Protecting Your Personal Information

Karomi Technology Pvt Ltd and its respective affiliates (collectively, “Karomi”, “we” and/or “us”) are committed to protecting the privacy of the individuals (“visitors” and/or “you”) who visit our website and subpages located at https://www.manageartworks.com/ (the “Site”).

This Website Privacy Notice (“Website Notice”) describes Karomi’s privacy practices in connection with your use of the Site. We provide information about the choices you have regarding the collection or use of your personal information including similar terms as defined by various jurisdictions, and the rights provided to you, including the ability to access or update your personal information.

What is Personal Information?

The Website Notice applies to personal information collected from visitors to the Site. For purposes of this Website Notice, “personal information” means information collected by Karomi relating to an identified or identifiable natural person and includes similar terms as defined by various jurisdictions.

Links to Non-Karomi Websites

For your convenience, the Site may contain links to third-party websites and/or information. When you access those links, you leave Karomi’s Site and are redirected to a third-party website. Karomi does not control third-party websites, thus the privacy practices of third parties might differ from Karomi’s privacy practices. We do not endorse or make any representations about third-party websites. When you share personal information with third-party websites, the third-party processing is not covered by this Website Notice. We encourage you to review the privacy policy of any website or company before sharing personal information.

HOW KAROMI COLLECTS YOUR PERSONAL INFORMATION

Sources of Personal information and Personal Information we collect:

Karomi collects personal information from several different sources, including:•

• ·        Directly from a website visitor including job applicants
• ·        From service providers or other third parties; and
• ·        Automatically from a website visitor’s visit or activity on our Site.

Please review each of the sections below to learn more about how Karomi collects personal information, and what personal information is collected.

How We Collect Personal Information

Karomi collects personal information when you visit our Site and when you choose to provide personal information. For example, we collect information when you contact us via our Site, provide your email, phone number or other similar contact information, such as the information that you provide when you sign up for a webinar. Job candidates who complete an application for employment with Karomi or create a profile on this website may also provide credentials and other information relevant to the job application.

Examples of Personal Information we collect

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Cookies and Other Similar Technologies

Like many websites, Karomi uses cookies and similar tracking technologies (including for analytics, functionality, advertising, and other purposes). We use cookies on all our websites and software applications. Cookies are small text files that your browser saves on your computer and mobile device, which allow an analysis of your usage. Cookies contain information about your device and your connection to the Internet, such as: IP address, operating system and browser used. We use the information in the cookies to optimize our offering, to present appropriate content to customers easily, and to improve our advertising and marketing. This is done as follows: Most of the cookies we use are so-called session cookies, which are automatically deleted by your browser after the end of your visit to our website. Session cookies provide us with information about visitor behavior on our website, which we analyze. With the knowledge gained, we will make our website more user-friendly, place important content on the most popular pages and develop our marketing strategies according to the interests of our target audience. Other cookies are stored longer on your device and allow us to recognize you as a user during a subsequent visit to our website. We do not pass on information that we receive through our cookies to third parties. By using the “Incognito” or “Private” mode of your browser, or by means of adjusting the settings in your browser, you can prevent the installation of cookies. As a result, some of the features in the website may no longer work. Our legitimate interest is to optimize our product, increase user experience, enhance our customer support and improve our internal process efficiency.

Other Information

If Karomi collects any other personal information from you, we will explain which personal information is collected and the purpose for its collection.

HOW KAROMI USES PERSONAL INFORMATION

Why We Use Your Personal Information:

Karomi relies on lawful bases, such as Performance of Contract or Legitimate Interest. Additionally, we may process personal information for the following purposes:

• ·        To fulfill the purpose(s) for which the information was collected or provided, including to communicate with you and respond to your inquiries and requests;
• ·        To improve our Site, products and services, through testing, research, analysis and product development;
• ·        To market, advertise, and promote our products and services, such as to make suggestions and recommendations to you about products or services that may be of interest to you;
• ·        To provide support and information about our product and services via virtual assistant, also known as chatbot, available 24/7 on our Sites;
• ·        To provide training related to the products and services, such as making available training materials or events (whether in-person or online) for which we may use your personal information to provide notices and information regarding such training and events;
• ·        For security, audit, internal investigation, and fraud prevention purposes, such as to prevent unauthorized access or disclosure, to maintain data accuracy, to protect the confidentiality, integrity, and availability of your personal information; to allow only the appropriate use of your personal information; to identify any fraudulent, harmful, unauthorized, unethical or illegal activity;
• ·        To manage litigation, such as in connection with establishing, exercising, or defending our legal rights where it is necessary for our legitimate interests or the legitimate interests of others;
• ·        To improve the content and format of our Site by using cookies and other similar technologies, such as to measure the preferences of our Site visitors, analyze trends, administer the Site, analyze use of the Site, and to gather demographic information about visitors to the Site;
• ·        To allow us to better understand the functionality of our mobile applications, though we do not link the usage information we collect through the mobile applications to any personal information you submit within the mobile application;
• ·        For other purposes for which you have provided consent;
• ·        To aggregate or anonymize your personal information so that the information can no longer be linked to you or your device and use and share such data for any business purpose in accordance with applicable law; and
• ·        To comply with all applicable legal obligations, such as to comply with subpoenas and other court orders to process data where we have determined there is a legal requirement to do so.

WHEN KAROMI DISCLOSES YOUR PERSONAL INFORMATION

Please note, Karomi does not sell personal information to third parties. The term “sell” as defined by applicable laws, means disclosure of personal information to third parties for monetary or other valuable consideration.

Please review each of the sections below to learn more about how we may share your personal information.

Affiliates:

We may disclose your personal information to our Affiliates in order to facilitate delivery of a product or service or complete a task that you requested.

Third Parties (Vendors/Service Providers):

We may engage with third parties (vendors and/or service providers) to facilitate delivery of a product or service (or perform certain functions such as enhancing and/or delivering our product and service offerings); complete a task that you requested; provide training; conduct marketing and advertising; operate, secure, and optimize the Site; and coordinate and work with our partners.

We have contracts with such third parties to perform certain functions on our behalf, and only at our direction. These third parties are bound by agreements that contain confidentiality and other data protection terms designed to ensure the third parties only use your personal information to the extent necessary to provide these contracted services in accordance with our instructions (and for the purposes we disclose).

Karomi may use support for marketing purposes, such as managing email campaigns. In such circumstances, Karomi is the data controller, and a virtual assistant (chatbot) acts as a processor. Data Protection Agreements are in place to ensure the privacy and use of your data are in accordance with this Notice.

Additional Disclosures

We may disclose your personal information as necessary to:

• To provide customer service or technical support regarding training or webinars for which you register or attend;•
• For our administration, and business operation purposes and to keep a record of your relationship with us;•
• Comply with the law or with legal obligations, such as with law enforcement officials, government authorities or other third parties in response to a lawful request for information by a competent authority, if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process, including to meet national security or law enforcement requirements;•
• To manage litigation and conduct internal audits and investigations, such as to protect and defend our rights and property, investigate fraudulent or illegal activity, and conduct internal financial, security, or other audits;•
• Protect against misuse or unauthorized use of our Site, products, and services;•
• Protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to use another’s identity, information about you may be disclosed as part of any investigation into your actions)•
• In connection with, or during the negotiation of, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or to another company, including the transfer of contact information and data of customers, partners, and end users;•
• In an aggregated and de-identified or anonymized form; and•
• When we have your consent to share the information.
• Other than as stated in this Website Notice, we will endeavor not to release your personal information to unknown or unaffiliated third parties, and we will not cross-reference your personal information with that of any other customer or entity.

PROCESSING PERSONAL INFORMATION

International Data Transfer:

We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.

Data processed:

Karomi provides Packaging Artwork Management software that our customers use for their teams. In providing these tools, Karomi processes data our customers submit to our services or instruct us to process on their behalf. While Karomi’s customers decide what data is processed, it typically includes information about their products. We also process data for authentication and identification purposes such as name and email address.

Purposes of data processing:

Karomi processes data submitted by customers for the purpose of providing Karomi’s online services to our customers. To fulfill these purposes, Karomi may access the data to provide the services, to correct and address technical or service problems, to respond to customer support matters, or to follow customer instructions who submitted the data, in response to contractual requirements or for security monitoring.

Inquiries and complaints:

If you believe Karomi maintains your personal data in one of the services, you may direct any inquiries or complaints concerning our compliance to privacy@karomi.com. Karomi will respond within 45 days.

Third parties who may receive personal data:

Karomi uses a limited number of third-party service providers to assist us in providing our services to customers. These third-party providers offer various services, including data storage services. These third-parties may access, process, or store personal data in the course of providing their services. Karomi maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our data privacy obligations, including the onward transfer provisions, and Karomi remains responsible and liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

Your rights to access, to limit use, and to limit disclosure:

If you wish to request access, or to limit use, or to limit disclosure, please provide the name of the user / customer who submitted your data to our services. We will respond back to your query within 45 days.

Compelled disclosure:

Karomi may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

RETAINING PERSONAL INFORMATION

Karomi will only retain personal information for the length of time necessary to fulfill the purpose(s) for which the information was collected or as required or permitted by applicable laws, (including the resolution of disputes) and in accordance with our customer contracts.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require your personal information, we will either delete or deidentify it or, if this is not possible, we will securely store it in accordance with this Website Notice and cease use of the personal information until deletion is possible. If we deidentify your personal information (so that it is no longer associated with you), we may retain this information for longer periods.

DATA SUBJECT RIGHTS

In accordance with applicable law and depending on your location, you may be entitled to exercise some or all the following rights regarding our collection, use, and sharing of your personal information:

• Access the personal information we maintain about you;•
• Update or correct any inaccurate or incomplete personal information about you;•
• Request that we delete your personal information;•
• Object to or restrict the processing of your personal information;•
• Receive the personal information you have previously provided to Karomi, in a machine-readable format, allowing you to transfer that personal information to another company at your discretion;•
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you; and•
• File a complaint directly with your governmental representative about how we process your personal information.
• Dispute resolution

Exercising Your Rights

To protect your privacy and security, we take reasonable steps to verify your identity before granting access to your personal information. Please follow the instructions below based on your relationship with Karomi and provide the requested information to allow us to adequately address your request. We will respond to your request within a reasonable timeframe and as otherwise required by applicable law in your location.

If you would like to request access to your personal information or request erasure (right to be forgotten) of personal information previously provided, please contact privacy@karomi.com.

KAROMI APPLICANTS & CANDIDATES

Karomi applicants who want more information on how Karomi processes applicant personal information, please review this section.

This section applies to the processing of Personal information by Karomi collected in connection our recruitment process and with your employment application with Karomi. This section applies to individuals who apply to work at Karomi or provide services to Karomi (including current employees who apply for new positions with us) (“you" or "Individuals").

The section describes the categories of Personal information we collect in connection with the recruitment and employee onboarding process, the purposes for which we collect that Personal information, the other parties with whom we may disclose that Personal information, and how Karomi protects that Personal information. This section also provides you with information about your rights and choices with respect to your Personal information, and how you can contact us to update your Personal information or make inquiries about our privacy practices.

1. Personal information We may collect

We collect the following personal information about in connection with your employment application and as part of our recruitment process, as permitted under applicable law:

*Lawful Basis for all of the above: The processing is necessary for performance of a contract with you, as well as legitimate interest and compliance with applicable laws and regulations.

In certain jurisdictions, and only to the extent permitted b applicable law, Karomi may process Sensitive Personal information, such as racial or ethnic origin, health-related data (for example, disability information), religious beliefs, and trade union membership, for the limited purposes as set out under Section 2, below.

To the extent permitted under applicable law, Karomi may receive Personal information directly from you through our Careers webpage and indirectly from third parties (e.g., former employers, educational institutions, publicly available sources, and professional social networking sites such as LinkedIn, online recruitment platforms, professional recruitment agencies, and government agencies).

2. How We May Use Your Personal information

We may use your Personal information to*:

• ‍Identify and contact you
• ‍Consider your application
• ‍Schedule and facilitate interviews
• ‍Determine your suitability for current and future job roles with us
• ‍Contact references or other individuals who may provide information about your employment history
• Perform pre-employment screening and testing
• ‍ Potentially prepare employment terms or an employment contract
• ‍Financial planning and budgeting
• ‍Engage in diversity and equal opportunity initiatives (where permitted and/or required under applicable law)
• ‍Provide reasonable workplace accommodations and safe workplace
• ‍Make staffing decisions
• ‍Enforce our policies and other legal rights
• ‍Improve and develop our recruitment processes (including surveys)
• ‍Ensure safety and security of our systems
• ‍Audit, research and perform analysis of our recruiting experience on our websites
• ‍Respond to inquiries, complaints or disputes
• ‍Perform certain data analysis regarding use of our recruiting sites and our recruitment programs
• ‍Comply with legal and other requirement

*Lawful basis for all of the above: The processing is necessary for performance of a contract with you, as well as legitimate interest and compliance with applicable laws and regulations.

Where we seek to review and implement measures to improve our recruitment activities and ensure compliance with our policies such as equal opportunity initiatives, we use aggregated data.

Karomi only processes Personal information for the above purposes to the extent permitted by applicable law and, where required, only when it can rely on a legal basis. In certain cases, such as when looking to fill a job opportunity, we may process your Personal information with assistance from automated employment tools. However, all decisions with regards to the use of automated employment tools also include the use of human review and/or intervention.

3. How We Share Your Personal information

We do not sell your Personal information, share or otherwise disclose Personal information we collect about you, except as described in this Notice or otherwise disclosed to you at the time the information is collected.

We may share your Personal information we collect with:•

• Companies within the Karomi group, including Karomi’s subsidiaries and affiliates globally to the extent that they are involved in the recruitment and/or hiring process;•
• Members of our internal departments to the extent that they are involved in the recruitment and/or hiring process. Company staff accessing Personal information are required to maintain its confidentiality and to process such information in accordance with applicable law;•
• Third parties to the extent necessary for the recruitment and/or hiring process (e.g., HR hosting services, candidate relationship management services, recruitment agencies and background screening agencies). The Company enters into contractual obligations with its third-party service providers to provide appropriate protection of Personal information.

For more information on service providers, please contact us as described in the "How to Contact Us" section below.

We also may share Personal information with our service providers who perform services on our behalf and in relation to the purposes described in this Notice:•

• With the consent or authorization of the Individual;•
• In the context of a sale or transfer involving all or a portion of the Company’s business or assets (including in the event of a reorganization, dissolution or liquidation);•
• In response to requests by government agencies, such as law enforcement agencies;•
• To protect the rights and properties of the Company;•
• If required to do so by law, regulation, or legal process (such as a court order or subpoena);•
• When we believe disclosure is necessary or appropriate to prevent physical harm to Karomi employees or financial loss;•
• As part of an investigation of suspected illegal activity.

The Company enters into contractual obligations with its third-party service providers to provide appropriate protection of Personal information.

Choosing Not to Share Your Personal information.

Denial of Requests.

Karomi may deny a request submitted in accordance with the above as permitted by applicable law in your location. Karomi will endeavor to notify you regarding any decision and reason(s) for denial in a timely manner and otherwise in accordance with applicable law in your location.

Dispute Resolution

In accordance with this Website Notice, Karomi will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of your personal information. Additionally, Karomi will cooperate with governmental authorities upon request.Any privacy-related dispute or concern that is still unable to be resolved to your satisfaction shall be handled in accordance with applicable dispute resolution procedures, free of charge.

We strongly encourage you to contact us directly with any complaints you may have with regard to this Website Notice or our privacy practices.

SECURITY

Karomi utilizes physical, technical, and administrative controls and procedures designed to safeguard the information we collect, prevent unauthorized access or disclosure, to maintain data accuracy of your personal information, and to restrict the processing of your personal information as set forth in this Website Notice.

We utilize a variety of physical and logical access controls, firewalls, intrusion detection and prevention systems, network and database monitoring, anti-virus, and backup systems. We use encrypted sessions when collecting or transferring sensitive data through our Site.

We limit access to your personal information and data to those persons who have a specific business purpose for maintaining and processing such information. Our employees who have been granted access to your personal information are made aware of their responsibilities to protect the confidentiality, integrity, and availability of that information and have been provided training and instruction on how to do so.

ENFORCEMENT AND VERIFICATION

Karomi will periodically assess its operations to validate compliance with this Website Notice.

We will take reasonable steps to prevent or address any unauthorized use or disclosure of your personal information in a manner contrary to this Website Notice. We hold our employees and third parties accountable for maintaining the trust that you place in Karomi.

CHANGES TO THIS PRIVACY NOTICE

This Website Notice is effective Jan 1, 2024. Karomi reserves the right to modify or amend this Website Notice at any time consistent with applicable laws. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT INFORMATION

At any time, you may contact Karomi with questions or concerns about this Website Notice at privacy@karomi.com.

Written responses may also be submitted to:

Karomi Technology Pvt Ltd

Attention: Chief Operations Officer

47,49 Bazullah Road

T. Nagar, Chennai – 600017

India

Karomi will respond to all correspondence within a reasonable timeframe, including as required by applicable law.

Karomi and its Affiliated Companies’ SubprocessorsSubprocessor Legal Name Data Processing Location Role in Delivery of ServicesMicrosoft US
EUIndia Cloud Provider: includes all Customer DataTwilio Inc. US Short Message Service (SMS) mobile network aggregator SMS: phone number and messageSendGrid US     Sending email notificationsGoogle analytics US Track product usage to improve adoption and trainingPlausible EU Track product usage to improve adoption and trainingHubspot US CRM tool for sharing product updatesChargebee Inc US Service provider providing Subscription and Billing servicesProduct Fruits EU Service Provider for Help, Product Tours, Onboarding and Chat support services