PRIVACY POLICY

PURPOSE OF POLICY

Kruze is committed to protecting your privacy. This Privacy Policy (“Policy”) covers how we collect, use, store, and share your information in connection with your use of the Kruze website at https://kruzeconsulting.com (“Website”), any related applications, products and platforms, and in connection with our marketing and client intake practices (collectively with the Website, the “Service(s). This Policy does not cover our data practices for Kruze clients in their capacity as clients which is subject to the terms of engagement letters between Kruze and its clients, nor data practices related to scenarios where Kruze enters into a nondisclosure agreement (or similar agreement) with prospective clients. Any conflict between the terms of this Policy and engagement letters or nondisclosure agreements shall be construed in favor of the terms in the applicable engagement letter or nondisclosure agreement. All references to “we”, “us”, “our”, or “Kruze” refer to Kruze Consulting, Inc., a California professional corporation. All references to “you”, “your”, or “user” refers to Website visitors and individuals who have opted to provide Personal Information to us on our website to receive marketing information from us or to request more information and/or a consultation with us (“Interested User”). Do not hesitate to contact us at support@kruzeconsulting.com if you have any questions or want to discuss this Policy.

By visiting and continuing to use the Website and/or by opting to become an Interested User, you agree to this Policy, and you consent to the privacy practices described in this Policy.

CHILDREN’S PRIVACY

The Website is intended for a general audience and is not intended for use or access by children under 18 years of age without parental consent, and we do not knowingly collect information about children or sell products to children.

INFORMATION WE COLLECT AND HOW WE USE IT

We collect several types of information from you and about users of our Services, such as Personal Information when you sign up as an Interested User on our Website or order our Services. Personal Information means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address, and telephone number (“Personal Information”). Other types of information we collect is information related to how you use our websites and applications, which helps us improve our Services.

You expressly consent to receiving communications from Kruze through the information you provided to us. For more information on how to access and control your communication preferences, please see the YOUR RIGHTS and the YOUR CHOICES REGARDING YOUR INFORMATION, sections of this Notice below. When you provide us with information in connection with a particular activity or otherwise sign up for or order our products and Services or provide your contact information to us, including your email address or telephone number in connection with that activity, product or service, you agree that such action constitutes a purchase or inquiry establishing a business relationship with us.

Information You Voluntarily Provide Us.

While you have the right not to provide us with this information, we may not be able to contact you about our offerings and consultations if you choose not to provide us with such information and Personal Information.

In addition, we may now or in the future offer forms or other functionalities on the Website which allow users to contribute information about their business, such as calculators for business tax estimates. In the event that you choose to provide information through such forms, we may analyze such data and use such data in anonymized and aggregated form for marketing purposes.

Tracking Technologies

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Tracking Technologies”) to automatically collect information through the Services. Tracking Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and Services. Depending on the specific Tracking Technology, we, our online data partners or vendors may use Tracking Technologies to associate these activities with other Personal Information they or others have about you, including by association with your email or online profiles. We (or service providers on our behalf) may then send communications and marketing to these emails or profiles.

• Pixel Tags/Web Beacons.

A pixel tag (also known as a web beacon) is a piece of code embedded on the Website that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

• Cookies.

A cookie is a small text file that can be stored on and accessed from your device when you visit and use our Website. We use cookies to analyze trends, administer the Website, and track users’ movements around the site.

Please review your web browser settings to modify your cookie settings, to disable the use of cookies, or to delete cookies. Please note that third parties such as advertisers or analytics providers may also use cookies and similar technologies while you are browsing or using the Website. We unfortunately have no control over such third parties’ use of these technologies.

Cookies can be categorized in different ways:

• First-Party vs. Third-Party Cookies: As the name implies, first-party cookies are put on your device by Kruze. Third-party cookies are placed on your device not by Kruze, but by a third-party. Kruze does not use first-party cookies, but it does use third-party cookies. Third-party cookies may include the Analytical tools described below.
• Analytics.
  • We may use Tracking Technologies and other third-party tools to process analytics information about our Services. These Tracking Technologies are used by us and our third party service providers to analyze how the Website is used and how the Website is performing. Tracking Technologies may collect information about your activities to provide you targeted advertising and to measure the effectiveness of our marketing campaigns. The third-party service providers that generate these Tracking Technologies, including, for example, Facebook, LinkedIn, and Google, have their own privacy policies, and may use their technologies to target advertising to you on other websites, based on your visit to our Website.
  • Tracking Technologies we use include:
  • Google Analytics. We use Google Analytics to analyze our web traffic and improve user experience. For more information on these cookies, please see here. To opt out of Google Analytics’ cookies, consider the web browser add-on available here.
  • RB2B. We may use RB2B to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about RB2B, please visit RB2B’s privacy policy, or opt out here.
  • You can generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising (DAA) by visiting the opt-out pages on the NAI website (http://optout.networkadvertising.org) and DAA website (http://www.aboutads.info/choices/).

 Do Not Track Signals.

To the extent that we receive any Do-Not-Track signals, we will not comply with them as we do not track users’ online activities over time and across third-party websites or online services.

MANAGE COOKIE PREFERENCES

Cookie Preferences

THIRD PARTY SERVICES AND PRACTICES ARE BEYOND OUR CONTROL

Our Website and Services utilize numerous third-party services as part of the functionality of the Service. We may share your Personal Information with third parties as explained in this Policy. We have no control over such third parties. We encourage you to review the privacy practices of such third parties. We make no guarantees about, and assume no responsibility for, the information, services, or data/privacy practices of third parties.

HOW WE SHARE YOUR PERSONAL INFORMATION

Our Personnel.

To be able to effectively provide you with the Website and to inform you of our Services as an Interested User, and to improve the functionality of the Website and our Services, we may disclose your Personal Information to our personnel, including our employees, contractors, and agents,

to the extent that such persons or entities have a need-to-know such information in furtherance of their job functions as service providers of Kruze.

Our Service Providers.

We may provide your Personal Information to third party service providers to provide website hosting, maintenance, data processing, customer service, customer relationship management, and other services for us in furtherance of our Services.

Our Advertising Partners

As described above (see “Tracking Technologies”) we partner with third party advertisers to display advertising on the Website. Our ad network partners use cookies and web beacons to collect user information about your activities on the Website and other websites to provide you targeted advertising based upon your interests.

Sale of Company or Assets.

In the event that we sell all or substantially all of our company or its assets, including the Personal Information collected by us as described herein, we may transfer your information to the acquiring company with or without notice to you.

Other Third Parties.

In addition to our practices described above, we may share your Personal Information if we have a good-faith belief that such action is necessary to (1) comply with the law (see the section below on “Government Requests”), (2) protect and defend the rights or property of Kruze, or (3) prevent an emergency involving danger of death or serious physical injury to any person.

STORING YOUR PERSONAL INFORMATION

Duration of Storage of Your Personal Information.

We will store your Personal Information until you request that we delete such data, at which time we will do so to the extent technically feasible within a reasonable period of time following such request. However, if required by applicable law, we may retain your Personal Information for such period as may be required by such law. To continue to provide an effective service, we may store your Personal Information perpetually and may anonymize your Personal Information and store that anonymized information perpetually.

Security.

We use reasonable efforts to secure your Personal Information and to prevent the loss, misuse, and alteration of the information that we obtain from you. For example, we require our personnel and third-party vendors to sign confidentiality agreements. In addition, we use reasonable technical safeguards such as encryption and secure hosting provided by industry leading third party vendors, to secure your Personal Information. However, loss, misuse, and alteration may occur despite our efforts to protect your Personal Information. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration.

YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION

You have several ways to exercise control over your information:

• E-Mail: You may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.
• Providing Consent: * * You may * * choose whether to receive from us offers and promotions for: our products and services, the products or services of third parties, or products and services that we think may be of interest to you, by providing your consent (for example, by clicking an unticked checkbox).
• Contact Us: * * You may contact us at support@kruzeconsulting.com to learn more about your rights and choices regarding your Personal Information.

Please be aware that if you do not allow us to collect Personal Information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our Services may not be able to take account of your interests and preferences.

YOUR RIGHTS REGARDING YOUR INFORMATION

Depending on where you are located, you may have certain rights regarding your Personal Information. Residents of certain jurisdictions may access, correct, update or delete your Personal Information; object to our processing of this information, ask us to restrict our processing of your Personal Information, or request portability of your Personal Information. Please see the please see the (YOUR RIGHTS REGARDING YOUR INFORMATION and the YOUR CHOICES REGARDING YOUR INFORMATION), sections of this Privacy Policy ** ** to learn more about exercising your rights. Upon request, Kruze will provide you with information about whether we hold any of your Personal Information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you submit a request to access all Personal Information you’ve submitted, we will respond to your request to access within 30 days or as otherwise required by law.

We will use commercially reasonable efforts to honor your requests for deletion; however, certain residual information may actively persist on the service even if you close your account. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information, we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the service. Bear in mind that neither you nor Kruze can delete all copies of information that has been previously shared with others on the service. If your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Services. Please note that our Services require a minimum amount of Personal Information in order to function. Individuals who do not provide Personal Information (e.g., by not filling out a profile) may not be able to access the full functionality of features found on Kruze.

California Residents – Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) and California Consumer Privacy Rights Act, amending the CCPA (“CPRA”) (collectively the CCPA and CPRA are the “California Privacy Laws”) provide you with additional privacy rights with respect to our collection, use and disclosure of your Personal Information, including:

• The right to know what Personal Information we have collected and how we have used and disclosed that Personal Information in the 12-month period preceding your request.
• We collected the following categories of Personal Information in the last 12 months: identifiers/contact information, commercial information, customer records information, Internet or other electronic network activity information, geolocation data, and inferences drawn from the above.
• The sources of Personal Information from whom we collected are directly from users, analytics tools, social networks, and third-party services that update or supplement information we hold about you.
• Please see the above section within this Notice titled INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT, to see the full list of categories of Personal Information we have collected about you.
• Please see the above sections please see the YOUR RIGHTS and the YOUR CHOICES REGARDING YOUR INFORMATION, sections of this Notice, to see applicable business or commercial uses and disclosures of your Personal Information.
• The right to request deletion of your Personal Information.
• The right to be free from discrimination related to the exercise of any of your privacy rights.
• The right to opt out of the sale of your Personal Information, and to request information about whether we have sold your Personal Information in the past 12 months.
• To the extent that our disclosure of Personal Information to the third parties described above in the HOW WE DISCLOSE AND SHARE YOUR INFORMATION section is considered a “sale” as defined under California Privacy Laws, we do not “sell” and have not “sold” Personal Information in the previous 12 months.
• The right to correct inaccurate Personal Information.
• The right to limit the use and disclosure of Sensitive Personal Information.
• The right to access information related to and opt-out of the use of automated decision-making technology.

For more information on how to exercise any applicable rights you may have under California Privacy Laws, please contact us at support@kruzeconsulting.com. Please note that we may require you to verify your credentials, by matching your e-mail address, or other account information to the information in our systems, before you can submit a request to exercise any of these rights. If you authorize another person to act as your agent to submit requests on your behalf, then unless you provide the agent with power of attorney under the California Probate Code, we will ask the agent to provide us the written and signed authorization that you provided to the agent, we will confirm with you that you did provide the authorization, and we will verify your identity.

INTERNATIONAL JURISDICTIONS

Our Services are hosted and offered in the United States of America (US), and are subject to, and comply with all applicable US laws. If you are accessing the Services from another country, please be advised that you may be transferring your Personal Information to us in the US, and you consent to that transfer, processing and storage of your Personal Information in accordance with this Privacy Notice. You also agree to abide by the applicable laws of your jurisdiction as they concern your use of the Services and your agreements with us. Any persons accessing our Services from any jurisdiction with laws or regulations governing the use of the Internet, including the collection, use, or disclosure of Personal Information, different from those of the jurisdictions mentioned above may only use the Services in a manner lawful in their jurisdiction. If your use of the Services would be unlawful in your jurisdiction, you may not use our Services.

GOVERNMENT REQUESTS

From time to time, we may receive requests from government agencies to obtain information about users. In handling such government requests, we greatly value the privacy of your Personal Information, however, we may turn over your information in accordance with such requests if we believe such action is warranted.

7. THIRD PARTY SERVICES AND PRACTICES ARE BEYOND OUR CONTROL

Our Website and services utilize numerous third-party services as part of the functionality of the Service. We may share your Personal Data with third parties as explained in this Policy. We haveno control over such third parties. We encourage you to review the privacy practices of such third parties. We make no guarantees about, and assume no responsibility for, the information, services, or data/privacy practices of third parties.

CHANGES TO THIS POLICY

We may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your Personal Information, we will update the Last Modified date at the top of this Policy upon becoming effective. We may also notify you by email, at our discretion. Your continued access to our Services after we make changes is deemed to be acceptance of those changes.

PLEASE REACH OUT TO US WITH ANY QUESTIONS OR FEEDBACK

If you have any questions or comments about this Policy or our Service, please feel free to contact us by email at support@kruzeconsulting.com