Privacy Policy

Introduction

Keru AI Inc. is a Delaware corporation doing business as Kepler (“Kepler,” “we,” “us,” or “our”).

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes Kepler’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. If you are located in the European Economic Area (EEA) or the United Kingdom (UK), “personal data” means any information relating to an identified or identifiable individual. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

How we collect and use (process) your personal information

Kepler collects personal information about its customers. With a few exceptions, this information is generally limited to:

• name
• job title
• employer name
• work address
• work email
• work phone number

We use this information to provide prospects and customers with services.

We do not sell personal information to anyone.

Use of the Kepler website

As is true of most other web applications, Kepler’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system, and other usage information about the use of Kepler’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Use of Cookies

Our application utilizes “cookies,” which are small text files that are stored on your device (computer, smartphone, etc.) when you visit our website. These files are not harmful and do not contain any personal information. The primary purpose of these cookies is to enhance your browsing experience and to help us understand how you interact with our website.

Performance Measurement

We use a service called Datadog for frontend performance measurement. Datadog helps us understand how our website is performing, where any issues might occur, and how we can improve your experience. It provides us with aggregate data about site traffic and site interactions so that we can offer better site experiences and tools in the future. Datadog uses cookies to collect this data, but it does not have access to or control over these cookies once we have permitted it to set cookies for advertising.

Please note that these cookies do not in any way identify you or give access to your computer or mobile device. Datadog only provides us with information about how you use our website, such as the pages you visit, the time spent on those pages, and other statistics. This data is entirely anonymized and cannot be traced back to you.

Your Choices

Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website.

Legal bases for processing European information

If you are located in the European Economic Area or the United Kingdom, we only process your personal data when we have a valid “legal basis,” including as set forth below.

• Consent. We may process your personal data where you have consented to certain processing of your personal data. For example, we may process your personal data to use Cookies where you have consented to such use.
• Contractual Necessity. We may process your personal data where required to provide you with our web application. For example, we may need to process your personal data to respond to your inquiries or requests.
• Compliance with a Legal Obligation. We may process your personal data where we have a legal obligation to do so. For example, we may process your personal data to comply with tax, labor and accounting obligations.
• Legitimate Interests. We may process your personal data where we or a third party have a legitimate interest in processing your personal data. Specifically, we have a legitimate interest in using your personal data for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our web application. We only rely on our or a third party’s legitimate interests to process your personal data when these interests are not overridden by your rights and interests.

Transferring personal data to the U.S.

Our web applications are hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use our web application from the EEA, the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal data outside of those regions to the U.S. for storage and processing. We may transfer information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved or UK Government-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our web application. By providing any information, including personal data, on or to our web application, you consent to such transfer, storage, and processing.

Data Subject rights

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described below.

• You may request access to the personal data we maintain about you, update and correct inaccuracies in your personal data, restrict or object to the processing of your personal data, have your personal data anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your personal data to another company. In addition, you have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• You may withdraw any consent you previously provided to us regarding the processing of your personal data at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
• You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you. Kepler does not use the personal data described in this Privacy Notice to make such automated decisions about visitors to our website.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Notice. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal data for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our web application. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our web application using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our web application may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

Your U.S. State Privacy Rights

If you are a resident of California or another U.S. state that grants residents specific privacy rights, this section describes those rights and how we handle your personal information.

Categories of personal information collected. In the last twelve (12) months, Kepler has collected the following statutory categories of personal information:

• Identifiers (such as name, work email address, work phone number, and IP address)
• Professional or employment-related information (such as job title and employer)
• Internet or other electronic network activity (such as pages viewed and how you interact with our website)
• Geolocation data (general location derived from IP address, not precise location)

Sources. We collect this personal information directly from you when you contact us or request a demo, and automatically through your interactions with our website (including via Cookies and similar technologies).

Business or commercial purposes. We use the personal information described above to: (i) operate, maintain, and improve our website and services; (ii) respond to inquiries and requests; (iii) measure site performance and security; (iv) send marketing communications where permitted; and (v) comply with legal obligations.

Categories of recipients. We share personal information with service providers and contractors that help us operate our website, communications, analytics, and infrastructure (for example, cloud hosting and performance monitoring vendors). We may also disclose personal information to comply with legal obligations, enforce our agreements, or in connection with a corporate transaction.

Sale and sharing. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act (CCPA) and other applicable U.S. state privacy laws.

Sensitive personal information. We do not collect or process sensitive personal information for purposes that would trigger a right to limit its use under the CCPA.

Retention. We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Notice, including to satisfy legal, accounting, and reporting requirements.

Your rights. Subject to applicable law and verification of your identity, you have the right to:

• Know what personal information we have collected about you, the sources of that information, the purposes for which we use it, and the categories of third parties with whom we share it
• Request access to or a copy of your personal information in a portable format
• Request correction of inaccurate personal information
• Request deletion of your personal information
• Opt out of the sale or sharing of your personal information (note: we do not sell or share)
• Limit the use of sensitive personal information (note: we do not process sensitive personal information for purposes that trigger this right)
• Not receive discriminatory treatment for exercising any of these rights

How to exercise your rights. You may exercise these rights by emailing us at compliance@kepler.ai. We may need to verify your identity before responding. You may designate an authorized agent to make a request on your behalf, and we may require proof of the agent’s authority. California residents may also request information under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) by contacting us at the same email.

Data storage and retention

Your personal data is stored by Kepler on its servers, and on the servers of the cloud-based database management services Kepler engages, located in the United States. Kepler retains service data for the duration of the customer’s business relationship with Kepler and for a period of time thereafter, to analyze the data for Kepler’s own operations, and for historical and archiving purposes associated with Kepler’s services. Kepler retains prospect data until such time as it no longer has business value and is purged from Kepler systems. Retention periods vary based on the type of data, the purposes for which it was collected, and applicable legal requirements. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: compliance@kepler.ai

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Children’s data

We do not knowingly attempt to solicit or receive information from children under 16 years of age, and no parts of our web application are directed to children. If you learn that a child has provided us with information in violation of this Privacy Notice, please alert us at compliance@kepler.ai.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:

Keru AI Inc. (d/b/a Kepler)

compliance@kepler.ai