1. CHILDREN’S PRIVACY
2. INFORMATION COLLECTION PRACTICES
a) Traffic Data.
Like most website and mobile application operators, Klinche automatically gathers information of the sort that browsers automatically make available, including: (i) IP addresses; (ii) domain servers; (iii) types of computers accessing the App; and (iv) types of Web browsers accessing the App (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify You.
“Cookies” are text files that are placed on Your computer or other electronic device (collectively for ease of reference, a “computer”) by websites and mobile applications that You visit, download, or use or certain emails that You open. A Cookie acts as a string of information that a website or mobile application stores on a user’s computer or mobile device, and that the user’s browser provides to the App each time the user submits a query. The purpose of a Cookie is to identify the user as a unique user of the App.
Klinche uses two types of Cookies – “first-party cookies” and “third-party cookies.”
First Party Cookies
Klinche may use first-party cookies on the Website and/or App, for example the Google Analytics Cookie, for the following purposes:
- to gather visitor and access information relevant to customizing your experience on the App to your interests; and
- to store Your password so You do not have to re-enter it each time You visit the App.
In addition to these purposes, Google, Inc. (“Google”), New Relic, and other third parties use third-party cookies to serve online interest-based advertisements on the Website and App. As an important example, Google uses of a cookie known as “DoubleClick” to enable both Google and Google’s third party marketing partners to serve advertisements to You based on information gathered during Your use of the Website or App or Your visit to other websites or download and/or use of other mobile applications and services (collectively, “Third Party Services”).
Klinche may advertise on Third Party Services to You after You access the Website or App. Klinche and its third party marketing partners, including without limitation Google, may use first party cookies (such as the Google Analytics cookie) and third party cookies (such as the DoubleClick cookie) to inform, optimize, and serve advertisements to You based on Your use of the Website or App or Your use of Third Party Services, specifically for the following reasons:
- to store information so that You will not have to re-enter it during your visit, the next time You visit the App, or after updating to a new version of one of the mobile applications;
- to provide custom, personalized content and information and overall experience;
- to measure advertising campaigns and to monitor their effectiveness;
- to monitor aggregate metrics and analytics, such as total number of visitors, pages viewed, etc.; and
- to track your entries, submissions, and the like.
c) Ad Serving.
Klinche uses third parties for advertising through the Website and/or App and to generate non-identifying analytics regarding Klinche users.
As explained more fully in the preceding section, these third parties may place cookies on Your computer or mobile device. These third parties may also use web beacons, gather IP addresses and log data to collect traffic and activity data in order to deliver relevant metrics, content, and advertising.
d) Personal Information.
In order for You to use certain features of the Website, App or Services—including, without limitation, in order for You to create Your Klinche Account and enter into a Transaction with other users— You will be asked to provide Klinche certain information that personally identifies You (“Personal Information”). Personal Information includes, without limitation: (1) “Identification Data” (such as Your name, Social Security Number, phone number, fax number, birthday, mailing address and e-mail address); (2) “Demographic Data” (such as Your gender, age and zip code), and (3) “Financial Data” (such as Your Payment Account details and information needed to ascertain Your creditworthiness, such as information regarding other credit card and bank accounts). In each case, You will be asked to provide Personal Information; the Website and App will not gather it surreptitiously. Klinche may supplement the Personal Information You provide with additional Personal Information gathered from public sources or from third-parties (e.g., consumer reporting agencies) who may lawfully provide such information to Klinche. You are under no obligation to provide Personal Information, with the caveat that Your refusal to do so may prevent You from using certain features of the Website, App or Services.
e) Information You Make Public.
The Website and App may contain features that permit You to upload, post, transmit, display, perform or distribute content, information or other, including Your Personal Information. Any information that You choose to disclose by means of such features, including Personal Information, becomes public information over which Klinche is unable to exercise control. You should exercise caution when deciding to disclose Your Personal Information by means of such features, and You agree to assume all responsibility for doing so.
f) Information That Becomes Part of Your Public Klinche Profile.
The Website and App may contain features that allow Your public Klinche profile to be populated with certain information about You and Your Transaction history, including without limitation, Your activity using the Website, App, and Services, the average amount of Your past Transactions, ratings by other users with whom You have entered into Transactions, and/or certain Personal Information, provided, however, that Your Social Security Number and Financial Data will not be auto-populated into Your public Klinche profile.
g) Computer and Mobile Device Information
Through the Website and App, Klinche may collect: (i) information about the type, make, and model of Your computer or mobile device, the operating system You use on the computer or device, browser type and specifications, the network service or wireless communication provider who connects Your computer or device to a telecommunications system or systems, Your internet protocol address, and other unique identifiers assigned by third parties to Your computer or device, and (ii) information about Your activity on the computer or device, including Your use of other mobile applications on the same device, click data and click patterns in relation to promotional advertising on your device, cookies (defined above), tracking tags, pixel tags, and visitor history.
The Website and App may access and collect information regarding the physical geographic location of your computer or device.
3. INFORMATION USE AND DISCLOSURE PRACTICES
a) Traffic Data and Information Gathered Using Cookies.
Klinche analyzes Traffic Data and information gathered using Cookies to help Klinche better understand who is using the Website, App and Services, and how they are using it. By identifying patterns and trends in usage, Klinche is able to better design the Website, App, and Services to improve Your experience, and to serve You more relevant and interesting content and advertisements. From time to time, Klinche may release Traffic Data and information gathered using Cookies in the aggregate, such as by publishing a report on trends in the usage of the Website, App or Services. Klinche does not attempt to link information gathered using Cookies to Personal Information.
b) Personal Information
(i) Transmission/Disclosure to Third-Party Participants in a Transaction. You understand and agree that Klinche is a payment service provider that facilitates Transactions between You and other users of the Website, App or Services. By submitting Personal Information via the App, You provide permission to Klinche to refer and/or transmit such Personal Information to other parties to the Transaction; provided, however, that Your Social Security Number and sensitive Financial Data will not be transmitted to the other parties to the Transaction.
(ii) Generally. Klinche may use Your Identification Data to send You information about Klinche and Klinche’s products and services, and to contact You when necessary in connection with the Website, App, or Services, including in connection with any particular Transaction. Klinche uses Your Demographic Data to customize and tailor Your experience with the Website and App. As with Traffic Data and information gathered using Cookies, from time to time Klinche may release Demographic Data in the aggregate, such as by publishing a report on trends in the usage of the App.
(iii) Disclosure Practices. Except with regarding to any Transaction as identified in subsection (i) above, and under the following circumstances, Klinche will keep Your Personal Information private, and will not share it with third parties.
- Disclosure in Connection with Services. Klinche discloses Personal Information to those who help it provide services, including without limitation those who perform technical, administrative, and data processing tasks such as hosting, billing, fulfillment, and data storage and security.
- By Law or to Protect Rights. Klinche discloses Personal Information when required to do so by law, or in response to a subpoena or court order, or when Klinche believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of Klinche, third parties or the public at large.
4. CONSENT TO RECEIVE ELECTRONIC COMMUNICATIONS FROM KLINCHE
Without limitation, by registering for the App and/or by providing your name, email, postal or residential address, and/or phone number through the App, You hereby expressly consent to receive electronic and other communications from Klinche, over the short term and periodically, including email and short-message service (“SMS” or “text message”) communications, regarding the Website or App, new product offers, promotions, and other matters. You may opt-out of receiving electronic communications at any time by (a) following the unsubscribe instructions contained in each communication; or (b) sending an email email@example.com.
5. SECURITY OF PERSONAL INFORMATION
While no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure, Klinche understands your concerns with the safety of Your Personal Information. Klinche has implemented and maintains reasonable security procedures and practices to protect against the unauthorized access, use, modification, destruction or disclosure of Your Personal Information.
6. LOST OR STOLEN INFORMATION
You must promptly notify us if Your user name or password is lost, stolen or used without permission. In such an event, we will remove that user name or password from Your account and updated our records accordingly.
7. USER ABILITY TO ACCESS, UPDATE, AND CORRECT PERSONAL INFORMATION
Klinche wants Your Personal Information to be complete and accurate. As stated in the Terms of Service, by using the App, You represent and warrant that all information You provide in connection with Your use of the App will be current, complete, and accurate, and that You will update that information as necessary to maintain its completeness and accuracy.
8. THIRD-PARTY SERVICES
9. PROMOTIONAL ACTIVITIES
Effective Date: January 21, 2015