January 11, 2019
You should consult this policy regularly for any changes, and it is your responsibility to become aware of and understand them.
For the purposes of this policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
NOTICE TO E.U. & E.E.A. RESIDENTS
Our use of your information is subject to the IN THE KNOW “Privacy Notice for EU & EEA Residents”. Please refer to that document for additional information on how we collect and use your personal data.
INFORMATION, COLLECTION, AND ITS USE
We collect information to provide and improve the App, our Site, our features and Content, to administer your Account, to provide the Services, and to enable users to navigate the Site. This information can be personally identifiable, non-identifying, and include information relating to your device and activity. Please see the “What Kinds of Information We Collect” for more details on what we collect.
We collect the Content and information you provide when you use the Services. For example, we collect the content and information you provide when you use our Services, including for Account registration, create, share, or request feedback, or message and communicate with us or other users. This includes information about the Content you submit, such as its creation date and subject, and your viewing preferences, such as whose profiles you visit and how you interact with the Services.
If you are an SNS user, and we provide a means to connect your SNS account with an ITK Account, we may have access to and collect information about your contacts and groups to whom you are connected, depending on your privacy settings with SNS providers. We will collect contact information if you voluntarily provide the information by yourself, or in response to our requests.
Depending on your privacy settings, we collect information about your computer and other devices you use to take part in the Services. We may associate device data to provide consistent Services, and to provide a secure environment for users. This can include collecting your device identifiers, location data, and IP address to verify Registered Users.
We collect information when you visit or use third-party websites that are associated with, or linked to our Site and Services. This necessarily includes your activity on any SNS site or platform and other information those providers may provide to you or us.
Depending on your permissions and third-party privacy policies, we may also receive information about you and your activities from our third-party partners, such as information a partner collects as part of jointly-offered services.
WHAT KINDS OF INFORMATION DO WE COLLECT?
PERSONALLY IDENTIFIABLE INFORMATION
In the course of using the Services, we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your legal name, email address, mobile phone number, sex/gender, date of birth, and billing or shipping address information (your "Personal Information").
We collect Personal Information in connection with your registration to form an Account, and to participate in certain Services. You can register to join via the App, our Sites, or (if we provide the means to connect them) by logging into your Account with certain third-party provider platforms and social networking sites (each, an "SNS").
If we provide a means to connect your SNS account with an ITK Account and you decide to register by logging into an SNS via our Site or App, we will obtain the Personal Information you have provided to the SNS (such as your real name, user name, phone number, email address and other information you make publicly available via the applicable SNS) from the account you have with the SNS and use that information to create your Account and make you a registered user. Any information we obtain from an SNS will depend on the privacy settings you have with the SNS. The Personal Information an SNS has about you is obtained by the SNS independent of our Service. SNS providers may follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other services you use.
We may also use your Personal Information to contact you with newsletters, email updates, marketing or promotional materials and other information that may be of interest to you. If at any time you decide you no longer wish to receive such communications from us, please unsubscribe from further messages from any “Unsubscribe” function we provide, update your Account's "Notifications" settings, or write to us at firstname.lastname@example.org.
We may also collect Personal Information about you, such as your name and mobile number, when you provide Feedback on the Services.
If you provide us with Personal Information about your contacts, such as to invite your contacts to take part in the Services, we will only use this information for the specific reason we requested, and you provided, the information.
We may also collect other information that you provide as part of registration and your use of certain Services, such as your ZIP or postal code, geographical data, birth month or day (but not both), and individual preferences ("Non-Identifying Information").
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, by combining your ZIP or postal code with your street address) in a way that enables you to be identified. Those same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information, such as your viewing preferences.
We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users to provide you with a better or more personalized user experience, to improve the quality and value of the Services, and to analyze and understand how our Services are used.
When you visit the Site, regardless of whether you are a registered user or a non-registered visitor, our servers automatically record information that your browser sends about your visit ("Log Data"). Log Data is also recorded when you access the App. Log Data may include information such as your computer's or device’s Internet Protocol ("IP") address, browser type, or the webpage you were visiting before you came to our Site, pages of our Site or App that you visit, the time spent on those pages, information you search for on our Site or App, access times and dates, and other statistics. We use this information to monitor and analyze use of the App or our Site and their technical administration, to increase Service 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 App or Site, we 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. We do not treat Log Data as Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
NOTICE ABOUT IDENTITY THEFT & PHISHING
Identity theft and the practice known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, login password, or identification numbers, such as your driver’s license number or Social Security number, in a non-secure or unsolicited email or telephone communication.
For more information about phishing, visit the Federal Trade Commission's website here: https://www.consumer.ftc.gov/articles/0003-phishing.
CalOPPA DISCLOSURE & TRACKING
We do not currently respond to web browser “Do Not Track” settings that allow you to opt-out of information collection about your activities on the Site or third-party websites.
WHO DO WE SHARE YOUR INFORMATION WITH?
The following list describes with whom we may share your information, including your Personal Information, and for what purposes. You may opt-out of any information disclosure by contacting us at email@example.com. If you choose to opt-out of any disclosure of your information, however, you may not be able to use all portions of the Site or certain functionalities of our Services.
When you register to join our Services, you must submit Personal Information to create an Account. You can choose what other Personal Information you provide in connection with our Services that may be shared with other users. Providing this information is voluntary and you should only share as much as you would like to share with others.
We may share generic, aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with our trusted business partners, affiliates, or advertisers for industry analysis, demographic profiling and other similar commercial purposes. Any aggregated information shared in these contexts will not contain your Personal Information. We will only share your Personal Information with our business partners for specific purposes, and only after receiving your prior consent to whom and for what purposes the information is shared.
THIRD-PARTY PROVIDERS & SUBCONTRACTORS
We engage and utilize third-party providers, and other third-party companies and individuals to facilitate our Services, to provide certain Services on our behalf, such as payment processing services, maintenance services, and to assist us in analyzing how our Services are being used. These third-parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
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 Information with affected users under this section.
PARTIES TO BUSINESS TRANSFERS
We may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy to third-parties.
NO OTHER USES
HOW TO CHANGE OR DELETE YOUR INFORMATION
We will retain your information for as long as you have an Account, or as needed to provide a Service. All users may review, update, correct or delete their Personal Information.
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 functionalities we provide in the App to do so. We will use commercially reasonable efforts to honor your request as soon as possible.
However, we reserve the right to retain an archived copy, which is not accessible to third-parties, of your records and information as required by law, to maintain accurate business records, resolve disputes, or enforce our agreement with you.
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 Information.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) 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.
NOTICE TO E.U. & EUROPEAN ECONOMIC AREA RESIDENTS
If you are a person residing within the European Economic Area, including the E.U., Iceland, Lichtenstein and Norway, 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. Please consult the IN THE KNOW “Privacy Notice for EU & EEA Residents” for more information on your rights under the GDPR regarding your personal data.
NOTICE REGARDING INTERNATIONAL TRANSFER OF INFORMATION
Your information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
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 data, or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information 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 FTC’s Children’s Online Privacy Protection Rule (“COPPA”). Our Services are not directed to, or meant for persons under the age of 13. We do not knowingly collect or solicit personally identifiable information from children under 13, or allow them register Accounts. If we become aware that a child under 13 has provided us with Personal Information, or any user has provided information of or about any person under the age of 13, we will delete such information from our systems. Do not submit any Personal Information to us if you are under the age of 13, or any information of, or about, persons under the age of 13.
If you are a parent or guardian and you become aware that your child has provided us with Personal Information without your consent, you should contact us immediately at email@example.com, or use the contact functionality we provide in the App to request we delete your child’s information.
IN THE KNOW;
18 Jiuxianqiao East Road Building 1 A1229
Chaoyang District, Beijing 100015
Tel: +1 (408) 548-0859