1. KOOLI Privacy and personal data protection policy

For this, KOOLI undertakes to:

• collect only data from data subjects, and only those which are strictly necessary for executing its business activity and managing its human resources;
• whenever legally required, obtain the data subjects’ informed consent directly and in advance, thus obtaining their permission to use such data in the company’s business context;
• not share personal data of data subjects with other entities which do not take the technical and organizational measures required to ensure the regulation requirements are met;
• inform the data subject, in accordance with the legislation in force, about any abnormal situation likely to result in a high risk to his/her fundamental rights and freedoms.

Cumulatively, KOOLI assures data subjects that the data are:

• processed lawfully, fairly and in a transparent manner;
• collected for specific, explicit and legitimate purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• kept for no longer than the time necessary for the purposes for which they are processed;
• processed in a manner that ensures their security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

KOOLI also guarantees the following rights to the data subjects:

• the right to access the personal data collected concerning the data subject, and to exercise this right easily;
• the right to have his/her personal data rectified or erased, or to withdraw his/her consent regarding the processing of his/her personal data;
• the right to know and obtain communication with regard to the purposes for which the personal data are processed, the period for which they will be processed, possible recipients, the logic involved in any automatic personal data processing and, at least when based on profiling, the consequences of such processing;
• the right to receive his/her personal data, in a structured, commonly used, machine-readable and interoperable format (which can be read and processed by any organization), and to transmit it to another controller;
• the right to lodge a complaint with KOOLI concerning any situation that the data subject considers abnormal regarding the protection of his/her personal data or privacy.

To guarantee the rights of the data subjects, as well as to address any other questions regarding the protection of personal data, KOOLI appointed a data protection process owner. This has the responsibility to ensure the implementation and continuous improvement of the technical and organizational measures required for the effective and efficient protection of personal data, and ensure the communication to KOOLI’ Executive Committee, in order to report any problem related to non-compliance with the regulation.

KOOLI staff members have a responsibility to comply with and enforce this privacy and data protection policy, as well as any other standards and regulations in force on this matter, and to communicate any weakness or abnormal situation detected and which may have an impact, even if potential, on the data subjects’ fundamental rights and freedoms.

Any violation of KOOLI staff members to the rules established by this regulation will be handled (if applicable) through disciplinary and/or criminal proceedings.

2. KOOLI Website Privacy Policy

KOOLI Soluções Tecnológicas, Lda (hereinafter referred to as KOOLI) has created this privacy policy to demonstrate its commitment to the privacy of the users of its website. Please read the following to learn more about the company’s privacy policy, and about how it handles personally identifiable information collected from the website’s visitors and users.

WHAT THIS PRIVACY POLICY COVERS

This privacy policy covers KOOLI’ treatment of personally identifiable information collected by KOOLI through a website owned and operated by KOOLI.

This privacy policy does not apply to the practices of companies that KOOLI does not own or control, or of persons that KOOLI does not employ or manage, including any third-party content contributors bound by contract, and any third-party websites to which KOOLI website links.

COLLECTION AND USE OF PERSONAL INFORMATION

You can visit KOOLI’ website without revealing any personal information. However, KOOLI needs certain personal information if you wish to receive KOOLI newsletter or use specific KOOLI services.

In some situations, this information may include your personal contact information and/or your company’s contact information. KOOLI will use this information to reply to your enquiries, to provide you with the requested products and services, to set up users accounts, and to contact you regarding new products and services.

By accessing KOOLI services and voluntarily providing the company with the requested personal information, you consent to the collection and use of the information in accordance with this privacy policy.

COLLECTION AND USE OF NON-PERSONAL INFORMATION

KOOLI automatically receives and records non-personal information in its server logs from your browser, including your IP address, cookie information, and the page you accessed. KOOLI may use this information to customize the advertising and content you see and to fulfil your requests for specific products and services. However, KOOLI does not connect this non-personal data to any personal information collected from you.

INFORMATION SHARING AND DISCLOSURE

KOOLI may disclose your personal information to third parties who work on its behalf to provide products and services requested by you. KOOLI will share personal information for these purposes only with third parties whose privacy policies are consistent with its own or who agree to abide by KOOLI’ policies with respect to personal information.

KOOLI may also disclose your personal information when it:

• has your express consent to share the information for a specified purpose;
• needs to respond to subpoenas, court orders or such other legal process;
• needs to protect the personal safety of the users of its website or defend its rights or property;
• finds that your actions on its website violate its usage guidelines for specific products or services.

USER ID TRACKING

KOOLI uses Google Analytics to track and analyse website visits and usage. Google Analytics uses a unique user ID when a user is authenticated and logged in.

On behalf of KOOLI, Google Analytics tracks users’ flow, location by country, language, browser and operating system, Internet service provider, and devices used to access KOOLI website. KOOLI tracks this information to improve the service provided to its clients.

KOOLI does not upload any data that allows Google to personally identify an individual (such as name, social security number, e-mail address, or any similar data), or data that permanently identifies a particular device (e.g. IP address).

To opt-out of Analytics for the web, go to the Google Analytics opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser.

CONSENT

If you do not consent to the collection, use or disclosure of your personal information as outlined in this policy, please do not provide any personal information to KOOLI. If you have provided personal information to KOOLI and no longer consent to its use or disclosure as outlined in this policy, please notify KOOLI using the e-mail address info.kooli.io.

SECURITY

Unfortunately, no data transmission over the Internet can be considered 100% secure. Nevertheless, the information you share with KOOLI when using its website is protected for your privacy and security. In some areas of the website, as duly identified, KOOLI uses industry-standard SSL-encryption to protect data transmissions.

KOOLI also safeguards your personal information from unauthorized access, through access control procedures, network firewalls and physical security measures.

Furthermore, KOOLI retains your personal information only for as long as necessary to fulfil the purposes identified above or as required by law.

LIMITATIONS AND EXCLUSIONS OF LIABILITY

Nothing in these terms and conditions will:

• limit or exclude any liability for death or personal injury resulting from negligence;
• limit or exclude any liability for fraud or fraudulent misrepresentation;
• limit any liabilities in any way that is not permitted under applicable law;
• exclude any liabilities that may not be excluded under applicable law.

The limitations and exclusions of liability set out in this section and elsewhere in these terms and conditions:

• govern all liabilities arising under these terms and conditions or relating to the subject matter of these terms and conditions, including liabilities arising in contract, in tort (including negligence) and for breach of statutory duty, except to the extent expressly provided otherwise in these terms and conditions.

To the extent that KOOLI’ website and the information and services contained therein are provided free of charge, KOOLI will not be liable for any loss or damage resulting from its use.

• KOOLI will not be liable to you in respect of any losses arising out of any event or events beyond KOOLI’ reasonable control.
• KOOLI will not be liable to you in respect of any business losses, including (without limitation) loss of or damage to profits, income, revenue, use, production, anticipated savings, business, contracts, commercial opportunities or goodwill.
• KOOLI will not be liable to you in respect of any loss or corruption of any data, database or software.
• KOOLI will not be liable to you in respect of any special, indirect or consequential loss or damage.
• You accept that KOOLI has an interest in limiting the personal liability of its officers and employees and, having regard to that interest, you acknowledge that KOOLI is a limited liability entity. You agree that you will not bring any claim personally against KOOLI officers or employees in respect of any losses you suffer in connection with the website or these terms and conditions (this will not, of course, limit or exclude the liability of the limited liability entity itself for the acts and omissions of its officers and employees).

CHANGES TO THIS PRIVACY POLICY

KOOLI may at any time, without notice to you and in its sole discretion, amend this policy. Please read this policy periodically. Your continued use of KOOLI website after any such amendments signifies your acceptance thereof.

QUESTIONS OR SUGGESTIONS

If you have any questions or suggestions about this privacy policy, or your own personal information, please leave us a note at info@kooli.io.

3. Terms and Conditions

Please read these Terms and Conditions carefully before using the www.kooli.io operated by KOOLI Soluções tecnológicas, Lda. Your access to and use of the Service (www.kooli.io) is conditioned on your acceptance of and compliance with these Terms.

These Terms apply to all visitors, users and others who access or use the Service. By accessing or using the Service you agree to be bound by these Terms. If you disagree with any part of the terms then you may not access the Service.

WEB BROWSER COOKIES

Our Service may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

LINKS TO OTHER WEB SITES

Our Service may contain links to third-party web sites or services that are not owned or controlled by KOOLI. KOOLI has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party web sites or services. You further acknowledge and agree that KOOLI shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such web sites or services. We strongly advise you to read the terms and conditions and privacy policies of any third-party web sites or services that you visit.

TERMINATION

We may terminate or suspend access to our Service immediately, without prior notice or liability, for any reason whatsoever, including without limitation if you breach the Terms. All provisions of the Terms which by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

GOVERNING LAW

These Terms shall be governed and construed in accordance with the laws of Portugal, without regard to its conflict of law provisions. Our failure to enforce any right or provision of these Terms will not be considered a waiver of those rights. If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions of these Terms will remain in effect. These Terms constitute the entire agreement between us regarding our Service, and supersede and replace any prior agreements we might have between us regarding the Service.

CHANGES

We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material we will try to provide at least 30 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion. By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Service.

Contact us through info@kooli.io if you have any questions about these Terms.

4. Cookies Policy

KOOLI uses cookies on this Website. By using the Website (the Service), you consent to the use of cookies. Our Cookies Policy explains what cookies are, how we use cookies, how thirdparties we may partner with may use cookies on the Website, your choices regarding cookies and further information about cookies.

WHAT ARE COOKIES

Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a thirdparty to recognize you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies.

HOW KOOLI USES COOKIES?

When you use and access the Service, we may place a number of cookies files in your web browser. We use cookies for the following purposes: to enable certain functions of the Service, to provide analytics, to store your preferences, to enable advertisements delivery, including behavioral advertising. We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:  Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.

THIRDPARTY COOKIES

In addition to our own cookies, we may also use various thirdparties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

HOW CAN YOU CONFIGURE OR DISABLE COOKIES?

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

WHERE CAN YOUR FIND MORE INFORMATION ABOUT COOKIES

You can learn more about cookies and the following thirdparty websites:

• AllAboutCookies: http://www.allaboutcookies.org/
• Network Advertising Initiative: http://www.networkadvertising.org/