KitOrder Privacy Policy

At KitOrder, we are 100% committed to protecting your privacy and security. As a multi-tenant SaaS platform, our approach to data handling is unique and prioritizes the privacy of end-users. We process personal information in accordance with the General Data Protection Regulation, the Data Protection Act 2018, and other applicable privacy laws.

Data Controller and Our Role

For this website, the data controller — the company responsible for protecting your privacy — is KitOrder Inc. However, it's crucial to understand our specific role in data handling:

  1. Multi-Tenant SaaS Platform: KitOrder operates as a multi-tenant Software as a Service (SaaS) solution. We provide curated micro-ecommerce functionality to third-party sellers ("vendors") of cycling and triathlon team clothing and gear (our “clients”).
  2. Data Custodian, Not User or Owner: KitOrder does not use the personal data collected by our system for our own purposes, nor do we own such data. Instead, we act as a custodian of this data, holding and safeguarding it on behalf of our clients.
  3. Client Data Usage: The personal data collected through our platform is intended for use by our clients - the clothing manufacturers (vendors) who use our system to create curated ecommerce experiences for their customers (athletic teams and groups).

Data Handling and Third-Party Access

  1. Data Protection: We implement robust security measures to protect all data stored in our system, ensuring it remains secure and confidential.
  2. Vendor Access: Our vendor clients and their authorized representatives (such as sales teams) may have access to and utilize your data within the scope of their business operations.
  3. Vendor Privacy Policies: As each vendor may have different data use practices, we strongly recommend that you consult the individual privacy policy of the vendor you are interacting with for specific information on how they use your personal data.



Your Rights and Choices

While KitOrder does not directly use your personal data, we respect and support your data privacy rights. If you have any questions or concerns about how your data is being handled, please contact us, and we will direct you to the appropriate vendor or assist you in exercising your rights under applicable privacy laws.

Remember, for detailed information on data use cases and specific privacy terms related to your interactions, please refer to the privacy policy of the individual vendor you are dealing with.

By using our platform, you acknowledge this data handling structure and agree to the terms outlined herein.

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: cookies; usage data; email address; data communicated while using the service; first name; last name; country; and phone number.

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 this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application 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.

Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application 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 this Application.

 

Mode and place of processing the Data

Methods of processing

The Data Controller 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 Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (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 Data Controller. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed in the cloud via Microsoft Azure and may be processed 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 Data Controller 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 including: Registration and authentication, Contacting the User, Handling payments, site Analytics, and Managing contacts and sending messages

For clarity, KitOrder does not use the data for: Access to third-party accounts, Interaction with external social networks and platforms, Advertising, Remarketing and behavioral targeting, Displaying content from external platforms, SPAM protection, Heat mapping and session recording, Interaction with live chat platforms, Interaction with online survey platforms, Location-based interactions and Information collection.

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”.

Explicit Permissions not carried out by KitOrder Inc. 

KitOrder Inc. recognizes that there are a number of ways in which user data may be used or transmitted that KitOrder’s application does not support. KitOrder Inc.’s permissions are limited solely to ecommerce type actions that require personal data related to processing a transaction. KitOrder explicitly does not process data associated with:

  • Facebook Accounts (Facebook, Inc.)
  • Facebook Audience Network (Facebook, Inc.)
  • Google Drive account access (Google Inc.)
  • Advertising and Trackers
  • Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
  • Google Ad Manager (Google Inc.)
  • Google AdSense (Google Inc.)
  • Google Ads conversion tracking (Google Inc.)
  • Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
  • Microsoft Advertising (Microsoft Corporation)
  • Display Advertising extension for Google Analytics (Google Inc.)
  • Displaying content from external platforms
  • Google Maps widget (Google Inc.)
  • Hotjar Heat Maps & Recordings (Hotjar Ltd.)
  • LiveChat Widget (LiveChat, Inc..)
  • SurveyMonkey Widget (SurveyMonkey Inc.)
  • Mailchimp (The Rocket Science Group Inc.)
  • Mandrill (The Rocket Science Group Inc.)
  • SendinBlue SMS (SendinBlue SAS)
  • Facebook Authentication (Facebook, Inc.)
  • Mailchimp OAuth (The Rocket Science Group Inc.)
  • Facebook Remarketing (Facebook, Inc.)
  • Facebook Custom Audience (Facebook, Inc.)
  • Google Ad Manager Audience Extension (Google Inc.)
  • Google Ads Remarketing (Google Inc.)

Permissions Supported by KitOrder

Analytics

The services contained in this section enable the Data Controller to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Universal Analytics) (Google Inc.)

Google Analytics (Universal Analytics) is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, 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.

In order to understand Google's use of Data, consult Google's partner policy.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy PolicyOpt Out.

Contacting the User

Mailing list or newsletter (this Application)

Kitorder Inc.’s clients may choose to integrate newsletter functionality. By registering on such a mailing list or for such a 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 this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data processed: country; email address; first name; gender; last name.

Google Fonts (Google Inc.)

Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

YouTube video widget (Google Inc.)

YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Handling payments

Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed. 

KitOrder works with a number of different merchant accounts, as directed by our clients. Please consult individual client sites for information on the Personal Data processed and various types of Data as specified in the privacy policy of the service. 

Information collection

Children's Privacy Policy

The Children's Online Privacy Protection Act ("COPPA") requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age, and that we obtain the consent of parents and guardians in order for children under 13 years of age to use certain features of our websites.

KitOrder does not knowingly collect any information from children under the age of 13.

We may amend our Children's Privacy Policy at any time. We will provide parents notice by email or posting on our website of any material changes in the way we intend to collect, use, and/or share a child's personal information. We will apply material changes in our Children's Privacy Policy only in conformance with applicable law, Inc.luding any applicable provisions of COPPA that require parental consent.

 

 

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn’t being connected back to the User’s profile.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc..

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Twitter Tweet button and social widgets (X Corp.)

The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc..

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Google+ +1 button and social widgets (Google Inc.)

The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc..

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

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.

Registration and authentication

By registering or authenticating, Users allow this Application 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, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Tag Management

This type of service helps the Owners to manage the tags or scripts needed on this Application 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 Inc.)

Google Tag Manager is a tag management service provided by Google Inc..

Personal Data processed: Usage Data.

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

Analysis and predictions based on the User’s Data (“profiling”)

The Data Controller may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Data Controller to evaluate User choices, preferences and behavior for the purposes outlined in the respective section of this document.


User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.


The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

Selling goods and services online

The Personal Data collected are used to facilitate the sale of goods from KitOrder’s 3rd party clients, including Client terms and control of payment and delivery. KitOrder does not manufacture, hold inventory, or have control over the sale or sale price of said products except to the extent such sale is facilitated by KitOrder’s software platform.

KitOrder does not collect credit cards. We do store tokens provided by the PCI compliant card processing integrations we use. Please consult individual Client sites for further details.

Cookie Policy

This Application uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Data Controller 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 Data Controller 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 Data Controller;
  • processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

In any case, the Data Controller 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 Data Controller and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Data Controller’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 Data Controller within the relevant sections of this document or by contacting the Data Controller.

The Data Controller 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 Data Controller may be obliged to retain Personal Data for a longer period whenever required to fulfill 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.

Rights of California Residents under the California Consumer Privacy Act (CCPA)

California residents have certain rights regarding their personal information processed by the business. Under the CCPA, California residents have the right to:

  1. Right to Know: Request that the business disclose what personal information it collects, uses, shares, or sells.
  2. Right to Delete: Request deletion of personal information that the business has collected and maintained, subject to certain exceptions.
  3. Right to Opt-Out: If a business sells personal information, California residents can direct the business to stop selling their personal information.
  4. Right to Non-Discrimination: A business cannot discriminate against a consumer because the consumer exercised any of their CCPA rights.
  5. Right to Access: Obtain access to the specific pieces of personal information that the business has collected about the consumer.
  6. Right to Data Portability: Receive personal information in a readily useable format that allows the consumer to transmit the information to another entity without hindrance.
  7. Right to Correct: Request that a business correct inaccurate personal information that it maintains about the consumer.
  8. Right to Limit Use and Disclosure of Sensitive Personal Information: Direct a business that collects sensitive personal information to limit its use of such information.

To exercise these rights, California residents may submit a verifiable consumer request to the business. The business will respond to verifiable requests within 45 days, with a possible 45-day extension when reasonably necessary.

California residents also have the right to designate an authorized agent to make a request under the CCPA on their behalf.

If a business has actual knowledge that a consumer is under the age of 16, it shall not sell the consumer's personal information without proper consent.

Businesses are required to provide notice to consumers at or before the point of collection of personal information. This notice should inform consumers about the categories of personal information to be collected and the purposes for which it will be used.

Please note that while we strive to protect your privacy rights under the CCPA, certain exemptions may apply, and not all rights may be absolute.

The Rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owners.

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 Data Controller, 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 Data Controller 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 Data Controller.
  • 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 Data Controller to safeguard its 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 Data Controller or for the purposes of the legitimate interests pursued by the Data Controller, 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 Data Controller 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 Data Controller through the contact details provided in this document. Such requests are free of charge and will be answered by the Data Controller 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 Data Controller 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 Data Controller 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 Data Controller in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.


The User declares to be aware that the Data Controller 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, this Application 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, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Data Controller. 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 Data Controller 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 this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, 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 this Application 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 this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application 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 this Application, if not stated otherwise within this document. 

In the event of a dispute, KitOrder will utilize an independent recourse mechanism provided by the private-sector dispute resolution body JAMS with regard to such data or choose to cooperate with and comply with the advice of the appropriate European data protection authorities with regard to such data.  

Latest update: March 19, 2024

Microsoft Azure hosts this content and only collects the Personal Data strictly necessary for it to be provided.

For more information please contact:

 info@kitorder.com

+1 415 367 3605