Privacy Policy, V1.00

Last updated, September 08, 2022

Kugelblitz values your privacy and therefore has set up this extensive Privacy Policy in order to notify you when is data stored, what is being processed and what is being disclosed to other entities. Though Kugelblitz Gross is not an EU based organization, its privacy policy is the spirit of the GDPR and is in full and strict compliance with all Israeli privacy regulations. 

 

How Do We Collect Personal Data?

We collect data solely based on your use of our services; meaning by the way you browse and use our service, and the information you fill when engaging with our smart agent. You have no legal obligation to provide us with such data, but without providing it we may not be able to provide you with our services.

 

What Personal Data Is Retained About You?

We collect two types of Personal Data; the first is statistic information about your use of the service, such as the times you used our service, the engagement with our smart agent, your device and browser type, you visit time, IP address and referral. 

 

The second is the information that you when you interact with our smart agent including images and recordings.

If you provided us with contact information in a contact form, we may also retain that information.

 

What Non-Personal Data Is Retained About You? 

We retain some non-personally identifiable data, 

When you use our service, we retain your activity on the service, and other information we may receive from you, provided that you were notified explicitly on such collection or retention.

 

Do We Process Your Personal Data? 

We shall process the data through the service we provide to better understand how people use our service. We also use your contact information to contact you with updates and notifications regarding our services, which you may opt out of.

 

Do We Use Cookies In Our Service?

A Cookie is a small file stored on your computer which is used in interaction between your computer and our servers (or third party servers). Cookies may sometime be used to identify you. We use both first and third party cookies; these include the following services and for the following purposes:

- Google Analytics to better track user behavior

Who has Access to Your Data?

We provide access to your data, solely to our employees and contractors, that are under strict confidentiality obligations. Our employees and contractors use of your Personal Data is monitored.

 

When we provide information to third parties who provide us a portion of the services, they are also under an obligation to keep information confidential.

 

Which third parties do we use to process the Personal Data? 

We need to access WhatsApp, Cloudinary and Workflowy’s data and to send you messages and contact on your behalf. We also use Google Analytics to help manage our website visitors and receive statistic information about their use.

 

How Can We Contact You?

We may send periodical newsletters and we may send you updates; you may always opt-out of these services.

Your Personal Data Rights

Right of Access and Rectification

You have the right to know what personal data we collect about you and to ensure that such data is accurate and relevant for the purposes for which we collected it. You can receive a copy of your personal data, and to rectify such personal data if it is not accurate, complete, or updated. However, we may first ask you to provide us with certain credentials to permit us to identify you before rectifying, deleting, or reviewing.

Right to Delete Personal Data or Restrict Processing and Right to Withdraw Consent

You have the right to withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing your personal data based on your consent before its withdrawal. Please note that in most cases, withdrawal of your consent would most likely cause us to delete your personal data rather than cease processing. 

You have the right to delete your personal data or restrict its processing by ourselves and third parties. We may postpone or deny your request if your personal data is in current use for the purposes for which it was

collected or for other legitimate purposes such as compliance with legal obligations.

Right of Data Portability

Where technically feasible, you have the right to ask to transfer your personal data in accordance with your right to data portability. In order to apply for this, please contact us.

 

The Right to Lodge a Complaint

You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data.

 

Your California Privacy Rights and Do Not Track Notices

We do not convey your personal data to third parties for direct marketing purposes. 

However, if we did, then the California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding its disclosure of personal data to third parties for their direct marketing purposes.

To make such a request, please send us an email, and we will let you know that none of your personal data was shared. We are only required to respond to one request per customer each calendar year.

 

Your Brazilian LGPD Rights

Notwithstanding anything in this privacy policy, you may exercise your LGPD rights, including your rights for (i) confirmation of the existence of the processing; (ii) access to the data; (iii) correction of incomplete, inaccurate or out-of-date data; (iv) anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD; (v) portability of the data to another service or product provider, by means of an express request and subject to commercial and industrial secrecy, pursuant to the regulation of the controlling agency; (vi) deletion of personal data processed with your consent, except in the situations provided in Art. 16 of this the LGPD; (vii) information about public and private entities with which the controller has shared data; (viii) information about the possibility of denying consent and the consequences of such denial; (ix) revocation of consent as provided in §5 of Art. 8 of the LGPD.

 

We respond to “Do Not Track” signals

If you do not wish your browser to allow us to use trackers, please use your browser’s “Do Not Track” option.

Exercising Your Rights

We acknowledge you have the right to access and change the Personal Data we collect and process. If you wish to access or to correct, amend, or delete Personal Data, please send us an email. We will respond within a reasonable timeframe, but in any event, no later than permitted by applicable law. 

What Can You Do If You Feel Your Privacy Was Invaded? 

If You feel your privacy was invaded, you can always contact our privacy officer, by email or through our contact form, and file a complaint, our privacy officer will inspect the complaints within reasonable time and send you and answer promptly, our privacy officer also publishes periodical reports about such complaints, which you can find on our website or contact us directly. You can contact our privacy officer by email at privacy@fredo.ai

 

Assignment

We may assign any of our rights and obligations under this agreement to any entity which we transfer the operation of the Fredo service to, or as a part of a merger, reorganization or similar reconstruct.

Our Data Protection Officer

Our data protection officer is Liat Zioni You can contact her directly at privacy@fredo.il