Privacy Policy
Effective as of October 3, 2026.
California Notice at Collection/State Privacy Rights Notice: See the State privacy rights notice section below for important information about your rights under applicable state privacy laws.
Kaiyu Hsu ("Dataembed," "we," "us" or "our") provides Dataembed, a web research tool that turns a plain-English description into a verified, structured dataset (a "webset"). This Privacy Policy describes how Dataembed processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website at dataembed.com and the JSON API it serves) and the other activities described in this Privacy Policy (collectively, the "Service").
Notice to European users: Please see the Notice to European users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe", and "European" should be understood accordingly).
Index
- Personal information we collect
- Tracking & Other Technologies
- How we use your personal information
- Retention
- How we share your personal information
- Your choices
- Other sites and services
- Security
- International data transfer
- Children
- Changes to this Privacy Policy
- How to contact us
- State privacy rights notice
- Notice to European users
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your email address and your name. If you sign up with an email address, the Service uses the part of the address before the "@" as your name.
- Profile data, such as the password that you may set to establish an online account on the Service, which we store only in hashed form.
- Communications data based on our exchanges with you, including when you contact us by email, through social media, or otherwise.
- User-generated content and input data, such as the websets you create: the descriptions, notes and titles you give them, the criteria and enrichment columns that you or the agent define, and the results the Service finds for them (each result's web address, title and page text, a verdict for each criterion with the evidence quoted for it, and the value extracted for each column), as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. For a webset, this includes when it was created and last run and which search provider surfaced each result.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:
- Public sources, such as the publicly available web pages, including public profiles and posts, that the Service searches and reads to build your websets.
- Third-party services, such as GitHub, that you use to log into your Service account. This data includes your name (or, if you have not set one, your GitHub username), the email address of your GitHub account, your profile picture and your GitHub account ID, together with the access token GitHub issues for the sign-in, as made available to us based on your account settings on that service.
- Service providers that provide services on our behalf or help us operate the Service or our business, such as the search providers that return results for your websets.
Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your IP address and the user agent your browser sends, which identifies your browser type and version and your operating system. Each sign-in session records the IP address and user agent it was created from; the rate limiter on our sign-in service records the IP address of each request your browser makes to it, including the automatic check of whether you are signed in; and a webset you create without an account stores a one-way hash of your IP address, computed with a secret key, instead of the address itself.
For more information concerning our automatic collection of data, please see the Tracking & Other Technologies section below.
Data about others. Websets can be about people as well as companies, research, articles and posts, so the descriptions you submit, and the results the Service finds on public web pages, may include personal information about other individuals, such as their names, roles, profile links and passages quoted from pages that mention them. Please do not use the Service to compile information about a person unless the law allows you to do so.
Tracking & Other Technologies
Cookies and other technologies. Some of our automatic data collection is facilitated by cookies and other technologies. The Service uses the following, by category:
- Essential. These are necessary to allow the technical operation of the Service (e.g., they keep you signed in). The Service sets two first-party cookies, both served by us: a session cookie that keeps you signed in, which expires after seven days unless your use of the Service renews it and is deleted when you sign out; and, only while you sign in with GitHub, a cookie that expires after five minutes and protects that sign-in from forgery. You can block or delete them in your browser settings, but you will then be unable to sign in.
- Functionality / performance. These enhance the functionality of the Service. When you create a webset without an account, your browser keeps its id in browser web storage (local storage), up to the 20 most recent, so that the Service can move those websets into your account when you sign in; the ids are removed once they have moved. This storage is first-party and stays in your browser until you sign in. You can clear it in your browser settings, but websets you created without an account will then not move into your account automatically.
- Analytics. The Service does not use analytics cookies or any other analytics technology.
The Service shows no ads. We do not use advertising or social media cookies, and nothing on the Service tracks you across other websites.
Chat and other artificial intelligence ("AI") technologies, such as the AI models we reach through the Vercel AI Gateway, including those of Anthropic, OpenAI and Perplexity, that we use to operate the webset-building features that you can use to describe a dataset in plain English and have an agent plan, search for, verify and fill it in through the Service. Vercel and these model providers may access and use the descriptions, notes, criteria and columns you submit, the search queries the agent writes from them and the text of the web pages the Service reads, and the search providers Exa, Parallel and Firecrawl may access and use those search queries, in each case to facilitate the provision of the Service. None of them receives your account details.
For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide the Service, including building, storing and exporting your websets;
- enable security features of the Service, such as limiting how often anyone can try to sign in and how many websets can be created without an account;
- establish and maintain your user profile on the Service, including moving websets you created without an account into your account when you sign in;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages, such as password-reset emails; and
- provide support for the Service, and respond to your requests, questions and feedback.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including analyzing and improving the Service and promoting our business.
Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.
Retention
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
Specifically:
- We keep your account information until your account is closed, and each webset until it is deleted, either by you or by us when we close your account at your request.
- Deleting a webset permanently deletes it from our database, together with its search queries, criteria, columns, results and verdicts.
- A sign-in session expires after seven days unless your use of the Service renews it. Signing out deletes that session's record, including the IP address and user agent stored with it; the record of a session that expires without a sign-out is kept until your account is closed.
- The rate limiter on our sign-in service keeps the IP address of each request in a counter that expires one minute after its last request; expired counters are deleted as later requests arrive.
- A webset you create without an account keeps the hash of your IP address for as long as the webset exists, including after it moves into an account. The hash is used only to enforce the hourly limit on websets created without an account, and we do not attempt to recover your IP address from it.
- The ids of websets you created without an account stay in your browser's local storage until they move into your account or you clear them.
- A password-reset link expires one hour after it is sent.
How we share your personal information
We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection). We do not sell your personal information or share it with advertisers.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, AI providers and email delivery). They include:
- Vercel, which hosts the Service, including the agent that builds each webset, and operates the Vercel AI Gateway;
- a managed Postgres database provider, which stores your account and your websets;
- Exa, Parallel and Firecrawl, which run the search queries for your websets and return search results;
- the AI model providers we reach through the Vercel AI Gateway, such as Anthropic, OpenAI and Perplexity, which plan, search for and verify your websets from the descriptions, notes, criteria and columns you submit and the text of the pages the Service reads; and
- Resend, which sends password-reset emails and receives only your email address and the reset link.
The search and model providers handle the data they receive under their own privacy policies, and we never share your account details with them.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, such as GitHub, we may share your personal information with that third-party service. The third party's use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Dataembed, financing of Dataembed, or the sale, transfer or merger of all or part of Dataembed or its assets). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Dataembed as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. A webset you create without an account can be opened by anyone who has its link, who can then view, run, edit, export or delete it, or move it into their own account. Websets in your account are visible only to you. Information you choose to share with others, such as a webset's link or an exported webset, can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
Your choices
In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states and Europe can find additional information about their rights below.
Access or update your information. If you have registered for an account with us through the Service, you may review your account's email address and your websets by logging into the account, and you can change your password through "Forgot password?" on the sign-in page. To review or update other account information, email us at kai@kyh.io.
Cookies and other technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly: you will not be able to sign in, although you can still build websets without an account. You can also clear your browser's local storage, but websets you created without an account will then not move into your account automatically when you sign in.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals because the Service does not track you across other websites.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, such as GitHub, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
Delete your content or close your account. You can delete websets yourself at any time: once you are signed in, from your list of websets (websets you created without an account in the same browser move into your account when you sign in), or through the JSON API. Deleting a webset permanently removes it and its results. To close your account, email kai@kyh.io from the address on your account: we will delete your websets first, so that none is left behind, and then your account and everything else associated with it.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are based in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should read the important information provided below about transfer of personal information outside of Europe.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
If you have questions about our practices or if you would like to exercise any privacy related right that may be available to you, please contact us via one of the methods listed below.
- Email: kai@kyh.io
State privacy rights notice
Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the "State Privacy Laws").
This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states listed above, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. To confirm your identity, we will ask you to send your request from, or confirm it from, the email address associated with your account; if your request concerns websets you created without an account, we will ask you for their links.
For purposes of this section, the term "Personal Information" has the meaning given to "personal data", "personal information" or other similar terms and "Sensitive Personal Information" has the meaning given to "sensitive personal information," "sensitive data", or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws.
Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.
Information. You can request the following information about how we have collected and used your Personal Information:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you.
Appeal. You can appeal our denial of any request validly submitted.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out.
- Opt-out of certain processing for targeted advertising purposes. We do not process your personal information for targeted advertising purposes.
- Opt-out of or appeal profiling/automated decision making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.
- Opt-out of other sales of personal data. We do not sell your Personal Information within the meaning of State Privacy Laws.
Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.
Sensitive Personal Information. While we process certain categories of Sensitive Personal Information as described in this Privacy Policy, such as the login credentials for your account, we do not process Sensitive Personal Information for the purpose of inferring characteristics about consumers under the CCPA.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.
Exercising your right to opt-out of the "sale" or "sharing" of your Personal Information. We do not sell your Personal Information or "share" it for cross-context behavioral advertising, as the State Privacy Laws define those terms, so there is nothing to opt out of. If that ever changes, we will update this Privacy Policy first, offer a way to opt out, and honor Global Privacy Control ("GPC") signals as valid opt-out requests, as required by applicable law.
Exercising other state privacy rights. You may submit requests to exercise any of the other state privacy rights listed above via email to kai@kyh.io.
Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.
Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
Information practices. The following describes our practices currently and during the past 12 months:
- Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described above in the Privacy Policy.
- Retention. The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
- Deidentification. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.
Personal information that we collect, use and disclose. We have summarized the Personal Information we collect, the purposes for which we collect it and the third parties to whom we may disclose it by reference below to both the categories defined in the "Personal information we collect" section of this Privacy Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). This chart describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.
| Personal Information ("PI") we collect | CCPA statutory category | Purposes | Categories of third parties to whom we "disclose" PI for a business purpose | Categories of third parties to whom we "sell" or "share" PI |
|---|---|---|---|---|
| Contact data | Identifiers; California Customer Records (Cal. Civ. Code §1798.80(e)) | Service delivery and operations; Compliance and protection; Data sharing in the context of corporate events | Service providers (hosting, database and email delivery); professional advisors; authorities and others; business transferees | None |
| Profile data | Sensitive personal information (account log-in credentials) | Service delivery and operations; Compliance and protection; Data sharing in the context of corporate events | Service providers (hosting and database); professional advisors; authorities and others; business transferees | None |
| Communications data | Identifiers; California Customer Records (Cal. Civ. Code §1798.80(e)) | Service delivery and operations; Compliance and protection; Data sharing in the context of corporate events | Service providers (information technology); professional advisors; authorities and others; business transferees | None |
| User-generated content and input data | Identifiers; Professional or employment-related information; other categories, depending on what the content contains | Service delivery and operations; Compliance and protection; Data sharing in the context of corporate events | Service providers (hosting, database, AI and search providers); other users and the public, for websets created without an account; professional advisors; authorities and others; business transferees | None |
| Data from third-party services (GitHub sign-in) | Identifiers; California Customer Records (Cal. Civ. Code §1798.80(e)); Audio, electronic, visual or similar information (your profile picture); Sensitive personal information (account log-in credentials) | Service delivery and operations; Compliance and protection; Data sharing in the context of corporate events | Service providers (hosting and database); professional advisors; authorities and others; business transferees | None |
| Device data | Identifiers; Internet or other electronic network activity information | Service delivery and operations; Compliance and protection; Data sharing in the context of corporate events | Service providers (hosting and database); professional advisors; authorities and others; business transferees | None |
| Data about others | Identifiers; Professional or employment-related information; other categories, depending on what the public pages contain | Service delivery and operations; Compliance and protection; Data sharing in the context of corporate events | Service providers (hosting, database, AI and search providers); other users and the public, for websets created without an account; professional advisors; authorities and others; business transferees | None |
Additional information for California residents.
Shine the light law. Under California's Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. We do not disclose personal information to third parties for their own direct marketing purposes. You may send us requests for this information to kai@kyh.io. In your request, you must include the statement "Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email kai@kyh.io.
Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.
Notice to European users
General
Where this Notice to European users applies. The information provided in this "Notice to European users" section applies only to individuals in the United Kingdom and the European Economic Area (i.e., "Europe" as defined at the top of this Privacy Policy).
Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.
Controller. Kaiyu Hsu, who provides Dataembed, is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called 'UK GDPR' (as and where applicable, the "GDPR")). See the 'How to contact us' section above for our contact details.
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed below.
- Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity").
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation ("Compliance with Law").
- Where we have your specific consent to carry out the processing for the Purpose in question ("Consent").
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see 'How we use your personal information'.
| Purpose | Categories of personal information involved | Legal basis |
|---|---|---|
| Service delivery and operations | Contact data; Profile data; Communications data; User-generated content and input data; Data from third-party services (GitHub sign-in); Device data; Data about others | Contractual Necessity. For data about others, which the Service finds on public web pages, Legitimate Interests: we and our users have a legitimate interest in finding and checking information that is publicly available on the web. |
| Security | Contact data; Device data | Compliance with Law. Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks. |
| Compliance and protection | Any and all data types relevant in the circumstances | Compliance with Law. Legitimate Interests. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety. |
| Data sharing in the context of corporate events | Any and all data types relevant in the circumstances | Legitimate Interests. We and any relevant third parties have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). However, we would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate. |
| To create aggregated, de-identified and/or anonymized data | Any and all data types relevant in the circumstances | Legitimate Interests. We have a legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that the Service operates as intended. |
| Further uses | Any and all data types relevant in the circumstances | The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected. |
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for Compliance and protection purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other info
No sensitive personal information. The Service does not ask for sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership). If you choose to include sensitive personal information in the descriptions, notes, criteria or columns you submit, you consent to our processing it in accordance with this Privacy Policy solely to provide the Service to you. If you do not consent, do not include it.
No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.
Your rights
General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
- Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by email to kai@kyh.io. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://www.edpb.europa.eu/about-edpb/our-members_en
For users in the UK – the contact information for the UK data protection regulator is below:
The Information Commissioner's Office, Water Lane, Wycliffe House, Wilmslow – Cheshire SK9 5AF, Tel. +44 303 123 1113, Website: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
We are based in the U.S. and many of our service providers, advisers or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
It is important to note that the U.S. is not the subject of a general 'adequacy decision' under the GDPR – the EU-U.S. Data Privacy Framework and its UK Extension cover only organizations certified under them, and we are not certified. Basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information transferred to us, which is equivalent to that provided by relevant European laws.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
- Transfers to territories without an adequacy decision. We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above). However, in these cases: we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or, in limited circumstances, we may rely on an exception, or 'derogation', which permits us to transfer your personal information to such country despite the absence of an 'adequacy decision' or 'appropriate safeguards' – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at kai@kyh.io.
This template was prepared and made publicly available by General Legal, PC ("General Legal"). It is provided for general reference purposes only and does not constitute, and should not be construed as, legal advice, or an endorsement or review of any particular transaction in which it is used. Use of this template does not create an attorney-client relationship with General Legal. General Legal has not reviewed, and takes no position on, any modifications made to this document or the deal terms it is used to document.