Introduction 

Kompato (hereinafter referred to as “Company”, “We” or “Us”), is the owner of the website domain at www.kompato.ai (“Platform”). 

Use of the Platform and sharing of Information by Visitors and Users (as defined herein below) is conditioned upon your acceptance of the terms and conditions contained in this privacy policy as available on the Platform (“Privacy Policy”) 

Use of the Platform and sharing of Information by Visitors and Users (as defined herein below) is conditioned upon your acceptance of the terms and conditions contained in this privacy policy as available on the Platform (“Privacy Policy”) 

Definitions 

‘Agreement’ shall refer to the Letter of Intent, Service Provider Agreement, Non-disclosure Agreement, the Tri-Party NDA and any other document executed between the User and Kompato that sets out the terms and conditions upon which the User shall use Kompato’s Services. 

‘Visitor’ shall refer to any person who browses the Platform and submits any inquiry on the Platform. 

‘User’ shall refer to any entity such as an individual, company, and partnership firm etc. who enters into the Agreement with Kompato. The Visitor and User may hereinafter be referred to as ‘you’ or ‘your’ as the case may be

 ‘Services’ shall refer to the services provided by Kompato to the User as detailed in the Agreement. 

About this Policy 

Kompato respects your privacy and is committed to protecting it through our compliance with this website Privacy Policy. Maintaining protection of the information entrusted to our care is of the utmost importance to Kompato. 

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our website and our practices for collecting, using, protecting, and disclosing that information. 

This Privacy Policy applies to information we collect or you submit to us through the Kompato website.  This Policy does not apply to information collected by or through websites, applications, or content operated by any third party. 

This Privacy Policy outlines our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not use our website. By accessing or using our website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy section below). Your continued use of our website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

How we Collect Personal Information 

As part of providing any of our Services to you, Kompato will, from time to time, collect, hold, process and share your personal information provided to us directly by you or other organizations that you have client relationships with or given to us in other forms.

 We will not collect and use any of your sensitive personal information unless it is necessary for us to provide our Services to you and with your prior consent or where a permitted general situation exists. 

You may provide basic information such as your name, phone number, address and email address, social media profile name to enable us to communicate with you when we provide our Services to you, when you contact us and when we provide you with updates. 

We may collect additional information at other times, including but not limited to, when you provide feedback, make a complaint, when you provide information about your personal or business affairs, change your content or email preference, provide financial or credit card information, communicate with our customer support teams or interact with us through our website, Services applications or digital communication channels. 

Additionally, we may also collect any other information you provide while interacting with us and when we manage our customer, client and service provider relationships and while employed by us. 

We may also collect personal information about you from third parties or organizations including our related companies, publicly available sources of information (such as public registers), your approved representatives, other organizations, who jointly with us, provide products or services to you, third-party websites, applications or platforms containing interactive InDebted content or that interface with our own websites and applications, social media platforms (if you publicly comment or send us a private message) and digital tracking tools such as cookies. 

When you visit our offices, CCTV footage may be recorded and other information that may be collected include details provided on a resume sent to us relating to an employment opportunity. 

We may also receive your personal information from third parties that we deal with on your behalf and from our clients and service providers. 

Any information we receive that we are not lawfully required to hold will be deleted or destroyed. 

How We Use Your Information 

Under applicable privacy laws (Privacy Laws) we are allowed to use your personal information in the following circumstances: 

1. to provide our Services to you and to fulfill a contract that we have with our clients and you;
2. when you provide your consent to our clients or to us; or
3. to comply with our legal and regulatory obligations as well as effectively manage our business risks; and/or
4. when it is necessary for the purposes of our legitimate interest. 

When we use your personal information for our legitimate interest it means that: 

1. processing your personal information is necessary and we cannot achieve the same outcome in any other way; and
2. we have undertaken a balancing exercise and ensuring that our interests are not outweighed by your interests, rights and freedoms. 

How We Disclose Your Information 

We will use or disclose your personal information held about you as permitted by law and for the business purposes for which it is collected. We may use your personal information on the following basis: 

1. where such processing is necessary for the performance of our contracts and compliance with our contractual arrangements with our clients including where we have contracts with our clients who place your accounts with us for collection;
2. to provide and manage our Services to you;
3. the proper management of our client and customer relationships;
4. to verify your identity and to authenticate you when you contact us;
5. when we communicate with you by sending you mail, email, telephone, SMS, mobile applications and social media platforms,
6. for legitimate business purposes;
7. using your personal information helps us to operate and improve our business, website, systems and minimize any disruption to the services that we may offer to you;
8. where we are processing information based on your consent;
9. to comply with our legal and regulatory obligations;
10. for the establishment, exercise or defense of legal claims, proceedings or in an administrative or out-of-court procedure;
11. for the purposes of obtaining or maintaining insurance coverage, managing risks and operations or obtaining professional advice;
12. for the purpose of fraud, crime prevention, suppression, or detection and help us run our business and maintain integrity;
13. ensuring workplace health and safety of our employees or enforcing our rights, making legal enquiries, or taking legal action; or
14. record-keeping purposes. 

When you are a client of our Services, we may also use your personal information to tell you about our Services we think may be of interest to you. 

We do not knowingly collect or process the personal information of anyone under the age of 18 years old. 

We may create statistical and anonymized reports, analysis and predictive models, rules and insights using information about you and other customers. Aggregated reports may also be shared with other businesses for business development and to provide insights into collection performance, identify customer demographics or behavioral insights and the information in these reports is not personal and cannot be used to identify you. 

We will not process your personal information for direct marketing purposes, and we will not sell your personal information to other companies or organisations. 

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. 

Automated Decisions Using Your Personal Information 

To provide an efficient and helpful customer experience we use automated decisioning in how we communicate with you. For example, if you communicate with us via email or SMS our system will automatically tailor communications with you based on your preferred digital method of communication, without any involvement of human intervention. We may also use automated decisions to detect and prevent fraud, detect and prevent money laundering and determining the most efficient and helpful way to provide our Services to you. 

How We Store Your Information 

We will keep your personal information securely whether in physical or electronic form. The security of your personal information is important to us. We will take appropriate technical and organizational precautions to secure your personal information and to prevent the loss, misuse, unauthorized access, disclosure or alteration of your personal information. 

We will store all your personal information on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems. 

Much of the information we hold about you will be stored electronically. We store your information in secure data centers via our cloud data storage service providers. 

How We Protect Your Information 

We use a range of physical, electronic and other security measures to protect the security, confidentiality and integrity of the personal information we hold and protect it from misuse, interference, loss and unauthorized access, modification and disclosure. For example: 

1. access to our information systems is controlled through identity and access management controls;
2. all of our employees are required to comply with our privacy framework and information security policies;
3. all of our employees complete training about privacy and information security;
4. we regularly monitor and review our security measures and compliance with internal policies and industry best practice; and
5. our contracted service providers are contractually bound to comply with the Privacy Laws and have appropriate information security measures and are obligated to keep the information secure. 

You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent to us by you over the internet and you do so at your own risk. 

Although we take measures to safeguard against unauthorized disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy. If you are concerned that the security of your interaction with us has been compromised, please contact us immediately by emailing us at [email protected] 

Also, our website may have links to external websites, and we take no responsibility for the privacy practices or the content of those other sites. 

Kompato Employees 

Access to your information is restricted to authorized employees who have a legitimate business purpose for using it. Unauthorized use and or disclosure of client and customer information by an employee of Kompato is strictly prohibited. All employees are required to maintain the confidentiality of client and customer information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal. 

Your Rights 

You have certain rights as to how your personal information is obtained and used and Kompato complies with your rights under the Privacy Laws as to how your personal information is collected, used and handled. 

Except as otherwise provided in the Privacy Laws, you generally have the following rights: 

1. if we rely on your consent to process your personal information, to withdraw your consent where we will stop processing the activities relevant to your consent;
2. to be informed how we received your personal information and how it is being used;
3. access your personal information (we will provide you with a free copy of it);
4. to object to us using your personal information, where we are relying on our legitimate interest to do so and we can challenge your objection and communicate with you in accordance with our legal obligations;
5. to correct your personal information if it is inaccurate or incomplete;
6. to restrict processing of your personal information including opt-out of the sale or sharing of your personal information (i.e., we will not sell your personal information); and
7. to not be subject to any retaliation for exercising your privacy rights. 

Please contact us at any time to exercise any of your rights under the Privacy Laws at the contact details in this Privacy Policy. We may ask you to verify your identity and provide us with additional information before acting on any of your requests. We will respond to you as soon as possible but within 30 days from the date of your request. 

Updates to this Policy 

This USA Privacy Policy was last updated last 15 October 2024