Privacy policy

KIN USA, INC is committed to protecting Your (as herein defined) privacy under the law in the way We (as herein defined) process Personally Identifiable Information (PII). This Privacy Policy outlines the kinds of PII We collect, how PII is used, how PII may be shared, how PII is secured, and the rights pertaining to PII.   

Company Information

Company is KIN USA, INC. 

Definitions

“Company,” “We,” “Us,” and “Our” refers to KIN USA, INC. 

“App” refers to the KUSA web or mobile application(s).

“Platform” refers to the App. 

“User,” “Users,” “You,” and “Your” refer to those visiting and accessing Company App or otherwise interacting with Company, and if You represent an entity or other organization, “User,” “You,” and “Your” may also refer to that entity or organization. 

“Personally Identifiable Information (PII)” refers to information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Acceptance Of This Privacy Policy

Continued use of Company App or other interaction with Company, constitutes acceptance of this Privacy Policy. Further, this Privacy Policy is incorporated into the Company’s Terms and Conditions. Acceptance of the Terms and Conditions is also required. By using Company App or other interaction with Company, You certify that you have read and understood both the Privacy Policy and the Terms and Conditions and agree to be legally bound by them.

Scope Of Privacy Policy

The scope of this Privacy Policy applies to Company’s processing of PII, including information collected via the  App and other potential points of interaction or collection where Company determines the specifics of processing PII. 

The Categories Of PII Collected

Company collects a range of PII from various sources. Here, Company outlines both the kinds of PII collected as well as how such PII is collected.

PII Provided Directly To Company 

When User interacts with Company, whether through the use of App, placing an order, contacting Company via phone, email, or other means, submitting content, by creating an account or signing up for a newsletter, among other interactions; various kinds of information is collected from or provided by User. Such information may include name, email address, photographs, videos, phone number, mailing address, payment information, and IP address, among other information. User warrants that they are authorized to provide any PII supplied to Company. 

PII Provided To Company Through Service Providers

Company’s affiliates and service providers may collect information from you on Our behalf. For example, User may receive prompts or emails requesting PII, such as via a survey, for the submission of a review, or to participate in a contest or sweepstakes. Said PII may include but is not limited to User’s name and email address. Any PII that you share with service providers will be subject to their respective policies and will not be subject to the practices outlined in this Privacy Policy. 

PII You Post

Certain information you post is viewable by the general public. Therefore, care should be taken concerning what appears in your public profiles, posts, submitted content, comments, and other information that will be publicly visible.

PII We May Get From Others

We may get PII from service providers and third parties to conduct Our business more effectively or market Company products and services. For example, Company may use user validation or data enrichment services to ensure that Company has accurate payment information or to attain a better ad targeting profile of a User to send them digital or direct marketing messages. We may also get PII about you from other Users. If You provide another person's PII to us, You warrant that You have the legal right to do so.

PII We May Get On Our Own

Company may collect User PII from publicly available sources and the public domain.

Information Automatically Collected, Cookies, And Related Technology

When User visits and uses Company App, Company may automatically collect various kinds of PII. The uses of this information, whether it be logs, device information, or via the placement of cookies, tags, scripts, beacons, or software development kits (SDKs), range from being able to effectively run Company App and avoiding abuse to being able to more effectively market Company products and services to both potential Users as well as past Users. PII automatically collected by Company may include account information, IP address, MAC address, browser, device, location, usage data, and operating system type, among other information. 

Cookies

Cookies are snippets of data stored on your computer or mobile device when accessing a website or app. The uses of cookies range from those that help identify users, ensure preferences and account login information are maintained, or identify users as they browse the web for targeted advertising.

Company also engages various technology and advertising partners who may also collect PII from Users via their own cookies present on Company App. These cookies are subject to the privacy policies of these respective companies. 

Categories Of Cookies Utilized By Company
Essential Cookies

Essential cookies help Company operate its App, are essential, and are therefore always in use. These cookies might assist in identifying User choices when it comes to accounts and cookie choices and prevent abuse of Company App. 

Performance, Functional, And Analytical Cookies

Performance, functional, and analytical cookies help to improve the functionality and performance of Company App and may include cookies relating to basic analytics, cache, and speed, among other uses. Blocking cookies of this type may affect the performance and experience of the App. 

Advertising And Social Media Cookies And Pixels

Advertising cookies collect User information that makes tailored and targeted advertising possible in addition to the ability to measure advertising performance. Social media cookies allow User to connect to social media platforms and share content from App. Blocking these cookies may diminish the relevance of the advertising you are served and limit your ability to share content and make use of linking to varying social media platforms. Advertising and social media cookies are generally provided by other companies and are therefore subject to said companies’ respective privacy and data protection policies. 

Blocking Cookies

User can make use of cookie-blocking functionality offered by many browsers and tools to limit the kinds of cookies utilized by Company. 

The Cookies We Utilize

Below is a chart of the cookies Company utilizes. Note that this may not be an exhaustive list but represents the kinds of cookies used. 

Essential Cookies (Strictly Necessary) 

Essential Cookies

Performance And Analytical Cookies 

Google Analytics                        | Privacy policy

Sample                                        | Privacy Policy

Sample                                        | Privacy Policy

Advertising And Social Media Cookies And Pixels

Facebook                                      | Privacy policy

LinkedIn                                        | Privacy policy

Sample                                          | Privacy Policy

Sample                                          | Privacy Policy

How Collected PII Is Used

PII provided to Company is used for a variety of purposes including the following: 

  • To respond to inquiries;
  • To manage User accounts;
  • To operate, improve, troubleshoot, and maintain Company App, and overall business such as through analytics; 
  • To run contests and sweepstakes;
  • To develop new products and services;
  • To protect Company;
  • For the processing of payments; 
  • To provide products and services; 
  • For the provision of marketing communications including via email, text, and phone; and
  • To employ a variety of advertising including targeted ads based on interests and other data markers as well as tracking and measurement.

How Collected PII Is Shared

Company does not disclose User's PII to third parties, except in the following scenarios:

  • To companies and vendors that provide services to Company or perform functions on Company’s behalf and have agreed to use your information only for the purposes Company delineates, to include payment processors, marketing and advertising services, among others;
  • To unrelated entity partners and companies to engage in joint marketing activities;
  • When Company believes disclosure is appropriate to comply with applicable law, legal process, and regulatory authorities;
  • When Company believes disclosure is appropriate to enforce Our Terms and other agreements or to protect Company’s rights, Company’s Users, Company’s property, Company’s employees, or others; 
  • If Company is involved in a business transfer such as a merger, acquisition, bankruptcy, partial or total sale of assets, or other corporate change; and
  • When User requests or consents to additional sharing or transfer.

Company may disclose or otherwise share information that is not PII (PII) due to anonymization or some other method that results in aggregate data not subject to de-anonymization. 

How To Manage Your PII And Communication Preferences

We want to ensure that Users are able to manage the kinds of PII we collect, process, and store to the extent possible and in accordance with relevant laws. 

PII Provided To Us

Where Company has collected User PII based on User providing it, User may have the right to delete said PII. Users can do this by contacting Company.

PII Collected Automatically

Browsers and devices offer a number of tools that allow Users to control whether certain kinds of PII are collected by Company, and Company encourages Users to make use of such options should they wish. 

Opting Out Of Marketing Communications 

Certain communications, such as marketing emails can be terminated by accessing the unsubscribe link at the bottom of the email. 

For Residents Of California  

To the extent Company is subject to California privacy laws, Users residing in California are afforded the rights listed below. 

Note: The terms used in this section have the meaning defined in the CCPA as amended by the CPRA.

The Right To Notice Of Categories Of PII Collected

Company may collect the following categories of PII as per the definitions outlined under California law:

  • Identifiers;
  • Commercial information;
  • Characteristics of protected classifications;
  • (Imprecise) Geolocation data;
  • Internet/electronic activity information;
  • Audio and visual information;
  • Categories of personal information as described in Section 1798.80(e) of the California Civil Code; and
  • Inferences drawn from the categories described above in order to create a profile about User to reflect User preferences, characteristics, behavior, and attitudes.

See the section titled The Categories Of PII Collected for additional details on the PII collected by Company. 

The Right To Notice Of How Collected PII Is Used

See the section titled How Collected PII Is Used to understand how Company uses PII. 

The Right To Notice Of How Collected PII Is Disclosed Or Shared

In the preceding 12 months, We may have disclosed for business or commercial purposes the categories of PII listed in the section titled The Right To Notice Of Categories Of PII Collected to the categories of recipients listed in the section titled How Collected PII Is Shared.

A Note On PII Shared With Online Advertising Platforms

The PII Company shares may include online identifiers such as IP addresses and device identifiers for online advertising. These identifiers being shared make it possible for Company to advertise to Users via platforms such as Facebook and Google. Said platforms may use this data to provide advertising services to others as well. Sharing this information with these service providers may be considered a “sale” or “sharing” of PII under California law, but Company does not receive money in return, and the information shared does not include User’s name.

Learn how You can opt-out of the sharing of this kind of information that may be deemed a sale or “sharing” (if applicable) by contacting Company via Our contact page.

Note: We do not knowingly “sell” or “share” (as those terms are defined by the CCPA as amended by the CPRA) the personal information of those under 16 years old.

The Rights Of Access, Deletion, And Equal Service

As a resident of California, Users also have the following rights (subject to exemptions under the law): 

  • Access: The right to request to know the categories of PII Company collects, the purpose for collecting and using such information, the categories and sources of said information, the categories of parties Company discloses, shares, or sells PII to (if applicable), and the specific PII Company has collected about you;
  • Correction: The right to request that we correct inaccurate PII;
  • Deletion: The right to request deletion of PII Company collects or maintains;
  • Opt-Out: The right to opt-out of any sale or certain sharing of PII; and
  • Non-Discrimination: The right to non-discriminatory treatment for exercising your rights under California law.
How To Exercise Your Rights Under California Law

To exercise your rights under California law, such as that of access, correction, deletion, opt-out, and non-discrimination, please contact Company. We will employ verification procedures in line with California law to ensure that You are authorized to exercise these rights. 

Authorized Agents 

You can use an authorized agent to make a request to exercise your rights by contacting Company via the contact information provided in this Privacy Policy. If an authorized agent is utilized to exercise certain rights, such as the right to deletion, access, or correction, Company may require that You verify directly with Company, unless You have provided Your authorized agent with a valid power of attorney consistent with relevant law. If You use an authorized agent to submit a request to opt-out of the sale or certain sharing of PII, We may require Your signature demonstrating that You have authorized the agent.

For Residents Of Nevada

Company does not sell User's PII as per the definition of "sale" under Nevada's Revised Statutes Chapter 603A.

Other States' Or Countries' Privacy Laws

To exercise your rights under other states' or countries' privacy laws, including as it relates to access, correction, deletion, opt-out, and non-discrimination, please contact Company via Our contact page.

For Residents Of The UK, EU And EEA

As per the respective versions of the UK and EU General Data Protection Regulation (GDPR), residents of the United Kingdom (UK),  the European Union (EU), and the European Economic Area (EEA), are afforded rights pertaining to the processing of their PII. 

Data Controller Vs. Data Processor

Company, in its general operations, is ordinarily deemed a data controller under the GDPR as opposed to a data processor. For this reason, data processing inquiries and requests relating to the rights afforded under the GDPR should be directed to Company. 

The Legal Bases For Processing Of PII

As per the GDPR, Company utilizes a variety of legal bases for the processing of User’s PII, which are listed below: 

Consent

Company may process, use, or disclose PII on the basis of User’s consent; at times, implicit consent where allowed, and at times explicit consent, where required. 

Contract

Company may process, use, or disclose User PII to meet obligations necessary under a contract with User, to take action based on User request, in anticipation of forming a contract with User, or as is otherwise necessary for Company’s contractual relationship with User. 

Legal Obligation

Company may process, use, or disclose PII when necessary to comply with a legal obligation.

Vital Interests

Company may process, use, or disclose PII where necessary to protect the vital interests of an individual. 

Legitimate Interests

Company may process PII on the grounds of legitimate interests of Company or third parties where such interests are not overridden by balancing the interests and fundamental rights of Users. 

The legitimate interests of Company may include:

  • Marketing activities;
  • Analyzing and improving Company;
  • Protecting the interests of Company, Users, and employees; 
  • Order fulfillment; and
  • Other activities which benefit Company. 
Rights Afforded Under The GDPR
The Right To Be Informed

For information about the kinds of PII collected, processed, shared, and stored, please refer to the sections titled The Categories Of PII Collected, How Collected PII Is Used, and How Collected PII Is Shared. Further, please review the section titled Cookies for information about which cookies are utilized as well as how to block such cookies. 

The Right Of Access 

User's may have the right to access and receive a copy of their PII. To exercise this right, please contact Company via the contact page. 

The Right Of Rectification

User's may have the right to rectify their PII. To exercise this right, please contact Company via the contact page. 

The Right To Erasure 

User's may have the right to the erasure of their PII. To exercise this right, please contact Company via the contact page. 

The Right To Restrict Processing

User's may have the right to restrict the processing of their PII. To exercise this right, please contact Company via the contact page. 

The Right To Data Portability

User's may have the right to portability of their PII. To exercise this right, please contact Company via the contact page. 

The Right To Object

User's may have the right to object to the processing of their PII. To exercise this right, please contact Company via the contact page. 

Rights Relating To Automated Decisionmaking Or Profiling

User's may have rights if Company conducts automated decision-making or profiling. Currently, Company does not conduct such activities. 

Other Rights

User’s may have other rights, including the right to withdraw consent and the right to lodge a complaint with the relevant regulatory authority. 

International Transfers of Data 

Company is based in the United States, and the recipients of PII Company collects and shares, as is outlined under the "How Collected PII Is Shared" above, may also be located in the United States or some other jurisdiction. PII may be transferred, stored, and processed on servers outside of User’s jurisdiction of residence, where privacy protections may be lesser than those of User’s. Continued use of Company App or other interaction with Company, may constitute consent to such transfer. 

Data Retention Policy 

User’s PII is retained for as long as it can be used for the purpose it was collected, or for the lifetime of the account being active, whichever is longer, and for any additional lawful purposes related to the improvement of the business and to protect the rights and interests of Company. 

Securing PII

Company implements reasonable safeguards in line with its sector to protect User's PII. 

Third-Party Websites

Third-party websites and services, whether accessed via a link on Company App, such as to make a payment via an embedded or outside processor or to login to your User account on Company App through a third-party service (such as a social media platform), are subject to the respective third party’s policies and are not governed by this Privacy Policy.  

Children’s Privacy 

Company’s services are not aimed at those under the age of 18, and Company does not knowingly collect PII from children under the age of 18. Should You be the legal guardian of someone younger than 18 that has provided Company with their PII, please contact us, and Company will take the necessary steps to delete such information. 

Severability

Any part, provision, or representation of this Privacy Policy that is prohibited or which is held to be void or unenforceable shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions hereof.

Changes To This Privacy Policy

Privacy and data protection laws are dynamic and subject to changes, which will likely result in Our Privacy Policy being updated. Company encourages Users to regularly review this Privacy Policy to stay updated on Our practices as it relates to the processing of PII, including the collection, use, and sharing of PII. Continued use of Company App or other interaction with Company after updates are made to the Privacy Policy, will be governed by the updated Privacy Policy. 

Contact Information

Questions concerning this Privacy Policy should be directed to Company via support@kusa.life  

Privacy Policy Last Updated

Sept, 2023