advertising (Google, Twitter, Hotjar, Mailchimp, Instagram, Facebook, LinkedIn). We and our advertising partners process certain personal data to help us understand your interests or preferences so that we can deliver advertisements that are more relevant to you. When doing this, we take into account the data protection requirements regarding your consent and opt-out. | EEA |
6. Transmission of Personal Data
6.1. KULG processes personal data in the European Union (EU) and within the European Economic Area (EEA). KULG receives, transmits, and processes personal data only digitally.
6.2. If we use service providers that process your data outside the EEA, we make sure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place (e.g. additional safeguards through Standard Contractual Clauses).
7. Security of Personal Data
7.1. We have taken necessary technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure, abuse, or other processing in violation of applicable laws.
8. Retention of Personal Data
8.1. The storage period of personal data depends on the legal obligations to store data (i.e. accounting regulations), contractual obligations, legitimate interest to provide the best services, or your explicit consent:
| Data type | Purpose | Retention time |
|---|---|---|
| User Account Information | To manage accounts on the platform and provide access to services | Retained for the duration of the services, and for a period of 3 years after the last login to comply with legal obligations or legitimate interests |
| Health data and Summaries | To retain your access to the health data and Summaries | Until withdrawal of consent |
| Financial data | Accounting law obligations | 7 years after the end of the current fiscal year |
| IP address, Device information such as the type and operation system, Browser information such as browser name and version, Geolocation | Providing the Platform and functionalities | Until account deletion and cookie retention time |
| Online identifiers (including cookie identifiers and IP addresses) | Website visitor statistics | Until cookie retention time or request for data deletion |
| Name, E-mail, User request content and communication | Client support | Until account deletion |
| User Name, Phone number, E-mail address | Marketing | Until withdrawal of consent |
9. Rights of the Data Subject
9.1. You as the data subject shall at all times have the right:
9.1.1. to be informed and to access personal data (You may get information regarding your personal data processed by us, accessed via the Platform);
9.1.2. to data portability (You have the right to receive your personal data from us in a structured, commonly used and machine-readable format and to independently transmit those data to a third party);
9.1.3. to erasure (You have the right to have personal data we process about you erased from our systems if the personal data are no longer necessary for the related purposes);
9.1.4. to object and restrict (You have the right to object to the processing of your personal data and restrict it in certain cases);
9.1.5. to rectification (You have the right to make corrections to your personal data);
9.1.6. to withdraw consent (if You have given us consent to process your personal data, You may withdraw said consent at any time).
9.2. In order to exercise these rights, please contact us at move@kulg.io. The application shall be responded to within a maximum of 30 calendar days.
10. Additional Provisions
10.1. With your explicit consent, we may send you our newsletter and marketing offers. You may opt out of these messages. Please note that email marketing messages, if used, include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the messages we send to you). Clicking on the link will opt you out of further messages. You may also opt-out on your account settings in case this option is available. We may also use social media tools to market our products and services. As social media and web analytics providers act as separate data controllers, there might be consent or opt-out requirements also on their side.
10.2. If you have questions or concerns about our use of your personal information, feel free to contact us at move@kulg.io. You may also lodge a complaint to the supervisory authority, the Estonian Data Protection Inspectorate , info@aki.ee.
10.3. KULG has the right to change the conditions for processing personal data. In the event, that there are substantial changes, KULG will provide at least 1 (one) month’s notice in advance through the Platform before the substantial changes take effect.