Effective date: 15 June 2022
This Privacy Policy explains:
How we collect, share, use, retain, analyze and delete your personal data,
What legal bases we rely on to process your personal data,
What legal rights you have over your personal data and how you can exercise these rights.
This Privacy Policy, alongside Our Cookie Policy, explains how we handle your personal data. These two Policies are inseparable and should be construed accordingly.
For any term not defined in this Privacy policy, the definitions set out in the Terms & Conditions shall apply.
WHEN DOES THIS PRIVACY POLICY APPLY?
This Privacy Policy applies when:
You visit and interact with our Website and Platform
You create an Account on our Platform and use our Platform Services
You purchase Services from third parties on our Platform
You order Services from Us such as when You subscribe to our Platform Services
You contact or engage with Us
WHO SHOULD READ THIS PRIVACY POLICY?
We collect and process personal data about:
Any individual who visits or browses through our Website and Platform Services,
Our Clients who create an account on our Platform and who use our Platform Services
Customers who purchase services from our Clients via our Platform
Individuals such as employees and contractors who create and use an Account on our Platform on behalf of another business.
WHO IS DATA CONTROLLER?
Launcbase Inc., a Delaware-based company, owner and operator of the “Kiwilaunch” brand (hereinafter referred to as "We/Us") provides a web-based Platform, and various website functionalities. It also allows its Clients (hereinafter referred to as “You”) to manage and receive bookings, customers, services, and staff via web-based tools.
How to Contact Us
Business Name: Launchbase Inc.
Website: https://kiwilaunch.com/
Business Address: Launchbase Inc.
600 N Broad Street
Suite 5 # 543
Middletown DE 19709 USA
Business email: support@kiwilaunch.com
DEFINITIONS
“Data Processor” means an entity that processes Personal Data on Our behalf,
“Personal data” means any piece of information that relates to an identified or identifiable individual (also as defined under the UK GDPR),
“Platform” means the software platform provided by Us,
“Platform Services” means the software-related services provided by Us to our Clients,
“Us” / “We” / “Data Controller” means Launchbase Inc. as defined in Section 3.
“Website” means https://kiwilaunch.com/
“User Account” means the account that enables Clients to access and use our Platform Services,
“User” & “Client”, “You” mean any person whose personal data We process as defined in Section 2 of this Privacy Policy.
For any term not defined in this Privacy policy, the definitions set out in the Terms & Conditions shall apply.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
Basic personal details
When you create a User Account on our Platform and use our Platform Services, we collect personal data about you such as:
Your name & surname,
Billing address,
Phone number,
Email address,
The business You represent or work for,
Your location or country of residence.
Data about Your browsing activities on our Website and our Platform
When you visit, interact with and use our Website and our Platform Services, we collect and process data about how You use and interact with Our Website and Platform Services and use this data for different purposes as described in Section 6.
For example, we collect data about:
Pages you viewed, the length of your visit on each page, and how you interacted such as your click records and Services you viewed, scrolling,
Previous URLs you visited, and from which source you arrived on our Website (Google search, ads or social media, etc)
We may use a variety of technologies such as tracking cookies, third-party analytics tools, social media plugins, and web beacons to collect such data.
For more details, please refer to Our Cookie Policy.
Personal data we collect about your device
By using a variety of technologies such as tracking cookies, third-party analytics tools, social media plugins, and web beacons, we also collect data about your device such as
Your IP address,
Your operating system,
Information about your devices such as your device ID, device model, browser type and your language settings
For more details, please refer to Our Cookie Policy.
Financial Data
When You subscribe to our Platform Services when You complete a transaction via our platform Services, we collect personal data about you such as:
Credit/debit card number
CVV number
card expiration date
Bank account details
Billing address
Card Brand
For more information about collection and processing of your financial data, please refer to Section 13.
HOW DO WE COLLECT YOUR PERSONAL DATA
We collect your personal data through the following ways:
Data You disclose to Us
When You create a User Account on Our Platform, when You purchase Services from third parties, when you contact us, or When You make a payment such as paying subscription fees to use our Services, You voluntarily provide Your personal data.
For example, when you subscribe to our Platform Services, you provide your financial details such as your credit card/debit card number, CVC code, and information about your card issuer.
When You create an Account, You provide us with your name, surname, billing address, and email address.
Data We automatically collect about you
We use a variety of technologies such as cookies, analytics tools, and web beacons to automatically collect information about how you browse our Website.
For example, we use Google Analytics to collect information about your behaviorbehavior across our Website, your browser type and your operating system, and your device ID.
HOW DO WE USE YOUR PERSONAL DATA?
We collect, use and process your personal data to achieve the following purposes:
To perform Our contractual obligations
We collect, use or share your personal data to fulfill our contractual obligations:
To allow you to access and use the Website and Platform Services:
When You create a User Account, You provide Us with your basic details such as name, surname, and the organization you represent.
To process Payment:
We collect data such as your card number, CVC/CVV number, and your billing address to allow you to purchase Services on our Platform and subscribe to our Services.
Customer Support:
To respond to your queries and to provide you with customer support.
User authentication:
We may process your personal data to verify that you are authorized to register and use an Account on behalf of a third-party business.
Maintain, improve and develop Services
We also collect and use your personal data for the following purposes:
To improve our Website, Platform, its content, and features
To maintain our Website, platform, and Content
To develop and offer new services
To carry out our quality control activities
Performance measurement and data analytics purposes
We also use personal data for following purposes:
To measure engagement with our Website, Platform, and Content
To better understand user behavior patterns across our Website and Platform and how our Platform and Website is used
To gain a better understanding of the profile of our Platform users and website visitors. For example, we may collect demographic information about our users.
We use various technologies to process your data for these purposes, including third-party cookies and other tools.
For example, we use Google Analytics to measure the performance of our Website and Content.
Please refer to our Cookies Policy to learn more about how we use these technologies for these purposes.
To prevent fraud and to comply with applicable laws and regulations
We may collect, process, or share your data such as your financial data and data related to your transactions and purchases to comply with applicable laws and regulations and to prevent fraudulent activities.
To carry out direct marketing activities
We may use your email address to send you marketing and promotional materials.
Ad personalization
We may use your personal data to tailor ads to you. For UK based clients we shall obtain your consent in compliance with Article 6 of the UK GDPR to tailor such ads to you.
WHAT LEGAL BASES DO WE RELY ON TO COLLECT AND USE YOUR PERSONAL DATA?
If you are a UK based client, we must identify and document a legal basis to process your personal data as per article 6 of the UK GDPR.
For such cases, we rely on the following legal basis under the UK GDPR to process your personal data.
Consent
When we process your personal data in the following ways, we rely on your consent as set out in article 6.1. (a) of the UK GDPR:
When We use cookies and other similar technologies other than those strictly necessary cookies. (Visit our cookie policy to learn more)
When we use your data for analytics, performance measurement, ad personalization, email marketing, and remarketing purposes.
When we run targeted ads on Facebook by using your email address, we rely on your consent.
Legitimate Interests
Legitimate Interests basis on article 6.1. (b) of the UK GDPR justifies our collection and processing of your data for the following:
Storage of strictly necessary cookies on your device.
Collection and use your personal data to carry out B2B marketing activities such as email marketing.
Prevention of fraudulent activities.
Contractual Necessity
When we collect, use, share, or otherwise process your personal data to fulfill our contractual obligations, we rely on “contractual necessity” ground under the GDPR.
This includes;
Collecting financial data to process payments.
Basic personal details such as your name and your organization to enable you to create and use a User Account and access and use our Platform Services.
DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
We disclose your personal data to third parties under the following circumstances:
When You consent to the disclosure of your data to third parties such as when you give consent to the use of third-party tracking technologies, cookies.
Where we provide personal data to third parties to perform our contractual obligations and carry out administrative tasks such as payment processing, customer service, email marketing, and web hosting. For a full list of third-party service providers we use, refer to section 15.
Where we are under a legal obligation to share your data with legal/regulatory authorities upon a valid and lawful request or to comply with applicable laws.
To detect and prevent fraud, security, and other technical issues.
DATA RETENTION AND DELETION POLICY
How and where do we store your data?
All data collected is hosted in secure databases and data storage systems with strict access limitations.
All requests for access to data are recorded and reviewed in line with the applicable threat detection and access control policies.
How long do we retain your Personal Data?
We retain each category of personal data for different periods of time depending on the type of data, the legal basis we rely on, and the purposes for which the data is used.
We only retain your personal data for so long as it is strictly necessary for the purpose we pursue.
For example, we retain financial records for the time periods set by applicable tax laws.
To learn more about how long we retain each category of data and why, email us at: support@kiwilaunch.com
When we no longer need to retain your data, we may use one of the following to delete it:
Erasure
Overwriting data
Deletion/Reformatting
INTERNATIONAL DATA TRANSFERS
Your personal data may be processed or stored in one of the following countries:
If you are a UK based client, and your personal data is transferred outside the UK to a non-adequate country, we rely on the 2010 SCCs approved by the EU Commission, by the Commission Decision 2010/87/ on 5 February 2010 in accordance with article 46(2) of the UK GDPR.
You can access the 2010 SCCs at:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087
HOW DO WE COLLECT AND PROCESS YOUR PAYMENT DATA
When you make a payment via our Platform, Your financial data such as your credit/debit card details will be shared with our payment-service providers that will process payments.
Please be noted that your financial details may be further processed by the payment processors we use and you should refer to these processors’ Privacy Policy for further information about what types of data are collected and how they can be used.
We use the following payment processors:
Stripe
To learn more about how your data is processed by Stripe, refer to Stripe’s privacy Policy at:
Apple Pay
To learn more about how your data is processed via Apple Pay, refer to Apple’s Privacy Policy at:
If you reside in the US : https://www.apple.com/legal/privacy/data/en/apple-pay/
If you reside in the UK:https://www.apple.com/uk/legal/privacy/data/en/apple-pay/
For a more detailed overview of Apple Pay and privacy, refer to this article:
https://support.apple.com/en-gb/HT203027
Google Pay
To learn more about how your data is processed through Google Pay, refer to Google’s Privacy Policy at:
YOUR STATUTORY RIGHTS UNDER THE GDPR
If you reside in the UK, you can exercise the following rights:
Right of Access: You may request to see and get copies of the personal data we hold about you and You may also submit a request to confirm we process your data;
Right to rectification: You may request the correction of any inaccuracies in the personal data that we have about you;
Right to Be Forgotten: Under the UK GDPR, you may exercise your right to be forgotten (have your personal data erased) under certain circumstances subject to limitations;
Right to Restriction: You may submit a request to restrict the processing of your personal data. For instance, You may raise objections in relation to the accuracy of your personal data.
Right to Object: If we are relying on Legitimate interest under article 6.A. (f) UK GDPR as the lawful ground for data processing; you have the right to object to such processing. After thorough analysis of your objection, we may still continue relying on legitimate interests to process your data if our reliance on this basis is justified.
Right to Data Portability: To the extent it is applicable, you have the right to ask for your personal data to be transferred to another organization.
HOW TO EXERCISE YOUR RIGHTS
You can contact us via the following ways to submit a request to exercise your rights described in Section 10.
Submission by post:
Business Address: Launchbase Inc.
600 N Broad Street
Suite 5 # 543
Middletown DE 19709 USA
Submission via email:
Business email: support@kiwilaunch.com
HOW TO LODGE A COMPLAINT WITH DATA PROTECTION AUTHORITIES
If you reside in the UK, you can lodge a complaint with the UK Data Protection Authority(ICO) via the following ways:
Submission by Post:
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline Number
Helpline number: 0303 123 1113
ICO Website
ICO website: https://www.ico.org.uk
THIRD-PARTY SERVICE PROVIDERS
We use third-party service providers to carry out various business activities such as processing of payments and provision of our Website and our Platform.
THIRD-PARTY SERVICE PROVIDER DETAILS | FOR WHAT PURPOSES DO WE USE THİS PROVIDER? |
Mailchimp | Email marketing |
Sendgrid | Email Marketing |
Twilio | SMS |
Google Analytics | Website analytics |
Stripe | Payments |
AWS | Cloud service, hosting, data storage |
Newrelic | Error logging |
To learn more about the third-party service providers we use, please email us at: support@kiwilaunch.com
SOCIAL MEDIA AND YOUTUBE PLUGINS
We embed the following social media plugins on our Website:
Twitter plugin
The "Twitter Share Button", which is recognisable by the symbol of a blue bird, enables You to share a post or page on Twitter or to follow Our Twitter page on Twitter.
Furthermore, it also enables Twitter to track You by assigning You a specific ID.
To find out more about how this button collects your data and how Twitter may use your data, read Twitter’s Privacy Policy at:
Use of Linkedin plugin
The "Linkedin Button", which is recognisable by the Linkedin logo, enables You to visit our Linkedin page and share or like our content on your Linkedin profile.
Furthermore, it also Enables the Linkedin to track You by assigning You a specific ID.
To find out more about how this button collects your data and how Linkedin may use your data, read Linkedin’s Privacy Policy at:
https://www.linkedin.com/legal/privacy-policy
Facebook Like & Share Widget
Facebook Like and Share buttons provided on our Website enable You to view and subsequently ‘Like’ our Facebook Page.
This button may collect personal data about You such as Your IP address and your browsing activities on our Website. Furthermore, it can combine this data with the data it already holds about You.
To learn more about how Facebook may collect and use your data, refer to the Facebook’s Privacy Policy at:
https://www.facebook.com/policy.php
Youtube plugin
Our website uses plugins from YouTube, which is operated by YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066, USA.
If you BROWSE one of our web pages containing a YouTube plugin, we will ask for your consent to view YouTube content. Once you provide your consent, information about your visit and your engagement with the Youtube plugin will be sent to Youtube.
By interacting with the Youtube button and Youtube videos, you give your consent to the collection and use of your personal data in accordance with the Privacy Policy of Google and Youtube.
https://www.youtube.com/intl/ALL_uk/howyoutubeworks/our-commitments/protecting-user-data/
https://policies.google.com/privacy?hl=en-US
We use the Youtube plugin on our Website in the privacy-enhanced mode and this plugin is not activated until You provide your consent.
To learn more about the privacy-enhanced mode, please visit the following pages:
https://support.google.com/youtube/answer/171780?hl=en-GB
https://policies.google.com/privacy?hl=en-GB
What personal data may be collected via these social media plugins and Youtube plugins?
IP address and your Device ID;
Technical data about your operating system
Geo-location data
If you are logged into the respective service, your user ID
Previous web pages you visited(if you landed on our Website by following a link)
Your browser settings such as language preferences
URL of the page the social media plugin is integrated into
The date and time of your visit
DATA SECURITY
We implement appropriate security measures to ensure the security of your personal data.
To get more information about the security measures we implement, contact us at support@kiwilaunch.com
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy at our sole discretion at any time.
When our Privacy Policy is updated, We will display the important changes on a prominent banner on our website and We will notify users via email.
DATA PROCESSING AGREEMENT ADDENDUM
(Effective date: 10 Feb 2024)
This Data Processing Agreement Addendum ("Addendum") is entered into between Launchbase Inc., a company duly incorporated under the laws of Delaware, USA, with its registered address at 600 N Broad Street, Suite 5 # 543, Middletown DE 19709, USA ("Launchbase Inc."), and its clients utilizing its online booking Software-as-a-Service (SaaS) solution ("Client").
Definitions
For the purposes of this Addendum, the terms shall have the meanings ascribed to them in the underlying Terms of Service or as follows:
Data Controller: Launchbase Inc., the entity that determines the purposes and means of the processing of personal data.
Data Processor: Launchbase Inc., the entity that processes personal data on behalf of the Data Controller.
Personal Data: Any information relating to an identified or identifiable natural person.
Scope of Agreement
This Addendum governs the processing of personal data by Launchbase Inc. on behalf of its Client, specifically pertaining to the provision of kiwilaunch, the online booking SaaS solution.
Data Processing Activities
Launchbase Inc. processes personal data provided by its Clients, including but not limited to, contact information, emails, staff information, internal notes, calendar events, and personal data of their customers, including emails, phone numbers, full names, booked services, and addresses for at-home services.
Data Protection Measures
Launchbase Inc. shall implement appropriate technical and organizational measures to ensure the security, confidentiality, integrity, and availability of the personal data processed in accordance with applicable data protection laws and regulations.
Data Transfers
Launchbase Inc. shall only transfer personal data to third-party processors or subprocessors with the prior written consent of the Client and in compliance with applicable data protection laws and regulations.
Subcontractors
Launchbase Inc. may engage subcontractors for the provision of the services, provided that such subcontractors agree to adhere to data protection obligations consistent with those set forth in this Addendum. The following subprocessors are engaged:
Amazon AWS: Core provider of cloud services to facilitate the provision of the services.
SendGrid and Twilio: For the sending of transactional SMS and emails.
Google Calendar: Providing calendar management services via integrations.
Sentry and New Relic: Personal data may be processed when necessary to log errors.
Intercom: Personal data may be processed to enable the help center and in-app messenger.
Stripe: Personal data maybe processed to facilitate payments.
Data Subject Rights
Data subjects shall have the right to request the erasure of their personal data processed by Launchbase Inc. Such requests shall be forwarded by the Client to Launchbase Inc., who shall promptly respond in accordance with applicable data protection laws and regulations.
Data Breach Notification
Launchbase Inc. shall notify the Client without undue delay upon becoming aware of any personal data breach affecting the personal data processed under this Addendum, and shall cooperate with the Client in the investigation and remediation of such breach.
Data Retention and Deletion
Personal data processed by Launchbase Inc. shall be retained for a period of two years following the deactivation of the Client's account. Upon the expiry of this retention period, Launchbase Inc. shall either delete or anonymize the personal data in accordance with the UK GDPR instructions.
Compliance with Laws
Launchbase Inc. shall comply with all applicable data protection laws and regulations, including but not limited to, the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018, with respect to the processing of personal data of UK and EU residents.
Indemnification
Launchbase Inc. shall indemnify, defend, and hold harmless the Client from and against any and all claims, damages, losses, liabilities, and expenses arising out of or resulting from any breach of this Addendum by Launchbase Inc. Launchbase Inc. shall further indemnify itself against any claims, damages, losses, liabilities, and expenses arising from the Client's breach of GDPR laws and violation of the rights of the data subject.
Governing Law and Jurisdiction
This Addendum shall be governed by and construed in accordance with the laws of the United Kingdom. Any disputes arising out of or in connection with this Addendum shall be subject to the exclusive jurisdiction of the courts of the United Kingdom.
COOKIE POLICY
This Cookie Policy ("Policy") explains how Launchbase Inc. ("we", "us", or "our") uses cookies and similar technologies when you visit our website [insert website URL] ("Website"). By using our Website, you agree to the use of cookies and similar technologies as described in this Policy.
What are Cookies?
Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work more efficiently and to provide information to the owners of the site.
Types of Cookies We Use
Essential Cookies: These cookies are necessary for the operation of our Website. They include cookies that enable you to log into secure areas of our Website, use a shopping cart. use the in-app messenger and help center, or make use of e-billing services.
Analytical/Performance Cookies: These cookies allow us to recognize 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 cookies are used to recognize you when you return to our Website. This enables us to personalize 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.
Third-Party Cookies
Some cookies may be placed by third-party services that appear on our Website. These third parties may use cookies in accordance with their own privacy policies. We do not have control over these cookies.
How to Control Cookies
You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.
Changes to This Policy
We may update this Policy from time to time. Any changes we make to our Cookie Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Cookie Policy.
HOW TO CONTACT US
Business Name: Launchbase Inc.
Website: https://kiwilaunch.com/
Business Address: Launchbase Inc.
600 N Broad Street
Suite 5 # 543
Middletown DE 19709 USA
Business email: support@kiwilaunch.com