Controller and Joint Controllership
Keeeb is associated with Keeeb Europe GmbH (“Keeeb Europe”) in Germany. For contact details of Keeeb Europe see the information set forth in the “Contact Us” section below regarding the EU Representative.
Keeeb and Keeeb Europe provide development and operation of Keeeb services in common. HR is provided either by Keeeb or Keeeb Europe. Keeeb is responsible for sales and marketing. Keeeb is the owner of the website keeeb.com and additional Keeeb websites.
Keeeb and Keeeb Europe agreed on a Joint Control Agreement to process Personal Data in Joint Control. Each of the entities is primarily responsible for processing data based on contracts of the specific entity with customers, employees or vendors. Data Subjects are advised to address Data Subject Rights to either Keeeb or Keeeb Europe depending on his/her direct business relationship. Nevertheless, each Data Subject is entitled to address his/her Data Subject Rights to any of the Keeeb entities.
Processing of your Personal Data
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing are established by Article 6 para 1 GDPR. They include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the Products) and our “legitimate interests” or the legitimate interest of others (e.g. our users) such as:
Personalizing, improving or operating our Products and business
Better understanding your needs and interests
Fulfilling requests you make related to the Products
Providing you with information and offers from us or third parties
Complying with our legal obligations, resolving disputes with users, enforcing our agreements
Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
We may collect the following categories of Personal Data about you when you use or otherwise interact with our Products:
Home/work/mobile telephone number
Postal or other physical address
SSO profile information (when you use 3rd party services to log-in to our Products or to create an account for our Products)
IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
We process your Personal Data in connection with the below activities related to our Products:
Use of certain Product features
Generating reports based on information collected from use of our Products
Requesting service and support for our Products and providing such support
Registering to attend a seminar or webinar
Participating in an online survey
Billing and collecting payments for our Products
Participating in discussion groups or forums
Registering for newsletter subscriptions
Customizing the advertising and content you see
We process Personal Data for purposes such as:
To process your orders and deliver the Products that you have ordered
To provide reports based on information collected from use of our Products
To keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information
To provide support and assistance for our Products
To provide the ability to create personal profile areas and view protected content
To provide the ability to contact you and provide you with shipping and billing information
To provide customer feedback and support
To provide and administer opt-in contests, sweepstakes or other marketing or promotional activities on the Keeeb or affiliate websites
To the extent you choose to participate, to conduct questionnaires and surveys in order to provide better products and services to our customers and end users
To support recruitment inquiries
To personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest
To meet contract or legal obligations
You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy.
Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.
Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
Right to File Complaint: You have the right to lodge a complaint about Keeeb’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Withdrawal and Objection
● Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Your Withdrawal of Consent does not affect past processing of your Personal Data but requires us to end future processing. If you would like to discontinue receiving electronic marketing communications, you can update your preferences by using the “Unsubscribe” link found in such emails. Withdrawal of any other Consent should be sent to us by using the information in the “Contact Us” section of this policy.
● Objection: You can contact us to let us know that you object to the collection or use of your Personal Data under the lawful basis of legitimate interest due to specific circumstances. If processing under the lawful basis of legitimate interest serves any purpose of direct marketing you can object to this processing without presenting any specific circumstances.
How long we retain your Personal Data depends on the purpose for which we process the data. If processing Personal Data does not serve a legitimate purpose any longer Personal Data needs to be erased. A number of retention periods are established by legislation like tax law or accounting law. Your contract with Keeeb may provide contractual retention periods regarding your Personal Data processed by us.
Keeeb and our third party service providers automatically collect some information about you when you use our Products, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, search terms and search results as processed by our Products, and/or clickstream data to analyze trends in the aggregate and administer the website and/or Products.
In addition, when you use some of our Products, network information is transmitted back to us such as Product usage information. This information is transmitted back to us so we can determine how users are interacting with our Products, to assist us with improving our Products, and to correct any problems that may occur.
Cookies and Tracking Technologies
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Products do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Products and after you leave our properties.
Users residing in the EEA need to agree first to cookies or similar technologies if a cookie or similar technology is not strictly necessary to provide a service requested by the user. Users residing in the EEA will be welcomed by our cookie consent manager to collect required consent in the appropriate manner.
Mobile Application (if applicable)
When you download and use our Products, we automatically collect information on the type of device you use, operating system version, and the device identifier (or ”UDID“). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
Sharing your Personal Data
We do not sell or rent your Personal Data to third parties for marketing purposes unless you have granted us permission to do so.
We share Personal Data within Keeeb, and with third party service providers for purposes of data processing or storage.
We also share Personal Data with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested Products or transactions, including processing orders, processing credit card transactions, hosting websites, hosting event and seminar registration and providing customer support. We provide these third parties with Personal Data to complete/utilize the requested Product or transaction.
Keeeb in its capacity as a Controller agreed on Data Processing Agreements following Article 28 GDPR with all business partners, service vendors and/or authorized third-party agents or contractors who act as a Processor. Keeeb agreed on Joint Control Agreements following Article 26 GDPR with all business partners, service vendors and/or authorized third-party agents or contractors who act as a Joint Controller.
As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.
We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Keeeb’s terms of service, or as otherwise required by law.
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party.
Security of your Personal Data
Keeeb is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer data over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology.
We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us by using the information in the “Contact Us” section of this policy.
Linked websites and third party services
Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.
If you participate in a Keeeb discussion forum or chat room, you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside Keeeb, who have access to that discussion forum or chat room. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. Each participant's opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Keeeb.
Transfer and Storage of Personal Data
Our Products are hosted and operated both in the United States (“U.S.”) and the EU through Keeeb and its service providers. We may transfer your Personal Data to the U.S., to any Keeeb affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our Products or providing any Personal Data for any of the purposes stated above, you are aware of the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.
Keeeb will transfer Personal Data from the EU in accordance with the European Commission-approved Standard Contractual Clauses (“SCC”). When transferring Personal Data from the EU Keeeb acts as a Data Exporter. Keeeb requires all Data Importer associated with Keeeb or Products by Keeeb to agree on SCC.
125 Cambridge Park Dr.
Cambridge, MA 02140
The representative of the Controller in the EU (“Representative”) is:
Keeeb Europe GmbH
Phone: +49 (0) 40 44 55 66