Privacy Policy

Last Updated: 13 Sep 2023
Effective: 31 May 2023

Thank you for using Kompas.ai Services. We are committed to protecting your privacy through our compliance with this Policy.

The following Privacy Policy outlines how ByteBridge Co.,Ltd.( "we","our","us", "company") safeguards and respects your privacy. This policy pertains to the collection, usage, and disclosure of information associated with an identified or identifiable individual (referred to as "Personal Data") and explains the available choices regarding this process. Should you have any inquiries, please feel free to reach out to us.

For the purpose of this Privacy Policy, the term "Website" refers to our public websites, including https://kompas.ai.

The collective reference to our online software-as-a-service platform, along with any associated APIs provided by Kompas.ai, and all related mobile and desktop applications is termed the "Services."

The Service encompasses separate sections, known as "Workspaces," which organize content submitted, posted, or modified by users.

The company recommends that you shall carefully read and understand the whole contents of this Policy before your use of the product (“Kompas.ai”). Definitions of key words in this Policy are consistent with those in our Terms of Service.

The company reserves the right to update this Policy online from time to time, and the new policy will immediately replace the older one once posted. In particular, if you do not accept the revised policies, please immediately stop your use of Kompas.ai. Your continuous use of Kompas.ai will be regarded as your acceptance of the revised policy. Furthermore, the revised policies will take into effect immediately upon being posted on Kompas.ai.

This Privacy Policy is not applicable to any third-party applications or software that integrate with the Services through the Kompas.ai platform ("Third-Party Services"), nor does it cover any other third-party products, services, or businesses that provide their services under their own terms of service and privacy policy.

If you have any questions regarding specific Workspace settings and privacy practices, please reach out to the Customer whose Workspace you are using. If you have an account, you can find the contact information of your Workspace owner(s) and administrator(s) at https://kompas.ai. If you have received an invitation to join a Workspace but have not yet created an account, please seek assistance from the Customer who sent the invitation.

California Notice of Collection of Personal Information: We collect the information outlined in the "Information We Collect and Receive" section for the purposes specified in the " How We Use Your Information" section. To obtain further information on how to exercise your California Privacy Rights, please refer to the "California Privacy Rights" section provided below.

This Privacy Policy applies to the following aspects:

Information We Collect and Receive

Account Data: When creating an account, you may provide us with your name, photo, phone number, email address, password information, and/or similar account details.

Workplace Data: We collect and process the content generated by you on the Platform and through the Services, including:

• Messages, files, photos, documents, or other content you upload, view, edit, share, or comment on.
• Uploaded address book and contacts (if provided).
• Created, edited, or invited calendar entries.
• Voice and video data, including voice messages, conference services, and associated transcripts.
• Search queries and commands.

Administrative and Interactions Data: We collect and process data to administer, provide, optimize, and market the Services. This data may be collected automatically by our service providers and third-party vendors. It includes:

• Metadata and inference information related to your use of the Services, such as online status, chat details, interaction with features and embedded content, shared file types, and use of third-party integrations.
• Internet network activity, cookies, and similar tracking technologies, including automatically recorded data by our servers such as web requests, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamps, language preferences, and other relevant information.
• Data about your online activity on websites and connected devices over time, across third-party websites, and interactions such as clicks, page visits, scrolling, mouse hovers, and other data to enhance user experience.
• Data about the device used to access the Services, including mobile carrier, device IDs, and operating system version.
• Data regarding your communications with us, such as feedback or inquiries through our chat services, including social media.
• Location Data: We collect and process location information, including general location details (e.g., city, state, country, and/or zip code) based on your SIM card, IP address, or other device information. With your consent, we may also collect precise location and GPS data. You have the option to disable GPS and location information in your system settings. If you choose to share your location and consent to our use of this data, we may process it to provide relevant location-based services.

Third-Party Data: Kompas.ai allows integration with other services and applications. If you use an integrated third-party service, we may receive and process data from that third party (and share certain data with them) to provide the integrated service. This Privacy Policy does not cover the processing of your information by third parties through third-party integrations available via our services. When using integrated apps and services on Kompas.ai, please review the relevant third-party provider's legal documents, including their Terms of Service and Privacy Policy.

In general, there is no legal or contractual requirement for anyone to provide Customer Data or Other Information (collectively referred to as "Information"). However, please note that certain Information is collected automatically, and if specific details regarding Workspace setup, for example, are not provided, we may be unable to provide the Services.

How We Use Your Information

In addition to the purposes already mentioned, we may use, process, and/or disclose your information for the following purposes:

• Administer, operate, and provide the Services to you.
• Provide user support and address your queries, requests, applications, complaints, and feedback.
• Investigate and prevent security issues and abuse, enhancing the security of our Services through automated systems that analyze content, such as documents, instant messages, and emails, to identify and combat spam, malware, and illegal content.
• Gain a better understanding of your interests and needs, personalizing your experience on the Services.
• Analyze and research how you interact with our websites and applications.
• Continually improve our Services and products by adding new features or capabilities.
• Comply with applicable laws, regulations, codes of practice, guidelines, or rules, and assist in law enforcement and investigations conducted by governmental and/or regulatory authorities as required by law.
• Communicate with you, including sending service messages to notify you of any changes to our Platform or Services.
• Send marketing and promotional materials from us or our trusted affiliates and third-party business partners.
• Measure and understand the effectiveness of our marketing campaigns.
• Enforce our terms, conditions, and policies.
• Fulfill any other purposes for which you have provided the data.
• Transmit data to third parties, including our business partners, third-party service providers and agents, and relevant governmental and/or regulatory authorities, both within the US and abroad, for the aforementioned purposes.
• Facilitating Collaboration in a Workspace: When you become a member of a Workspace owned by another user or organization or collaborate with other users on Kompas.ai, certain basic information about you, such as your name, email address, profile picture, Workspace name, and Workspace ID, may be shared with the other users or organizations by Kompas.ai.
• Managing Workspaces for Organizations: If you create a Kompas.ai account or associate it with an email address provided by your organization, Kompas.ai may share information about you and any Workspaces owned or managed by you with your organization. This information may include your name, email address, profile picture, as well as details about your Workspace, such as Workspace name, Workspace ID, membership size, creation date, email address, and content within the Workspace. If you registered for Kompas.ai's Services using such an email address but do not use the Services in connection with your organization and do not want this information to be shared with your organization, you have the option to transfer your account to a different email address.
• Aggregated and De-identified Information use: We may utilize de-identified and/or aggregated information that cannot be reasonably linked back to you or your device, derived from the data we collect. This de-identified and/or aggregated information is not covered by this Privacy Policy, and we may employ it for various purposes, including research, internal analysis, analytics, and other legally permissible activities. It is essential to emphasize that we will refrain from utilizing the aforementioned information for the purposes of third-party model training and we will not engage in the sale of the collected information.
• Processing Information on Behalf of Our Customers: Our customers may opt to utilize our Services for processing certain data that may include information related to you. Any personal information processed by us on behalf of our customers will be governed by the agreements we have in place with them, rather than this Privacy Policy.
• Fulfill other business purposes related to or connected with the above.

Legal Bases

If you are an individual from the European Economic Area ("EEA"), the UK, Switzerland, or any country that requires notification of the legal bases for processing, the legal bases for collecting and using your information, as described above, will depend on the specific type of information and the context in which we collect it, in accordance with the General Data Protection Regulation ("GDPR") and applicable data protection laws of each respective country. However, here are some examples of the legal bases we rely on for processing:

• When we have obtained your consent to do so.
• When the use of your information is necessary to fulfill our obligations under a contract with you (e.g., to comply with the Customer Terms of Service or User Terms of Service and provide the Services).
• When the use of your information is necessary for our legitimate interests or the legitimate interests of others (e.g., to operate our Services, ensure security, prevent fraud, analyze and improve our Services, and similar purposes).
• When the use of your information is necessary to comply with applicable legal obligations.

Disclosure of Your Information

We may disclose your information to the following categories of third parties:

1. Service Providers: We may disclose the information we collect about you to third-party service providers who assist us in various aspects, including:
• Provision of the Services
• Provision of requested information, products, and other services
• Marketing and advertising
• Payment and transaction processing
• Customer service activities
• IT and related services provision
• Fraud prevention and user authentication
2. Business Partners: With your request, we may provide information to business partners to offer you products or services of interest. We may also share information with business partners with whom we jointly provide products or services.
3. Advertising Partners: We do not disclose or use your information to advertise third-party products or services via the Services. However, as explained in detail in section above, we may disclose your information to third-party advertising partners to market our own Services and expand our user base.
4. We may disclose your information to other third parties, including other users, in the following circumstances:
• Workspaces Accessible by Other Users: Information you submit in a workspace that can be accessed by others may be displayed to other users in the same or connected workspaces. For example, your notes or reminders in a workspace may be visible to other users collaborating with you in that workspace. Additionally, your email address or photo may be shown with your workspace profile to other users collaborating with you in that workspace.
• Organizational Workspaces: We allow organizations to access the profile information of users within their workspace, including to verify that the user is authorized by the organization to use the Services.
• Sharing Content with Friends or Colleagues: Our Services may enable you to provide information about your friends and share certain content, such as an invitation email, with a friend or colleague. You agree to only provide information about a friend or colleague with their consent.
• Disclosures to Protect Us or Others: In good faith, we may access, preserve, and disclose any information associated with you to external parties if we believe it is necessary or appropriate to:
• Comply with law enforcement or national security requests and legal processes, such as court orders or subpoenas
• Protect your, our, or others' rights, property, or safety
• Enforce our policies or contracts
• Collect amounts owed to us
• Assist with the investigation and prosecution of suspected or actual illegal activity
• Disclosure in the Event of Merger, Sale, or Other Asset Transfer: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of some or all assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, in accordance with applicable laws and contracts.

Data Retention

We retain the information collected in accordance with this Privacy Policy for the duration of your use of our Services or as long as necessary to fulfill the purposes for which it was collected. This includes providing our Services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business interests, enforcing our agreements, and complying with applicable laws.

Security

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

As achieving permanent and absolute security is impossible, we strongly recommend that you take proactive steps to enhance the security of your information. This includes using a complex password, regularly changing it, and avoiding sharing your account password or any login-related information. These actions will help protect the security of your information. Additionally, we advise against using insecure channels to communicate sensitive or confidential information to us.

Age Limitations

The Services are designed and intended for use by adults, meaning individuals who have reached the legal age of consent in their respective jurisdictions. We do not knowingly seek or collect any personal data from children or minors below the legal age of consent in the applicable jurisdiction. If you become aware that an individual below the legal age of consent has unlawfully provided us with their personal data in connection with the Services, please contact us immediately. We will make commercially reasonable efforts to promptly delete such information from our database.

International Data Transfers

All information processed by us may be transferred, processed, and stored globally, including in countries such as the United States, which may have data protection laws different from those in your country of residence. When we engage in such transfers, we strive to protect your information in accordance with applicable laws.

Data Protection Officer

To get in touch with our Data Protection Officer, please send an email to [email protected].

Your Rights

Depending on your location and as permitted by applicable laws, you may have certain rights regarding your personal information, including:

• Access: You have the right to access information about you, in accordance with legal requirements. In some cases, you may also have the right to receive or have your electronic information transferred to another party.
• Correction: You can request the correction of inaccurate or incomplete information we have about you.
• Deletion: Subject to certain exceptions prescribed by law, you can request the deletion of your information.
• Restriction or Objection: You may request the restriction or object to the processing of your information.
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

If you would like to exercise any of these rights, please contact us via email ([email protected]). We will process your requests in accordance with applicable laws. Please note that in certain circumstances, we may need to deny your request in whole or in part if we have a legal obligation to retain your information for a specific purpose. To protect your privacy, we may need to verify your identity before fulfilling your request. If you submit a request through an authorized agent, we will require written permission from you and may need to verify your identity.

Depending on your country of residence, you may have the right to appeal our response to your request. If applicable, we will provide you with information about the right to appeal and the corresponding process.

California Privacy Rights

This section provides additional information regarding the personal information we collect about California consumers and the rights granted to them under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA").

Under California law, we are required to disclose the categories of personal information we collect and disclose for specific "business purposes," such as to service providers who assist us in securing our Services or marketing our products, and to other entities as described in earlier sections of our Privacy Policy. In addition to the information outlined in the "Information We Collect And Receive" section above, we collect the following categories of personal information for our business purposes:

• Identifiers/contact information
• Commercial information
• Internet or electronic network activity information
• Financial information
• Geolocation information
• Professional or employment-related information
• Audio and visual data

In limited circumstances permitted by law, information that may be protected under California or United States law, and inferences drawn from any of the above categories.

We collect this information for the business and commercial purposes described in the "How We Use Your Information and our legal bases" section above. We share this information as outlined in the "Disclosure of Your Information" section above.

The CCPA imposes certain obligations on businesses that "sell" personal information to third parties. Please note that Kompas.ai does not "sell" any of the data we collect about you.

Subject to certain limitations, the CCPA grants California consumers the right to request more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to request the deletion of their personal information, to opt out of any "sales," to be informed and opt out of the sharing of personal information for delivering advertisements on non-Kompas.ai websites, and to not face discrimination for exercising these rights.

If you are a California consumer and would like to make a request pursuant to your rights under the CCPA, please contact us at [email protected].

To verify your request, we will use the information associated with your account, including your email address. In some cases, government identification may be required. California consumers can also designate an authorized agent to exercise these rights on their behalf, provided that the authorized agent submits proof of authorization.

Data Protection Authority

If you are located in the European Economic Area or the UK, you have the right to file a complaint with a supervisory authority if you believe that our processing of your information violates relevant laws and regulations.

Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy at our discretion. In the event of any significant changes, we will notify you as required by applicable law. By continuing to use the Services after the updated Privacy Policy comes into effect, you acknowledge and accept the revised terms.

Contact Us

If you would like to discuss how we handle your personal data, please reach out to us at [email protected]. We will make every effort to address your inquiry promptly.