Privacy Policy
We appreciate your visit to our web pages and would like to provide you with some essential information regarding our commitment to the security and privacy of personal data.
By “Klever Website” we mean any web page (website, landing page, etc.) owned, managed or under the Klever umbrella. Example: https://kleverflows.com/contact/
Please check this section regularly as the policy may be subject to changes or updates. Any significant changes to this policy will be notified.
In addition to this policy, please see the Cookie Policy.
Who are we?
Klever (Kura Trading) is a marketing agency dedicated to online stores with over 5 years of experience, specializing in Email Marketing and Web development on the Shopify platform.
Information about the company Kura Trading
Kura Trading SRL (“Kura Trading”) has its registered office at Str. Piscului No. 5 Block 81, Ap. 35, Floor 5, Bucharest and is registered in the Trade Register under no. J40/10359/2023, with fiscal code no. RO48273862.
Klever contact details
Email: contact@kleverflows.com
Using the Klever.ro Website
By accessing or using any part/function of the Klever Website, you agree to accept and comply with the terms, conditions and policies mentioned and/or available via hyperlink and you are of minimum legal age in accordance with applicable national law. If you do not accept the terms, conditions and policies set forth in this documentation, then you should not continue to access our website and/or use our services.
Intellectual property rights
The content of the Klever Website: images, texts, web graphics, scripts, software, design rights, model rights, patents, registered trademarks, are the sole property of Kura Trading and are protected by copyright and related rights laws and by intellectual and industrial property laws. The use of any of the elements listed above without the consent of Kura Trading is punishable under applicable law.
Kura Trading may grant the user/client, through an agreement, the right to use certain content of the site in a described form. This agreement applies strictly to the content/contents defined, for a period established in the agreement and only to the person/persons who have been allowed to use these contents, without being able to use other contents of the Klever Website.
The use of any trademark name on the Klever Website does not constitute an endorsement of that company. Kura Trading assumes no responsibility and cannot be held liable for any damages arising from the use of the content of the website.
Please report any possible copyright infringement noticed on the site to contact@kleverflows.com.
Where do we collect data about you?
Generally, the personal data we collect is provided by you via email, through the Klever Website, social media networks, or during your visits to our premises.
Occasionally, when we are in the recruitment process, we may collect data about you from specialized online platforms (eJobs, LinkedIn, etc.) or from the CVs you send us.
Also, when you interact with us on social media (i.e. like, share, comment, review, etc.), we will inevitably have access to information about you, especially data that you have made public on your social media profile.
How we use personal data
Please find below the purposes for which we process your personal data, the people who have access to your data, and how we store it.
- When you interact with us through the contact channels available on the website or social media
If you interact with us using the contact details available on the contact pages/forms of the Klever Website or interact with us through the messenger functions of social networks (e.g. feedback, complaints, information requests, etc.), we will use your contact details and the data you communicate to us to provide you with information and offers regarding our services, to resolve the reported situation, to evaluate the degree of satisfaction of our customers and to continuously improve the services we offer.
Personal data | Name, surname, telephone number, email address, function, Internet Protocol (IP), cookie ID, data you have made public on your social media profile and any other data you voluntarily send us. |
Lawfulness of processing |
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Who can we share your data with? |
We will disclose your personal data only to the extent strictly necessary to achieve the intended purpose. We have taken all necessary steps to ensure that external service providers who have access to your data have also implemented physical, electronic and managerial security measures to protect the data. |
How long will we store the data? | We will not keep communications in our database older than 1 year from the date of the last interaction. Data transmitted through social media networks will be stored by them according to their own policies. |
Where is the data stored? | The data recorded through the Websites will be stored on the hosting provider’s servers, located in Romania. Data transmitted through social media networks will be stored by them according to their own policies. We will store the data we download locally on our secure, local and cloud servers. |
- Commercial and marketing communications
We may send you information about the services we offer if you have requested this information (for example, by subscribing to the newsletter) or if you are already our customer and this information may be of particular interest to you.
Personal data | Name, surname, email address, phone number |
Lawfulness of processing |
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Who can we share your data with? |
We will disclose your personal data only to the extent strictly necessary to achieve the intended purpose. We have taken all necessary measures to ensure that external service providers who have access to your data have also implemented physical, electronic and managerial security measures to protect the data. . |
How long will we store the data? |
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Where is the data stored? | We will store the data we download locally on our secure, local and cloud servers. |
Important:
If you no longer wish to receive newsletters or informational materials from the Klever Website, all you have to do is click the “Unsubscribe” button available in the email you receive, or send an email stating your desire to unsubscribe to contact@kleverflows.com and you will be unsubscribed from those communications.
- Processing candidate data in the recruitment, selection and talent assessment process
If you would like to join the Klever team, we invite you to contact us via the contact details or forms available on the Klever Website.
We will process the data you provide us when expressing your intention to join the Klever team and other additional information that we will request from you later, to analyze your real potential and motivation so that we can evaluate whether the information you have provided us corresponds to the employee profile we are looking for.
Important: The CV you send us must not contain sensitive data regarding (i) racial or ethnic origin (ii) political affinities (iii) philosophical or religious beliefs; (iv) membership of a trade union or political party; (vii) history of criminal offences or proceedings and related sentences or fines; (viii) commission of any illegal or inappropriate conduct and associated sanctions; or (ix) any national identification number of a person.
Personal data |
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Sensitive personal and/or demographic data | Sensitive and/or demographic information voluntarily provided by the candidate during the recruitment process, such as: citizenship and/or citizenship information, candidate medical or health information, racial, ethnic or religious origin data |
Lawfulness of processing | We process your data to take steps at your request before concluding a contract (Art. 6/1/b of Regulation (EU) 2016/679) |
Who can we share your data with? |
We will disclose your personal data only to the extent strictly necessary to achieve the intended purpose. We have taken all necessary steps to ensure that external service providers who have access to your data have also implemented physical, electronic and managerial security measures to protect the data. |
How long will we store the data? | We will not retain candidate data that is older than 3 years. |
Where is the data stored? | The data recorded through the Klever Website will be stored on the hosting provider’s servers, located in Romania. We will store the data we download locally on our secure, local and cloud servers. |
- Conclusion of contracts and execution of customer requests
We process in particular the personal data contained in the documents you send us and the information necessary for the conclusion and performance of contracts.
Personal data | Name, surname, phone number, email address, signature, role in the company |
Lawfulness of processing | We process your data for the conclusion and performance of a contract (Art. 6/1/b of Regulation (EU) 2016/679) |
Who can we share your data with? |
We will disclose your personal data only to the extent strictly necessary to achieve the intended purpose. We have taken all necessary steps to ensure that external service providers who have access to your data have also implemented physical, electronic and managerial security measures to protect the data. |
How long will we store the data? | We will not retain personal data older than 5 years, calculated from the moment of termination of the contract, with the exception of documents that are subject to retention conditions imposed by national legislation (for example accounting data). |
Where is the data stored? | We will store the data we download locally on our secure, local and cloud servers. |
- When you react to content on social media or share information from the site
We are present on Facebook, Instagram, LinkedIn, YouTube and TikTok. Whenever you interact with us through our accounts on these platforms (e.g. comments, likes, shares, reviews, etc.) we will have access to publicly available data on your profiles.
Personal data | Name, image and any other publicly accessible information in your social media profile or communication voluntarily made by you. |
Lawfulness of processing | We process your data to take steps at the request of the data subject before concluding a contract (Art. 6/1 / b GDPR) or in our legitimate interest (Art. 6/1 / f GDPR) to respond to any question, complaint or recommendation you send us and to improve our services and the experience we offer our customers and the legitimate interest in keeping you informed of the news that Kura Trading publishes and that may be of interest to you. |
Who can we share your data with? |
We will disclose your personal data only to the extent strictly necessary to achieve the intended purpose. We have taken all necessary measures to ensure that external service providers who have access to your data have also implemented physical, electronic and managerial security measures to protect the data. . |
How long will we store the data? | Data transmitted through social media networks will be stored by them according to their own policies. |
Where is the data stored? | The data is stored on the social network servers, located in the European Union or the USA. Marketing service providers (PR agency) will store the data on their own servers located We will store the data we download locally on our secure, local and cloud servers. |
- Facilitating easy and enjoyable navigation on our website
When you access our website, we collect data about you through online identifiers (cookies and IP), which are stored in log files.
We use this information to help us design our website to better meet the needs of our users. We may also use your IP address to help diagnose any problems with our servers and to administer our website, maintain the security of our website and prevent fraud, authorize the use of services available on our website, analyze trends, track visitor movements, and collect general demographic information to help identify visitor preferences.
You can find more information about cookies, as well as how to delete cookies and disable tracking by accessing the Cookie Policy available on our website.
Personal data | Internet Protocol (IP), general computer location, device (country level), website viewing history, timestamp, request/action, browser and operating system type and version Other information that is generated while you use our website, including when, how often and under what circumstances you use it |
Lawfulness of processing |
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Who can we share your data with? |
We will only disclose your personal data to the extent strictly necessary to achieve the intended purpose. We have taken all necessary steps to ensure that external service providers who have access to your data have also implemented physical, electronic and managerial security measures to protect the data. |
How long will we store the data? | There are session cookies and persistent cookies. While session cookies are deleted when you close your browser, persistent cookies may have a different lifespan depending on the purpose they serve. More information about the duration of use of the cookies we use can be found in the Cookie Policy. |
Where is the data stored? | The data collected through our own cookies will be stored on the hosting provider’s servers, located in Romania. Data collected through third parties that place cookies will be stored on their servers, located in the European Union or the USA. |
Is the data processed by Kura Trading secure?
Kura Trading pays special attention to the protection of your data and applies appropriate technical and organizational measures to ensure the protection of processed personal data, appropriate to the risks and categories of data protected, in particular, it protects the data against sharing it with unauthorized persons, taking it over by an unauthorized person, processing it in violation of applicable laws, as well as against the change, loss, damage or destruction of data.
However, please remember that unfortunately no data transmission is guaranteed to be 100% secure.
If you suspect a breach of the confidentiality of your data, please contact us immediately at: contact@kleverflows.com.
Important: After the data retention period has ended, your data will be deleted. If we believe that this data could help us improve the quality of our products or services, we will continue to use this data only after the data has been irreversibly anonymized.
Links to other websites
Please note that we are not responsible for the privacy practices of other websites or third parties. We encourage you to be aware when you leave our site and to read the privacy policies of each website that may collect personal information.
Processing of data of minors
Kura Trading Company is not intended for and does not knowingly collect information from minors under the age of 18 through the website. Access and use of the website by minors represents the implicit consent of the legal guardian in the navigation of our website by the minor under their care. Also, if we discover that a minor has used our website without the approval of the legal representative, we will delete all personal data about him.
International transfers of personal data
Kura Trading shares personal data with partners operating outside the European Economic Area (“EEA”).
List of international partners with whom we share data:
- Third parties that place cookies: Google (Google Tag Manager, Google Analytics and Google Ads), YouTube, Hotjar, Facebook Pixel, Linkedin, Tik Tok Pixel, OptinMonster
- Online platforms: Facebook, Instagram, LinkedIn, YouTube, TikTok
- Marketing automation tool (newsletter sending): Brevo
Personal data may be stored and processed in any country where we employ service providers. We may transfer the personal data we hold about you to recipients in countries other than the country in which the personal data was originally collected, including to the United States or Israel. These countries may have data protection rules that are different from those in your country. However, we will take steps to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected according to the standards described in this privacy policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may have the right to access your personal data.
Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms:
- EU Standard Contractual Clauses with a data recipient outside the EEA or the UK
- Verifying that the recipient has implemented binding corporate rules
- We will also ensure that all our international partners have adopted additional measures to provide adequate safeguards, enforceable rights and effective legal remedies. The role of these measures is to provide additional assurances to data subjects that data transfers based on standard contractual clauses or binding corporate rules provide a level of protection equivalent to that guaranteed within the European Union.
The rights you enjoy
As a data subject you have specific legal rights regarding your personal data that we collect and process. Kura Trading respects your rights and ensures that it takes your interests into due account.
- Withdrawal of consent: If the processing is based on your consent, you may withdraw your consent to that processing at any time.
- Data rectification: If you notice that we hold inaccurate personal data, you may at any time request that we rectify the personal data concerning you. We make reasonable efforts to keep personal data – which is used continuously and which is in our possession or control – accurate, complete, current and relevant, based on the most recent information available to us.
- Restriction of processing: If you are in one of the situations below, you can ask us to restrict the processing of your data:
- you contest the accuracy of the personal data for the period in which we need to verify the accuracy,
- the processing is unlawful and you request the restriction of processing rather than the erasure of personal data,
- we no longer need your personal data, but you request it for the establishment, exercise or defense of a right, or
- you object to the processing during the period in which we verify whether our legitimate reasons override your rights.
- Access to your data: You can ask us for information about the personal data we hold about you, including information about what categories of data we hold about you, what it is used for, where we collected it from, if not collected directly from you, and to whom it has been disclosed, if applicable. You can obtain a copy from us, free of charge, containing the personal data we hold about you. We reserve the right to charge a reasonable fee for abusive requests.
- Right to portability: Upon request, we will transfer your personal data to another controller, where technically feasible, provided that the processing is necessary for the performance of a contract. Rather than receiving a copy of your personal data, you can request that we transfer your data directly to another controller specified by you.
- Right to erasure: You can obtain from us the erasure of your personal data if:
- your data is no longer necessary for us in relation to the purposes for which it was processed;
- you object to further processing of your personal data (see Right to Object below);
- the personal data has been processed unlawfully;
- you withdraw your consent on the basis of which the processing takes place
Unless the processing is necessary:
- in order to comply with a legal obligation that requires us to process that data;
- in particular for legal requirements regarding data retention periods;
- for the establishment, exercise or defense of a right in court.
- Right to object: You may object at any time to the processing of your personal data on grounds relating to your particular situation. In this case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds and an overriding interest in the processing or in the establishment, exercise or defence of legal claims. When you object to the processing, please state whether you wish to have your personal data erased or to have the processing of your data restricted.
- Right to lodge a complaint: In the event of an alleged breach of applicable privacy legislation, you may lodge a complaint with the data protection supervisory authority:
- The National Supervisory Authority for Personal Data Processing by completing the online form available on the website www.dataprotection.ro
To remember!
Timeframe: We will try to resolve your request within 30 days. However, the period may be extended for reasons of specific legal right or complexity of the request.
Restricting access: In some situations, we may not be able to grant you access to all or part of your personal data due to restrictions set forth by law. If we deny your request for access, we will inform you of the reason for the denial.
Impossibility of identification: In some cases, we may not be able to identify your personal data due to the lack of identification elements provided in the request you send us. In such cases, if you do not provide additional information that allows you to be identified, we will not be able to comply with your request to exercise the legal rights as described in this section.
Exercising your rights
To exercise your legal rights, please contact our Data Protection Officer in writing at the email address contact@kleverflows.com.