IN THE KNOW PRIVACY NOTICE FOR EU & EEA RESIDENTS
Last Modified: January 11, 2019
This Privacy Notice for EU & EEA Residents (the “Notice”) applies to the Services, we, IN THE KNOW (or “ITK”) provide to our users and individuals in the E.U. and other countries in the European Economic Area (“EEA”, including Iceland, Lichtenstein and Norway).
Your rights as a EU/EEA resident means our collection, handling, and processing of your information is subject to the General Data Protection Regulation (or, “GDPR”). Our use of your information is fully intended to fully comply with the GDPR.
This Notice governs our privacy practices in handling your personal data which we process as a data controller.
This Notice is a part of our Terms of Service, and applies to all information that you provide to ITK. This Notice does not apply to separate sites, applications, or services of third-parties, or their own practices, who may be linked to, or linked from, the Services.
This Notice may be updated from time to time if there is a change in applicable law, or if there is a change to the way we process your personal data.
We will notify you of any material changes by posting the new Notice wherever it may appear on our App and/or Site, and give you notice that the Notice has been updated. At that time, we will change the date of this Notice and provide other required information.
Our contact information is included at the end of this Notice.
Terms which are not defined in this Notice have the same meanings in our Terms of Service, or the GDPR. If there is any conflict between the provisions of this Notice and those of our Terms of Service, the terms of this Notice will control.
INFORMATION, COLLECTION, AND ITS USE
For the purposes of this Notice, “personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or one or more factors specific to the person, such as her/his physical, physiological, genetic, mental, economic, cultural or social identity.
We collect personal data to provide and improve the Services, our features and Content, to administer your Account, and to enable you to navigate our App and Site. Please see the following sections for more details on what is being collected, and for what purposes.
CATEGORIES OF DATA OBTAINED FROM YOU
We collect personal data, such as your phone number, and/or actual name, sex/gender, date of birth, and billing or shipping address directly from you whenever you:
Register a new user Account.
Create, share, or request feedback from us, or message and communicate with other users as a part of the Services.
Participate in any paid Services, or when you choose to make a donation to us or any third-parties on your behalf.
Join any user group, or engage with other users as part of user group.
Submit any User Content to our App, Site or through the Services.
Respond to our promotional message or notices, newsletters, marketing materials, or user surveys.
Provide us with Feedback on the Services.
Invite your own contacts to join the Site or take part in the Services, including when you invite your contacts who are users of the same SNS service.
Whenever you provide us with your personal data directly, we will use only the information you provide, and only for the specific reasons we requested the information.
INFORMATION OBTAINED AUTOMATICALLY THROUGH TECHNOLOGY
When you access the Site and the Services, even if you are not a user, some personal data about you will be collected automatically through technology such as your browser processes, log data, cookie information. This information can include:
your computer's or device’s Internet Protocol ("IP") address(es);
your approximate geographic location (based on your IP address), and more specific location information once you provide consent from your browser or device;
browser type, or unique device identifiers;
the websites or pages you were visiting before you visit to our Site or open the App;
the pages or parts of our Site or App that you visit and the time spent on;
the time spent on any pages or parties of our Site or App;
access times and dates, duration, and frequency of your visits to our Site or App;
the information you search for on our Site or App;
your interactions with Content and User Content accessible through the Services; and
your personal data from SNS providers when you register or log-in through your SNS credentials.
We use this type of information which is automatically collected through technology to monitor and analyze use of the Services and its technical administration, to increase functionality and user-friendliness, and to better tailor it to our visitors' needs.
For example, some of this information is collected so that when you visit our Site, it will recognize you and serve information appropriate to your interests. We also use this information to verify that visitors meet the criteria required to process their requests.
COOKIES & DEVICE DATA
Depending on your privacy settings, we collect information about your computer and other devices you use to take part in the Services. This device data may be associated with users to provide consistent Services, and to provide a secure environment for users.
Based on our agreement with you, our legitimate needs, and your own consent, we aggregate, analyze and evaluate this information for any of the same purposes as other personal data.
INFORMATION NOT OBTAINED DIRECTLY FROM YOU
In certain situations, we may collect personal data from you which you did not directly share with us.
We collect your personal data from third-parties when you visit or use third-party websites or services that are associated with, or linked to our Site and Services. This includes your activity on any SNS site or platform and other information those providers may provide to us when you choose to associate your SNS account with our Services. For example, we may collect your personal information when you link a Facebook® or Google® account for log-in purposes.
From time to time, we may participate in jointly-offered services, promotions, or other activities with third-parties who may have already received your personal data. Depending on your permissions you grant those third-parties, we may also receive information about you in order to participate in those activities.
PURPOSES FOR PROCESSING PERSONAL DATA
ITK will process your personal data in order to:
Manage, administer, promote, analyze, evaluate, and improve the Services.
Provide you access to certain parts of the App, Site and Services, and to your Account.
Provide notice about changes to the App, Site or Services, and to respond to and process your questions, requests, and complaints.
Customize your experience with the App, Site and Services, such as to serve information appropriate to your interests.
Contact you with newsletters, email updates, marketing or promotional materials and other information that may be of interest to you.
To prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
To protect the property, rights, or safety of the public, us, our users, or any third-party.
Cooperate with government and law enforcement officials and private parties to enforce and comply with the law.
We may access, read, preserve, or disclose any information about you to government or law enforcement officials or private third-parties as we, in our sole reasonable discretion, are required.
Enforce our Terms of Service, including our Community Guidelines Policy and Copyright & IP Policy.
Please keep in mind that we enforce a strict “zero-tolerance” policy for violations and credible complaints under our Community Guidelines Policy, and we reserve the right, in our sole discretion, to share your personal data with affected users under this section.
SHARING YOUR PERSONAL DATA
ITK may share your personal data with the following categories of recipients:
Registered Users; for messaging and communications with other users.
You can choose what personal data you share with other users. Providing this information is voluntary and you should only share as much as you would like to share with others.
Affiliates, business partners, advertisers, and other third-parties; for industry analysis, demographic profiling, and similar commercial purposes.
Unless otherwise specified, any information shared in these contexts will be generic, aggregated, and anonymized. We will seek your prior consent to whom and for what purposes we share your personal data.
Third-party service providers and contractors; to provide certain Services on our behalf, such as payment processing services, database maintenance services, and to assist us in analyzing how our Services are being used.
Law enforcement; to respond to, or satisfy, applicable law, regulations, claims, court orders, and legal process, follow and enforce the Terms, or to investigate any suspected violations, to protect the property, rights, or safety of the public, us, our users, or any third-party, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
Parties to business transfers; in connection with the sale or transfer of some or all of our assets, including personal data, in connection with merger, acquisition, reorganization, sale of assets, or bankruptcy.
Other parties; when necessary to follow and enforce the Terms, or to investigate any suspected violations, to protect the property, rights, or safety of the public, us, our users, or any third-party, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
Other parties, including SNS providers; when we contact those parties on your behalf when you choose to message, share User Content, or invite them to use the Services.
Other parties, if we disclosed the purpose of the sharing with you at the time the information is collected and we have your prior consent to the sharing.
LAWFUL BASIS FOR PROCESSING PERSONAL DATA
ITK relies on our agreement with you, our legitimate interests, and your prior consent to process your personal data for the following purposes:
Managing user accounts
Operating, modifying, and improving the Services
Identifying usage trends
Customizing content and user experience
Network and information systems security
Responding to user questions and requests for information
To determine the effectiveness of promotional and sponsorship activity
Serve promotional and sponsorship messages based on user behavior and preferences
Comply with laws and regulations and to enforce the Terms and other legal rights
CONSENT TO PROCESSING
ITK relies upon your consent to process personal data in order to send messages from our business partners, to collect location information, to send newsletters and marketing or promotional materials to you, and to contact third-parties on your behalf.
If you have consented to the processing of your personal data for these reasons, you may withdraw your consent at any time. However, by doing so, you may not be able to access or use Services which rely on your consent. All processing of your personal data will cease once you withdraw your consent, but this will not affect any personal data which has already been processed.
Your personal data is retained no longer than is reasonably necessary to perform the processing described in this Notice and in case of any legal claims or complaints, or as otherwise required by applicable law.
Subject to other applicable laws, including those of the United States where we operate, you have the following rights with respect to your own personal data:
To request a copy of your personal data which we hold.
To request that we provide you access to and/or correct any personal data that is inaccurate or outdated.
To request we erase your own personal data where it is no longer reasonably necessary for use to retain it.
To withdraw your consent to any further processing at any time.
To request we provide you with your personal data, and when possible, to transfer that data to another data controller.
To request a restriction on any further processing when applicable.
To object to processing if the processing is based on legitimate interest or direct marketing.
To lodge a complaint with any supervisory authority.
You may exercise your rights by contacting us at firstname.lastname@example.org or by contacting us through the contact functionality we provide in the App, and providing a written statement for your request. We reserve the right to verify your identify and confirm your rights to data in question before taking any requested action.
WITHDRAWING CONSENT TO PROCESSING
In certain cases, the Services we provide may include a means to withdraw consent for any further processing of your personal data for those purposes. For example, you may withdraw your consent to receive newsletters, email updates, marketing or promotional materials and other information that may be of interest to you which is not directly related to your Account.
If choose to withdraw your consent, you may unsubscribe from further messages by operating any “Unsubscribe” function we provide, updating your Account's "Notifications" settings, or writing to us at email@example.com.
If you choose to opt-out of any processing of your information, however, you may not be able to use all portions of the Site or certain functionalities of our Services.
CHANGING AND DELETING YOUR DATA OR ACCOUNT
All users may review, update, correct or delete their personal data upon request.
If you would like us to terminate your Account, to stop using your information, or otherwise makes changes to, or delete, your information in our systems, please contact us at firstname.lastname@example.org, or use the termination functionality we provide in the App, with your request. We will use commercially reasonable efforts to honor your request as soon as possible.
HOW WE SECURE YOUR INFORMATION
We are very concerned with safeguarding your information. However, we are not in the business of providing information security, and cannot guarantee perfect security over your information. We do however employ commercially reasonable data collection, storage, processing practices, and security measures, such as using SSL encryption on some but not all systems to protect against unauthorized access, use, loss, alteration or destruction of your personal data.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or conspicuous posting on the Site as soon as commercially practicable, and without unreasonable delay, so long as those disclosures are consistent with (a) the legitimate needs of law enforcement; or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Do not provide us with your information if you are concerned with its disclosure or its security, or any of our policies described in this Notice.
NOTICE REGARDING INTERNATIONAL TRANSFER OF INFORMATION
Because ITK operates from the United States, your personal data will be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws are not deemed adequate under the GDPR.
However, we have taken all reasonable measure to ensure our use and processing of your information, whether under this Notice or any other policy concerning the protection of personal data fully complies with the GDPR.
If you are located in the EU or other countries in the EEA, any data transfers will be made subject to the GDPR “Standard Contractual Clauses” or your prior consent.
By submitting any personal data to us and opting-in to our personal data practices, you consent to the terms of this Notice and the data transfer.
LINKS TO OTHER SITES
Our Services may provide links to other websites. If you click on another third-party link, you will be directed to that third-party's website. The fact that we link to a third-party website is not an endorsement, authorization or representation of our affiliation with that third-party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect personal data, or solicit personal data from you. Other sites follow different rules regarding the use or disclosure of the personal data you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
OUR POLICY TOWARDS CHILDREN
Protecting the privacy of children is especially important to us, and we strictly comply with the GDPR regarding age limits. Our Services are not directed to, or meant for persons under the age of 18. We do not knowingly collect or solicit personally identifiable information from persons under 18 years of age, or allow them register Accounts.
If we become aware that a child under 16 has provided us with her/his personal data, we will delete such information from our systems.
If you are a parent or guardian and you become aware that your child under the age of 16 has provided us with personal data, you should contact us immediately at or through the contact functionality in the App to request we delete your child’s information.
If you have any questions regarding this Notice, or our practice and procedures about your information, please contact us at email@example.com, or through the contact functionality in the App. You may also contact us at our current mailing address and phone number at:
IN THE KNOW;
18 Jiuxianqiao East Road Building 1 A1229
Chaoyang District, Beijing 100015