Effective Date:December 1, 2024

This Privacy Notice explains how KronML, Inc. and its affiliates (“KronML”, “we”, “our”, and “us”) collect, use, disclose and otherwise process your personal information (also known as personal data) in connection with the use of KronML products and services, including websites, mobile applications, software, cloud-based solutions, and other products and services, that link to this Privacy Notice and in the usual course of business, such as in connection with our events, sales, and marketing activities (collectively, the “Services”). It also contains information about your choices and privacy rights.

California residents should refer to our Supplemental Privacy Notice to California Residents, which outlines your rights concerning your personal information, found below.

Our Services

We provide the Services to our customers and their users (collectively referred to as “Customers”) under the terms of an agreement with them. These services are exclusively for their benefit and the benefit of their authorized personnel (“Authorized Users”). The processing of Customer data is regulated by our agreement with the respective Customer. This Privacy Notice does not apply to: (i) data processed on behalf of Customers where we act as a data processor or service provider, including any data that Customers or their Authorized Users upload, submit, or otherwise make available in connection with the Services, which is covered by our agreement with the Customer; and (ii) any third-party products, services, websites, or content, which are subject to their own privacy policies.

We recommend that you review this Privacy Notice thoroughly to remain fully informed.

Information We Collect About You

Information that we collect from or about you includes information you provide, information we collect automatically, and information we receive from other sources.

Information you provide

When using our Services, we may collect certain information, such as:

• Identifiers: your name, email address, phone number, and postal address to administer your account and provide our Services to you.
• Employment-related information: information about your job title and company name.
• Account information: if you create an account in connection with the Services, we will collect your authentication information used to access the Services.
• Customer service and other interaction information: information that you provide through your interactions with us, for example if you request information about our Services, interact with our sales team or contact customer support, complete a survey, provide feedback or post comments, register for an event, or take part in marketing activities. We may keep a record of your communications with us and other information you disclose during the course of the communications, such as a recording or transcript.
• Commercial information: records of your history of past purchases and transactions with us (e.g., when you signed up for a free trial).
• Audio transcripts and audiovisual recordings: audio transcripts and audiovisual recordings when you communicate with us in person or on calls.
• Financial information: your credit card or other form of financial account information if chosen by you as a payment method, which may be collected by or disclosed to our third-party payment and billing service providers.

Information posted in public forums

Some features within our Services offer the ability to share content that may be visible to others, such as in public forums. Any information shared in this manner will be accessible to and usable by other users.

Information we collect automatically

Various automated data collection tools are employed, including cookies, web beacons, tracking pixels, tags, and similar technologies, to gather details about user interaction with our Services and emails.

For instance, during a visit to any website or mobile application that comprise the Services, certain data may be gathered from the user or their device. This can involve details like the operating system, device identifier, browser language, and Internet Protocol (IP) address, along with information regarding user activities on such websites or mobile applications, such as navigation patterns, access times, clicked links, browsing behavior, and other statistical data, including cursor movements. Such data helps improve the understanding of how the Services are used and allows functionality enhancements. Additionally, pixels and web beacons may be incorporated into emails to track engagement, such as when a link in the email is clicked. IP addresses may also be used to estimate general location information.

When accessing our Services, data on user interactions within our platform (“Usage Data“) is collected. While the majority of Usage Data does not include personal information, it could still involve account-related details like User ID, email, IP address, and device or browser specifications (e.g., browser type, operating system). Usage Data also captures user behavior, including visited pages, accessed features, time spent, search terms, executed commands, and details about the types and sizes of files processed in connection with the Services. This data is used to support, operate, and secure our platform, as well as to improve its functionality by better understanding how it’s being used.

Automatically collected data (such as IP addresses or unique device identifiers) may be combined with other information gathered from interactions with the Services or other sources, enabling the identification of a single user across different Services, resulting in a more cohesive and personalized experience.

The specific tools for data collection may evolve over time, reflecting advancements in technology. Additional details on cookie usage and similar technologies, including opt-out options, are available in our Cookie Notice.

Information we receive from other sources

We may gather information about you from various third-party sources, such as resellers, distributors, business partners, event sponsors, security and fraud prevention services, social media platforms, and publicly available databases. This may include details like marketing and sales data (e.g., your name, email address, phone number, and other contact information), along with records related to purchases, support interactions, and your overall use of our Services. Such data may be combined with the information we collect directly from you.

How We Use Your Information

We use your personal information to provide, maintain, improve and update our Services.

The reasons for collecting your personal information include:

• To Provide the Services:
  • to deliver, maintain, and improve the Services;
  • to create and manage your KronML account;
  • for billing, payments, and account management, such as ensuring accurate identification of your account and proper tracking of your product and service usage;
  • to enroll you in and facilitate training and certification programs; and
  • to offer you customer service and technical support.

• Sales and Marketing:
  • for sales calls aimed at training, coaching, quality control, and administrative purposes (in compliance with applicable laws), including analyzing sales interactions using analytics tools to gain insights into customer engagement; and
  • to customize and send newsletters, emails, and other promotional materials about our Services (you may opt out of marketing emails at any time by emailing us at privacy@KronML.com), and to enable our third-party partners (such as event sponsors) to send you promotional communications based on your preferences.

• To Communicate with You:
  • to provide notifications about the Services, including technical updates, security alerts, administrative messages, and invoices;
  • to respond to your inquiries, comments, and requests, and to stay in touch regarding the Services you use; and
  • to contact you for surveys, feedback, audits, or market research purposes.

• Online Advertising:
  • for online advertising purposes, such as displaying and measuring ads on third-party websites.

• Personalization and Service Improvement
  • to personalize your experience with the Services;
  • to evaluate usage and improve Services, as well as to create new products and services; and
  • to generate and analyze aggregate statistics on how our Services are being used.

• Legal and Security Purposes
  • to investigate security issues, prevent fraud, and address illegal or unauthorized uses of our Services, including those in our learning and certification programs; and
  • to comply with legal obligations, legal processes, or government regulations.

• With Your Consent:
  • we may also use your information for other purposes when you have provided consent.

De-Identified/Anonymized Information. We may take steps to de-identify or anonymize the information we collect so that it can no longer be reasonably linked to you or your device. Alternatively, we may gather information that is already in a de-identified or anonymized form. Unless restricted by applicable law, the use and disclosure of de-identified and anonymized information are not governed by this Privacy Notice. We may use and share this information freely and for any purpose, without limitations.

How We Disclose Your Information

We may share your personal information with third parties in the following circumstances:

• Affiliates: with our affiliates and subsidiaries for the purposes outlined in this Privacy Notice.

• Service Providers: with service providers who assist us in delivering the Services, including billing, payment card processing, customer support, sales, marketing, and data analysis. These providers are subject to contractual restrictions preventing the misuse of your information. We may also share data with service providers who help in detecting and preventing fraud, security threats, or other harmful, illegal, or malicious behavior.

• Third-Party Partners and Sponsors: with third-party business partners, such as resellers, distributors, and referral partners, who help provide content, products, or services to our prospects or Customers. Additionally, we may share information with partners involved in organizing or sponsoring an event you’ve registered for, to enable them to reach out to you regarding the event or their services (only where lawful, such as with your consent where required).

• Online Advertising Partners: with online advertising providers that use information about your online behavior across different services to tailor ads to your interests (also known as targeted online advertising).

• Sponsoring Organizations: with the organization sponsoring a training or certification program you’re enrolled in through the Services (e.g., your employer), to inform them of your registration and completion of the program.

• For Legal Purposes: when authorized by law or we deem necessary in good faith to comply with legal process; when required to protect and defend the rights or property of KronML or our Customers, including the security of our websites, mobile applications or other Services; or when necessary to protect the personal safety, property or other rights of the public, KronML or our Customers;

• With Your Consent: when you instruct us to do so or when you’ve provided consent to share your information with third parties.

• Business Transactions: in the event of business activities, such as a merger or the sale of assets or parts of our business, we may share your information as part of, or in anticipation of, such transactions, including with counterparties to such transactions. If some or all of our assets are transferred to, or otherwise controlled by, a third party or counterparty in connection with these transactions, your information may be part of the transferred assets, including during preparatory steps.

International Users and Transfers

KronML may transfer your personal information to countries outside your country of residence. Specifically, we may transfer your data to the United States and other locations where our affiliates, business partners, and service providers operate. These countries may have different data protection laws from those in your own country.

Wherever your personal information is processed, we implement safeguards to ensure its protection in line with this Privacy Notice and applicable data protection regulations. Additionally, KronML offers Customers the option to enter into a data processing addendum (DPA), which includes standard contractual clauses for transfers between us and our Customers. We also apply supplementary measures to further ensure the security of your information.

Your Choices and Rights

We provide you with options regarding how your personal information is collected, used, and shared, and we will honor your preferences in line with applicable law. Please note that if you choose not to provide certain personal information, it may limit your ability to access specific features of our Services.

Account information

If you wish to correct, update, or delete your account details, please log in to your KronML account and make the necessary changes to your profile.

Opt-out of Marketing

We may occasionally send you marketing communications to inform you about our Services, in line with your preferences. You can opt out of these communications by emailing us at privacy@KronML.com. Please note that it may take some time to process your request in accordance with applicable law. However, we may still send you essential service-related messages regarding your account, subscription, or important updates, such as service announcements or security notifications.

Your Privacy Rights

Depending on your place of residence, you may have certain rights concerning your personal information. These rights, as outlined in applicable data protection laws, may include the ability to:

• Request access to, or a copy of, your information (where feasible, in a portable, machine-readable format).
• Confirm whether we are processing your information.
• Request corrections or amendments to your information.
• Ask for the deletion of your information.
• Request the transfer of your information to a third party.
• Restrict or object to specific uses of your information.
• Withdraw consent for processing your information when it was initially based on your consent.
• Opt-out of the processing of your personal information for profiling that may result in decisions with legal or similar significant effects, if applicable.

If you (or an authorized agent acting on your behalf) would like to exercise any of your rights under applicable data protection laws, you can contact us at privacy@KronML.com. We will respond to requests in accordance with applicable laws. KronML may take steps to verify your request by using information we have on file, such as your email address or other details linked to your KronML account. If needed, we may ask for additional information to verify your identity. Any information provided for verification will only be used to process and maintain a record of your request. Depending on the relevant laws, if you are not satisfied with our response, you may have the right to appeal. If this applies to your situation, we will include this information in our response.

As mentioned above, we may also process personal information that has been provided by a Customer in connection with the Services. If your personal information has been submitted  in connection with the Services by or on behalf of a KronML Customer and you wish to exercise your privacy rights, please direct your request to the relevant Customer.

Notice of Right to Opt Out of Data “Sales” and “Targeted Advertising”

Depending on where you are located, you may have the right to opt out of the “sale” of your personal information or the sharing of your data for purposes of targeted online advertising (more details on our online advertising practices can be found in our Cookies Notice). While we do not “sell” personal information in the traditional sense—i.e., exchanging information for monetary compensation—the legal definitions of “sale” and “targeted advertising” may include the sharing of your data with certain advertising and marketing partners. Therefore, we offer the option to opt out of these activities.

To opt out of “sale” or “sharing” activities, please use the provided contact us at privacy@KronML.com. We do not knowingly “sell” or “share” the personal information of individuals under the age of 16.

Other Important Information

Notice to Authorized Users

Our Services are designed for use by organizations. If you are accessing the Services through an organization (such as your employer), that organization acts as the administrator and is responsible for managing the accounts and services under its control. For example, administrators may access and modify your account information, or limit or revoke your access to the Services. We are not responsible for the privacy or security practices of the administrator’s organization, which may differ from this Privacy Notice. For further details, please refer to your organization’s policies or contact them directly.

Data Retention

KronML retains the personal information described in this Privacy Notice for as long as you use our Services, as may be required by law (for example, to comply with applicable legal tax or accounting requirements), as necessary for other legitimate business or commercial purposes described in this Privacy Notice (for example, to resolve disputes or enforce our agreements), or as otherwise communicated to you.

Security

We are dedicated to safeguarding your information. A range of technical, physical, and organizational security measures are in place to protect against unauthorized access, modification, disclosure, or destruction of your data. However, no security measures are completely perfect or impenetrable, and as a result, we cannot guarantee the absolute security of your information.

Third Party Services

Our Services may include links to third-party websites, applications, services, or social networks (including co-branded websites or products managed by one of our business partners). Additionally, certain features may allow you to log in to our websites, mobile applications, or other Services using third-party credentials (such as LinkedIn, Facebook, Twitter, or Google+) or access third-party services through our Services (such as GitHub). Any information you choose to share with these third-party services is not governed by this Privacy Notice. We encourage you to review the terms of use and privacy policies of these third-party services before providing them with your information to understand how your data may be collected and used.

Children’s Data

The Services are not intended for children under the age of 18, and KronML does not knowingly collect personal information from anyone under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete the data. If you become aware that a child has provided us with such information, please contact us using the details provided below.

Changes to this Privacy Notice

KronML may change this Privacy Notice from time to time. We will post any changes on this page and, if we make material changes, provide a more prominent notice (for example, by adding a statement to the website landing page, providing notice through the Services login screen, or by emailing you). You can see the effective date on which the latest version of this Privacy Notice was posted above. If you disagree with any changes to this Privacy Notice, you should stop using the Services and deactivate your KronML account.

How to Contact Us

Please contact us at privacy@KronML.com if you have any questions about our privacy practices or this Privacy Notice. If you interact with KronML through or on behalf of your organization, then your personal information may also be subject to your organization’s privacy practices and you should direct any questions to that organization.

Supplemental Privacy Notice for California Residents

We offer the following details to California residents in accordance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). This information serves as a supplement to our general Privacy Notice. For a full overview of how we collect, use, and disclose data, please refer to our complete Privacy Notice above. Any capitalized terms that are not defined here carry the same meanings as outlined in our Privacy Notice.

Categories of Personal Information

Below, we outline the categories of Personal Information (as defined under the CCPA) that we have collected over the past 12 months and may continue to collect in the future:

• Identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., name, address, email address).
• Characteristics of protected classifications under California or federal law.
• Commercial information (e.g., transaction data).
• Internet or other similar network activity.
• Geolocation data (e.g., general location derived from an IP address).
• Sensory data (e.g., audio, video).
• Professional or employment-related information.
• Education information.
• Inferences drawn from the preceding categories of Personal Information.

Within these categories of Personal Information, we may also gather certain types of Sensitive Personal Information (as defined by the CCPA), such as account login details, financial account numbers, debit or credit card numbers, along with any required security or access codes, passwords, or credentials needed to access the account.

Categories of Recipients of Personal Information

For each category of Personal Information (including Sensitive Personal Information) mentioned above, we disclose this data as described in the “How We Share Your Information” section of our Privacy Notice above. Additionally, we share Identifiers and Internet or other network activity with advertising partners that customize online ads based on information gathered about your online behavior (commonly known as interest-based advertising).

Sources of Personal Information

We collect the categories of Personal Information listed above directly from you or from the devices you use to access our Services. We also gather this information from the following sources: our corporate affiliates, publicly available databases, third-party business partners, social media platforms, and other external sources, as further described in the “Information We Collect About You” section of the Privacy Notice above.

Purposes for Which We Use Personal Information

We use Personal Information for various business and commercial purposes, as outlined in the “How We Use Your Information” section of our Privacy Notice above.

Retention Period Criteria

KronML retains the Personal Information described above for as long as you continue to use our Services, as required by law (for instance, to meet legal tax or accounting obligations), or as necessary for other legitimate business or commercial purposes outlined in our Privacy Notice (such as resolving disputes or enforcing our agreements), or as communicated to you.

CCPA Rights and Requests

Under the CCPA, you can make certain types of requests regarding the Personal Information that we process on our own behalf. Please note: if you wish to make a CCPA request regarding Personal Information that has been submitted through or made available in connection with the Services, you should direct your request to the relevant Customer, as this data is governed by the terms of our agreement with them.

Requests to Know, Correct, and Delete: You may request:

(i) Access to a copy of the specific pieces of Personal Information that we have collected about you;

(ii) Correction of Personal Information that we maintain about you, if it is inaccurate; and/or

(iii) Deletion of Personal Information, subject to certain exceptions.

You can submit a request by emailing us at privacy@KronML.com. We will respond in accordance with the CCPA, subject to any applicable exceptions. To verify your identity and prevent fraudulent requests, we may need additional Personal Information, such as your email address, state of residence, or mailing address. If you have a password-protected account with us, we may verify your identity using our current authentication practices and require you to re-authenticate before disclosing or deleting your Personal Information.

Requests to Opt-Out of Sale or Sharing: You also may opt out of the “sale” or “sharing” of your Personal Information, as “sale” and “sharing” are defined under CCPA.

We do not sell Personal Information in the traditional sense of exchanging it for monetary compensation. However, under the CCPA, the terms “sale” and “sharing” may include disclosing your information to certain advertising and marketing partners. To comply with this definition, we provide California residents with the right to opt out of any such sale or sharing of their Personal Information. As specified earlier, we may disclose or make available Identifiers or Internet and other similar activity to advertising partners, which could be considered a “sale” or “sharing” under the CCPA. We do not knowingly “sell” or “share” the Personal Information of individuals under 16 years old.

You may opt out of the sale or sharing of Personal Information for purposes of online analytics and advertising by emailing us at privacy@KronML.com. We also honor opt-out preference signals as required by the CCPA.

Authorized Agents

If you are an authorized agent submitting a request on behalf of a California resident, you may use the submission methods outlined above. As part of our verification process, we may ask for proof to confirm your status as an authorized agent.

For Requests to Know, Correct, or Delete made on behalf of a California resident without a valid power of attorney, we may require the resident to directly verify their identity with us or confirm that they have given you permission to submit the request.

Nondiscrimination

You have the right to be free from unlawful discriminatory treatment for exercising any of your CCPA rights.

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