Privacy Policy

This Privacy Policy covers the processing of personal data that we collect and/or have access to through your use of our website, the KBOO Platform, and our associated digital services, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”), and any applicable local law or regulation implementing or enforcing the GDPR, as these may be amended from time to time, as well as any other law or regulation applicable to the protection of personal data.

This Privacy Policy describes what personal data or personal information we collect and/or access about you, the purposes for such collection or access, what we do with it, and the rights and choices that you have. It applies when you use our services, visit our website and/or Platform, or contact us.

KBOO reserves the right to update this Privacy Policy, at any time. Upon changes to the Privacy Policy, we will alert you via a conspicuous website banner notice and/or via the applicable communication channels.

When visiting our website, or using our Platform or services, KBOO may collect and process your personal data and personal information for the following purposes:

Identity Verification. To protect the services offered and to safeguard the KBOO Platform, protect Users and their accounts, prevent fraud, and strive for safe and professional user experiences, KBOO shall collect various personal details from each User, such as personal details (e.g. full name, date of birth, nationality or other personal/business details), contact information (e.g. email address), place of residency / registration information (e.g. place of business or fiscal address), and copies of official identification documents, business registration documents, fiscal/tax information (e.g. fiscal number or VAT number). This information helps protect the KBOO Platform and User accounts from fraud, by verifying the identity and eligibility of all Users. It also helps ensure the proper functioning of our services, and it allows us to meet our legal ‘know-your-customer’ (KYC) and anti-money laundering obligations.

Payment Processing. To facilitate the secure processing of invoicing and payments between Users, in accordance with the Terms & Conditions of Use of the KBOO Platform, we may use your personal and payment information (e.g. full name, fiscal information, place of residency / registration information, credit card information, bank account information, or transaction amounts). Your information is then shared with, and processed securely by, our trusted third-party payment service providers and is used exclusively for this purpose.

Account Management & Content Monitoring. To protect the services offered and to safeguard the KBOO Platform, protect Users and their accounts, prevent fraud, and strive for a safe, respectful, and professional environment, in strict compliance with applicable laws and regulations, KBOO may preventively monitor and review user accounts and published content, and it may carry out such monitoring and review in response to complaints and/or reports regarding suspected illicit or illegal content, or content that is in breach of the KBOO Community Guidelines. For this purpose, we may process user account information, including user profile information, as well as the content published by the users, through a combination of automated tools and human review. Any such content monitoring and review shall be carried out in accordance with this Privacy Policy and the Terms & Conditions of Use of the KBOO Platform.

Legal Compliance & Fraud Prevention. As part of our efforts to maintain a safe, trustworthy, and respectful environment, KBOO shall process certain personal information (e.g. account information, published content, financial information) to comply with applicable laws, respond to lawful requests from public authorities and other authorized third parties, detect and prevent fraud, and avoid abusive and/or malicious activity.

Customer Support & Service Operations. Throughout the duration of your engagement with our services, you may require support from KBOO in resolving any technical, or other Platform-related or service-related, issues that you may be experiencing. To allow us to promptly and effectively resolve any issues with which users may face, track case history, and improve help-desk performance, KBOO shall require access to and use of personal information, such as account details, issue description, support tickets, and chat logs.

Delivering and Improving KBOO Products and Services. To best tailor our services to your needs and deliver product choices related to your interests, we may process names and contact details, occupation, and usage data (including information about how you interact with and use our website, products and services), as well as additional information you may choose to share with KBOO to better address your needs.

Product Development & Testing. KBOO is continuously striving to improve your experience whenever engaging with our products and services, including the KBOO Platform. As such, we may process your usage and technical data (e.g. error logs, crash reports, or A/B test results) to proceed with debugging, test new features, and optimize UI/UX.

Personalization & Recommendations. To improve your user experience and understand trends and business needs that may be relevant to you, we may analyze your interaction and preference data to surface relevant content, features or training materials.

Information Updates & Marketing. To send you periodic newsletters, announcements of new gigs, and additional business marketing information, we may process personal information such as your name and contact details, addresses, marketing preferences, and IP addresses.

Third-party Integrations. As the proper functioning of our services is critical, KBOO may share anonymized or pseudonymized data with sub-processors (e.g. hosting, analytics, CRM tools) to deliver core services on which the proper functioning of our services and the KBOO Platform depend.

Queries & Requests for Information. Upon visiting our website, you may contact us with questions about our services and opportunities, as well as request specific business information. To ensure prompt response we may collect information from you such as names and contact details, occupation, and other information you may choose to share.

Improvement of Performance and Security. We continually strive to improve and optimize our services and platforms, and to protect them, as well as our users, against potential threats. To do so, we may collect and process:

• Technical & usage logs: page load times, server response metrics, JavaScript errors and crash reports to identify bottlenecks and optimize performance.
• Traffic & behavior analytics: the volume, source, and flow of requests (e.g. via IP addresses, user agents, cookies) to balance load, detect unusual patterns, and prevent DDoS attacks.
• Security monitoring data: intrusion-detection alerts, firewall and access-log records, device fingerprints, and geolocation metadata to detect, investigate, and mitigate unauthorized access or malicious activity.
• Penetration testing & vulnerability scans: results and findings from internal or third-party security assessments, used to patch, update and harden our infrastructure.
• User feedback on stability and performance: direct feedback, surveys or bug-reports to prioritize fixes and feature improvements.

Lastly, we may use aggregate information about users for statistical, marketing, and other purposes. This information does not reveal the identity of, or any information about, you or any users.

Under applicable law, we must have a “lawful basis” for collecting and using your personal data and information.

We process your personal data on grounds of necessity for the performance of a contract, particularly regarding the activation of the services acquired by users following their acceptance of the Terms & Conditions of Use of the KBOO Platform, and our provision of the services to users, including account creation and management, payment processing, identity verification, and customer and technical support, or other queries.

We process your personal data on grounds of necessity of compliance with legal obligations, particularly with regards to identity verification / KYC obligations, anti-bribery and anti-fraud obligations, monitoring of illegal or fraudulent content, online safety and security, and reporting obligations.

We process your personal data on grounds of legitimate interest, such as (i) account and content monitoring, particularly its compliance with the applicable Community Guidelines, (ii) maintenance and improvement of Platform security, (iii) performance improvement (e.g. ensuring services’ availability), (iv) third party integrations, (v) product development and testing, (vi) improvement of our products and services (tailoring our products to best meet our customers’ needs), and (vii) market research and analytics (understanding trends to adjust and improve our products and services).

We process your personal data on grounds of consent for (i) our marketing activities, including our newsletters, (ii) gig and/or product announcements, (iii) feedback and customer satisfaction queries, and (iv) cookies and tracking pixels.

When you visit our websites and/or use our services, including the KBOO Platform, our system may collect information about your visit, such as your browser type, your IP address, and the referring website. This collection may take place in conjunction with our vendors and partners (e.g. external marketing agencies). We may receive from them general demographic or usage data of our site visitors. We do not use automatically collected information to identify you personally without your consent. Such information is typically collected using web cookies, web or email pixels (also known as beacons), embedded hyperlinks, and similar tools. Popular browsers can generally be set to disable or delete individual cookies. See below the types of cookies we use and their respective purposes.

• Necessary Cookies: enable the navigation and basic functionality of the websites, e.g., access to protected areas of the websites.
• Preference Cookies: enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
• Marketing Cookies: allow us to better assess the effectiveness of our content marketing and advertising efforts. These cookies are provided by our third-party partners to analyze and track site visits and signups stemming from advertising.
• Statistic Cookies: help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
• Unclassified Cookies: these are cookies that we are in the process of classifying, together with the providers of individual cookies.

We do not share your personal information thus collected (such as name or email) with third-party providers outside of site visit data collected directly by the Marketing Cookies. However, please note that your visit data may be linked with other personal information collected elsewhere by such third-party providers. Such external data processing is governed by the privacy policies of these third-party providers.

Our website stores various cookies that are required for the navigation and usage of the website (‘Necessary Cookies’). You can configure your browser to disable these Necessary Cookies. Note, however, that this may reduce the website’s and/or Platform’s functionality.

The following cookies may also be used, from time to time, on our website, and with various degrees of frequency depending on testing and business needs:

• Google Analytics (Statistic Cookies). Our website uses Google Analytics, a web analysis service of Google, Inc. (“Google”). Learn more from their Terms of Service and Privacy Policy.
• Google AdWords (Marketing Cookies). Our website uses Google AdWords Conversion Tracking cookie to measure and optimize the performance and user experience related to our ads in Google Search or selected Google Display Network sites. Learn more about Google’s privacy policy.
• Hubspot (Marketing Cookies). Our website uses Hubspot CRM by Hubspot Inc., an inbound marketing and sales software that helps companies attract visitors, convert leads, and close customers.
• LinkedIn Ads (Marketing Cookies). Our website uses LinkedIn Ads by LinkedIn Corporation, a paid marketing tool that offers access to LinkedIn social networks through various sponsored posts and other methods.
• X Ads (Marketing Cookies). Our website uses X Ads by X Corp., which allows advertisers to target content and promotions to Twitter users.

Please note that, with the exception of Necessary Cookies, you can opt-out of any and all cookies, at any time, through the cookie panel which is to be found in the left bottom corner of the website (cookiebot).

We do not sell or rent your personal data and/or information to any third party. We do not share your personal data or information with third parties, except as may be required for the provision of our services and as provided in this Privacy Policy.

KBOO operates from offices that may be located outside the European Union (i.e. USA, the Philippines) and that support KBOO in its service offerings, Platform management, product development and improvement, security maintenance, customer and technical support, as well as other activities that are core to KBOO’s products and services.

KBOO relies on third-party service providers to process personal data on our behalf. Such service providers support KBOO regarding identity verification, payment processing, the hosting and operating of our websites, marketing, analytics, improvement and development, and sending email newsletters. These processors may be located outside the European Union.

Our website may also include social media features (e.g., share or like buttons), which are provided by third-party social media platforms. Where data is collected this way, its processing is governed by the privacy policy of the respective social media platforms.

Our content may link you to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.

We may disclose your personal information to the extent required by applicable laws and regulations, and/or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the rights, property, or personal safety of KBOO, its users and customers, or any third party.

We use service-oriented criteria to determine the period of storage of your personal data, and we only keep your data for as long as is necessary in the context of the services we offer, as described in the Terms & Conditions of Use of the KBOO Platform, and for the purposes set out in this Privacy Policy, or for as long as may be required by applicable laws and regulations.

You may subscribe to our newsletters, blogs, and other promotional materials, at any time. You can also elect to unsubscribe or change your preferences, at any time, by either (i) contacting the data protection officer, or (ii) selecting the ‘unsubscribe’ option in any email sent to you as a part of the newsletter or other types of communication.

Further, with your consent, we may make use of email tracking technology to obtain certain data and information, such as IP address, your device and browser information, and whether an email has been opened/read or whether links that may be found within our email communications have been checked. This data will be automatically processed for the sole purpose of improving future marketing communications and/or assisting in prioritizing follow up messages based on perceived communications relevance.

KBOO implements appropriate technical and organizational measures to protect your personal data against unauthorized access or disclosure, misuse, and loss. Note, however, that no transmission of data over the Internet, nor method of electronic storage, is fully secure. Still, we strive to protect all data and information entrusted to us. All personal data is stored in secure environments, with documented access control processes and procedures. We provide relevant training to our employees on data protection best practices and require them to enter confidentiality undertakings.

To make a data protection rights request, please contact us using the contact details found on our contact page. If you make a request, we must respond to you without undue delay. However, please note that the lawful basis we rely on may affect your data protection rights which are in brief set out below.

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exceptions which means you may not receive all the information you ask for.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure – In some circumstances, you have the right to ask us to delete your personal information.
• Your right to restriction of processing – In some circumstances, you have the right to ask us to limit how we can use your personal information.
• Your right to object to processing – You have the right to object to certain processing of your personal data.
• Your right to data portability – In some circumstances, you have the right to ask that we transfer the personal information you gave us to another organization, or to you.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.