Privacy Policy

Last updated: August 2018

Welcome to Kontomo (the “Platform”). The Platform is provided and controlled by Kontomo, Inc. (“Kontomo”, “we” or “us”). We are committed to protecting and respecting your privacy.

By accessing or using our website, services, applications, products and content (that include but are not limited to the Platform) (collectively, the “Services”), you acknowledge that you have read this policy and that you understand your rights in relation to your information and how we will collect, use and process it. If you do not agree with this policy in general or any part of it, you should not use our Services.

If you have any questions about how we use your information please contact privacy@kontomo.com.

 

SUMMARY

What information do we collect about you?

We collect information when you create an account, and use the Platform, such as your contact details, content you create, your location, and credit card details. We also collect information you share with us from third party social network providers, and technical and behavioral information about your use of the Platform. We also collect information contained in the messages you send through our Platform.

 

How will we use the information about you?

We use your information to fulfil and enforce our service contract with you, to improve and administer the Platform and allow you to use its functionalities. We also use your information to, among other things, show you suggestions, promote the Platform

 

Who do we share your information with?

We share your data with our third party service providers we rely on to help you provide you with the Platform. These providers include cloud storage providers, and other IT service providers. We also share your information with our business partners, advertisers, analytics and search engine providers. We may also share your information with law enforcement agencies, public authorities or government bodies as required by law.

 

How long do we keep hold of your information?

We retain your information for as long as it is necessary to fulfil (1) our contractual obligations and rights in relation to the information involved, (2) our legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time, taking into account statute of limitations under applicable law(s); (3) our legitimate business purposes;(4) and to conduct a defense in relation to disputes or potential disputes.

 

How will we notify you of any changes?

We will generally notify all users of any material changes to this policy, through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

  1. The types of information we collect

We may collect and use the following information about you:

  • Information you give us.You give us information about you when you register for and/or use the Platform, including your name, age, gender, address, email address, social media login details, telephone number and financial and credit card information and your photograph as well as your language selection. In addition, this category will include your customer profile, the comments you make on our Platform, account and billing details, including but not limited to, your Apple, Google or Windows account, PayPal or other third-party payment channel account where required for the purpose of paying or withdrawing cash. It also includes user-generated content, photographs and video content that you choose to broadcast on our Platform. You are also able to register using your user credentials to certain social media sites, such as Twitter, Facebook, Instagram or Google.
  • Information you choose to share from your social networks. If you choose to link your social network or public forum account (e.g. Facebook, Twitter, Instagram, Google or WeChat) to the Platform, you will provide us or allow your social network to provide us with information from your social network or public forum accounts, including your contact list. This data will include information relating to your use of the Platform on such public forums and/or social networks. For further information as to how and for what purpose the social network provider processes your data, please see the relevant privacy policies of these social network providers.
  • Technical Information we collect about you. We automatically collect certain information from you when you use the Platform, including your IP address, location-related data (as described below) or other unique device identifiers, your browsing history (including content you have viewed in the Platform), Cookies (as defined below), your mobile carrier, time zone setting, mobile or device information including the model of your device, your screen resolution, operating system and platform and information regarding your use of the Platform.
  • Behavioural information we collect about you: We also collect information regarding your use of the Services, e.g. your comments on our Platform or any other user-generated content and video content that you generate through and broadcast on our Platform. In addition, we link your contact or subscriber information with your activity on our Platform across all your devices using your email or social media log-in details. We collect engagement scores (“likes”, comments, repeated views) and relate users based on your behavior. Finally, we collect opt-ins and communication preferences.
  • Location data. When you use the Platform on a mobile device, we will collect information about your location, including location information based on your SIM card and/or IP address. If you allow us access to location data on your mobile device we will also collect Global Positioning System (GPS) data and mobile device location information. We will use this information to provide you with location-based services such as providing you with the appropriate digital brochures.
  • Information from third parties. We will receive information about you from third parties if you use any of the other websites we operate or other services we provide. We will also receive information from third parties (such as advertising networks and analytics providers) and from other sources, including business directories and other commercially or publicly available sources.
  • Your phone and Facebook contacts.You can choose whether to find other users of the Platform either through (i) your phone contacts or (ii) Facebook contacts. If you chose to find other users through your phone contacts, we will access and collect your phone contacts, including the names, phone numbers, addresses and any other information that you have stored on your phone about your contacts in order to determine if they are using the Platform by matching them with existing users of the Platform. If you want to find other users through your Facebook contacts, we will collect your public Facebook information as well as names and profiles of your Facebook contacts.
  • We collect and process (which includes scanning and analyzing) information you provide, including any personal information, in the context of composing, sending, or receiving messages (that means the content as well as information about when the message has been sent, received and/or read and the participants of the communication) through our Service’s messaging functionality. Please be aware that messages sent to other users of our Service will be accessible by those other users and that we are not responsible for the manner in which those users use or disclose messages.
  • When you upload a video to the Platform (“User Content”), you automatically upload certain metadata that is connected to the User Content. In essence, metadata describes other data and provides information about your User Content that will not always be evident to the viewer. In connection with your video the metadata can describe how, when and by whom the piece of User Content was collected and how that content is formatted. It further includes information such as your account name that enables other users to trace back the video to your user account. Metadata will further consist of additional data that you chose to provide with the video, e.g. any hashtags used to mark keywords to the video or comments.

 

  1. Cookies

We use cookies and other similar technologies (e.g. web beacons, flash cookies, etc.) (“Cookies”) to enhance your experience using the Platform, improve our services, and provide you with targeted advertising. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

We use the following Cookies:

  • Strictly necessary Cookies. These are Cookies that are required for the operation of the Platform. They include, for example, Cookies that enable you to log into secure areas of the Platform.
  • Functionality Cookies. These Cookies are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). These Cookies support the log-in function in the Platform for a 90 day period
  • Social media CookiesThese Cookies allow users to create an account on the Platform by using their existing log-in for other services (for example, for WeChat, Baidu, Facebook, and Google).
  • Targeting Cookies. These Cookies record your visit to the Platform, the pages you have visited and the links you have followed, including your interactions with other websites or applications. We will use this information to make the Platform more relevant to your interests.
  • Analytics Cookies. Analytics Cookies are statistical audience measuring systems that we use for our Services to help us measure which web pages you click on and how you use the Platform (see below for more details).

If for any reason you do not wish to take advantage of Cookies, you can disable Cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of the Platform and we will no longer be able to offer to you personalized content. Unless you opt out of Cookies, we will assume you consent to the use of Cookies.

“Do-not-track” signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. The Platform does not respond to “do-not-track” signals in your web browser.

Analytics information

On our Platform, we use third-party analytics tools to help us measure traffic and usage trends for the Services. Traffic refers to the different data flows surrounding activities of the users on the Services. These tools, for example, collect information sent by your device or our Services, including the pages you visit, add-ons, and other information that assists us in improving the Service. The information will be used to report and evaluate your activities and patterns as a user of the Platform to provide services in accordance with these activities.

Our third party analytics tool is Google Analytics provided by Google, Inc (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). Google Analytics uses Cookies, small text files containing a string of alphanumeric characters and which are stored on your computer. Google will use this information including your truncated IP address to assemble statistics on the use of our Service or to provide other related services as described above. For further information on how Google Analytics collects and processes information about you and information on how to opt out from Google’s collection of information from you, please click here. You can also find further information in the Google Analytics Terms of Service & Privacy.

We further use “Facebook Pixel” of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). This tool is used for advertising purposes in order to reveal if you have seen our advertisement on Facebook. If you do not want Facebook to collect the described information about you, you can opt-out of Facebook’s use of cookies and Facebook Pixels here.

  1. How we use your information

We will use the information we collect about you in the following ways:

  • to administer the Platform (i.e. to provide our Services to you) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (i.e. to guarantee the Platform’s stability and security) and to solicit your feedback;
  • to allow you to participate in interactive features of the Platform, when you choose to do so;
  • to personalize the content you receive and provide you with tailored content that will be of interest to you;
  • to improve and develop our Platform and conduct product development;
  • to measure and understand the effectiveness of the advertising we serve to you and others;
  • to provide you with services based on the country settings you have chosen, such as advertising and other content that is related to the country settings;
  • to make suggestions and recommendations to you and other users of the Platform about goods or services that will interest you or them;
  • to support the socializing function of the Services;
  • to provide you with your profile information to send to anyone you choose and to enable you to participate on the Platform and interact with other users;
  • to make your information available to other users in accordance with the privacy settings you chose for the respective information;
  • to enable our messenger service to function (although this information is only processed if you choose to use this function) and you can choose to delete any information in this regard on your discretion via the clear cache function within the Platform’s settings; and
  • to help us detect abuse, fraud, and illegal activity on the Platform;
  • to ensure that you are old enough to use our Services (as required by law).
  • to notify you about changes to our Services;
  • to communicate with you.
  • to provide you with user support;
  • to enforce our terms, conditions and policies;

 

  1. How we share your information

We will share your information with the following selected third parties:

  • our business partners so that we can make you special offers via the Platform;
  • advertisers and advertising networks that require the data to select and serve adverts to you and others.;
  • cloud storage providers to store the information you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
  • Analytics and search engine providers that assist us in the optimization and improvement of the Platform; and
  • IT service providers;
  • Our data center and the servers of our host providers.

We will also share your information with any member or affiliate of our group, in China, for the purposes set out above, to assist in the improvement and optimization of the Platform, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes (How we use your information).

We will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if such use is reasonably necessary to:

  • comply with legal obligation, process or request;
  • enforce our Terms of Serviceand other agreements, policies, and standards, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

We will also disclose your information to third parties:

  • in the event that we sell or buy any business or assets, in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
  • if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information will be among the transferred assets.
  1. Your Rights

If you have registered for an account, you may access and update certain personal information that you have provided to us by logging into your online account and using the features and functionalities available there.

You can manage third party advertising preferences for some of the third parties we work with to serve advertising across the Internet by clicking here and by utilizing the choices available at http://www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices.

You can opt out of marketing or advertising emails by utilizing the “unsubscribe” link or mechanism noted in marketing or advertising emails you receive from us.

You can switch off location information functionality on your mobile device if you do not wish to share your GPS or mobile device location information with us.

California Residents

California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To request a notice, please submit your request to privacy@kontomo.com.

  1. The security of your information

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

  1. How long we keep your information

We use the following criteria to determine the period for which we will keep your information:

  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law(s) and regulations to retain data for a certain period of time;
  • statute of limitations under applicable law(s);
  • our legitimate business purposes; and
  • disputes or potential disputes.

After you have terminated your use of our Services, we can store your information in an aggregated and anonymized format. Notwithstanding the foregoing, we can also retain any personal information as reasonably necessary to comply with our legal obligations, allow us to resolve and litigate disputes, and to enforce our agreements.

  1. Information relating to children

The Platform is not directed at children under the age of 13. If we become aware that personal information has been collected from a person under the age of 13 we will delete this information and terminate the person’s account. If you believe that we have collected information from a child under the age of 13, please contact us at privacy@kontomo.com.

 

  1. Changes

We will generally notify all users of any material changes to this policy, through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Services after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Services.

  1. Contact

Questions, comments and requests regarding this policy should be addressed to:

  • Kontomo, Inc
    Address: 125 Bramblebrook Rd., Ardsley, NY 10502, USA
    Email Address: privacy@kontomo.com