Privacy Policy

Controller of the Persona Data:

Apollo Intelligence Operating LLC, dba Konovo

140 Sherman Street, 5th Floor 

Fairfield, CT 06824,

USA

UK Data Protection Representative: Antonio Tropea, Managing Director (EU), United Kingdom,  United Kingdom. [email protected]

EU Data Protection Representative: Fabio Musumeci, Privacy and Compliance Director, Apollo Intelligence Operating LLC: [email protected]

DPO contact: privacy@apollointelligence.net

1. CATEGORY OF PERSONAL DATA
   • Konovo may collect a variety of personal data based on your interaction with us.
     
     

• Client and Prospective Clients: If you are a Client or a Prospective clients who is interacting with us through this website, for example by signing to a newsletter or for obtaining information about our services, or by responding to marketing communication or via social media interaction, we may directly collect from you certain personal data such as your full names, your company name, email address, professional title, telephone number and country of residence.
• Job Applicants: If you are applying for a position we have advertised on this website or on other websites, we collect your personal data that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide.
• Personal information that we may collect indirectly. We may use Cookies and other similar technologies to collect personal data or anonymized information when you interact with our website. Please refer to the below section DIGITA DATA for more information.
• Personal data that we collect from other third parties. We may also collect personal data by interacting with third parties that provide personal data and information related to potential customers or we may use information that is publicly available, or that you made publicly available.

Please find below the type of personal data and general information we may collect:

Data collected from Companies and business entities:

Data collected from Individuals:

2. PURPOSES OF DATA PROCESSING
   • Konovo processes Personal Data that it collects directly or indirectly from individuals for the following business purposes:
     
     

• Operations: maintaining and supporting our products as well as delivering and providing the requested products/services;
• Contractual: complying with contractual obligations related thereto (including managing transactions, reporting, invoices and other operations related to providing/receiving services to/from clients and individuals). This may include data included in Category A
• Employment applications: We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics and to respond to surveys.
• Relationships and communications: Processing contact data for the purpose of managing our relationships and communicating with you by email and/or telephone.
• Direct marketing: Processing contact data for the purposes of creating, targeting and sending direct marketing communications by email and making contact by telephone for marketing-related purposes. We do this to inform you about new offers or products related to our Company.
• Research and analysis: Processing usage data for the purposes of researching and analyzing the use of our website, for example monitoring, supporting, improving and securing our website, services and business generally. KONOVO has a legitimate interest in maintaining security conditions on our websites to prevent malware, or other types of attacks. Security is essential to protect the personal data of customers and visitors.
• Record keeping: Processing your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records in servers located in the United State. We do this to ensure that we have access to all the information we need to run our business properly and efficiently in accordance with this Notice.
• Legal compliance and vital interests: Processing your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
• Required by Law: for other business-related purposes permitted or required under applicable local law and regulation, for example satisfying governmental reporting, tax, crime investigation and national security; and as otherwise required by law). This may include data included in Category A
• In general: as requested by you;

3. LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
   • KONOVO uses the below legal bases for processing your data in relation to the above identified purposes:

4. SPECIAL CATEGORY OF PERSONAL DATA OR SENSITIVE DATA
   • If in specific circumstances KONOVO processes certain categories of data that can be considered very sensitive, we will handle this data with extreme care and only few authorized people will have access to it. Such data might include: information about your health, your ethnic origin, biometric data, trade union membership, etc. Where we process special categories of personal data, “Sensitive Personal Data,” we will always obtain your explicit consent to those activities unless:
     • Consent is not required by law;
     • To protect your vital interests where you are incapable of giving your consent;
     • For the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity;
     • Processing is necessary for reasons of public interest in the area of public health as required by the local law.
     • Where this is allowed by law, you might have the right to withdraw that consent at any time.

5. AUTOMATED DECISIONS
   • We reserve the right to make automated decisions, including using machine learning algorithms about website visitors in order to optimize and provide better experience when navigating our websites. Only digital data as specified in section “Digital Data” are included in this processing.
   • We may analyze the data you provide during your interaction with us with the purpose of enriching the profiling data we hold about yourself. The profiling data that we have collected might be used for making manual or automated decisions that involve the possibility to include you in Company’s newsletter, marketing campaigns and communication of new offers and products. If you are a Job Applicant, we may use the data we have collected from you for sending job opportunities that match your sphere of expertise and interest.
   • You may contact us if you would like any clarifications about the automated decisions.
6. DIGITAL DATA
   • Cookies: KONOVO may set and use cookies to enhance your user experience on the sites, such as retaining your personal settings and preferences.  You may set your browser to prevent or reject cookies, or you may manually delete any cookies set. If you reject the cookies on the sites, you may still be able to use the sites, but they shall be limited to certain minimal functionality. From time-to-time KONOVO may use third-party tracking utilities that use session ID cookies that track site usability and assist KONOVO in improving user experience. This Privacy Notice does not cover the use of cookies by our third-party providers as we do not have access or control over these cookies.
   • We may collect information on our sites or in our emails using web beacons and or tracking pixels (electronic images). We may use beacons to count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.
   • You can review the cookies used by the website in our Cookie Policy
   • Configuration Panel: You can configure the Cookie by using the configuration panel pupping up when you visit our website.
   • Trend Analyses: KONOVO may use IP addresses to analyze trends, administer the Sites, track your movement within the Sites, and gather broad demographic information for aggregate use.
   • Links to other sites: our sites include links to other websites whose privacy practices may differ from KONOVO’s. If you submit personal data to any of those sites, your information is governed by the privacy statements of those third-party sites.
   • Managing cookies: Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

• • • https://support.google.com/chrome/answer/95647 (Chrome);
    • https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
    • https://help.opera.com/en/latest/security-and-privacy/  (Opera);
    • https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
    • https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac           (Safari);
    • https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
      
      

7. CHOICE WITH RESPECT TO USES AND DISCLOSURES OF PERSONAL DATA
   • KONOVO recognizes that individuals have the right to limit the use and disclosure of their Personal Data, and we are committed to respecting those rights. We offer individuals the opportunity to opt out of disclosures of Personal Data to a third party or the use of Personal Data for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individual. We will comply with the GDPR with respect to disclosures of Sensitive Data including, when applicable, obtaining the explicit consent (i.e., opt in consent) of an individual prior to disclosing Sensitive Data to a third party or using Sensitive Data for purposes other than those for which it was originally collected or subsequently authorized by the individual.
     
     
8. DISCLOSURE/TRANSFER OF INFORMATION FOR A BUSINESS PURPOSE
   • KONOVO may disclose your Personal Information to a third party for a business purpose. We do this by entering into a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. Furthermore, third parties must comply with the GDPR and agree to provide adequate protection that is no less protective than those set out in this Notice.

• Disclosure: We may disclose your Personal Information for business purposes to the following categories of third parties:
  • Our affiliates and subsidiaries
  • Service Providers and consultants
  • Professional services organizations, such as auditors and law firms
  • Our business partners
  • Internet service providers
  • Government entities
  • Operating systems and platforms
  • Background checks providers
  • Customer support services
  • Tax authorities

• Purposes of disclosure: KONOVO may disclose your personal information for the following purposes:
  • Email services
  • Identity verification
  • Offering and providing customer support
  • Internal marketing campaigns for communicating new offers to our clients
  • Internal marketing engagement e.g. newsletters
  • Auditing purposes and governmental reporting
  • Tax reporting
  • For complying with your requests or contract obligation we have with you

• Disclosures due to acquisition or merger: We may share your information in connection with a merger, sale of company assets, financing or acquisition of all or a portion of our business to another company, if any. In this event, KONOVO will notify you before information about you is transferred and becomes subject to a different privacy policy.
• Anonymous information: We may also share aggregated or anonymous information that does not directly identify you. KONOVO may share anonymized aggregated demographic information with KONOVO partners.
• Other forms of disclosures: KONOVO also may disclose your personal data for other purposes or to other third parties when you have consented to or requested such disclosure or under the following circumstances:
  • We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
  • We believe it is necessary to share information in order to investigate or prevent fraud, or to take action regarding illegal activities, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
  • In response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• Third party compliance: Such third parties must agree to use such Personal Data only for the purposes for which they have been engaged by KONOVO, and they must either:
  • comply with the GDPR, the Data Privacy Framework (DPF) principles, or another mechanism permitted by the applicable European data protection law(s) for transfers and processing of Personal Data; or
  • agree to provide adequate protection for the Personal Data that are no less protective than those set out in this Notice.
• Liability: KONOVO is potentially liable in cases of onward transfers of Personal Data to third parties, such as when third parties that act as agents on our behalf process Personal Data in a manner inconsistent with applicable data protection regulations.
  
  

9. TRANSFER PERSONAL DATA OUTSIDE THE EEA, UK AND SWITZERLAND
   • The third parties as described in paragraph “DISCLOSURE/TRANSFER OF INFORMATION FOR A BUSINESS PURPOSE” might be based in US or in countries other than EEA, UK and Switzerland. In these instances, KONOVO imposes strict contractual obligations and executes Standard Contractual Clauses with third parties to maintain a level of protection that is equal to the GDPR requirements.
   • In other instances, we may ask your consent to allow us to transfer your personal data into another country. In doing so we will provide you with full information about the transfer.
   • You may contact our DPO if you would like to know more about our international transfer assessment and/or copy of the transfer mechanism that we use for sharing your Personal Data outside your country of residence.

10. ANTI-SPAM
    • KONOVO maintains a strict “No-Spam” policy, which means that KONOVO does not intend to sell, rent or otherwise give your email address to a third-party without your consent.

11. DATA INTEGRITY, PURPOSE LIMITATION AND RETENTION
    • KONOVO will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. To that end, KONOVO will take reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete, and current. KONOVO uses reasonable efforts to maintain the accuracy and integrity of your Personal Data and to update it as appropriate.
    • We retain your personal data as follow:
      • We will retain personal data only for as long as necessary to fulfill the purpose for which it was collected or to comply with legal or regulatory obligations. To determine the appropriate retention period for personal data, we consider the type and the sensitivity of data that we collected about you, any harm that an illegal disclose may pose to your rights and freedoms, and the last time that your data has been updated.
      • We may retain your information as necessary (including a longer period) to comply with our legal obligations, resolve disputes and enforce our agreements.

12. PERSONNEL ACCESS OF PERSONAL DATA
    • Personnel from KONOVO may access and use your personal data only if they are authorized to do so and only for the purpose for which they are authorized.
      
      
13. DATA SECURITY
    • KONOVO has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to KONOVO’s electronic information systems requires user authentication via password or similar means. KONOVO also employs access restrictions, such as limiting the scope of employees who have access to Customer Personal Data. Further, KONOVO uses secure encryption technology to protect certain categories of personal data.
    • Despite these precautions, no data security safeguards guarantee 100% security all of the time.
      
      
14. YOUR RIGHTS
    • Right of Access You have the right to obtain confirmation about whether your personal data is included in our databases. Upon request, KONOVO will provide an individual access to your personal data within the time frame dictated by the applicable data protection regulations. KONOVO will allow you to know what Personal Data is included in our databases and to ensure that such Personal Data is accurate and relevant for the purposes for which KONOVO collected the Personal Data. You may also request a copy of your data in a commonly used and machine-readable form.
    • Right of Rectification: You may review your own Personal Data stored in the databases and correct, update, modify, or delete any data that is incorrect or incomplete.
    • Right of Erasure: You may request to have the personal information that we have about you to be deleted from our servers. KONOVO will take reasonable steps, including technical measures, to comply with your request. In some circumstances your request might be rejected if it falls under one of the categories included in ART. 17.3:
      • exercising the right of freedom of expression and information
      • for compliance with a legal obligation
      • for reasons of public interest in the area of public health
      • archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
      • establishment, exercise or defense of legal claims  
    • Objection: You may object, at any time, to your Personal Data being processed for a specific purpose.
    • Restriction of Processing: You may restrict processing of your Personal Data for certain reasons, such as, for example, if you consider your Personal Data collected by us to be inaccurate or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration.
    • Data Portability: You may request the Personal Data you provided to us in a commonly used and machine-readable form.
    • Right to Withdraw Consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn, including processing related to existing contracts for our Services.
    • Right to complain to a supervisory authority: you might lodge a complaint about our processing of your personal data with your local Data Protection Authority; KONOVO will collaborate with the authority to resolve it.
    • Limitations: these rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
      
      
15. HOW TO EXERCISE YOUR RIGHTS
    • You can exercise your rights by filling out the form found at . You may also submit a request at [email protected], reach us on toll free number 877-390-2735 or via postal mail at KONOVO, Attn: Compliance Department, 480 Pleasant Street, Suite B100, Watertown, MA 02472 USA USA.
      
      
16. RESPONSE TIMING AND FORMAT
    • We endeavor to respond to a verifiable request within 30 days of its receipt. If we require more time (up to two extra months), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a verifiable request, if applicable.
    • We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
    • Request that we can’t process: We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable request does not require you to create an account with us. We will only use Personal Information provided in a verifiable request to verify your identity or authority to make the request.
    • KONOVO will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise:
      • legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or
      • requests received from the Data Subject.

17. NOTIFICATION
    • KONOVO notifies Clients and individuals about its adherence to GDPR and other applicable data protection regulations, as well as the Data Privacy Framework (DPF) principles, through its publicly posted website privacy notice, available on the below webpages: https://apollointelligence.net/.
      
      
18. RESPONSIBILITIES AND MANAGEMENT
    • KONOVO has designated the Privacy Department to oversee its information security program, including its compliance with the Data Privacy Framework (DPF) program. The Privacy Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Notice also may be directed to: [email protected]
      
      
19. ENFORCEMENT AND DISPUTE RESOLUTION
    • We commit to resolving individuals’ complaints related to our privacy practices or our collection, or use, or disclosure of Personal Data. An individual may file a privacy complaint by contacting our DPO at [email protected]. Further, individuals with questions or concerns about the use or disclosure of their Personal Data should contact us as outlined in Section 17.
    • If an individual’s complaint cannot be satisfied through our internal complaint process, the individual may bring a complaint before the ICDR/AAA Data Privacy Framework (DPF) program, a non-profit alternative dispute resolution provider located in the United States and operated by the international division of the American Arbitration Association. The ICDR/AAA Data Privacy Framework (DPF) program is designed to handle eligible complaints brought by Swiss, UK and EU citizens about Data Privacy Framework (DPF) If you have any complaints regarding our compliance with the Data Privacy Framework (DPF) you should first contact us (as provided above). If contacting us does not resolve your complaint or you do not receive timely acknowledgement of your complaint, please visit the ICDR/AAA Data Privacy Framework (DPF) program website at https://go.adr.org/dpf_irm.html for more information and to file a complaint.  We will cooperate with the independent dispute resolution mechanism to resolve any complaint that is not resolved through our internal processes.
    • If a complaint regarding the Data Privacy Framework (DPF) compliance is not resolved by any of the above dispute resolution mechanisms, an individual has the possibility, under certain conditions, to invoke binding arbitration. Additional information about binding arbitration can be found here: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
    • The above does not preclude your right to contact your local Data Protection Authority. We will collaborate with the DPA to find a solution to resolve the complaint.

20. CHANGES TO THIS NOTICE
    • KONOVO will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. KONOVO personnel will receive training, as applicable, to effectively implement this Notice.
    • This Notice may be amended from time to time, consistent with the Data Privacy Framework (DPF) Principles and applicable data protection and privacy laws and principles. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

21. DEFINITIONS
    
    
22. Capitalized terms in this Privacy Notice have the following meanings:
    • “Customer” means a prospective, current, or former partner, vendor, supplier, customer, or client of KONOVO. The term also shall include any individual agent, employee, representative, customer, or client of an KONOVO Customer where KONOVO has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.
    • “Data Subject” means an identified or identifiable natural living person in the European Union. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics.
    • “Employee” means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of KONOVO.
    • “Europe” or “European” refers to a country in the European Economic Area.
    • “Personal Data” as defined under Regulation (EU) 2016/679, the General Data Protection Regulation means any and all data (regardless of format) that (i) identifies or can be used to identify, contact or locate a natural person, or (ii) pertains in any way to an identified natural person. Personal Data includes obvious identifiers (such as names, addresses, email addresses, phone numbers and identification numbers) as well as biometric data, “personal data” (as defined in the GDPR), and any and all information about an individual’s computer or mobile device or technology usage, including (for example and without limitation) IP address, MAC address, unique device identifiers, unique identifiers set in cookies, and any information passively captured about a person’s online activities, browsing, application or hotspot usage or device location.
    • “Sensitive Data” is a subset of Personal Data which due to its nature has been classified by law as deserving additional privacy and security protections. Sensitive Personal Data consists of: (i) all government-issued identification numbers, (ii) all financial account numbers (including payment card information and health insurance numbers), (iii) individual medical records, genetic and biometric information, (iv) user account credentials, such as usernames, passwords, security questions/answers and other password recovery data, (v) data elements that constitute Special Categories of Data under the GDPR, namely EEA Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, and (vi) any other Personal Data designated by KONOVO as Sensitive Personal Data.