KOMBO AI is committed to protecting the privacy of our users. In compliance with the European Union General Data Protection Regulation (EU) 2016/679 (“GDPR”) and Spanish Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights (“LOPDGDD”), this policy outlines how we collect, use, and protect your personal data.

Who is responsible for your data?

• Entity Name: KOMBOAI TECHNOLOGIES S.L. (“KOMBOAI“)
• NIF: B-70709753
• Address: C/ Mèxic, 3, 3º, 08024 Barcelona
• Website: www.getkombo.ai
• Email: [email protected] 

What data do we collect?

We may collect various categories of personal data depending on how you interact with our services:

• Contact information: Name, email address, phone number, job title, company name, and similar details.
• Usage data: Data about your interaction with our platform, including pages visited, features used, and time spent.
• Professional data: Information available on external platforms (such as LinkedIn) including your job history, professional skills, company-related data, and other publicly accessible data relevant to business operations.
• Commercial information: Emails or other communications with prospects or leads analyzed through our system.
• Recruitment data: If you apply for a job with KOMBO AI, we will collect information related to your job application, such as your CV, education history, work experience, and references.

In addition to collecting data from our clients, KOMBO AI processes and analyses available personal data from third-party sources and APIs. The types of data we may collect from these sources include:

• Professional data: Name, job title, company, job history, skills, education, professional achievements, public pictures, contact data, revenue data, customer reviews and other information available on public profiles. The data collected from these sources is used exclusively for professional and commercial purposes as described below.

Lastly, we collect aggregated data, such as statistical or demographic data for internal analysis. This information does not directly identify any individual.

How do we collect your data?

We collect personal data through:

• Information you provide directly: When you register on our platform, use our services, apply for job positions, or communicate with us.
• Third-Party sources: We gather publicly available professional data from platforms like LinkedIn and Crunchbase.
• Automated technologies: As you use our website, certain information may be collected automatically, if any (e.g., via cookies, analytics tools). In that case, you shall accept the Cookies Policy. 

How do we use your data?

We process personal data for the following purposes:

• Providing our services: To offer data analysis and recommendations, helping sales professionals optimize their digital pitches and customer outreach efforts.
• User support: To assist with any inquiries, technical support, or requests for information.
• Improving our services: We analyze usage data to enhance the functionality and performance of our platform.
• Compliance with legal obligations: We process your data to comply with legal obligations, such as financial reporting or cooperating with regulatory authorities.
• Marketing communications: With your consent, we may send you updates and information about our services. You can opt out at any time.
• Receiving and evaluating job applications: We process data related to job applications you submit to KOMBO AI, such as evaluating your qualifications, arranging interviews, and communicating with you regarding employment opportunities.

What is the legal basis for processing your data?

The processing of your personal data is based on one or more of the following:

• Consent: When you voluntarily provide data for specific purposes, such as subscribing to newsletters or using our platform.
• Legitimate interest: We may process your data to provide our services, analyze performance, evaluate job applications or market to you unless your interests or fundamental rights override our legitimate interest.
• Contractual need: If you are a customer, we process your data to perform the contract for services provided to you.
• Legal compliance: In some cases, we process data to comply with legal or regulatory obligations.

Additionally, the legal basis for processing Publicly Available Data is our legitimate interest in providing data-driven insights and recommendations to our clients for business development purposes. We ensure that the data we process is limited to what is necessary and relevant for professional purposes only.

How long do we keep your data?

The personal data will be processed for the period necessary to fulfill the purposes established in this Privacy Policy, as well as to retain your personal information in compliance with the provisions of relevant laws and regulations, particularly in relation to statutory limitation periods and for the formulation, exercise, or defense of legal claims, during which the data will remain blocked.

The criteria used by KOMBO AI are determined by the purpose of the data collected and the fulfillment of that purpose (e.g., in the case of consent, you may revoke it at any time), and the retention periods required by contractual and regulatory obligations.

Do we share your data?

We may share your personal data with:

• Service providers: Third-party vendors who help us with data storage, analysis, or communication tools. These providers act as data processors and are bound by confidentiality agreements.
• Business partners: In some cases, we may share data with external partners if necessary for delivering services to you.
• Public authorities: We may disclose data when required by law or in response to valid legal processes.

What are your rights?

You have the following rights regarding your personal data:

• Access: Request access to your personal data and obtain a copy of it.
• Rectification: Request correction of any inaccurate or incomplete data.
• Erasure (“Right to be Forgotten”): Request the deletion of your data when it is no longer necessary for the purposes it was collected.
• Restriction: Request a temporary suspension of data processing under specific circumstances.
• Data Portability: Request the transfer of your data to another service provider in a structured format.
• Object: Object to the processing of your data for direct marketing or other legitimate interests.
• Withdraw Consent: Withdraw your consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

If you believe your data has been processed in a way that infringes upon your rights, or you wish to object to the processing of your publicly available data, you may contact us at [email protected] to exercise your rights to access, rectify, or delete your personal data. If you believe your rights have been violated, you also have the right to file a complaint with the Spanish Data Protection Authority (AEPD).

Security Measures

KOMBO AI has implemented appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. 

Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services or legal requirements. You will be notified of any significant changes. The latest version will always be available on our website.