October 3rd, 2022
This Policy is incorporated into, and is subject to, the Kommo Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Kommo Terms of Service.
“Client” means a customer of Kommo (QSOFT LLC).
“Client Data” means data of any type that is submitted to the Services by or on behalf of Client,including: data submitted, uploaded or imported to the Service by Users and data provided by or about People.
“People” (singular “Person”) means Client’s customers, potential customers, and other visitors.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“User” means a Client or an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
2. The Information We Collect
We collect different types of information from or through the Service. The legal bases for Kommo’s processing of personal data are primarily that the processing is necessary for providing the Service in accordance with Kommo’s Terms of Service and that the processing is carried out in Kommo’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.
2.1 Registration and contact information
We collect information about you when you register to use the Service and otherwise provide contact information to us via email, phone, or chat. This information may include your username, first and last name, email address or phone number.
2.2 Payment information
When you purchase the Service, we will also collect transaction information, which may include your credit card information, billing and mailing address, and other payment-related information. Any credit card information you provide is collected and processed directly by one of our two payment processors, Bank of America through First Data Software or PayPal through their online checkout service.
2.3 Technical, usage and location information
When a User or Visitor uses the Service, we automatically record certain information such as IP address, web browser or device type, location, pages viewed, dates and times of the visit and items clicked. This information is collected using various types of technology, including cookies, clear “gifs” or “log information.” We do not collect data regarding a particular user’s activity across websites or applications that are not owned by us. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens or clicks on a message.
2.4 Integrated Services
2.4.1 Integrated Services for Single Sign-On
2.4.2 Integrated Services: Google API Scopes
When you connect Google services to your Kommo account, we request the use of Google OAuth scopes. These are needed for the following reasons:
- https://www.googleapis.com/auth/gmail.insert: This scope is needed in order to read and modify the status of email data
- https://www.googleapis.com/auth/gmail.send: This scope is needed in order to send emails
- https://www.googleapis.com/auth/gmail.readonly: This scope is needed in order to read all email resources and their metadata (no write operations)
- https://www.googleapis.com/auth/userinfo.email: This scope is needed in order to view the email address
- https://www.googleapis.com/auth/userinfo.profile: This scope is needed in order to view personal information, including information you have made publically available.
- https://www.googleapis.com/auth/calendar: This scope is needed in order to read/write within your synchronized calendars
- https://www.googleapis.com/auth/adwords: This scope is needed in order to give our customers the ability to add and remove contacts from audiences in Google Ads based on their pipeline stage in Kommo
- https://www.googleapis.com/auth/drive.file: This scope is needed in order to give our customers the ability to create a template in Google Docs, and then use our bot to fill it in. It also allows the automatic creation and update of leads by syncing a Google Sheet with Kommo as well as exporting leads to Google Sheets
In compliance with Google’s requirements for restricted scopes:
- We only use your data to provide you with user-facing features, and these features were specifically authorized by you;
- We do not transfer your data to third parties, except in the case of Legal Compliance or a Change of Ownership (outlined in Sections 4.5 and 4.5);
- We do not use or transfer your data for serving advertisements, including retargeting, personalized, or interest-based advertising; and
We do not allow humans to read your data, unless
- You have permitted a member of our support team to view your data in order to assist you in solving a specific problem;
- It is necessary for us to investigate technical problems, in which case the data has been aggregated and anonymized.
App’s use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy , including the Limited Use requirements
2.5 Information from Other Sources
We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners and advertisers. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
2.6 Client Data
A Client or User may store or upload various data into the Service (“Client Data”), including information about their own clients and potential customers (“People”), as well as other Users of the Service, such as colleagues. Kommo has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to People concerning the collection and storage of Client Data in the Service.
2.7 Mobile Application
Our Mobile Application, Kommo, is available for Android in the Google Play store at https://play.google.com/store/apps/details?id=com.kommo.mobile and for iOS in the App store at https://apps.apple.com/app/kommo/id6443626329.
If you use our Mobile Application, we also collect the following information:
- Contacts. We may request access to your contacts to enable you to import and export contact information and use the caller ID feature. This includes collecting the following information from the contact: their name, phone number, email address and handle in messaging applications (e.g. Skype).
- Push notifications. We may request access to send you push notifications regarding your account or certain features of our application. After opting-in, you may change your notification settings at any time in your device’s settings.
3. How we use the information we collect
We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:
We use your information (not including Client Data) to operate, maintain, enhance and provide all the features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.
We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require Kommo to process Client Data, then the data will only be used in anonymized or aggregated form.
3.3 Communications section "For administrative purposes"
We may use a Visitor’s or User’s email address or other information (not including Client Data) to contact that Visitor or User
- For administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or
- With updates on promotions and events relating to the Service.
You have the ability to opt‐out of receiving any promotional communications as described below under “Your Choices.”
3.4 Cookies and Tracking Technologies
We use automatically collected information and other information collected on the Service through cookies and similar technologies to:
- Personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits;
- Provide customized advertisements, content, and information;
- Monitor and analyze the effectiveness of Service and third-party marketing activities;
- Monitor aggregate site usage metrics such as total number of visitors and pages viewed; and
- Track your entries, submissions, and status in any promotions or other activities on the Service.
You can obtain more information about cookies by visiting http://www.allaboutcookies.org
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
4. To Whom We Disclose Information
Please see section 2.4.2 for details about our use of Google API restricted scope user data.
Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
4.1 Unrestricted Information
Any information that you voluntarily choose to include in a Public Area of the Service, such as leaving a comment on a blog post, will be available to any Visitor or User who has access to that content.
4.2 Service Providers
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
4.3 Certified Kommo Expert Partners
We do not sell personal information about you. However, we may share your information with Certified Kommo Expert Partners in order to:
- Improve or customize our services;
- Provide support or technical services;
- Offer you additional value-added services including, but not limited to, CRM set-up and onboarding.
Our Certified Expert Partner list is available here: https://www.kommo.com/partners/
4.4 Non Personally Identifiable Information
We may make certain aggregated, non-personally-identifiable information available to third parties for various purposes, including
- Compliance with various reporting obligations;
- For business or marketing purposes; or
- To assist such parties in understanding our Clients', Users' and Visitors' interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
4.5 Law Enforcement, Legal Process and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to
- Take precautions against liability,
- Protect ourselves or others from fraudulent, abusive, or unlawful uses or activity,
- Investigate and defend ourselves against any third-party claims or allegations,
- Protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or
- Protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
4.6 Change of Ownership
5. Your Choices
5.1 Access, Correction, Deletion
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “How to Contact Us” section. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page in the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit 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.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at firstname.lastname@example.org. You also have a right to lodge a complaint with data protection authorities.
5.2 Navigation Information
You may opt out from the collection of information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
5.3 Opting out from Commercial Communications
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
Kommo has no direct relationship with the Client's customers or third parties whose Personal Data may be processed on behalf of a Client. Any Person who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User directly. If the Client requests for Kommo to remove the data, we will respond to the request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the “How to Contact Us” section, and include sufficient information for Kommo to identify the Client or Person or third party and the information to delete or amend.
6. Third-Party Services
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators' policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties' privacy and security policies before providing them with information.
7. Privacy Shield
In compliance with the Privacy Shield Principles, QSOFT LLC commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact QSOFT LLC at email@example.com.
QSOFT LLC has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles and the Swiss-U.S. Privacy Shield Principles to JAMS, a non-profit alternative dispute resolution provider located in the United States to assist with the complaint resolution process. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. The services of JAMS are provided at no cost to you.
QSOFT LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) to ensure compliance with the EU-US Privacy Shield Principles and the Swiss-U.S. Privacy Shield Principles outlined in this notice.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may also be able to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Kommo shall comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
8. Your California Privacy Rights
We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
- Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you;
- Remember your settings on the pages you visit, so that we can display your preferred content the next time you visit;
- Display personalized content and targeted advertisements on our Service as well as on other websites and services;
- Perform analytics, and measure traffic and usage trends, and better understand the demographics of our users;
- Diagnose and fix technology problems; and
- Otherwise plan for and enhance our Service.
10. Do Not Track Policy
California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal. We continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.
In the meantime, you may opt out of receiving interest based advertising from advertising networks that may be delivered on our platform and other websites by visiting the following websites. If you want to opt out of this online behavioral advertising, visit the following sites: http://www.aboutads.info/consumers and http://www.networkadvertising.org.
This will opt you out of many, but not all, of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices. Other third-party Sites provide visitors with the ability to opt-out of receiving interest-based ads on their Sites that you need to control through your settings on that Site. For example, to opt out of Google's use of your online behavior for advertising purposes, visit Google's Ad Settings page.
11. Third Party Tracking And Interest-Based Advertising
We may permit third parties to collect data about your use of our Site to understand the various activities and behaviors of our Clients, Users and Visitors. We do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide useful and relevant ads - for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.
Typically, though not always, these third parties collect information through cookies or similar tracking technologies, which recognize the device you are using and collect information about your online browsing behaviors so that they may personalize the ads you see.
We may use and support one or more Google tools including without limitation, Google Analytics (including Universal Analytics), (hereinafter, collectively, “Google Analytics”), Google AdWords (including Smart Pixel), Google Developer Console, Google Displaying Advertising and Google Customer Match which may include, without limitation, one or more of the following features:
- Remarketing (as such term is defined below),
- Google Display Network Impression Reporting,
- The DoubleClick Campaign Manager integration, and
- Google Analytics Demographics and Interest Reporting.
We connect Google Analytics with Google Developer Console in order to better understand user behavior in connection with the applications we provide. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Site or other sites on the Internet.
You may opt out of the use of Google Analytics for Display Advertising (including disabling the DoubleClick Cookie for interest-based advertising, if applicable) and customize Google Display Network ads by visiting the Google Ads Settings page. Even though you may opt out of the use of such Google services, we may still use other third party services, including, without limitation, to collect and/or analyze data.
We use remarketing with Google Analytics (including Universal Analytics) and/or Google Adwords (including Smart Pixel) (collectively, “Remarketing”) to advertise online including after you've visited our Site. Remarketing may be based on your interests, location and other information collected about you in compliance with Google’s Policy For Advertising Based On Interests And Location. In connection with Remarking and otherwise
- We and our third party vendors, including, without limitation, Google, may show you ads on sites across the internet, and
- We and our third party vendors, including, without limitation, Google, use first party cookies (including, without limitation, the Google Analytics cookie) and third party cookies (including, without limitation, the DoubleClick cookie) to inform, optimize and serve you ads based on your past visits to our Site. We also use third-party tags (including, without limitation, Twitter conversion tag, Facebook conversion tag, LinkedIn conversion tag, Capterra conversion tag, Quora conversion tag, Crozdesk conversion tag, Yandex metrika, Adwords conversion tag and Google Tag Manager) in connection with our online marketing and analytics.
- We and our third-party vendors, including Google, may also use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Site.
You may opt out of having your activity tracked by Google Analytics (e.g. through cookies) by following the instructions contained in Section below entitled “Information about Unsubscribing and Opting Out.” In connection with our use of Google Analytics Demographics and Interest Reporting we use data from Google's Interest-based advertising or 3rd-party audience data (such as age, gender, and interests) with Google Analytics for several purposes, including, without limitation:
- Understanding our audience and the interests and demographics of the Site's users,
- Improving Site content to better serve our audience,
- Segmenting Remarketing campaigns by demographics, location or interests, and/or
- Targeting ads in Google Adwords.
12. Information About Unsubscribing And Opting Out
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google's Ad Settings page. Google also allows you to install the Google Analytics Opt-out Browser Add-on for your browser. The Google Analytics Opt-out Browser Add-on provides visitors with the ability to restrict their data from being collected and used by Google Analytics via the browsers where it is installed.
Our interest-based ads may be served to you on third-party platforms, such as Facebook. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.
Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all – of the interest-based advertising activities in which we or third parties engage.
13. Minors and children's privacy
Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at firstname.lastname@example.org and request that we delete that child's Personal Data from our systems.
14. Data Security And Data Transfer
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
We may store all Personal Information we collect anywhere in the world, including but not limited to, in the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers.
15. Data Retention
How long we retain your Personal Data depends of the type of data and the purpose for which we process the data, which is explained further in the section “The Information We Collect”. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. If you wish to request that we no longer use your data, please contact us at email@example.com. Except as otherwise set forth below, Personal Data contained in the Service Data is retained and deleted in accordance with the Terms.
Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
17. Additional Users
When you add additional Users to your account we send them an invitation to join our site and request that such Users provide us with certain additional contact information including their email addresses. When you use such a service, you represent and warrant to us that you have an existing business or personal relationship with the invited User, sufficient to avoid liability under any law that applies to unsolicited email. You will be deemed to be the sender of any such email (or other electronic communication), and we will be deemed to merely be a service provider facilitating your sending of the email (or other electronic communication).
18. Data Controller And Data Processor
Kommo does not own, control or direct the use of any of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. Kommo is unaware of what Client Data is actually being stored or made available by a Client or User to the Service and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client and its Users.
The Client or the User is the data controller under the Regulation for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.
Kommo is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors' servers) at the discretion of the Client or User nor is Kommo responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.
19. Changes And Updates To This Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
20. How To Contact Us
Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at firstname.lastname@example.org.