Updated December 10, 2019.
Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), should consult the sections of this policy relating to the “Rights of EEA Residents” and “International Data Transfers” for provisions that may apply to them.
Personal Information That We Collect and How We Use It
We collect Personal Information about you when you visit the Site. “Personal Information” is information that may be used to directly or indirectly identify an individual (which in some cases, may include certain Device Information). Personal Information may include (a) names, aliases, postal addresses, unique personal identifiers, online identifiers, Internet Protocol (IP) address, email address, or other similar identifiers; (b) internet or other electronic network activity information; or (c) audio, electronic, visual or similar information. We may combine the Personal Information that we obtain about individuals from more than one source.
The majority of such Personal Information is collected when you register with the Site or otherwise provide us with your contact information or participate in certain activities provided for on KWK’s Site.
In general, the type of Personal Information we collect includes, but is not limited to:
Personal Information to keep in touch with you regarding features or matters of interest, including our programs or to participate in certain activities on our Site;
Personal Information necessary submitted to our third-party vendor if you apply to become part of our team or which to contribute to Kode with Klossy;
Un-identifiable and aggregated Personal Information pertaining to your Site visits that help us maintain the appropriate features, functionality and user experience
We and our partners may use that data to maintain regular communication with you as may be necessary to inform you of offers, updates and other information regarding KWK.
Use of Personal Information
We use your Personal Information to: (i) enable you to log in to the Site or participate in certain activities on the Site; (ii) provide information about our programs; (iii) guard against potential fraud; (iv) contact you (v) provide answers to your inquiries or questions; and (v) maintain regular communication with you as may be necessary to inform you of offers, updates and other information regarding KWK.
The shop on our Site is hosted by Shopify, Inc. Shopify provides us with the online e-commerce platform that allows us to allow you to purchase of merchandise. Your data is stored through Shopify’s data store, databases and the general Shopify application. Shopify stores your data on a secure server behind a firewall.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted according to the requirements of the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. For further information, please consult Shopify’s Terms of Service (https://www.shopify.com/legal/terms) and Privacy Statement (https://www.shopify.com/legal/privacy).
Non-Identifiable Data and Aggregated Personal Information [Please verify if this is correct]
We or our service providers, including Google Analytics, may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, "click stream" transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. We may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Site based on the needs of our users.
How and When Your Information Is Shared With Other Parties
Additional Sharing of Information
We may engage third parties to help us carry out certain other internal functions relevant to our business. Personal Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services. Our partners are legally required to keep your Personal Information private and secure.
We may share your Personal Information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your Personal Information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your Personal Information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our services, or to protect the rights, property or personal safety of us, our users, issuers, or others.
We will not share your Personal Information if such sharing is prohibited by applicable privacy and data protection law, including, without limitation, the EEA’s General Data Protection Regulation effective May 25, 2018.
From May 25, 2018, all processing of Personal Information of EEA Residents is performed by us in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Information and on the free movement of such data (“GDPR”).
Under the GDPR, we are the controller and a processor of the Personal Information of EEA Residents. Our purpose for collecting and processing Personal Information from EEA Residents is to obtain contact information and to substantiate such information. The legal basis for collecting Personal Information is your consent. You may withdraw consent for obtaining such communications by following the “Unsubscribe” instructions on any communication or by contacting us at firstname.lastname@example.org.
If you are a resident of the EEA and wish to access or correct the Personal Information that we have about you or have any questions relating to the processing of your Personal Information, please contact us at email@example.com with the subject line “GDPR Data.”
International Data Transfers
If you are resident outside the United States, including in the EEA, we transfer Personal Information provided by you for processing in the United States. Under the GDPR, we are considered a “controller” and a “co-processor” of the Personal Information of EEA Residents. By providing Personal Information to us for the purpose of subscribing to our mail lists, you consent to the transfer of your Personal Information to the United States.
Please note that the United States does not have data protection laws equivalent to those in the EEA and other jurisdictions.
Notifications and Communications from Our Site
Communications Regarding Our Services
We will send you email notifications and free newsletters from time to time with offers, suggestions and other information. Some notifications are communications relating to us and our Services. You may “opt-out” from receiving such communications by following the “Unsubscribe” instructions provided in the e-mail.
Legal or Security Communications
Deleting Your Information
If you want us to delete your Personal Information and your account, please contact us at firstname.lastname@example.org with your request. We will take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
Personal Information Retention
Links to Other Sites
Privacy in Submitted Materials
If you submit any materials to us, either directly or through a social media platform, such as Instagram, such materials, including photos or comments may be displayed on the Site, including photos of yourself or other individuals. We may also display your first name in connection with the first initial of your last name in connection with comments submitted by you. By submitting such materials you forego any privacy rights in such materials. Please consult the Terms of Service for other conditions relating to submission of materials to us directly or through social media sites.
We take commercially reasonable steps to protect our customers’ Personal Information against unauthorized disclosure or loss. However, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us or from the Site. You engage in such transmissions at your risk.
If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at email@example.com.
Children Under 13
This Site is restricted to the use of individuals over the age of 13. We therefore will take measures to verify the age of our users. No portion of the Site is directed to children under the age of 13. Consequently, we do not knowingly collect personal identifying information from any person we know is a child under the age of 13. If we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at firstname.lastname@example.org.
Your California Privacy Rights
Civil Code Section 1798.83
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marking purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
California Consumer Privacy Act
As a charitable not-for-profit organization, we are not subject to the provisions of the California Consumer Privacy Act (“CCPA”), which will come into effect after January 1, 2020. We nonetheless take our privacy obligations very seriously. If you are a California consumer and would like to make any inquiry regarding your Personal Information, please contact us at email@example.com.
Your Rights and Obligations
We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at firstname.lastname@example.org. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.