Owner and Data Controller
KPI6.com Srl
Via P. Togliatti, 5/C
42049 - Rubiera (RE)
Italy
Owner contact email: info@kpi6.com
Types of Data collected
Among the types of Personal Data that KPI6.com collects, by itself or through third parties, there are:
first name; last name; email address; company name; profession; Cookies; Usage Data; Data communicated while using the service.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using KPI6.com.
Unless specified otherwise, all Data requested by KPI6.com is mandatory and failure to provide this Data may make it impossible for KPI6.com to provide its services. In cases where KPI6.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by KPI6.com or by the owners of third-party services used by KPI6.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through KPI6.com.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of KPI6.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Registration and authentication, Handling payments, Analytics, Advertising, User database management, Contacting the User, Managing contacts and sending messages, Remarketing and behavioral targeting, Tag Management, Hosting and backend infrastructure and Interaction with live chat platforms.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on KPI6.com, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data.
Place of processing: Malta – Privacy Policy – Opt Out.
X Ads conversion tracking (X Corp.)
X Ads conversion tracking is an analytics service provided by X Corp. that connects data from the X advertising network with actions performed on KPI6.com.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics with anonymized IP (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of KPI6.com, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Woopra (Woopra)
Woopra is an analytics service provided by Woopra Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
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Contacting the User
Mailing list or newsletter (KPI6.com)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning KPI6.com. Your email address might also be added to this list as a result of signing up to KPI6.com or after making a purchase.
Personal Data processed: email address.
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Handling payments
Payment processing services enable KPI6.com to process payments by credit card, bank transfer or other means. To ensure greater security, KPI6.com shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable KPI6.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of KPI6.com.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of KPI6.com, for contacting and being contacted by KPI6.com support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Freshchat Widget (Freshworks, Inc.)
The Freshchat Widget is a service for interacting with the Freshchat live chat platform provided by Freshworks, Inc.
Personal Data processed: Cookies; Data communicated while using the service; email address; Usage Data.
Place of processing: United States – Privacy Policy.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data processed: Cookies; email address.
Place of processing: United States – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow KPI6.com to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, KPI6.com will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (KPI6.com)
The User registers by filling out the registration form and providing the Personal Data directly to KPI6.com.
Personal Data processed: company name; email address; first name; last name; profession.
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Remarketing and behavioral targeting
This type of service allows KPI6.com and its partners to inform, optimize and serve advertising based on past use of KPI6.com by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of KPI6.com with the Facebook advertising network.
Personal Data processed: Cookies; email address.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of KPI6.com with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Twitter Remarketing (X Corp.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of KPI6.com with the Twitter advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on KPI6.com in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to KPI6.com, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving KPI6.com.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on KPI6.com.
Intercom (Intercom Inc.)
Intercom is a User database management service provided by Intercom Inc.
Intercom can also be used as a medium for communications, either through email, or through messages within KPI6.com.
Personal Data processed: Cookies; email address; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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Use of our Service by the clients
In order to use our Service, the clients have to disclose to their users the use of the Service and provide them a privacy policy in compliance with the applicable law that should be conspicuously posted on their website/mobile application.
We do provide for an opt-out facility, the link of which must be available on such privacy notice.
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What our Service does and how Authors can opt-out
Our Service consists of a sophisticated tool that our clients can use to analyze their actual or potential audience through social media (such as Twitter, Facebook etc.) content, or content published on our clients' websites and/or mobile applications.
In order to analyze social media content, we enter into an agreement with the relevant social network provider which makes available, usually via API, the technical means that we need in order to make our Service happen and perform our analyses.
The information we gather are published or, in any case, made publicly available by the social network users or our client's users (the “Authors”).
If you are an Author on social media, please be aware of the fact that if we are able to access your information, this means that you have previously given permission to the social network (who acts as data controller) and you have consented to such processing.
You may deny this consent at any time by changing your privacy setting on the social network platform.
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What type of information do we collect about Authors?
We do collect the information that our clients share with us. To learn more about this, we invite you to read their privacy policy, and in particular the section dedicated to our Service.
As for the social media, the information collected largely depends on the information made available by the social network provider, which in turn depends on the policy they have in place.
In any case, if any of the following information is shared or otherwise made available, we may have access to:
- your name, surname, screen name or username, or other online identifier of yours;
- any content that you have published under your name/username and the like, such as, including but not limited to, comments, expressions, opinions, posts, tweets, etc.;
- your profile picture or other images, such as avatars, or videos that you post or interact with;
- your job title or profession;
- your interests;
- your location;
- your gender/marital status; and
- any other information you decide to make publicly available.
Authors must also be aware that further information can be derived from the information above and, in general, from any information we are provided with.
For example, if you share your location and we know that you live in the USA, we may reasonably infer that you can speak English, if you like a product or service we may infer that you may want to see more of the same in your ads etc.
Sometimes we may also infer very sensitive information about you, which means that, despite the fact that we do not, in principle, process this type of information, they can be nonetheless inferred by simply combining what we we already know about you.
For example, if you share your marital status and name of your spouse, we may infer your sexual orientation, if you share information about your profession we may infer what your yearly income is likely to be, if you share your picture we can infer your gender, and so on.
The inferences are based on algorithms that analyse the data that you have posted. In other words, we do not make any decisions about you based on the data that we process about you (either inferred or not). Our Service consists of making the analyses based on the data provided available to our clients. It is up to our clients to decide what (if anything) to do with the data and any inferences thereof.
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What is our position with respect to the processing of Authors' Data?
We are not the data controller of the above information and process them as data processor according to the terms and conditions set forth in the agreement that we entered into with the controllers (i.e. on one side our client, on the other side the social network provider).
This means that we are bound to both the terms and conditions of the social network providers, entered into whenever we use their API or other technical tools, and by the data processing agreement that we sign with our clients.
Whenever we do create a report or a pitch or any kind of document, brochure, newsletter to promote the Service, we never use information that can be used, even if combined with any other information, to identify, either directly or indirectly, individuals.
This means that the statistics and analyses we publish shall never contain personal data in such a way that makes them relevant for, or fall within the scope of, the European data protection law.
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Are Author's data securely processed?
Yes, they are. We have in place a very strict policy in this regard that meets the principles of privacy by design and privacy by default and ensure that your data are processed in such a manner that minimize the risks of, including but not limited to, loss, erasure, disclosure, dissemination of your data.
Despite the above, please be aware that we not responsible for the way our clients use the Service.
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According to what legal basis do we process Authors' Data?
We do process Authors' data to comply with our contractual obligation to provide the Service to our clients.
We may process such data also in ways related to, but ancillary, to the Service that we offer. For example, we may use the data to comply with our legal obligations or enforce our rights, including the legal obligations or enforcement of rights of third parties.
Please be aware that, since we act as data processor, meaning that we process your data on behalf of a controller, the latter must have a legal basis to process your data to begin with.
As stated above, the social network provider must be given your consent to utilize your personal information and permit third parties like us to utilize your information in the way we do.
Our clients have, in principle, the legitimate interest to learn more about their customers, how their brand is perceived, what their customers like about them and what they don't, where their competitors position themselves, and the like.
In this respect, we are simply technical providers that empower them and their business by providing them with the means to do so.
Please note that other legal basis of the processing may be found in the client's privacy policy which we strongly encourage you to read first.
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How long shall the above information be retained?
As long as it takes for us to provide the Service to our clients.
We don't keep the data any longer and don't process them for other purposes other than providing the Service to our clients.
In some cases, the law may provide for a longer retention period or we may retain your data for a longer period because we need to defend our rights and prerogatives before a Court (e.g. in case of criminal offense or in case any illicit conduct has been perpetrated against us).
However, if none of the above occurs, upon delivery of the analysis requested, your data is immediately deleted.
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How do I opt-out from your Service?
Simply contact the Owner at the following email address: optout@kpi6.com
Cookie Policy
KPI6.com uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of KPI6.com or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, KPI6.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, KPI6.com and any third-party services may collect files that record interaction with KPI6.com (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within KPI6.com and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through KPI6.com (or third-party services employed in KPI6.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use KPI6.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using KPI6.com who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of KPI6.com. The Data Controller, unless otherwise specified, is the Owner of KPI6.com.
KPI6.com (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by KPI6.com as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to KPI6.com, if not stated otherwise within this document.