PRIVACY & DATA PROTECTION POLICY

Last updated: December 1, 2022
 

INTRODUCTION

This privacy policy applies to all users accessing www.Koomby.com and/or any domain or subdomain where Koomby provides its services.

Koomby is owned by “APPLAY TECH SAS”, a company registered in France, with registration number RCS Paris 900 648 502 and registered office at 10 rue de Penthièvre, 75008 Paris, France. Our EU VAT number is FR42900648502.

Applay Tech SAS and its subsidiaries (collectively, “Koomby,” “we,” “us,” “our”) respect your privacy and are committed to protecting the personal data we hold about you. If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us. Koomby is the data controller of the personal data collected, and is responsible for the processing of your personal data.

Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed. 

Our Policies and Terms are based on the laws of the French Republic and/or on European regulations on privacy rights such as the GDPR, for any claim or dispute about our policies or terms French law applies and will be the courts of France and/or of the European Union the competent ones to resolve any disputes.
 

CONSENT

By using our website, you hereby consent to our Privacy Policy and agree to its terms.
 

INFORMATION WE COLLECT

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.
 

HOW WE USE YOUR INFORMATION

We use the information we collect in various ways, including to:

  • Provide, operate, and maintain our website
  • Improve, personalize, and expand our website
  • Understand and analyze how you use our website
  • Develop new products, services, features, and functionality
  • Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
  • Send you emails
  • Find and prevent fraud


LOG FILES & ISP TRACKING

Koomby follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

IMPORTANT: Although Koomby does not track your Internet activity, we remind you that your Internet Service Provider (ISP) intensively tracks all your activity whether it is through your 3G, 4G or 5G mobile connection or through ADSL/Fiber connection at home or work.

These internet service providers have very specific systems capable of even bypassing the security offered by some free VPN's and can share this information with government agencies, so Koomby always recommends its users to use a Premium VPN that is capable of encrypting and anonymize all your web traffic on your mobile device or on your internet connection at home or at work to prevent this abusive tracking techniques by your internet service provider.

Recommended VPNs for your security: 

ANALYTICS

Unlike other websites, Koomby has its own Analytics system to monitor and improve our services.

The data obtained through Koomby Analytics is completely anonymized and there is no way to track users, it is exclusively used to improve and optimize our web traffic and detect possible security flaws in our network.

You can access our Analytics service at https://analytics.koomby.com and learn more about our privacy procedures.
 

COOKIES AND WEB BEACONS

Like any other website, Koomby uses 'cookies'. These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.

Koomby only uses its own cookies, these are used on our platform for certain configurations such as:

USER PREFERENCES
- Language preferences
- Safe search preferences
- Theme preferences

ADVERTISING
- Show ad in your geographical area
- Ad content preferences

ANALYTICS
- Improve the service
- Detect failures in our systems
- Optimization of our web traffic
- Help developers optimize their websites

All the cookies that Koomby uses are designed by our experts to prevent any type of user tracking and are compliant with the GDPR. Learn more on our Cookies Policy.
 

OUR ADVERTISING PRIVACY

Some of advertisers on our site may use cookies and web beacons. Our advertising partners are listed below. Each of our advertising partners has their own Privacy Policy for their policies on user data. For easier access, we hyperlinked to their Privacy Policies below.

ADVERTISING PARTNERS PRIVACY POLICIES

You may consult this list to find the Privacy Policy for each of the advertising partners of Koomby.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Koomby, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

Note that Koomby has no access to or control over these cookies that are used by third-party advertisers.
 

THIRD PARTY PRIVACY POLICIES

Koomby's Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.

Payments for the services offered by Koomby are processed by our partners PayPal, Stripe, Coinbase. All payments are made directly from our website in Euros.

Koomby does not have access to your payment data, these are processed by payment providers and stored in accordance with their policies, which you can check here:

CCPA PRIVACY RIGHTS (Do Not Sell My Personal Information)

Under the CCPA, among other rights, California consumers have the right to:

Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.

Request that a business delete any personal data about the consumer that a business has collected.

Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
 

GDPR DATA PROTECTION RIGHTS

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
 

CHILDREN'S INFORMATION

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Koomby does not knowingly collect any Personal Identifiable Information from children under the age of 16. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
 

PROTECTING PERSONAL DATA

We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. Those safeguards include: (i) the encryption of personal data where we deem appropriate; (ii) taking steps to ensure personal data is backed up and remains available in the event of a security incident; and (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards.

However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.
 

RETENTION OF PERSONAL DATA

We retain personal data for a period of six (6) months after a user closes their account, and certain personal data for longer periods to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties. Under applicable law, we are required to retain certain financial information for seven (7) years.
 

APPLICABILITY OF THIS PRIVACY NOTICE

This Privacy Notice is subject to the Terms of Service and Acceptable Use Policy that govern your use of the Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services.

This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.
 

ADDITIONAL INFORMATION AND ASSISTANCE

If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please contact us at privacy@koomby.com.

In addition, we have appointed a data protection officer (“DPO”) who is responsible for, among other things, responding to questions, requests, and concerns in relation to this Privacy Notice and our use of personal data. You may contact the DPO as follows:

Data Protection Officer
dpo@koomby.com

We have also appointed an EU Representative who may be reached as follows:

APPLAY TECH SAS
DPO Rights
10 rue de Penthièvre
75008 Paris (France)
dpo@koomby.com

We hope that we can resolve any query or concern you raise about our use of your information. If not, contact the National Commission for Computing and Liberties at https://www.cnil.fr/en/home or telephone: +33 1 53 73 22 22 for further information about your rights and how to make a formal complaint.