Collecting and using your Personal Information

Personal Information is any information that identifies you and describes your relationship with Kluly. Some examples of the information that we may collect include:

• • Name, address and phone number
• • Financial information
• • Other information you give Kluly

We require you to share your Personal Information with us for some of our online and other activities and features. For example, we may collect your Personal Information so you can access your information, enroll and participate in certain activities, and ask us questions. We collect your Personal Information from the online registration form or via any follow-up communications we may have with you, such as when you:

• • Ask a question
• • Complete a form
• • Conduct transactions
• • Send email to us
• • Subscribe to receive emails from us

We assign you a username and password of your choosing so that you may continue to securely access your specific information when you return to the Website.

We also use Personal Information to allow you to use some features on our Website. In particular, we use Personal Information for the following purposes: internal research, studies, related statistical analysis, and to design and improve the services we offer. We will not disclose Personal Information related to such purposes. We may use, disclose, and otherwise process for any purpose all information that is not in personally identifiable form (i.e., anonymous data).

Access to Personal Information is restricted to those employees, contractors or agents of Kluly who need such access to administer or assist Kluly to administer the Services.

Personal Information also may be disclosed, where permitted by applicable law, in connection with a corporate restructuring, sale, or assignment of assets, merger, divestiture, or other changes of the financial status of Kluly or any of our subsidiary or affiliated companies. Personal Information also may be disclosed to third parties, in accordance with applicable law, to protect your vital interests, to protect the rights of Kluly or others, or in Kluly’s good faith judgment to comply with applicable law, law enforcement investigations, or court orders.

You may choose to use your personal email to correspond with Kluly. Please be careful about the information you send to us in email. As with any public web tool, your email may not be secure; so please do not include sensitive information.

SPECIAL NOTICE RELATED ONLY TO EMPLOYER-SPONSORED USERS

IF YOUR USE OF THE SITE IS OFFERED TO YOU BY AN EMPLOYER, THE FOLLOWING ADDED PROVISIONS AND NOTIFICATIONS SHALL APPLY:

YOUR EMPLOYER (OR THE EMPLOYER OF YOUR SPOUSE, PARTNER OR FAMILY MEMBER) MAY HAVE ALLOWED YOU TO USE THE SERVICES DESCRIBED ON THIS SITE AND MAY HAVE PROVIDED US WITH YOUR ELIGIBILITY INFORMATION. YOUR PARTICIPATION IN THE SERVICES IS COMPLETELY VOLUNTARY, BUT IF YOU DO PARTICIPATE, WE WILL NEED TO COLLECT YOUR PERSONAL INFORMATION TO ALLOW YOU TO USE THE SERVICES.

AT THE DIRECTION OF YOUR EMPLOYER AND IN ACCORDANCE WITH APPROPRIATE REGULATIONS, WE MAY DISCLOSE YOUR PERSONAL INFORMATION TO CONTRACTORS, AGENTS OR DATA PROCESSORS THAT WORK WITH YOUR EMPLOYER. SUCH USES MAY INCLUDE SHARING YOUR NON-PERSONALLY IDENTIFIABLE INFORMATION ON A CONFIDENTIAL BASIS WITH A DATA WAREHOUSE FOR ANALYSIS OF TRENDS AND EFFECTIVENESS OF SERVICES OR WITH OTHER THIRD PARTY SERVICE PROVIDERS, INCLUDING THOSE ASSOCIATED WITH YOUR EMPLOYER THAT HELP YOUR EMPLOYER MANAGE THE QUALITY AND COST OF THE SERVICES.

WE WILL NOT SHARE ANY PERSONAL INFORMATION DIRECTLY WITH YOUR EMPLOYER.

WE MAY SHARE LIMITED PERSONAL INFORMATION ABOUT YOU WITH YOUR EMPLOYER CONSISTING OF YOUR NAME AND CONTACT INFORMATION ONLY. WE SHARE THIS INFORMATION WITH EMPLOYERS PRIMARILY FOR THE PURPOSES OF TRACKING THE NUMBER OF PARTICIPANTS ENROLLED, PAYMENT AND ADMINISTRATIVE PURPOSES, INCLUDING PROVIDING INCENTIVES FOR PARTICIPATION FROM YOUR EMPLOYER.

Selling your Personal Information

We do not sell your Personal Information.

Sharing your Personal Information for marketing

WE DO NOT SELL YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES. EXCEPT AS DISCLOSED ABOVE, WE DO NOT SHARE YOUR PERSONAL INFORMATION WITH ANYONE EXCEPT TO DELIVER OUR SERVICES, AS OUTLINED. SO, THERE IS NO REASON FOR YOU TO OPT OUT. IF WE CHANGE OUR POLICY, WE WILL TELL YOU AND GIVE YOU AN OPPORTUNITY TO OPT OUT BEFORE WE SHARE YOUR INFORMATION.

Data located in the United States

The Site is hosted on servers located in the United States. All Services-related analyses of the Personal Information you provide will be performed by Kluly employees or agents using servers in the United States. Therefore, if you reside or work outside the United States, the Personal Information that you provide via your computer may be transferred to the United States, a jurisdiction where the privacy laws might not provide a level of protection to Personal Information that is equivalent to that of the laws of your home jurisdiction or jurisdiction in which you are located. This does not change any of our commitments to safeguard your privacy.

Data Security

We maintain technical, electronic, and organizational procedures to maintain the security of Personal Information, and safeguard Personal Information against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access. Our security procedures include contractual terms with any contractors, agents or data processors to ensure that such entities protect the security and confidentiality of Personal Information in accordance with our standards and applicable laws and regulations.

We limit access to your Personal Information to those who need it to do their jobs. The law requires our business partners to use your Personal Information only for our purposes. They may not share it or use it in any other way. We comply with all data security laws.

It is your responsibility to safeguard any username or password that you have received in connection with the Website, and to notify us if you ever suspect that the security and confidentiality of such username or password has been compromised in any way. You are solely responsible for any use of this Website via your username and password.

Retention of Personal Information

We will maintain Personal Information for as long as we are required to do so by applicable law(s), or for as long as necessary for the purpose(s) for which it is collected, used, or processed as outlined above. We will delete Personal Information when it is no longer needed for a purpose related to its collection or use or upon expiration of the storage term set forth by applicable law.

Web Links

Other companies or organizations may have links to their websites on our web pages. We are not responsible for how they collect, use, disclose or secure the information that you provide to them. Please read their privacy policies so you can learn how their website uses your information.

Access Rights and Questions

Where required by applicable law, you are generally entitled to update or access Personal Information that we hold about you. In most circumstances, you may do so via the Site or by contacting us at hello@kluly.com. Requested copies of your Personal Information will be provided in a reasonable period. If there is a charge for the cost of producing a copy, we will advise you of the cost in advance of processing your request.

We have a process that allows you to review your information after we have verified your identity. Please note that we can only give you access to, correct or update Personal Information that we control.

These are our privacy practices. They apply to all current and former clients of Kluly.