Privacy Statement
California and Applicable State Law
1. Background
This privacy statement for California and other applicable US state residents supplements the information contained in our Privacy Policy. Klarifi has adopted this statement to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act (collectively the “CCPA”) and other California privacy laws, as well as other states’ laws in or coming into effect at various times during 2023 (“Other Applicable States”), and it applies solely to residents of those U.S. states.
2. Information Klarifi Collects
Klarifi collects personal information. We have collected the categories of personal information indicated below within the last twelve (12) months:
Identifiers
- Personal Information Collected:
- Internet Protocol address
- Online identifiers, such as Cookie IDs
- Business email address
- Job title and department
- Business phone numbers (general, direct and fax)
- Business related postal address of consumer
- Social Networking URLs
- Categories of Sources from which this Personal Information was Collected:
- Publicly available information
- First-hand research
- Third-party data vendors
- Directly and indirectly from activity on Klarifi’s website
- Directly and indirectly from our customers or their representatives
- Directly from vendors and other contractual counterparties
- Through communications with prospective customers and other businesses and their representative
- Purpose for Collection of this Personal Information:
- To fulfill or meet the purpose for which the information is provided.
- To provide the consumer with information, products or services that the consumer requests from Klarifi.
- To provide the consumer with email alerts, event registrations and other notices concerning Klarifi products or services, or events or news, that may be of interest to the consumer.
- To carry out Klarifi’s obligations and enforce Klarifi’s rights arising from any contracts entered into between Klarifi and an Klarifi customer or other contractual counterparty, including for billing and collections.
- To improve Klarifi’s website and present its contents to the consumer.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of Klarifi, our customers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Klarifi’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Klarifi is among the assets transferred.
- To modify, enhance, or improve Klarifi’s services and/or provision such services to Klarifi customers.
- To include in Klarifi’s database of business contacts, which Klarifi licenses to its users of customers, sometimes at no cost, for such users or customers to use for business-to-business sales and marketing, as well as data hygiene, analytics and other internal business purposes.
- Categories of Third Parties with whom this Personal Information is Shared:
- Service Providers
- Klarifi users
- Klarifi customers
Protected Personal Information Categories Under California Laws or Other Laws:
- Personal Information Collected:
- Name
- Business address
- Business telephone number
- Employment
- Employment status
- Categories of Sources from which this Personal Information was Collected:
- Publicly available information
- First-hand research
- Third-party data vendors
- Directly and indirectly from activity on Klarifi’s website
- Directly and indirectly from our customers or their representatives
- Directly from vendors and other contractual counterparties
- Through communications with prospective customers and other businesses and their representatives
- Purpose for Collection of this Personal Information:
- To fulfill or meet the purpose for which the information is provided.
- To provide the consumer with information, products or services that the consumer requests from Klarifi.
- To provide the consumer with email alerts, event registrations and other notices concerning Klarifi products or services, or events or news, that may be of interest to the consumer.
- To carry out Klarifi’s obligations and enforce Klarifi’s rights arising from any contracts entered into between Klarifi and an Klarifi customer or other contractual counterparty, including for billing and collections.
- To improve Klarifi’s website and present its contents to the consumer.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of Klarifi, our customers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Klarifi’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Klarifi is among the assets transferred.
- To modify, enhance, or improve Klarifi’s services and/or provision such services to Klarifi customers.
- To include in Klarifi’s database of business contacts, which Klarifi licenses to its users of customers, sometimes at no cost, for such users or customers to use for business-to-business sales and marketing, as well as data hygiene, analytics and other internal business purposes.
- Categories of Third Parties with whom this Personal Information is Shared:
- Service providers
- Klarifi customers
Internet or Other Similar Network Activity
- Personal Information Collected:
- Information on a consumer’s interaction with a website, application, or advertisement
- Internet Protocol address
- Categories of Sources from which this Personal Information was Collected:
- Customer, user and visitor interaction with Klarifi’s website and Service
- Purpose for Collection of this Personal Information:
- To carry out Klarifi’s obligations and enforce Klarifi’s rights arising from any contracts entered into between Klarifi and an Klarifi customer or other contractual counterparty, including for billing and collections.
- To improve Klarifi’s website and present its contents to the consumer.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of Klarifi, our customers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.
- To modify, enhance, or improve Klarifi’s services and/or provision such services to Klarifi customers.
- Categories of Third Parties with whom this Personal Information is Shared:
- Service Providers
Professional or Employment-Related Information
- Personal Information Collected:
- Business email
- Business telephone number
- Business physical address
- Current or past job history
- Title
- Categories of Sources from which this Personal Information was Collected:
- Publicly available information
- First-hand research
- Third-party data vendors
- Directly and indirectly from activity on Klarifi’s website
- Directly and indirectly from our customers or their representatives
- Directly from vendors and other contractual counterparties
- Through communications with prospective customers and other businesses and their representatives
- Purpose for Collection of this Personal Information:
- To fulfill or meet the purpose for which the information is provided.
- To provide the consumer with information, products or services that the consumer requests from Klarifi.
- To provide the consumer with email alerts, event registrations and other notices concerning Klarifi products or services, or events or news, that may be of interest to the consumer.
- To carry out Klarifi’s obligations and enforce Klarifi’s rights arising from any contracts entered into between Klarifi and an Klarifi customer or other contractual counterparty, including for billing and collections.
- To improve Klarifi’s website and present its contents to the consumer.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of Klarifi, our customers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.
- To modify, enhance, or improve Klarifi’s services and/or provision such services to Klarifi customers.
- To include in Klarifi’s database of business contacts, which Klarifi licenses to its customers for such customers to use for business-to-business sales and marketing.
- Categories of Third Parties with whom this Personal Information is Shared:
- Service Providers
- Klarifi customers
- Personal Information Collected:
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes a consumer’s CCPA rights and explains how to exercise those rights. Those laws also apply (in slightly different form) to residents of Other Applicable States, which may include, in addition to California, Colorado, Connecticut, Virginia and Utah
3.1 Disclosure or Sale of Personal Information and the Right to Opt-Out
3.2 Access to Specific Information and Data Portability Rights
- The categories of personal information we collected about that consumer.
- The categories of sources for the personal information we collected about that consumer.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about that consumer.
3.3 Deletion Request Rights
- Complete the transaction for which we collected the personal information, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if a consumer previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which a consumer provided it.
3.4 Exercising Access, Data Portability, and Deletion Rights
- Contacting us by calling the toll-free number listed on our Privacy Center.
- Submitting a request via our Privacy Center.
- Provide sufficient information that allows Klarifi to reasonably verify a consumer is the person about whom we collected personal information or an authorized representative.
- Provide sufficient information that allows Klarifi to reasonably verify a consumer is the person about whom we collected personal information or an authorized representative.
3.5 Authorized Agentss
3.6 Response Timing and Format
3.7 Non-Discrimination
3.8 Changes to Our Privacy Statement
We sell personal information collected for our database to our customers. This database may contain information about consumers’ business personas including name, employer, job title, email address, phone number, office address, social media or professional profile link, and work or educational history. This information is sold to Klarifi’s customers for the purpose of business-to-business sales and marketing and is provided subject to license agreements that limit its use to those purposes.
A consumer has the right to opt out of the sale of that consumer’s personal information by Klarifi by visiting our Privacy Center and submitting a request to remove the consumer’s profile or delete the consumer’s data. In order to submit a request, a consumer (to the extent permissible under state law) may be required to demonstrate that such person has control of an email inbox associated with the profile in question.
In the preceding twelve (12) months, we have sold or disclosed the following categories of personal information for a business purpose:
| Category | California and Other State Customer Records personal information categories |
| Category A | Identifiers |
| Category I | Professional or employment-related information. |
For avoidance of doubt, the personal information disclosed and/or sold by Klarifi within the identified categories is limited to information related to a consumer’s profile as an employee of its employer. No sensitive personal information (e.g., sexual orientation, race, ethnicity, religious or health-related information) is collected, shared, disclosed, or sold by Klarifi for purposes of providing its services. We do not sell the personal information of minors under 16 years of age.
A consumer has the right to request that we disclose certain information to that consumer about Klarifi’s collection and use of that consumer’s personal information over the past 12 months. Once we receive and confirm a consumer’s verifiable consumer request, we will disclose:
A consumer has the right to request that Klarifi delete any of its personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete that consumer’s personal information from our records, unless an exception applies.
We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to comply with important purposes, such as legal, auditing, accounting and security, and in particular if the data is necessary to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
A consumer may only make a verifiable consumer request for access (or data portability) twice within a 12-month period. The verifiable consumer request must:
We cannot respond to a consumer’s request or provide a consumer with personal information if we cannot verify the consumer’s identity or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may also designate an agent to make requests to exercise your rights under the CCPA or Other Applicable Laws, as applicable. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a legally sufficient power of attorney, depending upon the request made. We likewise may require that you verify your own identity, depending on the type of request you make.
We endeavor to respond to a verifiable consumer request within statutorily-designated time frames, If we require more time (up to 90 days), we will inform the consumer of the reason and extension period in writing. We will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12- month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to a consumer’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide the consumer with a cost estimate before completing that consumer’s request.
We will not discriminate against a consumer for exercising any CCPA rights.
We reserve the right to amend this privacy statement at our discretion and at any time. When we make changes to this privacy statement, we will provide notification by email or through a notice on the page where this policy is presented and updated.
4. When We Act as a Service Provider
Often, Klarifi receives information from its customers for purposes of providing services. This information may or may not overlap with the information used in Klarifi’s services. In either case Klarifi often processes data received from its customers in order to provide services to those customers. In turn, if you would like to know what information those customers process or possess about you, you would need to contact that specific customer to make that inquiry.
Contact Information
If there are any questions or comments about this statement, our Privacy Policy , the ways in which we collect and use a consumer’s personal information, how to receive a copy of the Privacy Policy and/or this statement in an alternative format (for consumers with a disability), a consumer’s choices and rights regarding such use, or wish to exercise consumer rights under California law, please do not hesitate to contact us at:
Klarifi ApS
Rådhuspladsen 16, 1550 Copenhagen V, Denmark
This statement was last updated on February 20, 2023