Privacy Policy of Komuu.co

Updated at 2024-01-16

Komuu (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used, and disclosed by Komuu. This Privacy Policy applies to our website, its associated subdomains (collectively, our “Service”), and our application, Komuu GEO Tool Extension. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

Definitions and Key Terms
To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, they are strictly defined as:

• Cookie: A small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, remember information about you such as your language preference or login information.
• Company: When this policy mentions “Company,” “we,” “us,” or “our,” it refers to Listva Ltd., (010000, Kazakhstan, Astana, Taras Shevchenko St., 4/1, b.17) that is responsible for your information under this Privacy Policy.
• Country: Where Komuu or the owners/founders of Komuu are based, in this case, Kazakhstan.
• Customer: Refers to the company, organization, or person that signs up to use the Komuu Service to manage the relationships with your consumers or service users.
• Device: Any internet-connected device such as a phone, tablet, computer, or any other device that can be used to visit Komuu and use the services.
• IP address: Every device connected to the Internet is assigned a number known as an Internet Protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.
• Personnel: Refers to those individuals who are employed by Komuu or are under contract to perform a service on behalf of one of the parties.
• Personal Data: Any information that directly, indirectly, or in connection with other information—including a personal identification number—allows for the identification or identifiability of a natural person.
• Service: Refers to the service provided by Komuu as described in the relative terms (if available) and on this platform, including the Komuu GEO Tool Extension.
• Third-party service: Refers to advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or services we think may interest you.
• Website: Komuu.co’s site, which can be accessed via this URL: Komuu.co
• You: A person or entity that is registered with Komuu to use the Services.

1. What information do we collect?
1.1 Information you provide directly
We collect information from you when you:

• Visit our website
• Register on our site
• Install or use the Komuu GEO Tool Extension
• Place an order
• Subscribe to our newsletter
• Respond to a survey
• Fill out a form

Collected Information Includes:

• Name / Username
• Email Address

1.2 Information automatically collected
When you use our Service, including the Komuu GEO Tool Extension, we may automatically collect certain information about your device and usage, such as:

• IP Address
• Browser type and version
• Operating system
• Operating system language
• Device type
• Browsing behavior (e.g., pages visited, time spent on pages)
• Browser window size

Extension-Specific Data:

• Prompts and generated content: Any text you input into the Komuu GEO Tool Extension for optimization.

Note: This data is processed by OpenAI and stored locally in your browser; it is not transmitted to Komuu's servers.

2. How do we use the information we collect?
We use the information we collect in the following ways:

• To personalize your experience: Your information helps us to better respond to your individual needs.
• To improve our website and extension: We continually strive to improve our website and the Komuu GEO Tool Extension offerings based on the information and feedback we receive from you.
• To improve customer service: Your information helps us to more effectively respond to your customer service requests and support needs.
• To process transactions: We may use your information to process transactions when we have paid options.
• To administer contests, promotions, surveys, or other site features: Your information helps us to administer these activities.
• To send periodic emails: We may use your email address to send you information and updates pertaining to your order or other products and services.

Extension-specific usage:

• Local data handling: All data entered into the Komuu GEO Tool Extension, including prompts and API keys, are stored locally in your browser and are not transmitted to our servers. We do not access, store, or use this data beyond facilitating its processing by OpenAI’s services.

3. When does Komuu use end user information from third parties?
Komuu will collect End User Data necessary to provide the Komuu services to our customers. End users may voluntarily provide us with information they have made available on social media websites. If you provide us with any such information, we may collect publicly available information from the social media websites you have indicated. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.
4. Do we share the information we collect with third parties?
4.1 General sharing
We may share the information that we collect, both personal and non-personal, with third parties such as our current and future affiliated companies and business partners. In the event of a merger, asset sale, or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest.
4.2 Trusted third-party service providers
We may engage trusted third-party service providers to perform functions and provide services to us, such as:

• Hosting and maintaining our servers and the website
• Database storage and management
• Email management
• Storage marketing
• Credit card processing
• Customer service
• Fulfilling orders for products and services you may purchase through the website

We will share your personal information, and possibly some non-personal information, with these third parties to enable them to perform these services for us and for you.
4.3 Analytics and advertising partners
We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the website from a shared location, and type of device used to visit the website. They may aggregate information about our advertising and what you see on the website and then provide auditing, research, and reporting for us and our advertisers.
4.4 Legal requirements
We may disclose personal and non-personal information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to:

• Respond to claims
• Comply with legal processes (including subpoenas)
• Protect our rights and interests or those of a third party
• Ensure the safety of the public or any person
• Prevent or stop any illegal, unethical, or legally actionable activity
• Comply with applicable court orders, laws, rules, and regulations

4.5 Extension-specific data sharing
Komuu GEO Tool Extension does not transmit or store your prompts, generated content, or OpenAI API keys on Komuu’s servers. All data is processed directly by OpenAI, and Komuu does not have access to this information. Therefore, there is no sharing of this specific data with Komuu or its affiliates.

5. Where and when is information collected from customers and end users?
Komuu will collect personal information that you submit to us through:

• Our website
• Registration forms
• Installation or use of the Komuu GEO Tool Extension
• Contacting us via email or other communication channels

We may also receive personal information about you from third parties as described above.

6. How do we use your email address?
By submitting your email address on this website or through the Komuu GEO Tool Extension, you agree to receive emails from us. You can cancel your participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe option included in the respective email.
Specific uses:

• Marketing communications: We may use your email address for customer audience targeting on platforms like Facebook, where we display custom advertising to individuals who have opted-in to receive communications from us.
• Order orocessing: Email addresses submitted through the order processing page will be used solely to send you information and updates pertaining to your order.
• Other interactions: If you have provided the same email to us through another method, we may use it for any of the purposes stated in this Policy.

Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

7. How long do we keep your information?
We keep your information only as long as necessary to provide Komuu to you and fulfill the purposes described in this policy. This applies to anyone we share your information with who carries out services on our behalf.

• Retention period: When we no longer need to use your information and there is no legal or regulatory obligation to retain it, we will either remove it from our systems or depersonalize it so that you cannot be identified.
• Backups: Due to the need to back up our systems to protect information from inadvertent loss, a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate.

8. How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you place an order, enter, submit, or access your personal information.

• Secure Server: We offer the use of a secure server.
• Encryption: All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers' databases, accessible only by those authorized with special access rights.
• Confidentiality: Authorized personnel are required to keep information confidential.
• Post-transaction security: After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on file.

Limitations: We cannot ensure or warrant the absolute security of any information you transmit to Komuu or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

9. Could my information be transferred to other countries?
Komuu is incorporated in Kazakhstan. Information collected via our website, through direct interactions with you, or from use of our help services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws regulating the use and transfer of such data.
Consent: To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and hosting of such information.

10. Is the information collected through the Komuu service secure?
We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information.
However:

• Neither people nor security systems are foolproof, including encryption systems.
• Individuals can commit intentional crimes, make mistakes, or fail to follow policies.
• While we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
• If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standard used to measure our compliance with that duty.

11. Can I update or correct my information?
11.1 General users
Customers have the right to:

1. Update or correct: Request updates or corrections to your personally identifiable information.
2. Change preferences: Modify your preferences with respect to communications and other information you receive from us.
3. Delete information: Request the deletion of personally identifiable information maintained about you on our systems by canceling your account.

Procedure: Such updates, corrections, changes, and deletions will have no effect on other information that we maintain or information that we have provided to third parties in accordance with this Privacy Policy prior to such updates.
Verification: To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting profile access or making corrections.
Responsibility: You are responsible for maintaining the secrecy of your unique password and account information at all times.
Limitations: It is not technologically possible to remove every record of the information you have provided to us from our system. Copies of your information may exist in non-erasable forms that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use and other readily searchable media will be updated, corrected, changed, or deleted as appropriate, as soon as and to the extent reasonably and technically practicable.

11.2 Extension Users
Komuu GEO Tool Extension users who have provided their email addresses or other information through the Extension can manage their preferences and data directly within the Extension settings.
11.3 End users
If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting the organization of which you are a customer.

12. Personnel
If you are a Komuu worker or applicant, we collect information you voluntarily provide to us. We use the information collected for Human Resources purposes to administer benefits to workers and screen applicants.
You may contact us to:

1. Update or correct: Your information.
2. Change preferences: With respect to communications and other information you receive from us.
3. Receive a record: Of the information we have relating to you.

Such updates, corrections, changes, and deletions will have no effect on other information that we maintain or information that we have provided to third parties in accordance with this Privacy Policy prior to such updates.

13. Sale of business
We reserve the right to transfer information to a third party in the event of a sale, merger, or other transfer of all or substantially all of the assets of Komuu or any of its Corporate Affiliates. This includes any portion of Komuu or its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization, or similar proceeding. The third party must agree to adhere to the terms of this Privacy Policy.

14. Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity that directly or indirectly controls, is controlled by, or is under common control with Komuu, whether by ownership or otherwise.
Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

15. Governing law
This Privacy Policy is governed by the laws of Kazakhstan without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy, except for those individuals who may have rights to make claims under Privacy Shield or the Swiss-US framework.
The laws of Kazakhstan, excluding its conflicts of law rules, shall govern this Agreement and your use of the website. Your use of the website may also be subject to other local, state, national, or international laws.
By using Komuu or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our website or use our services. Continued use of the website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.

16. Your consent
We've updated our Privacy Policy to provide you with complete transparency into what is being set when you visit our site and how it's being used. By using our website, registering an account, installing or using the Komuu GEO Tool Extension, or making a purchase, you hereby consent to our Privacy Policy and agree to its terms.

17. Links to Other Websites
This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Komuu. We are not responsible for the content, accuracy, or opinions expressed on such websites, and such websites are not investigated, monitored, or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

18. Cookies
Komuu uses "Cookies" to identify the areas of our website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser.

• Purpose: We use Cookies to enhance the performance and functionality of our website, but they are non-essential to their use. However, without these cookies, certain functionalities like videos may become unavailable, or you would be required to enter your login details every time you visit the website as we would not be able to remember that you had logged in previously.
• Personal Information: We never place Personally Identifiable Information in Cookies.

Blocking and disabling cookies and similar technologies
Wherever you're located, you may set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our website from functioning properly. You may also lose some saved information (e.g., saved login details, site preferences) if you block cookies on your browser.
Different browsers offer different controls. Disabling a cookie or category of cookies does not delete the cookie from your browser; you will need to do this yourself from within your browser. Visit your browser's help menu for more information.

19. Local storage
Local storage, sometimes known as DOM storage, provides web apps with methods and protocols for storing client-side data. Web storage supports persistent data storage, similar to cookies but with greatly enhanced capacity and no information stored in the HTTP request header.

20. Sessions
Komuu uses "Sessions" to identify the areas of our website that you have visited. A Session is a small piece of data stored on your computer or mobile device by your web browser.

21. Payment details
In respect to any credit card or other payment processing details you have provided us, we commit that this confidential information will be stored in the most secure manner possible.

22. Kids' privacy
We do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.

23. Changes to our Privacy policy
We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete your account.

24. Third-party services
We may display, include, or make available third-party content (including data, information, applications, and other products or services) or provide links to third-party websites or services ("Third-Party Services").
You acknowledge and agree that Komuu shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality, or any other aspect thereof. Komuu does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services. Third-Party Services and links thereto are provided solely as a convenience to you, and you access and use them entirely at your own risk and subject to such third parties' terms and conditions.

25. Tracking technologies - Cookies
We use Cookies to enhance the performance and functionality of our website, but they are non-essential to their use. However, without these cookies, certain functionalities like videos may become unavailable, or you would be required to enter your login details every time you visit the website as we would not be able to remember that you had logged in previously.

26. Information about General Data Protection Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic Area (EEA). This section of our Privacy Policy explains how and why this data is collected and how we maintain this data under protection from being replicated or used improperly.
26.1 What is GDPR?
GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data is protected by companies and enhances the control EU residents have over their personal data.

• Scope: GDPR is relevant to any globally operating company, not just EU-based businesses and EU residents.
• Komuu’s compliance: Our customers’ data is important irrespective of their location, which is why we have implemented GDPR controls as our baseline standard for all our operations worldwide.

26.2 What is Personal data?
Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own or in combination with other pieces of information to identify a person. Personal data extends beyond a person’s name or email address. Examples include:

• Financial information
• Political opinions
• Genetic data
• Biometric data
• IP addresses
• Physical address
• Sexual orientation
• Ethnicity

26.3 Data Protection Principles

• Fair processing: Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a manner that a person would reasonably expect.
• Purpose limitation: Personal data should only be collected to fulfill a specific purpose and used solely for that purpose. Organizations must specify why they need the personal data when collecting it.
• Data minimization: Personal data should be adequate, relevant, and limited to what is necessary for the intended purpose.
• Accuracy: Personal data should be accurate and, where necessary, kept up to date.
• Storage limitation: Personal data should be held no longer than necessary to fulfill its purpose.
• Integrity and confidentiality: Personal data should be processed in a manner that ensures appropriate security.

26.4 Individual data subject's rights

• Access: Individuals have the right to access their personal data.
• Portability: Individuals can request a copy of their data and have it transferred to another organization.
• Deletion: Individuals can request the deletion of their personal data.
• Restriction: Individuals can request the restriction of certain uses and disclosures of their personal data.

Komuu’s commitment: We are committed to helping our customers meet the data subject rights requirements of GDPR. Komuu processes or stores all personal data in fully vetted, DPA-compliant vendors. We store all conversation and personal data for up to 6 years unless your account is deleted, in which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy within 60 days.
26.5 GDPR importance
GDPR adds new requirements regarding how companies should protect individuals' personal data and enhances compliance stakes by increasing enforcement and imposing greater fines for breaches. Beyond legal compliance, it is fundamentally about respecting and protecting individuals' privacy rights.

27. California residents
The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, as explained above.
27.1 California Residents' Rights

• Right to Know and Access: You may submit a verifiable request for information regarding:

1. Categories of Personal Information we collect, use, or share.
2. Purposes for which categories of Personal Information are collected or used by us.
3. Categories of sources from which we collect Personal Information.
4. Specific pieces of Personal Information we have collected about you.

• Right to equal service: We will not discriminate against you if you exercise your privacy rights.
• Right to delete: You may submit a verifiable request to close your account, and we will delete Personal Information about you that we have collected.
• Right to Opt-Out of sale: You may request that a business that sells a consumer's personal data not sell your personal data.

Response time: If you make a request, we have one month to respond to you.
Non-sale commitment: We do not sell the Personal Information of our users.
Further information: For more information about these rights, please contact us.

28. Contact Us
Don't hesitate to contact us if you have any questions.

• Via Email: admin@komuu.co