PRIVACY POLICY
LAST UPDATED: JANUARY 9, 2022
How information is used
Types of information
Legal basis for use under GDPR
Process your transactions
Send you information about your relationship or transactions with us
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Contact information
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Transaction history
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Payment information
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Contact information
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Transaction history
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Consent
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Necessary for the performance of a contract with you
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Necessary for compliance legal obligations associated with processing online financial transactions
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Necessary for the purposes of our legitimate interests of providing the Services
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Consent
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Necessary for the performance of a contract with you
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Necessary for compliance legal obligations associated with processing online financial transactions
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Necessary for the purposes of our legitimate interests of providing the Services
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Contact information
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Profile name
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Profile picture
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Photos
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Location
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Personal website
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Instagram & Twitter username
Send you alerts or other communications via SMS messages or other media or networks & notify you about new features of the Services, special events, or products, services, and special offers
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Contact information
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Consent
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Necessary for the performance of a contract with you
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Necessary for the purposes of our legitimate interests of providing the Services
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Contact information
Process and respond to your inquiries
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Contact information
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Consent
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Necessary for the performance of a contract with you
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Necessary for the purposes of our legitimate interests of providing the Services
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Consent
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Necessary for the purposes of our legitimate interests of providing the Services
Contact you with information that we believe will be of interest to you
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Device information
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Mobile device information
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Usage information
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Location information
Generate and review reports and data about our user base and Service usage patterns
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Consent
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Necessary for the purposes of our legitimate interests of providing the Services
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Consent
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Necessary for the purposes of our legitimate interests of maintaining and improving the Services
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Device information
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Mobile device information
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Usage information
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Location information
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Consent
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Necessary for the purposes of our legitimate interests of maintaining and improving the Services
Perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services
Improve the content and features of the Services or develop new Services
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Device information
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Mobile device information
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Usage information
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Location information
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Consent
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Necessary for the purposes of our legitimate interests of improving the Services
Administer and troubleshoot the Services
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Necessary for the purposes of our legitimate interests of protecting our legal rights
Enforce the legal terms that govern your use of the Services
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Consent
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Necessary for the purposes of our legitimate interests of providing the Services
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Device information
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Mobile device information
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Usage information
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Location information
Allow us to personalize the content and advertising that you see on the Services and to understand how users interact with and use our advertisements and Services
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Contact information
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Transaction history
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Payment information
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Usage information
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Location information
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Contact information
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Transaction history
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Payment information
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Usage information
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Location information
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Consent
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Necessary for the performance of a contract with you
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Necessary for the purposes of our legitimate interests of maintaining and improving the Services
Associate your activities, customize content or tailor advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications and websites)
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Device information
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Mobile device information
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Usage information
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Location information
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Consent
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Necessary for the purposes of our legitimate interests of improving the Services
For the specific purpose for which you provide information which will be disclosed at the time you provide the information
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Consent, which will be obtained at the time information is collected
Create a profile for you after submitting your work
We may aggregate and/or de-identify your information so that the information no longer relates to you individually. Our use and disclosure of such aggregated or de-identified information is not subject to this Privacy Policy, and may be disclosed to others without limitation and for any purpose.
Tailored advertising
When you use the Service, Klineduo may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your searches, demographic data and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests. You have the right to opt out of cookies and other technologies that provide you with such tailored advertising.
If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiatives Consumer Opt-Out link, the Digital Advertising Alliances Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use any links that may be available in advertisements that appear in the Services to learn more.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored specifically to you. We do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
When using a mobile application you may also receive tailored in-application advertisements. Each operating system (iOS for Apple phones, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.
How we protect information.
We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology.
Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.
How long we retain your information.
We will retain your information for as long as you use the Services and for a limited period after you stop using the Services for billing and collection purposes.
Linked websites and advertisements.
The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites. We have relationships with third-party providers to provide content, products, services, and functionality through the Services. When you visit websites or use any Services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the website or Services in connection with such content, products, services, or functionalities, we share any information you provide or that is collected during your use of those Services with those providers. In some cases, the provider may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information.
Use of the Services by children prohibited.
Our Website does not address anyone under the age of 18 (“Children”). By using the Services, you hereby represent that you are at least 18 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.
If you become aware that your child has provided us with personal information, please contact us. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we take steps to remove such information immediately.
USAGE AND PREFERENCE INFORMATION (Do Not Track Policy)
We collect information about how you and the site visitors interact with the service, preferences expressed. In some cases we do this by use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers. Just like any other usage information we collect, this information allows us to improve the service and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites.
OUR THIRD PARTY SERVICE PROVIDERS
The personal information of users may be held, transmitted to or processed on our behalf outside Kenya, including ‘In the cloud’, by our third party service providers. Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions.
Our third party providers include:
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Cloud hosting, storage, networking and related providers
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SMS providers
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Marketing and Analytics providers
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Security Providers
USE OF INFORMATION
We may use the information we collect about you to:
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Provide, maintain, and improve the service, including, for example; provide products and services you request (and send related information), develop new features, provide customer support to users, authenticate users, and send product updates and administrative messages;
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Perform internal operations, including, for example, to prevent fraud and abuse of the service; to troubleshoot bugs and operational problems; to conduct data analysis, testing; and research; and to monitor and analyze usage and activity trends;
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Send you communications we think will be of interest to you, including information about products, services, news, of where permissible and according to local applicable laws.
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Personalize and improve the service, including to provide or recommend features, content, referrals, and advertisements.
SHARING OF INFORMATION
We may share the information we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:
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With Klineduo partners and affiliated entities that provide services or products and/or logistics purposes;
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With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out on our behalf;
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In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
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With law enforcement officials, government authorities, or third parties if we believe your actions are inconsistent with our Terms of Service/conditions on other relevant Policies, or to protect the rights, property, or safety of Klineduo or others;
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If we otherwise notify you and you consent to the sharing; and
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In an aggregated and/or anonymized form which cannot reasonably be used to identify you.
ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
We may allow others to provide audience measurements and analytics services for us, to serve advertisements on our behalf across the internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you use the service, as well as when you visit other online sites and services.
No rights of third parties.
This Privacy Policy does not create rights enforceable by third parties.
Changes to this Privacy Policy.
Klineduo reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Privacy Policy will mean you accept those changes. For any questions in relation to the protection of personal privacy, please contact us by sending questions, suggestions or feedback about this policy.
We at Klineduo know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the service in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the ways listed below.
Klineduo collects information about you when you use our site and through other interactions and communications you have with us. This Privacy Policy applies to the Klineduo website, and products and services available on or at the website (taken together, the “service”). Remember that your use of the service is at all times subject to the Terms of Service, which incorporates this Privacy Policy.
We are constantly trying to improve the Service, so we may need to change this Privacy Policy from time to time as well. We will alert you to changes by posting a notice on relevant said social media platforms, and/or by some other means. Please note that if you’ve opted not to receive legal notice from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the service, and you are still responsible for reading and understanding them. If you use the service after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy that is in effect at the time the information is collected.
If there is any conflict between the English version of our Privacy Statement and a version translated in another language, the English version controls.
SCOPE
This Privacy Policy (“Policy”) applies to persons anywhere in the world who use the service, to shop products online or use the services listed in the site.
We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the services listed in this site or send any personal information about yourself to us or third party sites. If we learn that we have collected personal information from individuals under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal information, please contact us.
THE TYPES OF PERSONAL INFORMATION WE COLLECT AND HOLD
We collect personal information about our users in order to provide our products, services and Customer Support. Our Products, Services and Customer Support are provided through many platforms including but not limited to; websites & email. The specific platform and product, service or support you interact with may affect the personal data we collect.
We maintain records of the interactions we have with our users, including the products, services and Customer Support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button.
When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used.
Not all information requested, collected, and processed by us is “personal information” as it does not identify you as a specific natural person. This will include majority of “User Generated Content” that you provide us with the intention of sharing with other users. Such “Non-Personal Information” is not covered by this Privacy Policy. However, as non-personal information may be used in aggregate or be linked with existing personal information; when in this form it will be treated as personal information. As such this Privacy Policy will list both types of information for the sake of transparency.
In some situations users may provide us with personal information without us asking for it, or through means not intended for the collection of particular types of information. Whilst we may take reasonable steps to protect this data, the user will have bypassed our systems, processes, and control and thus the information provided will not be governed by this Privacy Policy.
In some situations users may provide us personal information over platforms that are outside our control; for example through Social media. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy.
Information you provide to use the Services
We collect any information that you provide during your use of the Services, including your first and last name, username, email address, postal address, phone number, mobile phone number, payment information, gender, and birth year. We also collect information you provide or allow us to access when you do certain things, such as:
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Submitting information for one or more of our Services;
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Make a purchase;
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Request certain features (e.g., newsletters, updates, and other products);
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Sign up to receive SMS (text message) notifications;
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Download or use one of our mobile applications; or
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Connect with the Services or otherwise allow us to access certain information about you via a social networking site (SNS).
You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of the Service because such information may be required in order for you to participate in a survey, or; ask a question; or initiate other transactions through the Services.
Payment information
If you choose to donate to us, we will collect information such as your credit or debit card information, billing address and transaction history.
Automatically-collected information
We automatically collect certain information when you use the Services:
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Device information: We collect information about the device that you use to access or use the Services, such as hardware model, operating system, browser information, and IP addresses.
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Mobile device information: In addition to the device information described above, we collect certain information when you access the Services via a mobile device, such as the unique device identifier assigned to your device, operating system, and other device attributes.
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Location information: We collect information about your location, such as general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
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Usage information: We collect information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information.
As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.
We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique identifier (that is not intended to be used by itself to identify you) for our internal use, in which case your identifier will be considered Klineduo information and nothing in this Privacy Policy restricts how Klineduo may use this information.
Cookies and other electronic technologies
When you use the Services, we use persistent and session cookies and other similar tracking technologies to: (a) analyze the usage of the Services by collecting the information discussed above; (b) customize the Services to your preferences; and (c) control the advertising displayed by the Services, as well as advertisements that may be displayed on other websites or mobile applications. The cookies may reflect de-identified data linked to or derived from data you voluntarily have submitted to us, e.g., a hashed version of your email address that we may share with service providers, solely in non-human readable form. We and our vendors may also use other Internet technologies, such as Flash technologies, Web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Services, as well as serve you ads when you are using our Services and/or when you are on other websites when those cookies can be accessed. We also may include Web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. As we adopt additional technologies, we may also gather additional information through other methods.
Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline or otherwise disable cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove Flash cookies. To learn more about how to manage Flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel. You have the right to opt out of non-essential cookies, such as for analytics or advertising purposes, at any time.
INFORMATION WE COLLECT FROM OTHER SOURCES
We may combine information from this site with information we have collected from you in your capacity as a use of the service.
We use Analytics to help analyze how our users use the service. Google Analytics uses cookies to collect information such as how often our users visit the service. We may use the information we get from Google Analytics to improve our service or to send you promotional messages about our service. Google Analytics collects the IP address assigned to you on the date you visit the service, but not your name or other personal identifying information. We do not combine the information generated through the use of Google Analytics with any personal identifying information. Although Google Analytics plants a persistent cookie to identify you as a unique user the next time you visit the service, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the service is restricted by the Google Analytics and Google Privacy Policy. You may find additional information about Google Analytics at http://www.google.com/policies/privacy/partners/.
Third parties, including Facebook, may collect or receive information from the service, and use that information to provide measurement services and targeted ads. By using the Service, you agree to the collection and use of information for ad targeting.
You can opt out of (i) Google Analytics by using the following add-on
https://tools.google.com/dlpage/gaoptout/ , and (ii) Facebook by visiting http://www.aboutads.info/choices/.
Information from third parties
We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other product, or service we provide.
Aggregate or de-identified data
We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.
Emails
You must provide your email when you sign up to our newsletter, submitting your work and donating to us. We use your email to provide you with service related materials and correspondence. You may also opt-in to receiving promotional materials via email. Members may opt out of receiving promotional emails at any time.
1. What we do with the information we collect.
We use the information that we collect for the following purposes:
The Services are supported in part by advertising revenue. We may send you commercial emails on behalf of ourselves, our Affiliates, and advertisers. Each such email we send you may have an opt-out that you can use to stop receiving such communications. It may take up to seven days for us to process an opt-out request. We may continue to send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving such emails. Please note that opting out of receiving promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change you preferences directly with that third party.
2. How we share and disclose information with third parties.
We will make your information available to other companies, websites, applications, or people in the circumstances described below:
With non-affiliated third parties to provide services or products that may be of interest to you)
Third parties to which information is disclosed
Legal basis for disclosure under GDPR
Types of information
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Consent
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Necessary for the purposes of our legitimate interests of advertising products or services that may be of interest to you
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Web page history
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IP address
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Email address
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Device ID
With third-party service providers or affiliates of Klineduo in order to provide the Services or to communicate with you on our behalf
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Web page history
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IP address
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Email address
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Device ID
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Consent
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Necessary for the performance of a contract with you
With third-party service providers or affiliates of Klineduo in order to provide advertising on our behalf
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Web page history
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IP address
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Email address
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Device ID
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Consent
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Necessary for the performance of a contract with you
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Necessary for the purposes of our legitimate interests of advertising the Services
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Necessary for the purposes of our legitimate interests of complying with the law or protecting our rights or the rights of others
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Necessary for the performance of a task carries out in the public interest
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Necessary for compliance with our legal obligations
Any relevant personal information
With third parties in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims
Any relevant personal information
With third parties such as law enforcement, government agencies, courts, and/or other organizations when we believe in good faith that a disclosure is appropriate in order to investigate, prevent, or take action regarding possible violations of this Privacy Policy or the Terms of Service for the Services you accessed and/or to protect the rights and property of Klineduo, our employees, users and the public
With third-parties with whom we have a contractual relationship for advertising, including without limitation third-party advertisers and advertising networks
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Consent
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Necessary for the purposes of our legitimate interests of advertising products or services that may be of interest to you
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Necessary for the purposes of our legitimate interests of complying with the law or protecting our rights or the rights of others
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Necessary for the performance of a task carried out in the public interest
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Necessary for compliance with our legal obligations
Any relevant personal information
With third parties such as law enforcement, government agencies, courts, and/or other organizations when we believe in good faith that a disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person
Any relevant personal information
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Necessary for the purposes of our legitimate interests of complying with the law or protecting our rights or the rights of others
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Necessary for the performance of a task carried out in the public interest
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Necessary for compliance with our legal obligations
With third parties in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all Klineduo assets, or a financing or acquisition of all or a portion of our business by another company
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Necessary for the purposes of our legitimate interests of corporate restructuring
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Necessary for compliance with our legal obligations