Privacy Policy

1. INTRODUCTION

Welcome to the Keywee’s (“COMPANY”) website (the “Site”). Keywee is a web-based solution to manage paid content distribution and content creation (“Services”).

This Privacy Policy explains what data we collect when you use our Site and/or the Services, why we collect it and how that data is used. It applies to personal data and other information collected by us from or about: (i) visitors to, or users of, our Site, (ii) prospective customers, (iii) current customers (“Customers”), and (iv) job applicants.

By using the Site and/or the Services, and providing us with your personal data, you consent to the processing of your personal data in the manner set out in this Privacy Policy.

2. INFORMATION WE COLLECT

When you interact with the Site, we may collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”), as described below:

Personal Data That You Provide Through the Site:

When you create an account, order products or services, request information, communicate with customer service, subscribe to email lists, or apply for employment through the Site, we collect the following Personal Data from you:

  • First and last name
  • Title
  • Company name
  • Email address
  • Company Mailing address
  • Job Title
  • Company Phone number
  • Account password
  • Company Payment and billing information
  • Country location
  • IP Address

Automatically Collected Data:

When you visit the Site, we may automatically collect information about you through cookies and similar technologies. This information includes the browser or operating system that you use to access the Internet, your IP address, the date and time you may have viewed certain pages on the Site. Please see the “Use of cookies” section below to find out more about how we use cookies.

Facebook Cookies

We may use Facebook Cookies as part of our service to evaluate and customise content and advertising. For information about Facebook Cookies, please visit https://www.facebook.com/policies/cookies/

Data Collected during Paid Content Distribution and Creation:

Our customers use our web-based solution to manage paid content distribution and content creation (“Services”). In order to use our services we may collect certain non-personally identifiable information. This information may includes: Masked IP address, browser type, Internet Service Provider, URL, computer (or mobile device’s) operating system and mobile device model.

We use this information in a number of ways, including: a) to help us ensure content is being deployed correctly, b) to help us understand how the content that we distribute is being viewed, and c) to help ensure that the content is both appropriate and relevant.

We may use cookies in association with our Services. Cookies are small files placed on the hard drive of your computer. We may use cookies to help us understand how our services are being used, to tailor how we distribute content, and to report on delivery on the content. Please see the “Use of cookies” section below to find out more about how we use cookies.

Facebook Cookies

We may use Facebook Cookies as part of our service to evaluate and customise content and advertising. For information about Facebook Cookies, please visit https://www.facebook.com/policies/cookies/

 

3. HOW WE USE YOUR INFORMATION

To provide the Services to Customers and respond to requests.

We use account-related data provided by Customers to us in connection with the purchase, sign-up, use or support of Customer account (such as usernames, email address and billing information) to provide you with access to the Services and/or the Site, contact you regarding your use of the Services and/or the Site or to notify you of important changes to the Services and/or the Site. For EU data subjects, such use is necessary for the performance of the contract between you and us.

When you ask for information about the Services (for example, when you ask us to send you offers or price information), we will use your contact information to respond to your requests. For EU data subjects, such use is necessary to respond to or implement your request prior to entering into a contract with us.

You have the right to withdraw your consent at any time, including by following the instructions contained in each promotional communication we send you permitting you to “opt-out” of receiving future promotional information. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us at:

  • Email: support@keywwee.co
  • Postal Mail: 37 West 20th St, Suite 1010
    New York, NY 10011

Please note that we will continue to contact you via email to respond to your requests and regarding the provision of our Services.

To analyze, administer, support, improve use of the Site and the Services.

We use data relating to your use of the Site and/or the Services to analyze, administer, support and improve your access to and use of the Site and the Services. We may also compile, anonymize and/or aggregate your Personal Data and other data and use such anonymized and/or aggregated data for our business purposes, including sharing such data with affiliates and business partners. This aggregate information does not identify you.

To process applications for a job.

When you apply for employment through our Site, your contact details and data about your employment history and education may be collected by our provider of recruiting services and we will use such data to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment. For EU data subjects, processing of this data is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.

Other Uses of Personal Data.

We also may use your Personal Data in other ways for which we provide specific notice at the time of collection.

If you are an EU data subject, please see the “EU Data Subjects” section below for information on your rights in relation to your Personal Data.

4. SHARING AND DISCLOSURE

We may share your Personal Data and other information with certain third parties without further notice to you, as set forth below:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions: [providers of payment processing and fraud prevention, marketing, web analytics, hosting, email communication and customer support services, recruiting services.] Pursuant to our instructions, these parties may access, process or store Personal Data in the course of performing their duties to us.
  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or lawful requests by public authorities, including meeting national security or law enforcement requirements and applicable law, rule, order, or regulation, (ii) protect and defend the rights or property of COMPANY, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

5. EU DATA SUBJECTS

Scope.

This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland).

Data Controller.

COMPANY is the data controller for processing personal data provided to us through the Site. Our registered office is in 37 West 20th St, Suite 1010 New York, NY 10011.

Your Rights.

Subject to applicable law, you have the following rights in relation to your Personal Data:

  • Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
    • If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
      If we are processing your Personal Data for direct marketing.
  • Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Contact Us” section below.

Legitimate Interest.

“Legitimate interests” means the interests of COMPANY in conducting and managing our organization. For example, we have a legitimate interest in processing your Personal Data to analyze how our products and services are being used by you, and to ensure network and information security, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.

6. PUBLICLY POSTED INFORMATION

Comments posted to public areas may be viewed, accessed and used by third parties subject to those third parties’ privacy practices and policies.

7. CHILDREN

COMPANY does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to COMPANY through this Site, please contact us at support@keywee.co and we will endeavor to delete that information from our databases.

8. LINKS TO OTHER WEBSITES

The Site may contain links to other websites not operated or controlled by us (“Third Party Sites”). The privacy practices described in this Privacy Policy do not apply to Third Party Sites. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact those sites directly for information on their privacy practices and policies.

9. SOCIAL MEDIA

Through our Site, you can choose to access certain social media websites and services that are owned and/or controlled by third parties, such as Facebook, Twitter, Instagram, Pinterest and YouTube (“Social Media Services”). When you choose to access and use Social Media Services, including interacting with our pages on those sites, you will be sharing your Personal Data and other information with them. The information that you share with the Social Media Services will be governed by the specific privacy policies and terms of service of the Social Media Services and not by this Privacy Policy.

10. SECURITY

We maintain reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in light of the risks inherent in processing this information. However, the Internet cannot be guaranteed to be fully secure and we cannot ensure or warrant the security of any information you provide to us. Please keep this in mind when providing us with your Personal Data. [see Annex A]

11. USE OF COOKIES

COMPANY uses cookies on the Site. A cookie is a piece of information sent to your browser from a website and stored on your computer’s hard drive. Cookies can help a website like ours recognize repeat users and allow a website to track web usage behavior. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. We use cookies to collect information about your device, such as operating system and browser type.

The Site also uses pixel tags, a technology similar to cookies that is placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies.

Upon your first connection to our Site, you will be asked to confirm whether you agree to our use of cookies and similar technologies in accordance with this Policy, and if you accept we will store them on your computer.

12. OTHER TERMS AND CONDITIONS

Your access to and use of our Site is subject to the Terms of Service.

13. CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on this page. By continuing to use the Site and/or the Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.

14. CONTACT US

Please feel free to contact us if you have any questions about COMPANY’s Privacy Policy or the information practices of our Site.

You may contact us as follows: You may send an email to support@keywee.co or send postal mail to:
37 West 20th St, Suite 1010 New York, NY 10011

Annex A
INFORMATION SECURITY

(1) Information Security Policies and Standards

COMPANY’s security measures shall include:

· Preventing unauthorized persons from gaining access to Personal Information Processing systems (physical access control);

· Preventing Personal Information Processing systems being used without authorization (logical access control);

· Ensuring that persons entitled to use a Personal Information Processing system gain access only to such Personal Information as they are entitled to access in accordance with their access rights and that, in the course of Processing or use and after storage, Personal Information cannot be read, copied, modified or deleted without authorization (data access control);

· Ensuring that Personal Information cannot be read, copied, modified or deleted without authorization during electronic transmission, transport or storage, and that the target entities for any transfer of Personal Information by means of data transmission facilities can be established and verified (data transfer control);

· Ensuring the establishment of an audit trail to document whether and by whom Personal Information have been entered into, modified in, or removed from Personal Information Processing (entry control);

· Ensuring that Personal Information are protected against accidental destruction or loss (availability control); and

· Ensuring that Personal Information collected for different purposes can be processed separately (separation control).

These measures are kept up to date, and revised whenever relevant changes are made to the information system that uses or houses personal data, or to how that system is organized.

(2) Network Security

The COMPANY maintains network security using commercially available equipment and industry standard techniques, including firewalls, intrusion detection and/or prevention systems, access control lists and routing protocols.

(3) Access Control

Only authorized staff can grant, modify or revoke access to an information system that uses or houses use Personal Information.

User administration procedures define user roles and their privileges, how access is granted, changed and terminated; addresses appropriate segregation of duties; and defines the logging/monitoring requirements and mechanisms.

The COMPANY implements commercially reasonable physical and electronic security to create and protect passwords.

(4) Business Continuity

The COMPANY implements appropriate disaster recovery and business resumption plans.