Privacy Policy

INTRODUCTION

This Privacy Policy applies to the manner in which Kozaly (“we”, “us” or “Kozaly”) processes personally identifiable information (“Personal Data” or “Data”) in connection with kozaly.com (“Site” or “kozaly.com”), its visitors, and people who create accounts on the Site (“User Account(s)”). The purpose of this Privacy Policy is to provide these visitors and account holders (“You”) with information about how Kozaly processes personal data, including:
  • - the data we collect;
  • - what we are going to do with it;
  • - the processes we will follow;
  • - and what are Your rights with regard to this Data.

Personal Data will be collected and processed in accordance with applicable national or state legislation and/or regulations, including, but not limited to, the European Union Data Protection Regulation 2016/679 (the “GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”), and the Japanese Personal Information Protection Act (“APPI”).

Changes and Updates


We encourage you to regularly consult this Personal Data Protection Policy to stay informed of any modifications. For important updates, we will notify you via the Site and/or the method You chose during registration or on Your User Account.

DEFINITIONS

This Privacy Policy is part of the General Conditions of Use of kozaly.com. In addition to the capitalized terms in the Terms of Service, there are a few other important terms to this Privacy Policy. You can find the definitions of these terms below:

  • “Applicable data protection regulations” means any law or regulation relating to the processing of Personal Data which applies to the processing by Kozaly of Your Personal Data, in particular the GDPR.
  • “Customer” means a natural or legal person (represented by their legal representative or any other duly authorized person), who accesses or creates a User Account on kozaly.com for the purpose of collecting and analyzing calls or transcriptions of calls.
  • “Processing Controller” means the natural or legal person, public authority, service or other body which determines the purpose of the processing of Personal Data.
  • “Data” or “Personal Data” means any information relating to a natural person, including any information considered to be personal under the applicable Data Protection Regulations and/or any information by which a person can be identified directly or indirectly (for example by reference to a user identifier, an identification number, location data, an online username, or one or more specific elements linked to the physical or health state of a person, their nationality, their cultural or social identity).
  • “Deliverable” means call analysis services ordered by the Customer; “Processing” or “process” means any operation or set of operations carried out by Kozaly concerning Personal Data, such as collection, recording, organization, retention, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection as well as archiving and/or deletion;
  • “Services” means the call analysis services ordered by Customers via Kozaly.com


1. PERSONAL DATA

Kozaly collects different Personal Data depending on how you interact with the Site.

1.1. If you visit kozaly.com


  • 1.1.1. We collect the following Personal Data:
    • Your email address when You subscribe to one of our newsletters or submit a request to us;
    • Audience measurement information, including aggregated visitor region;

  • 1.1.2. Your Personal Data is collected for the following purpose(s):
    • To monitor and improve the performance of kozaly.com (including A/B testing and other similar tests);
    • To measure the number of visitors;
    • To make kozaly.com easy and pleasant to use;
    • To communicate with you regarding Kozaly news, products and/or opportunities;

  • 1.1.3. We process this Data according to the following legal bases:
    • Your consent,
    • Our legitimate interest in improving our site and our services;
    • Our legitimate interest in the operation of the site;
    • Our legitimate interest in monitoring our site for fraud and/or other illegal or impermissible use.


1.2. If You register as a customer on kozaly.com


  • 1.2.1. We collect the following Personal Data:
    • Your identification (e.g. name, first name, e-mail address, login, phone number);
    • Your professional life (e.g. position, company, contact information);

  • 1.2.2. Your Personal Data is collected for the following purpose(s):
    • To create and maintain Your Kozaly user account;
    • To enable you to order Services and Deliverables;
    • To process and fulfill your order for Services and Deliverables;
    • To manage your comments and/or feedback regarding the Deliverables

  • 1.2.3. We process this Data according to the following legal bases:
    • The execution of the contract concluded between You and Kozaly;
    • Our legitimate interest in improving our site and our services;
    • Our legitimate interest in monitoring our site for fraud and/or other illegal or impermissible use.


2. MANDATORY OR OPTIONAL DATA COLLECTION

Kozaly will inform you when you are required to provide certain information, or when it is optional. If the information requested is mandatory, the fields you must complete will be marked as mandatory. For the other fields, it's up to you.

3. INFORMATION WE SHARE

No personal data is disclosed to third parties.

4. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

No data is transferred outside the European Union, and our priority is to use services mainly based in France. Secondary regions used may include Germany and Ireland.

5. DATA RETENTION

The duration of Data retention depends on:
  • - the nature of the Data;
  • - why we process the data (the purpose);
  • - any directive or recommendation from the competent authorities regarding data protection;
  • - any relevant legal obligation(s).
As a general rule, we retain Data for the time necessary and for the purpose for which it was collected. Your Data will then be archived for the applicable legal limitation period in order to enable Kozaly to comply with its legal obligations.


6. DATA SECURITY

Security procedures are in place to protect the confidentiality of your data. We use encryption to protect your information for:
  • - data at rest
  • - data in transit;

Among our security principles and measures:
  • - We store your data in secure datacenters in Paris, France.
  • - We never use your data for any other purpose than giving you feedback on the content
  • - We regularly do internal OWASP scans of our systems
  • - We follow the principle of least priviledge
  • - We follow industry security best practices such as ISO 27001
  • - When needed we use pseudonymization to remove personal identifiers from your data and we replace it with placeholder values


7. DATA & AI MODELS

We don't use any of your data to develop, improve, or train generalized AI and/or ML models. This include any data from the integrations that you might enable such as Google Workspace, Outlook, Hubspot, Aircall.


8. SOCIAL MEDIA AND YOUR CONTENT

Our Site sometimes mentions other Kozaly pages or other Kozaly accounts on social networks. We draw your attention to the fact that the content presented on these platforms can be seen by the public, and that Kozaly cannot be held responsible for the actions taken by third parties if you publish something (including anything that contains Personal Data) on one of our accounts on social networks.

9. HOW TO EXERCISE YOUR RIGHTS OVER YOUR PERSONAL DATA

You have the rights to your Personal Data: access; rectification; deletion; portability; limitation of the processing of Personal Data; opposition; You also have the right to withdraw your consent for any processing activity at any time. In certain cases, particularly in the case where you request access to all of your Personal Data, we may ask you to prove your identity (copy of national identity card or passport). Your identity document will be kept for the time necessary to process your request and then will be permanently deleted. You can exercise your rights by sending a request by email (paul@kozaly.com). Furthermore, you can also submit a complaint to the CNIL:
  • - directly online;
  • - by mail: 3 Place Fontenoy- TSA 80715- 75334 Paris Cedex 07.


10. INFORMATION FROM THE CONTROLLER

9.1. Identity and contact details of the Data Controller:

Personal Data is collected and processed by: The Kozaly company (“KOZALY”) currently being registered in the register.

10. CONTACT US

By email: paul@kozaly.com
For any additional information on the protection of your Personal Data, you can contact us via the site kozaly.com/contact

Last update date: 26/09/2024