Version 1.1 (May 12, 2021)
We respect the privacy of every person who visits or interacts with our websites and/or the websites of our clients (“Sites”); who uses our applications and/or the applications we build for our clients (“Applications”); and who otherwise utilizes the goods and/or services that we provide (our “Services”). We are committed to ensuring transparency in terms of how we process personal data within our business.
Our Sites and Applications are operated by Kluge Strategic, Inc., (“we”, “us” or “our”).
Kluge Strategic, Inc. is a US company and the data controller responsible for your personal information with its registered address at 4133 Redwood Avenue #4032 Los Angeles, CA 90066.
Our primary goal in collecting personal information from you is to:
In particular, we use your personal information for the following purposes:
We collect and maintain personal information that you voluntarily submit to us by email, or during your use of the Sites, Applications, our products and/or our Services. We use the personal data you provide to us so that we can fulfil the supply of Services you have engaged us to provide. We will also use your data to coordinate your attendance at events hosted by us or our third-party partners, if you have provided it for that purpose.
Sometimes, we may be granted access to certain user data (including personal data) when we help our clients build, maintain and develop their own products, applications or software.
We might share your personal information with the following categories of third parties:
We do not share user data (or other personal data) that we might inadvertently process as part of helping our clients build, maintain and develop their own products, applications or software.
It is necessary for us to use your personal information in this way to perform our obligations in accordance with any contract that we may have with you, or to which the data subject is otherwise a party.
Our Sites feature a “Contact Us” page which invites you to submit general enquiries, media enquiries, and games / ‘Synth Riders’ enquiries. We collect the personal data you submit to us when making your enquiry.
Where you are a prospective client, we may use personal information that you voluntarily submit to us to prepare proposals for your purchase of our Services, to contact you, or otherwise to manage or administer our relationship with you.
We do not actively share your personal information with any third parties, but we do store your data using secure third party servers based in the cloud.
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best client service we can to you.
We may analyze your activity and interactions with the Sites and Applications. We do this either as a way of helping us to improve our own Sites (as a controller), or as part of the services we provide to our clients (as a processor).
Where we process your user data as part of the services we provide to clients, this allows us to advise them on key analytics relating to their websites and apps. This helps our clients tailor projects for your benefit.
Our Sites and emails may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and collect other types of aggregate information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.
In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
This information is used to create profiles and insights about your interaction with the Sites and Applications. Where we have your consent to do so, we may also use your location data for user insight purposes.
By using this information, we are able to measure the effectiveness of content and how visitors use the Sites, Applications and our Services. This allows us to learn what pages of the Sites and Applications are most attractive to visitors, which parts are the most interesting, and what kind of offers registered users like to see.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best services to you and our other customers.
From time to time we will contact you to invite you to provide feedback about our Sites, Products and/or Services in the form of online surveys. Alternatively, you may submit queries or feedback to us via the “Contact Us” section on our Site. We use this information to help us improve the quality of service provided by us. We also use your feedback to monitor the quality of our services and to assist with the selection of future interactive features and service lines.
We often use a third-party service provider to assist us with customer surveys and feedback requests.
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
We carry out the following marketing activities using your personal information:
We may use your personal information to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so. Please let us know if you would like to be added or removed from our mailing list.
Sometimes, as part of the services we are engaged to provide to clients, we advise them on (a) how to capture and store user data from their websites and apps, and (b) how to use this user data to inform their email marketing strategy. We process your personal information in these circumstances as a processor (not a controller).
We share your personal information with a variety of third-party email marketing providers who assist us in delivering our email marketing campaigns to you.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply for with us, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal information to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We may process any personal information about you that you volunteer when you apply for a job with us. We may also process your personal information obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies, your referees and the Disclosure and Barring Service (if applicable).
The personal information we process may include your name and contact information (e.g. email address, postal address, telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae and covering letter, which you volunteer in an application form or during an interview or which is contained in any reference we receive about you. Such information may also include special categories of personal information (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
We may share your personal information with external recruiters or third parties who provide background checks. We may also share your personal information with third parties who assist us with the recruitment process.
Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make appropriate and informed recruitment decisions.
We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
We use your personal information for the following business administration and legal compliance purposes:
We may share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Where our use of your personal information requires your consent, you can provide such consent:
Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties linked to our Sites. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
We keep your personal information indefinitely so that we have a record of requests you have made in the past e.g. requests for information in relation to our Products and Services. It is also important for us to maintain a record of your personal information in the event that you have asked us to no longer contact you.
If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
You have the following rights in relation to the personal information we hold about you:
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
With effect from 25 May 2021, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
You can ask us to stop processing your personal information, and we will do so, if we are:
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. We will assess any deletion request on a case by case basis and will endeavour to respond as soon as possible, at most within 10 working days.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the FTC (Federal Trade Commision). You can find details about how to do this on the FTC website at https://reportfraud.ftc.gov/#/.