Last update: 31/03/2021

KAYRROS is careful about the personal information (i.e., all information that is about any individual, or from which any individual is identifiable) we may collect about our users (“You”) through the performance of our services, such as our website and application, as described below.

KAYRROS complies with the General Data Protection Regulation (GDPR (EU) 2016/679) and any national law within the European Union that is applicable to the protection of privacy and personal information.

The following Privacy Policy explains KAYRROS’s position regarding personal information protection, i.e., how we collect, store, process, transfer, share and use personal information. This Privacy Policy is part of our Terms of Use.

1. Who is the controller of your personal information?

KAYRROS SAS is a French simplified share company, having its registered office at 33, rue La Fayette 75009 Paris, France, with a share capital of € 238,969.00, registered under number 818 399 651 at the Paris Registre du Commerce et des Sociétés (EU VAT number: FR52818399651) (“KAYRROS” or “We”).

KAYRROS is the controller of the personal information that is collected through the website www.kayrros.com, the application app.kayrros.com, and the performance of our services.

2. What is the information We collect?

KAYRROS collects information in three different ways: information You provide to us, information collected automatically, and information collected from outside sources.

  • Information You personally share with us:

You can share personal information with KAYRROS through our website, our application or by directly contacting us by email. For example, through the “get in touch” or “join us” pages of KAYRROS’s website, You are able to share the following information with us: your name, your email address and your phone number, and You are able to send us a message. Only your name and email address are mandatory to enable KAYRROS to reply to You. The same information is shared with us through our application app.kayrros.com if You become a subscriber to our products. This information enables KAYRROS to provide and improve our services and to answer any query from its subscribers.
Please note that You are never compelled to provide your personal information to KAYRROS. However, if You decide not to provide us with your personal information, We might not be able to conclude a contractual relationship with You and to fulfill our contractual obligations towards You.

  • Information We collect automatically, with your consent when it is mandatory, when you browse our Websites (www.kayrros.com, services.kayrros.com) and our Apps (app.kayrros.com, platform.kayrros.com)  
    • Cookies: Cookies are text files that may be recorded on your terminal’s hard drive or internal memory during your visit to KAYRROS’s websites and applications. Cookies are used to improve your online experience and to help KAYRROS make its websites and applications more efficient. KAYRROS uses four types of cookies, each one having its own purposes: 

 

  • Strictly necessary cookies: These cookies are set on all our Websites and Apps identified above. They are essential to enable you to browse the websites and apps in a secure manner and to use their functionalities. Without these cookies, the operations and functions of the websites and apps cannot be ensured.

We use the following types of cookies: 

  • Cookies retaining your choice on the deposit of Cookies requiring your consent.
  • Session or load-balancing cookies that allow faster loading of the website’s pages and better navigational fluidity.
  • Cookies to personalise the interface, enabling us to memorise your connection data, such as the country from which you are visiting the website. They can also be used to provide you with an experience more suited to your device and to make your visits more pleasant and personalised (e.g. display of the website adapted to the configuration of the device you are using (tablet, computer, telephone).
  • Authentication cookies to remember your authentication credentials and thus enable you to remain logged into your user account throughout your browsing. 
  • Cookies to identify fraudulent or repeated login attempts in order to protect the login system from misuse. These cookies are only used on www.kayrros.com and www.services.kayrros.com.

To place these cookies, your consent is not required. 

Some of these cookies are “session cookies”, i.e. they are only retained during your browsing on the website before being deleted; other cookies are “persistent cookies”, i.e. they are retained beyond the duration of your browsing on our Site, between 1 day and 13 months.

They allow Kayrros and its partners listed in the consent module available on our Websites and Apps to analyse your browsing and generate statistics on traffic and performance that are useful for improving the Websites and our services, including existing systems and software as well as to develop new products.

They enable us to understand how you interact with the Websites, to know the use and performance of the various elements making up the Websites (the pages and content visited, the path taken on the Websites, the time spent on certain content) and the volume of traffic (the pages or sections most often consulted, the articles most frequently read). 

To measure content performance, Kayrros’ partners can: Measure and report on how content was delivered to and interacted with by users; Provide reporting, using directly measurable or known information, about users who interacted with the content; Combine this information with other information previously collected, including from across websites and apps.

Kayrros’ partners can also: Use information to improve their existing products with new features and to develop new products; Create new models and algorithms through machine learning.

Such cookies are only placed with your consent. If you refuse these cookies, we will not be able to analyse the traffic and browsing on our Websites in order to improve it and enhance our services.

This type of cookie is stored on your terminal for a maximum of 6 (six) months.

Kayrros and its partners listed in the consent module available on our Websites and Apps use cookies in order to display relevant and personalised advertising based on your browsing and your profile and to measure the performance of such ads.

To personalise the advertising displayed on our Websites or about our products and services on the websites of third parties, including social media, and/or to enable our partners to display such personalised advertising, we and our partners base ourselves on your personal profile and interests which are deduced and combined from your browsing and behaviour on our Websites and/or on third party apps and websites you visited before and after your visit on our Websites (i.e. the type of websites and apps you visited, the content you viewed, the advertisements you interacted with) as well as your location, or demographic information.

The performance and effectiveness of ads that you see or interact with can be measured. To measure ad performance, Kayrros’ partners can: Measure whether and how ads were delivered to and interacted with by a user; Provide reporting about ads including their effectiveness and performance as well as users who interacted with ads; Provide reporting to publishers about the ads displayed on their property; Measure whether an ad is serving in a suitable editorial environment (brand-safe) context; Determine the percentage of the ad that had the opportunity to be seen and the duration of that opportunity; Combine this information with other information previously collected, including from across websites and apps.

Such cookies are only placed with your consent. If you refuse such cookies, Kayrros and its partners will not be able to display personalised advertising and measure their performance.

This type of cookie is stored on your terminal for a maximum of 6 (six) months. 

  • Cookies and buttons to interact on social media: on www.kayrros.com as well as on www.services.kayrros.com, Kayrros and its partners listed in the consent module available on our Websites and Apps use social media buttons to allow you to interact on social media and/or share content on them. These cookies allow you to interact directly from our Websites with the modules of the social media and to share the content of our Websites or to inform the users of these social media of your consultation or your opinion on it, when you click for example on the “Share” or “Like” modules of these social media. If you accept the placement of such cookies, when you use the sharing functionalities on our Websites, data is transferred directly to the social media concerned to allow the sharing of content and/or to interact with the pages of our company. If you are logged-in to the social media when you browse our Websites, the sharing functionalities allow you to link the content directly to your user account. Otherwise, you will be asked to authenticate yourself.

In addition, if you accept the placement of such cookies, the social media providing such buttons is also likely to identify you, even if you have not used such buttons while browsing our Websites. Indeed, this type of button may allow the social media concerned to track your navigation on our websites. We have no control over the process used by social media to collect information relating to your browsing on our website and their possible association with the personal data they have about you. Please read the privacy policy of each of these social networks in order to know how these cookies work. 

Such cookies are only placed with your consent. If you refuse the placement of such cookies, you will not be able to share content or interact with us on the social media directly from our website.

This type of cookie is stored on your terminal for a maximum of 6 (six) months. 

  • Logs: During your visit to our Apps, We may collect logs regarding the way You interact with our online tools. The logs are used for statistical purposes but also to detect or investigate any suspicious activity related to our website or application.
  • Information We collect from outside sources:

KAYRROS may get information about individuals who are not yet subscribers, such as a mailing address, from third-party service providers which We may use, for example, for marketing purposes such as mailers advertising our services. KAYRROS always makes sure that such third-party service providers comply with the GDPR and our Privacy Policy.

3. Why do We collect your personal information?

KAYRROS collects information about You only if there is a valid reason to do so – for example, to provide our services to subscribers, to communicate with You, to recruit candidates, or to monitor the use of our services.

KAYRROS makes sure your personal information is processed with a valid ground. That might be, with the consent of the person whose information is collected, to perform our obligations under an agreement, or to pursue a legitimate business interest in using the information – for example, to improve the effectiveness of our online tools or to market our products, to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

The personal information We collect about You will help us to perform our services for You and to send you e-mails about our services. It also may help us to improve our services in general (such as our website or application).

Your personal information will never be used by us for other purposes that are not explained in either this Privacy Policy or our Terms of Use.

4. How do We make sure that the information We process is accurate and limited?

KAYRROS makes every reasonable effort to ensure that the personal information that We process is limited to the personal information reasonably required for the purposes set out in this Privacy Policy (including the performance of our services to You).

Moreover, KAYRROS makes every reasonable effort to ensure that the personal information We process is accurate and that any personal information that is inaccurate is erased or rectified without delay. From time to time, we may ask You to confirm the accuracy of your personal information.

5. How long do We store your personal information?

KAYRROS only keeps your personal information as long as We need it to achieve the purpose for which it was collected. We generally discard information about You if We no longer need it or if We do not have a legal obligation to keep it.

Each type of information has its own retention period. For example:

  • We keep the logs for a period of 3 (three) months, and in no case for longer than 13 (thirteen) months.
  • Information We collect from cookies which cannot be used without your prior consent is in no case kept more than 6 (six) months. 
  • The information shared by candidates who apply for positions within KAYRROS is stored for a period of 12 (twelve) months from receipt of the application.
  • We store the personal information related to our subscribers for a period of 5 (five) years after termination of the relevant agreement.

6. How do We share the personal information We collect?

KAYRROS does not sell the personal information collected in the course of our business activities.

We share the information about You in limited circumstances – for example, with our subsidiaries, employees and independent contractors, or with third-party service providers who need to know your information in order to help us provide our services and perform our obligations.

If KAYRROS engages a third-party processor to process your personal information, We will enter into a data processing agreement with such third-party processor that will require it to: (i) only process the personal information in accordance with our prior written instructions; and (ii) take measures to protect the confidentiality and security of the personal information.

We may have to share your personal information with a law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights, or any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties.

7. What about transfers of personal information outside the EU?

KAYRROS’s products and services are offered worldwide. That means that some of your personal information might be processed or shared outside the European Union (“EU”) and transferred to other countries that may have lower standards for data protection than the EU.

Before transferring your personal information outside the EU, We make sure that the recipients agree to comply with this Privacy Policy and that all measures are taken to ensure the protection of your information. To that end, when We transfer your personal information to other countries, We do so, where required, on the basis of standard contractual clauses as approved by the European Commission.

8. What security measures do We take to protect your personal information?

KAYRROS employs effective technical and organizational measures to protect your personal information against loss, destruction, alteration or access by unauthorized persons. For example, we regularly monitor our online tools to identify potential vulnerabilities and attacks.

You are responsible for ensuring that any personal information that You send to us is sent securely.

9. What are Your rights regarding your personal information?

If your personal information is processed by KAYRROS, You have the following rights:

  • to be informed: You have the right to obtain clear, transparent, understandable and easily accessible information about how We use your personal data and about your rights. That is why We provide you with the information in this Policy.

 

  • to access your personal information: You have the right to access and obtain a copy of the personal data We have on You (provided that the request is not manifestly unfounded or excessive, for example due to its repetitive nature). If You wish to access the data We hold about you, please contact us at the contact details below. 

 

  • to request the correction or modification of your personal information: You have the right to demand that your personal data be rectified if they are inaccurate or out of date and/or that they be completed if they are incomplete (provided that the request is not manifestly unfounded or excessive, for example due to its repetitive nature). If You wish to modify your personal data, please contact us at the contact details below.

 

  • to request the deletion of your personal information: In certain cases, You have the right to obtain the deletion or removal of your personal data. This is not an absolute right, insofar as we may be obliged to retain your personal data for legal or legitimate reasons. If You wish us to delete your data, please contact us at the contact details below.

 

  • to request the limitation of the processing of your personal information; This right means that the processing of your data by us is limited, so that We can keep this data, but We cannot use or process it. This right applies in special circumstances, namely:

–  In cases where the accuracy of personal data is contested by You. Processing is then limited for a period of time that allows us to verify the accuracy of the personal data;

– In cases where the processing is unlawful and You do not object to the deletion of the personal data and instead demand the limitation of its use;

– In cases where We no longer need the personal data for the purpose of processing but the personal data is still necessary for You to establish, exercise or defend legal claims;

– In cases where You have objected to the processing based on the legitimate interests pursued by us during the verification on whether or not the legitimate grounds pursued by us prevail over those of the data subject.

If You wish to obtain the limitation of the processing, please contact us at the contact details provided below

 

  • to object to the processing of your personal information based on our legitimate interest: You may at any time object to the processing of your personal data for reasons relating to your particular situation, unless we assert legitimate and compelling reasons for the processing of such data which prevail over your interests, rights and freedoms, or when such data is necessary for the establishment, exercise or defence of a legal right. If You wish to exercise your right to object or to obtain more information on how to exercise this right, please contact us at the contact details below.

 

  • to withdraw the consent You gave for the processing of your personal information

 

  • to object to direct marketing communications: You may, at any time, unsubscribe or object to the receipt of direct marketing communications from Kayrros. All you need to do is either (i) click on the link at the bottom of the communications you receive from Kayrros; or (ii) send a message to the contact details specified below. It is nevertheless specified that the sending of certain electronic communications from Kayrros will persist, in particular communications transmitting order confirmations and invoices.
  • to request the portability of your personal information – You have the right to receive your personal data that You have provided to us and that We hold about you in a structured, commonly used, machine-readable format. This only applies to data that you have provided directly or indirectly and only when the processing is based on your consent or the execution of a contract and is carried out using automated processes. To exercise your right to data portability or to obtain further information, please contact us at the contact details below. 

 

  • The right to send us special instructions regarding the fate of your personal data after your death. 
  • to file a complaint regarding the processing of your personal information with a supervisory authority such as the CNIL “Commission Nationale Informatique et Libertés” (the French administrative body dealing with personal data regulation). We nevertheless invite You to contact us at the contact details below before making any complaint to the competent data protection authority.

 

To enforce these rights, You can email us at contact@kayrros.com. We will respond as soon as possible, and in no case more than 30 (thirty) days after receipt of your request.

10. Your choices about Cookies

Your prior consent is required before the placement of cookies other than those strictly necessary for the operation and proper functioning of the website. 

In accordance with the CNIL guidelines and guidance on the topic, your consent is collected through an accessible platform when you first connect to our website.

You may also withdraw your consent to the placement of all or part of the cookies at any time by means of a button entitled Manage Cookies in the bottom left-hand corner of all pages of the website, and also accessible by clicking here : Manage cookies.

This platform allows you to:

  • directly accept the placement of all types of cookies for which consent is mandatory; or
  • directly refuse the placement of all types of cookies for which consent is mandatory; or
  • choose in a granular way the purposes of cookies for which you wish to give your consent or refuse it; and/or
  • choose precisely each of the partners who may use the cookies and the purposes for which they wish to use them.

11. Contact details of our Data Protection Officer

Data protection and privacy is really important to Kayrros. It has therefore decided to appoint a data protection officer in front of the French Data Protection Authority. Our Data Protection Officer can be contacted at the following address: dpo@kayrros.com.

12. How do we update this Privacy Policy?

KAYRROS may update or change this Privacy Policy to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this Privacy Policy the date when this Policy was last updated.

Please review this Privacy Policy every time You access or use our website and application to make sure that You have reviewed the latest version.