KURANI DOES NOT SELL PERSONAL INFORMATION TO OTHERS. Residents of the European Union (“EU”) and the State of California should refer to Section 9.0, Data Rights for information regarding their rights under applicable law.
1.0 HOW INFORMATION IS COLLECTED
Kurani typically collects personal information directly from the individual to whom it relates, except where that individual has consented to Kurani collecting the personal information from a third-party or the law otherwise permits Kurani to do so.
Kurani will collect and store your personal information when you interact with kurani.us. We collect information, some of which may contain personal information, by online applications as follows: (i) limited information is automatically collected about you when you visit kurani.us through the use of Google Analytics or Log Data (as discussed below); or (ii) you may voluntarily provide information, including personal information, to us by: (a) emailing Kurani about our services, employment, or internship opportunities, marketing, media requests, and other business matters; (b) by registering online to attend an event; or (c) downloading one of our online publications or resources.
Google Analytics is a free third-party service that uses “cookies” to measure, collect, analyze and report web data for purposes of optimizing the experience of users of kurani.us. Cookies are files with small amounts of data, that are sent to your browser from a website and stored on your computer’s hard drive. You can opt-out and prevent your data from being used by Google Analytics with the Google Analytics Opt-Out Browser Add-on.
Log Data is information your browser sends us whenever you visit kurani.us. Log Data may include information such as your computer’s browser type, the browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
Kurani does not make any attempt to use Google Analytics or Log Data to find out the identities of those visiting kurani.us. It is your responsibility to adjust your browser settings to accommodate your personal privacy preferences and, by your use of kurani.us without configuring your browser to Google Analytics or Log Data, you have consented to Kurani’s collection of information as discussed above.
Risk Intelligence Data is data obtained by Kurani to assess risk that may arise from a new business relationship. When considering a new business relationship, we may request additional information about a person or entity seeking to do business with Kurani such as: (i) details on the business entity (including date and place of incorporation, tax identification number, legal status, authorized representative, and other similar information); (ii) details on beneficial ownership interests (including identify of ultimate parent company and details on the identity of individual shareholders in the ultimate parent with significant ownership interests); and (iii) details on the relationship of the person or entity seeking to do business with Kurani to any official, officer, legislator, director, employee, or agent of any government of any tier or any state-owned entity. Risk intelligence data may include sensitive personal information on companies and individuals such as political activities, criminal allegations or convictions, regulatory inquiries or penalties, precise geolocation information, financial and banking information, reputational information, government issued identification numbers, relationships to sanctioned or otherwise politically exposed persons and organizations, and other similar information. Kurani uses risk intelligence data to analyze potential risks associated with new business associates. We will take reasonable steps to ensure all risk intelligence data that we store is current, accurate, complete, and confidential.
User-Supplied Personal Information. Kurani may request your name, email address, affiliated company and other contact information upon your request to contact individuals within Kurani or to download information from kurani.us. This information will be stored by Kurani and may be used by us to respond to your inquiry or to inform you of Kurani’s services or sponsored events. Users providing Kurani with this information consent to use of their personal information for marketing purposes.
2.0 TYPES OF PERSONAL INFORMATION COLLECTED
Personal information means any information relating to a person or their household that enables that person to be identified either directly or indirectly. Personal information that we hold about you may include your contact details (e.g. name, phone number, address and email address), IP address, language, gender and geolocation.
If you are a client, vendor or subconsultant, personal information that we hold about you may include the same information listed above, along with your date of birth, social media/network accounts, business address, email address, phone number and fax number, function/job title, company, types of services provided, and financial compensation. Kurani may request that you provide additional information such as your company’s legal status, date of incorporation, place of incorporation, your company’s related entities, your company’s shareholding details, your relationship to any government official, your company’s tax identification numbers, country of origin, business and professional licenses, your company’s insurer, broker and insurance policies, and other information you consent to provide us for purposes of performing contracts or services.
We will take reasonable steps to ensure the personal information that we store is current, accurate, complete, and confidential.
3.0 HOW PERSONAL INFORMATION IS USED
We will use your personal information, and may share your personal information with other parties acting on our behalf, for one or more of the following: (i) to conduct research about the use of our website; (ii) to improve services provided by Kurani; (iii) to assess and respond to a complaint you might make to us; (iv) for our own administrative purposes, including training our staff, conducting internal audits, improving our services or transferring assets as part of a sale, purchase or investment in the business; (v) if you are a client, vendor or subconsultant, to perform services or carry out our contract with you; (vi) for market research purposes; (vii) to make informed decisions about business relationships and to prevent inadvertent engagement in illegal or corrupt practices; (ix) to conduct investigations of suspicious or harmful activity; (x) to comply with Kurani’s regulatory and legal obligations; (xi) to manage risks related to Kurani’s contracts and services; and (xii) for marketing Kurani’s services or sponsored events. If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law.
4.0 INFORMATION FOR MARKETING PURPOSES
Where you have consented to us using your personal information for marketing purposes, we may use your information to conduct marketing and data analysis or to send you updates and news concerning Kurani and its business partners. If at any time after you have consented to us using your information for marketing purposes and you wish us to stop using your information for these purposes, please contact us by email at email@example.com.
5.0 GROUNDS FOR PROCESSING
To process your data lawfully we will rely on one or more valid legal grounds. The grounds we may rely upon include:
1. Your consent to a particular processing activity. For example, where you have consented to us using your information for marketing purposes;
2. Our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your information to prevent or detect fraud or abuses of our website;
3. Our compliance with a legal obligation to which Kurani is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
4. If you are a client, vendor or subconsultant, because processing your personal information is necessary for the performance of a contract or services.
6.0 DISCLOSURE OF YOUR PERSONAL INFORMATION
There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third-parties. This will only take place in accordance with the applicable law, for the purposes listed above, and pursuant to terms consistent with Kurani’s Third-Party Data Privacy Addendum. These scenarios include disclosure to: (i) Kurani’s subsidiaries, branches or associated offices; (ii) outsourced vendors or subconsultants to facilitate the provision of our services (including other professional service providers); (iii) third-party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons (including cloud service providers); (iv) another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event; (v) attorneys in connection with negotiation of a contract, dispute resolution, and other legal advice; (vi) tax advisors for purposes of tax filings, obtaining tax credits, negotiating tax liabilities, and other tax advice; (vii) public authorities where we are required by law to do so; and (viii) any other third-party where you have provided your consent. Further, we may disclose your information to any person as required by law and specifically to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting Kurani.
7.0 RETENTION OF PERSONAL INFORMATION
8.0 CONFIDENTIALITY AND SECURITY
9.0 DATA RIGHTS
Your rights regarding data collected and used by Kurani are subject to applicable law. Kurani will comply with a verified request to exercise your rights or provide you with a lawful basis for not doing so when applicable.
9.1 EU RESIDENTS
The EU GDPR provides EU residents with certain rights discussed below. EU residents may contact Kurani regarding any of these rights by email at firstname.lastname@example.org; Attention: Corporate Compliance Officer. Kurani will respond within a reasonable time following receipt of a verified data subject request, in any event, within the time period specified by law. Persons exercising these rights will be required to submit a proof of identity and residency in the EU at the time the request is made. EU residents have the right to:
1. Obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you by contacting us as directed above. Kurani may deny a request to obtain a copy of your personal information when: (i) providing access to information would have an unreasonable impact on the privacy of others; (ii) the information relates to a legal proceeding or an investigation; (iii) we are required by law or contract not to disclose the information; (iv) we have an option under law not to disclose the information and have formed a good faith view that it would be inappropriate to provide access; (v) we are unable to verify your identity or residency at the time the request is made; or (vi) it is otherwise lawful to refuse the request.
2. Correct your personal information. You may request that we rectify any inaccurate and/or complete any incomplete personal information by contacting us as directed above. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy.
3. Withdraw your consent to processing. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time by contacting us as directed above. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
4. Object to processing. You may, as permitted by law, request that we stop processing your personal information by contacting us as directed above.
5. Erasure. You may request that we erase your personal information by contacting us as directed above. We will comply, unless there is a lawful reason for not doing so.
6. Lodge a complaint. We suggest that you first contact us as directed above regarding any questions or complaints in relation to your rights or how we process your personal information. However, this does not limit your right to contact your local data protection authority directly.
9.2 CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (referred to as “Consumers”) with certain rights discussed below. Consumers may contact Kurani regarding any of these rights by email at email@example.com; Attention: Corporate Compliance Officer. Kurani will respond within a reasonable time following receipt of a verified Consumer request, in any event, within the time period specified by law.
Consumers exercising their rights will be required to complete a questionnaire and submit a proof of identity and residency in California. Verification of identity will require, at a minimum, two (2) forms of government issued identification (such as a passport and driver’s license) and (1) form of proof of residency (such as a utility bill) showing residency in California at the time the request is made. Kurani may request additional information it deems necessary or desirable to verify the identity of a person making a request under the CCPA for specific personal information. All information requested during the verification process shall be used solely for verification of identity and residency.
Consumers have the right to designate an agent to act on their behalf. Consumers wishing to do this and agents acting on behalf of Consumers should contact Kurani as provided above.
Kurani does not sell personal information as defined under the CCPA.
Consumers have a right to:
1. Request to Know. You have the right to obtain a copy of the personal information and the categories of personal information we hold about you by contacting us as directed above.
2. Request to Delete. You have the right to request that we delete your personal information by contacting us as directed above.
3. You have the right to receive Kurani’s products and services on equal terms regardless of whether you exercise your rights under the CCPA.
Our website may provide hyperlinks to websites owned and controlled by others. Kurani is not responsible for the privacy practices of any website that it does not own or otherwise control.
11.0 THIRD PARTIES
Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this policy and that they have consented to such collection, use and disclosure.
12.0 COMPLIANCE WITH PRIVACY LAWS
13.0 CHANGES TO THIS POLICY