Privacy Policy

Last modified: Apr 26, 2019
I. Introduction

Kyligence USA Inc. (“Company”, “We” or “Kyligence”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes our privacy practices for our website located at (the “Website”), as well as different applications and products, such as the Kyligence Robot, Kyligence Hub and Kyligence Account and various related services, features, and content accessible or downloadable from the Website (collectively, the “Services”). This policy also explains how we collect, use, maintain, protect, and disclose the information you provide in connection with your access to or use of the Website and/or the Services.

This policy applies to information we collect:

  • On this Website.
  • Through use of the Services.
  • In email, text, and other electronic messages between you and this Website.
  • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • us offline or through any other means, including on any other website operated by Company or any third party; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and/or Services. By accessing or using this Website and/or Services, you agree to this privacy policy. This policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

II. Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at

III. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website and/or Services, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number or any other identifier by which you may be contacted online or offline (“personal information”);
  • that is about you but individually does not identify you, such as your occupation, affiliated companies and general location; and/or
  • about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
  • From third parties, including without limitations, Google Analytics and Baidu Tongji.

Information You Provide to Us

The information we collect on or through our Website and/or Services may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our Services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online services that a user visits, indicating that the user does not wish to be tracked. As there is not yet a common understanding of how to interpret and implement such “Do Not Track” signals, we do not currently honor or respond to “Do Not Track” signal when we collect information about your activities on the Website.


The information we collect automatically is statistical data and does not include personal information but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:


  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information.”
  • Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies 

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers, such as Google, Bing, Baidu, Twitter, and Facebook. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

To prevent your data from being sent to and used by Google Analytics, you may download a Google Analytics Opt-out Browser Add-on at You may opt out of Google’s use of cookies by visiting Also, you may opt out of third party’s usage of cookies by visiting

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Choices About How We Use and Disclose Your Information.”

IV. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:


  • To present our Website and its contents to you.
  • To carry out sales, sales solicitation, shipment of products, delivery of services, completion of orders.
  • To advertise or promote our products or the products of third parties offered through the Website to you
  • To carry out marketing data surveys, statistics and/or analysis.
  • To communicate with you regarding your use of the Website and/or Services.
  • To create, send and utilize mailing lists.
  • To conduct data and system analytics, including research to improve the Website and/or the Services.
  • To develop new tools, products or services based on your feedback.
  • To operate, maintain and improve the systems and infrastructure that provide the Services.
  • To carry out identify verification and authentication services.
  • To provide other services performed by us or third parties.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please opt-out by using the “Unsubscribe” feature contained in the electronic communications. For more information, see “Choices About How We Use and Disclose Your Information.”

V. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To third-party service providers that are in the U.S. or in other countries where such service providers assist in providing the Services and/or facilitating the Website; for example, we disclose personal information to service providers such as Hotjar, Google Analytics, and Zoho to track user behavior information and to improve user experience of visitors to the Website.
  • To third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Kyligence’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Kyligence about our Website users is among the assets transferred.
  • To our business partners for Kyligence’s marketing and analytics purposes.
  • To financial institutions, credit card companies, payment collection companies that are authorized to collect payments owed to us from you.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of service at and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Kyligence, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

VI. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt-out by using the “Unsubscribe” feature contained in the emails we send to you.
  • Targeted Advertising. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
VII. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

VIII. Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to

IX. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

X. Data Transmission and Processing

The information that we collect from you may be transmitted to, processed and/or stored at a destination outside the U.S. or your country or region of residence. By signing up, accessing and/or using the Website and/or the Services, you expressly consent to our transmission, processing and storage of your information of your information in locations outside the U.S. or your country or region of residence.

XI. The EU General Data Protection Regulation

As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (the “GDPR”) becomes effective through the European Economic Area (“EEA”), Switzerland, and the United Kingdom. The GDPR requires us and those using our Services to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used under the GDPR that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile IDs, precise location data, and biometric data.

To comply with the GDPR, we provide the below representations and information, which are specific to persons located in the EEA, Switzerland, or the United Kingdom.

    a. Legal Grounds for Processing Personal Data

The GDPR requires us to tell you about the legal ground we are relying on to process any Personal Data about you. The legal grounds for us to process your Personal Data for the purposes set out in Sections III, IV and V above will typically be because:

  • You Provided Your Consent: To store and/or gain access to information, we rely on your consent, including the “cookie consent.”
  • The Processing is in Our Legitimate Interest: In some cases, we rely on legitimate interest as a legal basis for processing Personal Data to provide our and/or other data controllers’ services. For instance, legitimate interests may include the tailoring of promotional communications, providing analysis of and reporting about ad campaigns, maintaining the security of our Services, etc.
  • Contractual Relationships: Sometimes we process certain data as necessary under a contractual relationship we have.
  • Legal Obligations: Some processing of data may be necessary for us to comply with our legal or regulatory obligations.

    b. Transfer of Personal Data

As Company works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside of the EEA, Switzerland, or the United Kingdom, and which have no data protection laws or laws that are less strict in comparison to those in Europe.

When we transfer Personal Data outside of the EEA, Switzerland, or the United Kingdom, we take steps to ensure appropriate safeguards are in place to protect your Personal Data. Please contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.

    c. Personal Data Retention

As a general matter, we retain your Personal Data for as long as necessary to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. If you are a client of ours and thus have an account with us, we will typically retain your Personal Data for a period of seven (7) years after you have requested that your account be closed, or such account has been inactive.

    d. Your Rights as a Data Subject

The GDPR provides you with certain rights in respect to Personal Data that data controllers (as explained further below) hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).

  • Right to Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through the email address Upon receiving your request, we will assess requests on a case-by-case basis, verify your identity and whether the data truly and solely belongs to you, and may limit the Personal Data we make available. Please note that we will only grant requests submitted for Personal Data for which we are a data controller. Where we act as a data processor for one of our clients, we will refer your request to that client. Please identify the client your request refers to (if possible) to simplify this process.
  • Right to Correct: If you wish to exercise your right to correct or update your Personal Data, you may do so by contacting us at the contact information below.
  • Right to Object to Processing or to Withdraw Consent: By using the “opt-out” feature described in Section IV above, you may withdraw consent for processing your Personal Data.
  • Right to Erasure: You also have the right to request that we erase the Personal Data concerning you that we hold as a data controller. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our own internal and necessary purposes, including but not limited to auditing, accounting and billing, legal, or bug detection. We will retain your Personal Data for the period necessary to fulfill any important purposes that we have in retaining it, principally regarding legal, auditing, accounting, and billing obligations.
  • Right to Lodge Complaints:You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.

    e. Company as a Data Controller and a Data Processor

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, we encourage you to direct your inquiry to the relevant data controller, since data controllers hold primary responsibility for your Personal Data.

Company may act as either a data controller or a data processor in handling your Personal Data, depending on the precise circumstances. For instance, for Personal Data that we use internally and independently or we collect about our clients, we are a data controller. When we handle Personal Data strictly on behalf of our clients or partners in order to provide our Services to them, we are a data processor. Thus, for instance, if you have questions about data that is used primarily by companies that serve advertisements that use our technology, you should contact those companies regarding questions about the Personal Data they handle and control.

    f. Questions or Concerns

If you are a resident of the EEA, Switzerland, or the UK and have concerns regarding this Section XI, you may contact us by email at or at Kyligence USA Inc., 99 Almaden Boulevard, Suite #320, San Jose, CA 95113.

XII. Third-Party Links

Our Website or Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We have no control over and assume no responsibility for the content, privacy policies or practices of any such third-party sites or services. We strongly advise you to review the privacy policy of every site you visit.

XIII. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will add a statement on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and we encourage you to periodically visit our Website and this privacy policy to stay informed about our practice in protecting your privacy.

XIV. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Kyligence USA Inc.

Almaden Boulevard, Suite #320,

San Jose, CA 95113.

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