Privacy and Cookie Policy (“Policy”)

Last update: June 2020 

KliKlu considers data protection and privacy to be of paramount importance. We never sell personal data and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation (“GDPR”) as well as other data protection related laws applicable.

KliKlu (“We”, “Us” or “Our”) collects personal information and non-personal data from the visitors on our website and users of our services (“you”, “your(s)”).

1. Who we are:

KluKlu BV, registered as a business in the Netherlands under business registration number: KVK 77812506 with its registered address: Gravin Juliana van Stolberglaan 31, UNIT-D4557, 2263 AB Leidschendam.

For questions regarding this Privacy and Cookie Policy and the way we protect your personal data, please e-mail us at: privacy@kliklu.com.

The storing and processing of personal data is subject to the GDPR, and any other law or regulation that may apply.

2. Types of data we collect

There are different types of data and personal information that we collect. Please read the following list:

  • First and last name.

  • Date of birth.

  • E-mail address(es).

  • Physical address.

  • Photo ID and/or (EU) Passport.

  • Bank account information.

  • Insurance information.

  • Passport or ID number.

  • Phone number.

  • IP addresses.

  • Country and city.

  • Location data.

  • Business registration number.

  • VAT-number.

And any other type of personal information that is necessary to provide our services to you.

We may use the data we have collected to create User’s profiles. This allows us to evaluate your choices, preferences, and behavior on our platform. By doing so, we fulfil our legal duty of a legitimate purpose of processing data.

User profiles may also be created by automated tools. As a user of our services you always have the right to object to this kind of profiling activity and to exercise your right to opt-out. Please contact us.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Sharing your information with us occurs without any restrictions unless imposed by the applicable law. All personal data we request is obligatory to use our services, unless otherwise indicated by us. The failure to give such information means that we cannot provide the services to you. We may indicate that providing certain data is not obligatory. You are free to communicate this information with us when it has no consequences for our services. If you are not sure which type of information and personal data is mandatory for using our services, you may contact us at: privacy@kliklu.com.

On our mobile and web application, we may also use tracking tools, such as cookies and other technologies. Please read the section about cookies in this Policy. We may also use third-party services contracted by us, which are necessary to provide our services to you. We may share your (personal) data with those third-party services providers. You acknowledge and agree that you are aware of those third-party processors we mention in this Privacy Policy.

3. How do we collect data

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by using our live chat, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • use our services.

    • create an account on our website/app.

    • subscribe to our service or publications.

    • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [link] for further details.

  • Third parties. We might receive personal data about you from third parties such as payment processing services.

We will take all reasonable security measures to avoid disclosure and modification of and unauthorized access to your data. The data collection and processing are executed following organizational procedures.

All information and personal data may be accessed to authorized persons working for us. This includes authorized external parties appointed by us, including but not limited to contractors, agents, and affiliates. In case these external parties are processors under the applicable law, they will be mentioned in these Policies, and we are referring to their respective privacy policies. We recommend you check their privacy policies regularly.

4. Legal basis of controlling data

The legal basis to process your personal data is always based on your permission to provide such data to us, meaning you have given your full consent. We may process personal data until the moment you clearly object to the processing of your data.

  • The processing of your data is necessary for the performance of a contract with you or to fulfil a pre-contractual duty.

  • The processing of your data is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • The processing of data is necessary to comply with an obligation by law to which we are subjected.

  • The processing of data is necessary for reasons of public interest and/or safety.

We are always happy to answer any question to clarify the legal basis mentioned above.

5. Place of processing 

The data may be processed at our offices, or at any other site where the organization may be located. We also may transfer personal data to another country other than your place of residency. We always make sure that there are adequate data protection mechanisms and measures in place. You can find more information about the place of processing in the section about third party processors.

6. Retention of data

Your personal data will be stored for as long as the legitimate purpose requires this. Personal data collected in case of a legitimate interest shall be retained if it is necessary. You may always contact us to ask about how long we store your data.

We may store your personal data for a more extended period, if you have not withdrawn your permission, or for the performance of a legal obligation or based on a (judicial) order. After the retention period, your personal data will be fully erased by us. As a result, your legal rights to access, delete, correct, and transfer your data cannot be exercised by you.

7. Purposes of processing data

In addition to the aforementioned purposes, your data is processed for the following purposes:

  • Location information.

  • IP addresses.

  • Registration, authentication and login credentials and procedures.

  • Access to third-party accounts.

  • Displaying content from external and third parties’ platforms.

  • Payments and completion of invoices.

  • Managing support services and contact requests.

  • Social plugins.

  • Marketing and Analytics.

  • Database management.

8. Third-party processors

We may share data and personal information with third-party processors. Their services allow them to access your data. Sometimes, the services may require your authorization. Please read their respective privacy policies to learn about your legal rights.

Processor, Company and Country

Service

Privacy Policy Link

Stripe, INC. (USA)

Receiving payments from customers and transferring payments to Agents

https://stripe.com/privacy

Amazon Web Services, INC. (USA)

Hosting Backend server, database, and front app web code that Jungleworks is using

https://aws.amazon.com/privacy/

Google Play Developer Console (Google, LLC. USA)

Upload and run apps on Android Play store

https://play.google.com/about/privacy-security-deception/

Apple Developer Console (Apple, INC. USA)

To upload apps to Apple iTunes Store

https://www.apple.com/legal/privacy/en-ww/

JungleWorks (Clicklabs, INC. USA)

Main platform developer and provider

https://jungleworks.com/privacy-policy/

TBD

Agent identity and document verification service

TBD

9. Your rights

You may exercise your legal rights regarding your data stored and processed by us. You have the following rights.

  • Withdraw your consent at any time if the processing is based on your consent.

  • The right to object to the processing of your data if this is done on a legal basis other than consent.

  • Right to access and obtain information about the processing of your data and receive a copy of the data that has been processed.

  • The right of rectification, meaning the right to verify the accuracy of your data and request an update or correction.

  • The right to have your data permanently deleted.

  • The right to have your data transferred to another controller or processer without any obstacles.

  • File a complaint or claim before your national data protection, in the Netherlands, the National Data Protection Authority (Autoriteit Persoonsgegevens).

If you want to exercise one of those rights, please email us at privacy@kliklu.com.

10. Right to object to processing

If personal data is processed for the public interest or any other legitimate interest, you may object by writing a notification to us. Any request can be directed to us through the contact details provided in this document. These requests can be exercised free of charge, and we will process such requests within one (1) month.

11. Amendements 

We may change these policies at any time, and we will make a reasonable effort to inform all the changes in our privacy policy to you. We recommend you check our website regularly and check the date on top of this Policy indicating the most recent version.

In case these changes affect processing, activities performed based on the User’s consent, we shall collect again consent from the User when the applicable law requires this.

12. Cookies 

Our website uses cookies, which are small files that are placed on your device to improve your experience. The use of cookies is common practice with almost all websites. If you prevent cookies from being stored on your computer, this may affect the functionality of our website.

Our cookies are used for the following purposes:

Cookie type

Purpose

Strictly necessary cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

For example, we use Google Analytics to help us understand how our customers use the Site – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/.

You can also opt-out of Google Analytics here: 

https://tools.google.com/dlpage/gaoptout.

Third Party Cookies

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies

Our cookies

We recommended you keep all cookies settings unchanged. You may disable cookies by adjusting your browser settings. If you do so, it will affect the functionality of our website and other sites you visit. If you create an account with us, then we will use cookies for the management of the signup process and login credentials. These cookies will usually be deleted when you log out.

To participate as a KluKlu Agent, you must permit the KluKlu Services to access location services through the permission system used by your mobile operating system (“Platform”) or browser. We may collect the precise location of your device when the KluKlu app is running in the foreground or background of your device. We may also derive your approximate location from your IP address. We use your location information to verify that you are present in your preferred region or city when you begin or engage in a delivery through the KluKlu Services (a “Delivery”), connect you with delivery opportunities in your zone, and track the progress and completion of your Deliveries. You can enable the location tracking feature through the settings on your device or Platform or when prompted by the KluKlu mobile app. If you choose to disable the location feature through the settings on your device or Platform, KluKlu will not receive precise location information from your device, which will prevent you from being able to Trip and receiving delivery opportunities in your area.