8th October 2015
This policy applies to all products and services offered by “Digital Emotions Limited” (doing business as “kin2kin”, also referred to in this policy as "we", "us" and "our") (the "Service"). This policy explains:
- what information kin2kin collects from you (and why we collect it); and
- how we use and share that information.
This policy is designed to provide transparency into our privacy practices and principles. We are dedicated to treating your personal information with care and respect.
The Service is a relationship platform based around closest-family, godparents and a few family friends "as-good-as-kin". It allows parents to promote positive relationships between their kids and a small positive network of family and closest friends. It allows grandparents to engage with all their grandchildren and close family from one simple platform. The focus is on including the younger and older generations and promoting a direct relationship.
Child safety and security is the highest priority, and the Service is designed to comply with the Children’s Online Privacy Protection Act (“COPPA”).
1 Types of Information We Collect
2 How We Collect Your Information
3 Use of Your Information by Digital Emotions Limited
4 Sharing Your Information with Other Companies
5 Your Controls and Choices
6 Children’s Privacy
7 Data Security, Integrity and Retention
8 Data Transfers, Storage and Processing Globally
9 Changes to this Policy
10 Privacy complaints process
1. Types of Information We Collect
We collect two basic types of information: personal information, which is information about an identifiable individual; and anonymous information. We may use personal and anonymous information to create a third type of information, aggregate information. Aggregate information will be treated as personal information.
We collect the following categories of information:
- Registration information you provide when you create an account, which, if you are over the age of 13, can include your name, mobile number, email address, username and a password.
- Information you provide in public forums on our sites and applications.
- Information you provide to us when you use the Service, our applications on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform with your account on the Service, including user content that you upload through the Service.
- Location information when you visit our sites or use our applications, including location information either provided by a mobile device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information.
- Usage, viewing and technical data, including your device identifier or IP address, when you visit our sites, use our applications on third-party sites or platforms or open emails we send to you.
2. How We Collect Your Information
We collect information from you in two ways: information that you voluntarily provide us by using the Service; and information collected automatically as result of your use of the Service.
2.1 Information you voluntarily provide to us:
Children under the age of 13 ("Minors") are only permitted to access the Service via a parent's or guardian's account that links them as a minor account. Minors are only able to provide personal information to us if permitted to do so through the settings selected by their parent or guardian. If a parent or guardian selects settings which allow a Minor to provide personal information to us, we will obtain the parent's or guardian's verifiable consent before the Minor is able to provide any personal information.
We collect and store the following types of information from each type of user of the Service:
- Account Sign-up and Profile Information: To create an account you may be asked to provide some basic information such as your first and last name, email address, telephone number, password and a profile photo. We will also ask for your age level and, if you are a Minor, you will not be able to provide us with any personal information or create an account unless a parent or guardian sets up an account, creates a linked account for the Minor and, in some circumstances, provides verifiable consent.
- Inviting Others: You can invite others join the Service, for example by providing their email address or phone number (to invite them via SMS). You can also invite others to join the Service by utilizing your own native mobile application functionality through the Service, for example by email, SMS or sharing via Facebook or Twitter. We collect and store the email and phone numbers you provide with these requests, and will also treat this as personal information in accordance with this policy.We may also ask you for access to the contacts on your mobile device to prevent you having to enter contact information for those invitations you send through the Service and may store these contacts from your address book.
- Other Information: When you choose to provide us with information through the Service or in any other manner. This includes when you submit or send any information or other content through the Service, send us an email asking a question, submit a support request, participate in a video testimonial about the Service, or choose to participate in any research efforts with kin2kin to improve the Service.
We collect information you provide to us when you request products, services or information from us, register with us, participate in public forums or other activities on our sites and applications, respond to customer surveys, or otherwise interact with us.
Where you provide us with any information about any other person, you warrant that you have obtained that person's consent to provide us with their information.
If individuals about which you provide any information would like to request deletion of their information, they may contact us directly at email@example.com.
Information collected automatically:
Like most web-based services, we automatically collect and log information on our server logs when you use the Service.
The technologies and information we automatically collect include:
- Information collected by cookies and other similar technologies: We (or our third party service providers) may use various technologies to collect and store information when you visit our Service including clear GIFs (also known as web beacons), tags, scripts and cookies. The Service uses both session and persistent cookies. A session cookie disappears after you close your browser; a persistent cookie remains after you close your browser (although it can be removed) and may be used by your browser to identify you on subsequent visits to the Service. We may also use, collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5). We use these technologies to tailor the Service for you, and to help the Service work better for you and as otherwise permitted by this policy.
- Device information: We collect device-specific information such as your operating system, hardware version, device settings, file and software names and types, battery and signal strength and device identifiers. This helps us measure how the Service is performing, improve the Service for you on your particular device, and send you push notifications if you’ve opted in to receive them.
information: This is information related to your use of the Service
- Details of how you used our service, such as your activity on the Service, and the frequency and duration of your visits to the Service.
- Telephony log information like your phone number and SMS routing information.
- IP address.
- Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
This information helps us market the Service and make decisions about what we should work on next.
3. Use of Your Information by Digital Emotions Limited
Digital Emotions Limited will be the data controller for your information. It will have access to and use your information for the following purposes:
- Provide you with the products and services you request.
- Communicate with you about your account or transactions with us and send you information about features on our sites and applications or changes to our policies.
- Send you offers and promotions for our products and services or third-party products and services.
- Personalize content and experiences.
- Optimize or improve our products, services and operations.
- Detect, investigate and prevent activities that may violate our policies or be illegal.
4. Sharing Your Information with Other Companies
We will not share your personal information except in limited circumstances, including:
- Information that you submit to the Service will be automatically shared with your network.
- When you direct us to share your personal information with third party sites or platforms, such as social networking sites. Once we share your personal information with a third party, the information received by the third party becomes subject to that third party's privacy practices. We are not responsible for the use of your information by any third party.
- In relation to the sale of the kin2kin business or any part of the kin2kin business.
- To enforce this policy, our Terms of Service or any other rules we make in relation to the Service.
- To ensure the safety and security of our customers.
- To protect our rights and property and the rights and property of our customers and third parties.
- To comply with legal process or in other cases if we believe in good faith that disclosure required by law.
- Where disclosure or use is otherwise permitted by applicable law.
5. Your Controls and Choices
provide you the ability to exercise certain controls and choices
regarding our collection, use and sharing of your information. In
accordance with local law, your controls and choices may include:
- You may request that we correct, update and delete your personal information.
- You may change your choices for alerts, as permitted within the Service.
- You may choose whether to receive targeted advertising from many ad networks, data exchanges, marketing analytics and other service providers.
You may exercise your controls and choices, or request access to your personal information, by visiting the communication choices part of the Services or by contacting guest services.
If you refuse to provide certain personal information, or do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, including all or part of the Service, and some of our services may not be able to take account of your interests and preferences.
6. Children’s Privacy
Service is designed to comply with COPPA.
Parents and guardians control the private network around them and
their children, and set the level of access for their children. In
the safest mode, Minors can see photos and respond with emoji only.
In this mode, Minors cannot submit text or photos to the Service. If
Minors are permitted, by their parent or guardian, to submit text or
photos to the Service, this may include personal information, and
If you are a Minor, you cannot establish your own account with the Service. You can only gain access via a minor account, created and managed from your parent's or guardian's parent account.
If you are between the ages of 13 and 18, you represent that your parent or guardian has reviewed and agreed to this policy and the Terms of Service before you used the Service. If you don’t get your parent or guardian to read and agree to this policy and the Terms of Service, you are not entitled to use the Service.
7. Data Security, Integrity and Retention
The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods.
Despite our best efforts, no security measures are perfect or impenetrable. We do not warrant that the information you provide or information that we collect about you will be completely secure and protected from disclosure.
We will retain your personal information for the length of time needed to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law.
8. Data Transfers, Storage and Processing Globally
We operate globally. The information we collect may be stored anywhere in the world, including with our third party service providers.
9. Changes to this Policy
From time to time, we may make changes to this policy. These changes will be effective when the updated policy is posted in the Service, and your use of the Service after the updated policy has been posted will constitute your acceptance of the updated policy. If you do not wish to agree to any changes to this policy, you must stop using the Service.
10. Privacy complaints process
If you wish to complain about how we have handled your personal information, please provide full details of your complaint and any supporting documentation to our privacy officer at firstname.lastname@example.org.