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OUR COMMITMENT TO YOU

KIN Privacy Policy

OUR COMMITMENT TO YOU

At KIN, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections. We appreciate that you put your trust in us when you provide us with your information, and we do not take this lightly. Our commitment to privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that our decisions are taken with the utmost respect for your privacy. Our commitment to transparency. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we’re doing our best to write our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices! Our commitment to security. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information. PRIVACY POLICY Welcome to KIN’s Privacy Policy. Thank you for taking the time to read it. We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum. WHERE THIS PRIVACY POLICY APPLIES This Privacy Policy applies to websites, apps, events and other services we operate under the brand . For simplicity, we refer to all of these as our “services” in this Privacy Policy. Some services may require their own unique privacy policy. If a service has its own privacy policy, then that policy -- not this Privacy Policy -- applies. INFORMATION WE COLLECT It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details. We also collect information about your use of our services such as access logs, as well as information from third parties, like when you access our services through your social media account or when you upload information from your social media account to complete your profile. Information you give us You choose to give us certain information when using our services. This includes:

When you create an account, you provide us with at least your login credentials and/or phone number, as well as some basic details necessary for the service to work, such as your gender and date of birth.
When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos.
When you participate in reflections, surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
If you contact us (e.g., through our engagement team or on social media), we collect the information you give us during the interaction.
If you share with us information about other people (for example, if you use contact details of a friend for a given feature), we process this information on your behalf in order to complete your request.
Of course, we also process your chats with your Kin partner as necessary for the operation of the services.

Information we receive from others In addition to the information you may provide us directly, we receive information about you from others, including:

Users

Users may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you.

Social Media

You may decide to share information with us through your social media account, for instance if you decide to create or log into your KIN account via your social media or other account (e.g., Facebook, Google or Apple) or to upload onto our services information such as photos from one of your social media accounts (e.g., Facebook or Instagram).

Affiliates

KIN is part of KOL LLC. KIN considers the safety and security of users a top priority. If you were banned from another KIN Universe service, your information can be shared with us to allow us to take necessary actions, including closing your account or preventing you from creating an account on our services.

Other Partners

We may receive information about you from our partners, including when KIN accounts can be created through a partner’s service(in which case they pass along registration information to us) or where KIN ads are published on a partner’s service (in which case they may pass along details on a campaign’s success). Where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our users’ safety and security.

Usage Information

Using the services generates data about your activity on our services, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you, referring webpages address and ads that you interacted with) and your interactions with other users (e.g., users you connect and interact with, when you exchanged with them, number of messages you send and receive).

Device Information

We collect information from and about the device(s) you use to access our services, including hardware and software information such as IP address, device ID and type, apps settings and characteristics, app crashes, advertising IDs (which are randomly generated numbers that you can reset by going into your device’s settings), identifiers associated with cookies or other technologies that may uniquely identify a device or browser. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels and SDKs) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them and how you can better control their use. Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including KIN, do not currently respond to DNT signals. HOW WE USE INFORMATION The main reason we use your information is to deliver and improve our services. Additionally, we use your information to help keep you safe, and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons for which we use your information, together with practical examples.

To administer your account and provide our services to you

Create and manage your account
Provide you with customer support and respond to your requests
Communicate with you about our services

To help you connect with other users

Recommend you other Kin users to meet

To operate advertising and marketing campaigns

Perform and measure the effectiveness of advertising campaigns on our services and marketing campaigns promoting KIN on and off our services
Communicate with you about products or services that we believe may interest you

To improve our services and develop new ones

Administer focus groups, market studies and surveys
Review interactions with engagement teams to improve our quality of service
Understand how users typically use the services to improve them (for instance, we may decide to change the look and feel or even substantially modify a given feature based on how users react to it)
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

To prevent, detect and fight fraud and other illegal or unauthorized activities

Find and address ongoing, suspected or alleged violations of our Terms of Use, notably through the review of reports and interactions between members.
Better understand and design countermeasures against violations of our Terms of Use.
Retain data related to violations of our Terms of Use to prevent against recurrences
Enforce or exercise our rights, for example our Terms of Use.
Communicate to users what we’ve done as a result of their reports.

To ensure legal compliance

Comply with legal requirements
Assist law enforcement

HOW WE SHARE INFORMATION Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other users. We also share some users’ information with service providers and partners who assist us in operating the services, with other KIN Universe companies for specified reasons as laid out below and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

With other users

If someone submits a report involving you (such as a claim that you violated our Terms of Use), we may communicate to the reporter actions, if any, we took as a result of their report.

With our service providers and partners

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising and security operations. We also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. We follow a strict vetting process prior to engaging any service provider or working with any partner. Our service providers and partners must agree to strict confidentiality obligations.

With our affiliates

We share your information with affiliates for limited legitimate purposes as laid out below:

- to make all KIN platforms safer, by making sure that when a bad actor is found on one of them (for instance on our services), it is not only addressed there (for instance by banning them), but also on the others;
- for them to assist us in data processing operations, as service providers, upon our instructions and on our behalf. Their assistance may include technical processing operations, such as data hosting and maintenance, customer engagement, marketing and targeted advertising, analytics, finance and accounting assistance, improving our service, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings.
- in order to improve your chances at building significant connections with others, we may make you visible on other KIN Universe services or allow you to benefit from cross-platform functionalities. We will of course comply with applicable law and, where relevant, notify you of any such opportunity and allow you to agree or to refuse. Examples of such opportunities may include the creation of a new service within KIN Universe, addressing a specific demographic that we think might be interesting to you based on your profile.
- for other legitimate business purposes including audit, analysis and consolidated reporting, where and as allowed under applicable laws.

For corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

With law enforcement / when required by law

We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information. We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other KIN companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy. YOUR RIGHTS We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

Access / Update tools in the service. Tools and account settings can help you access, rectify or remove information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our engagement team.
Device permissions. Mobile platforms can have permission systems for specific types of device data and notifications, such as phone contacts, pictures, location services, push notifications and advertising identifiers. You can change your settings on your device to either consent or oppose the collection or processing of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose functionality.
Account closure. You can close your account by reaching out to our engagement team.

We also want you to be aware of your privacy rights. Here are a few key points to remember:

Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability, right to know or variations of those terms). You can exercise this right by putting in such a request with our engagement team.
Updating your information. If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, object to or restrict its processing, please contact our engagement team.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests, including if we are unable to authenticate you, if the request is unlawful or invalid, or if it may infringe on trade secrets or intellectual property or the privacy or other rights of someone else. If you wish to receive information relating to another user, such as a copy of any messages you received from them through our service, the other user will have to contact us to submit a separate request for their information. We may also ask them to provide proof of identity before we can answer the request. Also, we may not be able to accommodate certain requests to object to or restrict the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth and thus cannot ensure that you are 18 years of age or older. In certain jurisdictions, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. HOW LONG WE RETAIN YOUR INFORMATION We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. If you decide to stop using our services, you can close your account. Note that we will close your account automatically if you are inactive for a period of two years. CHILDREN'S PRIVACY Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a user is under the age of 18, please use the reporting mechanism available on the service.

PRIVACY POLICY CHANGES

Because we’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.