Welcome to the Keywee’s (“COMPANY”, “Keywee”, “we”, “our”, and “us”) website (the “Site”). Keywee is a web-based solution to manage paid content distribution and content creation (“Services”).
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”)
We obtain the categories of personal information listed below from the following categories of sources:
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:
You will be informed what personal information is required and what information is optional when asked to submit personal information to us. By submitting personal information to Keywee at this Site, you hereby consent and opt-in to Keywee’s collection, use, and disclosure of such personal information.
We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on-or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including from your publicly available social media profiles), and other third parties.
Automatically Collected Data:
Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We collect Device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Keywee account.
Your IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.
Facebook Cookies and Other Third Party Technologies
We may use Facebook Cookies as part of our service to evaluate and customize content and advertising. For information about Facebook Cookies, please visit https://www.facebook.com/policies/cookies/
We permit third-party advertising partners to use tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site. For example, we use advertising services provided by third-party partners, such as Google, to market our service to you on other websites and online services. Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you can select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt-outs on those industry pages at networkadvertising.org/choices or aboutads.info/choices.
Data Collected during Paid Content Distribution and Creation:
Our customers use our web-based solution to manage paid content distribution and content creation. 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.
3. HOW WE USE YOUR INFORMATION
The information that Keywee collects about you and your Devices may be used:
Communication with you in connection with these uses may be via mail, telephone, e-mail, text message, social media, or other electronic messages, or via our websites and applications.
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.
We also use and transfer personal information from or about you:
You may choose to receive certain communications from Keywee via your email address upon interaction with the Site. From time to time, Keywee may include surveys, information requests, or other features on the Site which ask you to provide personal information such as your name, telephone number, email address or mailing address. Any information you may provide will be used by Keywee to allow you to participate in the particular feature being offered. Keywee may also retain any information you provide in order to send you information about Keywee’s products and services that may be of interest to you. Keywee will provide you with the opportunity to opt-out of receiving such communications. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.
You have the right to withdraw your consent that was provided to us 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:
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:
In the preceding twelve (12) months, we have not sold any personal information.
In the last twelve (12) months, we have disclosed the following categories of personal information about consumers for a business purpose:
5. EU DATA SUBJECTS
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).
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.
Subject to applicable law, you have the following rights in relation to your Personal Data:
You may exercise your rights by contacting us as indicated under “Contact Us” section below.
6. CALIFORNIA PRIVACY RIGHTS
Under the CCPA, a data subject may only make a personal information request twice in a 12-month period. Keywee will respond to such personal information request within 45 days of receiving the personal information request.
You may exercise your rights by contacting us as indicated under “Contact Us” section below.
7. 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.
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 firstname.lastname@example.org and we will endeavor to delete that information from our databases.
9. LINKS TO OTHER WEBSITES
10. SOCIAL MEDIA
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]
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. Pixel tags, web beacons, clear GIFs, or other similar technologies may be used in connection with some Site pages to, among other things, track the action of Site users and compile statistics about Site usage and response rates.
Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or Device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.
13. OTHER TERMS AND CONDITIONS
Your access to and use of our Site is subject to the Terms of Service.
14. COMPLIANE WITH LOCAL LAWS
16. YOUR RIGHT TO COMPLAIN
If you have a complaint as to our use of your information, you may file a complaint with us, the GDPR supervisory authority (for EU residents), the California Attorney General (for California residents), any other governmental agency, and/or a judicial body.
17. CONTACT US
You may contact us as follows: You may send an email to email@example.com or send postal mail to:
37 West 20th St, Suite 1010 New York, NY 10011
(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.