Your Privacy.
Protected.

Thank you for using KloneMe APP. We are committed to protecting your privacy and, for that reason, we have adopted this Privacy Policy to explain our data collection, use, and disclosure practices for the KloneMe APP (including its mobile application, and any other tools, products, or services provided by Haplet that link to or reference this Privacy Policy) (collectively, the “App”). The App is owned and operated by Haplet LLC, a New Jersey limited liability company (“we”, “us” or “our”).

This Privacy Policy applies to information Haplet collects through the App, as well as other information provided to us online or offline by third parties, when we associate that information with customers or users of the App; however, it does not apply to information collected from our employees, contractors, or vendors. It also does not apply to information that you ask us to share with third parties or that is collected by certain other third parties whose software or services are featured or included in the App (as further described below).

This Privacy Policy describes, among other things:

• Personal and other information we collect about you;
• How we use your information;
• How we may share your information with third parties; and
• Your choices regarding the personal information we collect about you.

1. Consent

By accessing or using the App, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the App. Information gathered through the App may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the App, you agree to the transfer, use, and storage of your Personal Information and Your Documents (as each are defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the App or Haplet are deemed to occur in the United States, where our servers are located.

2. Collection of Your Personal and Other Information

When you register for or use our App, we collect Personal Information. By “Personal Information” we mean information that can identify or reasonably be linked to an individual, such as:

• Names;
• Personal or business addresses;
• Email addresses;
• Phone numbers;
• Credit card information (which you submit for payment purposes and which is collected by Apple’s App Store or Google Play);
• The names of other members of your household, and their relationship to you;
• If you use the App’s OCR Features as described below, the information contained in Your Documents; and
• Information contained in any user profile you choose to submit to us.

The App's Profile page lets you optionally provide additional information about yourself, including (but not limited to) your age range or date of birth, gender, marital status or family situation, education, occupation, industry or sector, country of birth, country of citizenship, and personal interests or hobbies. Providing this Profile information is entirely optional and is not required to use the App. We use this Profile information solely to personalize which document categories and document types are shown to you in your vault. You may review, edit, or clear any of this Profile information at any time through the App's Profile page.

Our App may integrate with your Apple or Google account on your mobile device. When you connect an Apple or Google account to our App, then we may collect information about that account and share information with Apple or Google as described in the connection process. This collected information may include, but is not limited to, your name, email address, and other information associated with your Apple or Google account. You acknowledge and agree that Haplet is not responsible for the data collection or use practices of Apple or Google. You should read Apple or Google’s respective privacy policy before connecting that account with the App.

Certain aspects of the App may also access certain features of your mobile device, including its camera, location services (GPS), microphone, and contacts, and collect information from those features, such as photographs, videos, your precise location, audio recordings, and contact information. You consent to this access.

You may choose not to provide Personal Information or prevent the App from accessing certain features of your mobile device (subject to the controls offered by your mobile device’s operating system), but this may prevent you from receiving certain features of the App.

Your Documents

The App enables you to store and view digital versions of Your Documents in one convenient place. By “Your Documents”, we mean the identifications, credentials, or other documents you choose to store on the App, such as your digital identification cards (e.g., digital versions of your driver’s license, passport, or health insurance card), household-related records (e.g., documents concerning your income, property, or taxes), personal health documents (e.g., health records or personal fitness statistics), or travel-related documents (e.g., travel itineraries or reservations, boarding passes, or other digital tickets).

Each of Your Documents that you choose to store on the App is protected using end-to-end encryption, using keys that are derived from your device and your device’s passcode (which only you know). Haplet does not maintain or have access to the encryption or decryption keys for Your Documents, and, unless you choose to use the App’s OCR Features to analyze Your Documents, there is no foreseeable way for Haplet to decrypt, view, or otherwise access unencrypted versions of Your Documents that are stored on the App or our servers, or any of the personal or other information contained in Your Documents. In other words, unless you use the App’s OCR Features to analyze Your Documents, Haplet only receives ciphertext data when you store Your Documents on the App (“Ciphertext-only Data”), and Haplet has no means to decrypt or read the plain text of Your Documents from the Ciphertext-only Data.

You may choose to use the optical character recognition features of the App (the “OCR Features”), which enable the App to scan and extract certain personal and other information from Your Documents, such as the expiration date of your driver’s license or passport, and store that scanned information (“Your Scanned Information”) in the App. Use of the OCR Features is optional. If you use the OCR Features, then we will also collect and store Your Scanned Information. Your Scanned Information is encrypted when transmitted over the Internet and when at rest on our servers; however, unlike Ciphertext-only Data, Haplet will have access to the personal and other information contained in Your Scanned Information.

We also collect non-Personal Information relating to the App, that is, information that does not personally identify an individual (“Non-Personal Information”). The non-Personal Information we collect includes how you interact with the App, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the App.

Examples of the non-Personal Information we collect are:

• The features of the App you use;
• What information or features you view or interact with using the App;
• Language preferences;
• The city and state in which you are located (but not your precise geographic location); and
• Unique identifiers that are not connected and cannot reasonably be connected to your identity.

We will not use non-Personal Information to try to identify you, and if we associate any non-Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather Personal Information and non-Personal Information.

Information collected by the App may be collected by us or one of the third parties we utilize in providing the App (as further described below).

3. Use of Your Information

We may use the information we collect to:

• Assist us in providing, maintaining, and protecting the App;
• Set up, maintain, and protect accounts to use the App;
• Improve our online operations;
• Process transactions;
• Provide customer service;
• Communicate with you, such as provide you with account- or transaction-related communications, or other newsletters, RSS feeds, and/or other communications relating to the App;
• Send or display offers and other content relating to the App that is customized to your interests or preferences;
• Prevent fraud and other misuse;
• Perform research and analysis aimed at improving our products and services and developing new products or services;
• Manage and maintain the systems that provide the App; and
• Comply with our legal obligations and exercise our legal rights.

Haplet does not use the contents of Your Documents, or the Personal Information contained in them, to train machine learning or artificial intelligence models. As discussed above, if you choose to use the App’s OCR Features, we and our Online Tool Providers (such as Microsoft Azure Document Intelligence) will perform optical character recognition and similar functions on Your Documents and process Your Scanned Information, as described above. The use of Your Scanned Information by our Online Tool Providers is governed by their own terms and privacy policies, as further described in Section 5 below, which we encourage you to review.

Our OCR Features are opt-in. Before any of Your Documents are transmitted to our Online Tool Providers (such as Microsoft Azure Document Intelligence) for OCR processing, the App will display a confirmation prompt that identifies the Online Tool Provider receiving Your Documents and describes the data being sent. Your Documents are transmitted only after you confirm. You may grant one-time consent for a single upload, or you may enable OCR processing as a standing preference through the privacy settings within the App. You may review or revoke this preference at any time through those same settings.

4. Disclosure of Your Information

We may disclose your Personal Information, including Your Scanned Information, and Ciphertext-only Data, to third parties as described below.

We may disclose Personal Information to provide the App, or when you authorize or instruct us to do so, for example, when you use the App to submit content or profile information.

You may also use the app to share Your Documents with other App users or third parties. If you wish to share any of Your Documents with another App user, such as another member of your household, you can add Your Documents to the “Family Vault” on the App. When you make Your Documents available to other users via the Family Vault, the decryption and subsequent re-encryption of Your Documents is performed using the recipient user’s public key. Each user with access to the Family Vault can access and share any of Your Documents that you add to the Family Vault; accordingly, you are responsible for controlling which of Your Documents you add to the Family Vault.

If you wish to share any of Your Documents with an external third party (i.e., an individual that is not an App user), the file is shared using a pre-signed URL (“Access Link”), at which the unencrypted file is made available by your device and can be accessed for a set amount of time by anyone with access to the Access Link; accordingly, you are responsible for controlling access to any Access Link you create.

We may also disclose Personal Information, including Your Scanned Information, as well as non-Personal Information and Ciphertext-only Data, to Service Providers. By “Service Providers” we mean companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, and conducting audits). When we use a Service Provider, we require that the Service Provider use and disclose the Personal Information, including Your Scanned Information, received from us only to provide their services to us or as required by applicable law.

We may also disclose Personal Information and non-Personal Information to Online Tool Providers. By “Online Tool Provider” we mean a licensor of software that we include in, or use with, the App, including an API or SDK, that provides a specialized function or service to us and that requires the transmission of Personal Information and/or non-Personal Information to the Online Tool Provider. We select Online Tool Providers based on their commitments to data protection. For example, our OCR Online Tool Provider, Microsoft Azure Document Intelligence, processes Your Documents and Your Scanned Information under Microsoft's commercial service terms, which commit Microsoft to processing Your Documents only to provide the OCR services we have requested, not to use Your Documents for advertising, and not to retain Your Documents beyond service delivery. Online Tool Providers may have the right to use Personal Information and non-Personal Information about you for their own business purposes. Use and disclosure of Personal Information and non-Personal Information by an Online Tool Provider is described in its privacy policy. See Section 5 below for some of the key Online Tool Providers we use.

We may also disclose your Personal Information, including Your Scanned Information, or Ciphertext-only Data, to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the App, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) submit insurance claims, cooperate with insurance investigations, and fulfil insurance subrogation activities, (e) prevent a crime or protect national security, or (f) detect, prevent or otherwise address fraud, security or technical issues.

Finally, we reserve the right to transfer information (including your Personal Information, including Your Scanned Information, as well as Ciphertext-only Data) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the App, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example, via email or by posting notice on our website.

Lastly, we may also disclose non-Personal Information, aggregated with information about our other users, to our clients, business partners, merchants, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

5. Cookies and Automatic Information Gathering Technologies

Every time you use the App (e.g., navigate to a specific location within the App), we collect Personal Information and non-Personal Information (discussed above in Section 2) regarding that use. For example, to improve our App, we collect how, when, and which parts of the App or its features you use. Also, we may use your device’s unique identifier (UDID) or other unique identifiers to assist us in collecting and analyzing this data.

To assist us in collecting and storing this non-Personal Information, we may employ a variety of technologies, including “Cookies,” local browser storage, and “web beacons,” “pixels,” or “tags.” A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website. A web beacon, pixel or tag is a small, usually-transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a Cookie.

Your operating system and web browser may allow you to erase information stored in Cookies and local browser storage. But if you do so, you may be forced to login to the App again, and you may lose some preferences or settings. You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of our App may not function properly without it. We may use Cookies to keep you logged in, save your preferences for the App, and to collect information about how you use our App.

More information about managing Cookies is available here. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.

An Online Tool Provider may collect information automatically, in which case Personal Information and non-Personal Information it receives are subject to the Online Tool Provider’s privacy policy. Some Online Tool Providers may allow you to opt out of certain collection and/or uses of your information. You can read more here:

• Clerk — https://clerk.com/legal/privacy
• Microsoft Azure Document Intelligence — https://www.microsoft.com/en-us/privacy/privacystatement

6. Transparency and Choice; Do Not Track Signals

You may request access to your Personal Information, including Your Scanned Information, by sending an email to contactus@kloneme.ai. We will try to locate and provide you with your Personal Information or Your Scanned Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. Because we do not have access to any information contained in Ciphertext-only Data, we cannot assist you in correcting inaccurate information contained within Your Documents for which we possess only Ciphertext-only Data, or with deleting any information contained within Your Documents for which we possess only Ciphertext-only Data. However, you can request that we delete Your Scanned Information and your Ciphertext-only Data from our servers. But, in either case, we may need to retain your Personal Information, including Your Scanned Information, or Ciphertext-only Data, for legal reasons or for legitimate business purposes. You may also remove any of Your Documents or other content that you upload to the App using the deletion or removal options within the App. However, we (and you) are not able to control Your Documents and other information that you have already shared with other users or made available to third parties through the App.

If you need further assistance with removing any content you uploaded to the App, you can email us at contactus@kloneme.ai. Removal of your uploaded content may not ensure complete or comprehensive removal from our computer systems.

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. We may also require you to verify your identity to our satisfaction before providing you with access to Personal Information, including Your Scanned Information, or deleting Ciphertext-only Data.

You can choose to delete your account by navigating to [Deactivate & Delete Profile] in the settings for the App.

Please be aware that if you request us to delete your Personal Information, including Your Scanned Information, or Ciphertext-only Data, you may not be able to continue to use the App, or certain of its features or functionality (as applicable). Also, even if you request that we delete your Personal Information, including Your Scanned Information, or Ciphertext-only Data, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

We also support the development and implementation of other standardized “do not track,” universal opt-out mechanism, or similar browser features that provide customers with control over the collection and use of information about their web-browsing activities. Once other standardized “do not track” features are widely recognized, we intend to adhere to those features accordingly.

You can opt out of receiving marketing e-mails from us by clicking on the “unsubscribe” link in the e-mails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Also, even if you opt out of marketing e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.

7. Certain State Residents

You may be aware that there are various comprehensive state data privacy laws currently in effect in the United States. Our App is not currently subject to any comprehensive state laws providing rights in connection with Personal Information. However, we do provide notice and transparency about our collection and use of Personal Information as described in this Privacy Policy.

8. Residents of Canada

If you have an objection to the use of your Personal Information as described in this Privacy Policy, you may file a complaint by sending an email to contactus@kloneme.ai. We will attempt to accommodate your objection or complaint, but you understand that, to the extent you object to our processing of Personal Information that is necessary for us to provide the App to you, certain features and functionalities of the App may no longer be available to you. Nothing in this Privacy Policy prejudices your rights to file a complaint with the Office of the Privacy Commissioner of Canada, and/or with any other applicable data protection authorities.

9. Users in India

If you are located in India and use the App, the following terms apply to you in addition to the rest of this Privacy Policy.

Lawful Basis for Processing

We process your Personal Information based on the consent you provide when registering for and using the App. You may withdraw your consent at any time by contacting us at the email address listed at the end of this Privacy Policy or by deleting your account in the App. Withdrawing consent may limit your ability to use certain features of the App.

Your Rights as a Data Principal

Under the Digital Personal Data Protection Act, 2023, you have the right to (a) access information about the Personal Information we hold about you and how it is processed; (b) request correction of inaccurate or incomplete Personal Information; (c) request erasure of your Personal Information, subject to applicable legal retention requirements; (d) nominate another individual to exercise these rights in the event of your death or incapacity; and (e) raise a grievance with us about the processing of your Personal Information.

Aadhaar

The App does not collect, store, process, or otherwise handle Aadhaar numbers, Aadhaar card images, or any data extracted from Aadhaar credentials. Indian users should not upload Aadhaar cards or Aadhaar-derived information to the App. If you upload an Aadhaar card by mistake, please delete it from the App immediately and contact us so we can confirm removal.

Grievance Redressal

If you have a grievance about how we process your Personal Information, you may contact our Grievance Officer at contactus@kloneme.ai. We will acknowledge your grievance within seven (7) days and respond within thirty (30) days. If you are not satisfied with our response, you may file a complaint with the Data Protection Board of India.

Cross-Border Data Transfer

Personal Information of Indian users may be transferred to, processed in, and stored in the United States and other countries where our service providers operate. By using the App, you consent to this transfer. We will only transfer your Personal Information to countries that provide adequate protection or pursuant to safeguards permitted under Indian law.

10. Residents of Nevada

We do not sell your Personal Information. However, you may contact us at contactus@kloneme.ai with questions.

11. Children

The App is not intended for users under 13 years of age. We do not knowingly collect Personal Information from users under 13 years of age. We do not authorize users under 13 years of age to use the App, and you must not invite any individual under 13 years of age to use the App or join your Family Vault on the App.

12. Information Security

We utilize reasonable information security measures to safeguard your Personal Information, including Your Scanned Information, and Ciphertext-only Data, against unauthorized access, modification, or destruction. For example, we utilize Transport Layer Security (TLS), or similar encryption technology, when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network. However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, including Your Scanned Information, and Ciphertext-only Data, we cannot guarantee its security.

We restrict access to Personal Information, including Your Scanned Information, and Ciphertext-only Data in our possession to our employees, Service Providers, and Online Tool Providers who need to know that information in order to operate, develop, improve or support our App.

13. Third Party Websites

Please note that the App may link or integrate with third-party sites, services or apps. We are not responsible for the privacy or security policies or practices or the content of such third parties. Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how they collect, use, share and protect your information.

14. Changes to this Policy

We may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on this page. You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed. If we make any material changes to this Privacy Policy, we will notify you by reasonable means, which may be by e-mail or posting a notice of the changes on our website or the App prior to the changes becoming effective. We encourage you to check this Privacy Policy from time to time.