- Scope and Relation to Other Policies
- Personal Information We Collect
- How We May Disclose Your Personal Information
- Children's Privacy
- Third Party Links
- How We Safeguard Your Information
- Additional Disclosures For California Residents
- Use of the Websites from Outside the United States
- Privacy Questions and Contacting Us
- Effective Date
If you are a resident of California, please see the section below titled “ YOUR CALIFORNIA PRIVACY RIGHTS ” for more information.
- What personal information we collect from you through the Websites.
- How we use the information we collect.
- With whom the information may be shared.
- Information related to third-party websites.
- How we take steps designed to safeguard your information.
- What rights and choices you have regarding collection, use and distribution of your information.
- What rights you have if you are accessing the Websites from outside of the United States.
- How you can learn about changes to our privacy policies, practices and procedures.
- How you can contact us with privacy questions.
Scope and Relation to Other Policies
Personal Information We Collect
We collect information that describes or relates to you (“personal information”). Personal information does not include:
- Publicly available information as defined under applicable laws.
- De-identified or aggregated information.
A. Personal Information You Provide And How It Is Used:
Certain services, requests and features of our Websites do require that you voluntarily provide us with some personal information (including, but not limited to, name, postal address, email address) as more particularly described below; availing yourself of any of these services, requests and features is voluntary.
You represent and warrant that you will only provide information and use the Websites acting in your capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit or other legal entity, and that your communications and transactions with Kyriba occur solely within the context of Kyriba providing the Websites to the company, partnership, sole proprietorship, nonprofit or other legal entity that you represent.
Personal information includes data that can be used to identify or contact you. Please note that we may use the personal information we collect through any of the services, requests and features listed below for our business purposes, such as providing content or information, products and services to you, and our marketing and advertising activities. Please do not send confidential information to us directly through the Websites, or by email to any of the contact email addresses listed on the Websites.
- Webinars: If you opt to view one of our webinars, we will ask you to provide certain personal information, including your first and last name, email address, country of origin and phone number.
- Blogs: We provide you the ability to comment on our blogs. In order to leave a comment on one of our blogs, you will be required to provide your name and email address.
- Events: We provide information related to events that we periodically host. If you are interested in attending one of Kyriba’s events, we will ask you to provide an email address and other contact information so that we can reserve your seat and follow up with you.
- Careers: We post certain career opportunities on the Websites. If you are interested in learning more about any of these opportunities, we provide you a link to email us, and our service provider will collect your email address and any other information required such as name, mailing address, and your resume and share that information with us. We use this information to contact you to review or pursue your candidacy.
- Email Newsletters/Updates: When you register to get access or take part in any of our resources, such as events or webinars, we may use the information that you provide us when you register to keep in touch and update you on upcoming events, new developments or other Kyriba-related or partner-related information. You may unsubscribe from receiving all or some these updates at any time by using the opt-out link provided in any subsequent email you receive from us, or by emailing your request to [email protected].
- Contact Us: If you contact us through the contact form option on the Websites, we will ask that you provide certain personal information, including your first and last name, email address and country of origin, and you will have the option to provide additional personal information. We will use the information you provide to contact you and to respond to any requests.
B. Personal Information We Collect Automatically And How It Is Used
We or vendors on our behalf also collect certain information by automated means when you visit the Websites. The personal information collected may include usage information, such as the numbers and frequency of users to the Websites, pages visited, social networking activities; device information, such as operating system, browser type, and IP address; and similar data.
Do Not Track – Every time your computer sends or receives information over the Web, the request begins with some short pieces of information called “headers.” These headers include information like what browser you are using, what language your computer is set to, and other details. The Do Not Track technology provides individual users with the ability to include a simple, machine-readable header indicating that they don’t want to be tracked, and sends a signal to websites visited requesting that the website disable either its tracking or cross-site user tracking of an individual user. Presently, there is no consensus on how Do Not Track should be interpreted, and no common or accepted industry standard for implementing. Consequently, please note that the Websites may or may not respond to a particular browser’s “Do Not Track” signals and while we make every effort to respect an individual’s choice in the matter, we cannot guarantee that no tracking will occur.
How We May Disclose Your Personal Information
- Operating Services and Websites and Providing Related Support. To provide and operate our Websites and Services, communicate with you about your use of the Websites and Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, communicate with you, and for similar service and support purposes.
- Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, and third-party advisors, including attorneys and consultants.
- Marketing. We may disclose your personal information to third-party ad networks to serve advertisements on our Websites or other media. This enables us and other third parties to target advertisements to you for products and services in which you might be interested. We may also disclose personal information to partners, such as resellers and marketing providers, to identify prospects and share information about upcoming events and developments.
- In Response to Legal Process. We may disclose your personal information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect You, Us, and Others. We disclose your personal information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which we are involved.
We may disclose personal information, such as contact information, with the following recipients:
- Business Partners and Affiliates. We disclose personal information to our subsidiaries, affiliates and channel partners such as resellers and co-sellers for business purposes. Those business purposes include identifying prospects and facilitating the ability of those entities to share information with existing and potential business customers regarding Kyriba upcoming events and other new developments.
- Service Providers. Additionally, we share information we collect with service providers who perform activities on our behalf, such as payment processing, data analytics, marketing and promotional services, website hosting and technical support. In accordance with applicable law, our service providers are required to take appropriate security measures to protect your personal information in line with our policies and are not permitted to use personal information for their own purposes.
- Third party providers. We may disclose personal information to our third party vendors, such as our hosting providers and internet service providers, with whom we have contracted.
Kyriba’s Websites, products and services are intended for a general audience and are not directed to children under the age of sixteen (16). As such we do not knowingly collect, use, solicit or disclose personal information about visitors less than 16 years of age. If you are under the age of 16, we ask that you do not access the Websites. If you are the parent or guardian of a child under 16 years of age and believe that they have disclosed personal information to us, please contact us at [email protected].
Third Party Links
We may provide links to a variety of third-party social media sites and other websites as a service to you or in order to provide you additional information related to Kyriba or additional venues in which you can learn about and discuss Kyriba. Please note that we have no affiliation with these third parties, and we cannot control and are not responsible for the information collection, use, and disclosure practices of such third parties; we encourage you to review and understand their privacy practices and policies, if any, before providing any information to them. We are not responsible for the content or information of these websites, any products or services that may be offered through advertisers or third parties, or any other use of the linked website.
How We Safeguard Your Information
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect the Personal Information we collect about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
Additional Disclosures For California Residents
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively “CCPA”), California residents have the right to receive certain disclosures regarding our information practices related to “Personal Information,” as defined under the CCPA. To the extent you are a resident of California, and we collect Personal Information subject to CCPA, the following applies.
What Personal Information We Collect
The following identifies the categories of personal information we collect (and have collected in the prior 12 months), as enumerated by the CCPA.
- Identifiers, such as your name, email address, and phone number.
For more information about the personal information, we collect and how we use or disclose it please refer to the sections above.
How Long We Retain Personal Information
We store your personal information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions that require data retention (e.g., issued any legal holds or otherwise need to preserve data).
Rather than delete your personal information, we may also deidentify it in accordance with the CCPA, by removing identifying details. If we deidentify any personal information, we will not attempt to reidentify it.
Your California Privacy Rights
If you are a California resident, you may have the following rights under the CCPA with respect to your Personal Information.
- Right to Know/Access. You have the right to request (subject to certain exemptions):
- The categories of Personal Information we collected about you;
- The sources from which we have collected that Personal Information;
- Our business or commercial purpose for collecting, selling, or sharing that Personal Information;
- The categories of third parties to whom we have disclosed that Personal Information; and
- A copy of the specific pieces of Personal Information we have collected.
- Right to Delete. Subject to certain exceptions, you have the right to request deletion of Personal Information that we have collected from you. Please note, Kyriba is not obligated to delete Personal Information that is necessary to provide services that you request or required to comply with applicable laws.
- Right to Opt-Out. Under the CCPA, California residents may have the right to opt-out of the “sale,” or “sharing,” of Personal Information. California CCPA defines a “sale” as disclosing or making available to a third-party Personal Information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available Personal Information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA), the following categories of Personal Information: Identifiers, and Internet or Other Electric Network Activity Information to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old. To opt out from the sharing or sale of personal information, please click on the “Do Not Sell or Share My Personal Information” link on the bottom of the website homepage.
- Right to Limit Use and Disclosure. Subject to certain conditions and exceptions, you may have the right to limit the use and disclosure of “sensitive personal information,” as defined under the CPRA. However, we do not engage in activities triggering this right.
- Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.
How To Exercise Your Privacy Rights
To exercise any of these rights, California residents may submit a request through our online form available at info.kyriba.com/ca-consumer-privacy-act-opt-out, call our toll free number at 844-845-7161, or email us at [email protected]
In the request, please include “California Privacy Rights Request” in the first line of the description, and specify which right you are seeking to exercise. We will confirm receipt of your request within 10 days. Kyriba will need to confirm your identity before fulfilling the request, so please provide us with your name, street address, city, state, and ZIP code. We may require additional information from you to help us verify your identity and process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.
You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf. We may also ask you directly to verify that you have authorized your authorized agent to act on your behalf.
If Personal Information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.
In addition, our Policy and your rights thereunder have been designed to be accessible for blind and visually-impaired users and to allow for user interaction on such web form. If you experience any difficulties accessing this information, please call our toll-free number at 844-845-7161, or email us at [email protected].
Notice of The Right to Opt-Out of Sale or Sharing
To the extent Kyriba sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information. You may also submit a request to opt-out by calling our toll-free number at 844-845-7161, or emailing us at [email protected].
Use of the Websites from Outside the United States
Transferring Personal Data to the U.S.
If you have an inquiry, dispute or unresolved questions that arise out of or relate to our compliance with applicable data protection regulations, please contact us at [email protected]
To read more about how we treat information collected from the EU, UK and Switzerland, please read our Kyriba Technology Platform Customer Privacy Notice here.
Data protection laws in Europe and the UK make a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Kyriba acts as a controller with respect to personal data collected as you interact with our Websites, emails, and advertisements.
Lawful Basis for Processing
Data protection laws in Europe and the UK require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
Your European Privacy Rights
Upon request, Kyriba will provide you with information about whether or not we hold any of your personal data. To the extent required by law, we provide you with (i) reasonable access to the personal data you provide to us, (ii) the ability to review, correct and delete such personal data, (iii) the right to data portability, and (iv) the ability to restrict or object to our processing of personal data we collected about you. If you believe that any of the personal data that you have submitted through the Websites is no longer accurate, or you wish to make any updates or changes, or rights requests, you may do so by emailing us at [email protected].
Upon appropriate request, we will endeavor to comply with your request as soon as reasonably practicable. However, we reserve the right to use any information previously obtained to verify your identity or take other actions that we believe are appropriate and lawful. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are impractical, or for which access is not otherwise required by local law. Please note we may need to retain certain information for record keeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed from such locations.
If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us at [email protected].
Your California Privacy Rights
Privacy Questions and Contacting Us
4435 Eastgate Mall, Suite 200
San Diego, CA 92121