);

Effective: 21 February 2019

The new version of the Kudos Knowledge Privacy Policy has been updated to comply with the GDPR.

Our Privacy Policy explains how Kudos Knowledge collects, uses, and discloses information about you. The terms “Kudos Knowledge,” “we,” “us,” and “our” include Kudos Knowledge Pty Ltd and our affiliates (Kudos Knowledge Pty Ltd, Startech Solutions Pty Ltd and Imaginative Technology Solutions Pty Ltd). We use the terms “member,” “you,” and “your” to mean any person using our Platform or attending related events, including any organization or person using the Platform on an organization’s behalf. This Privacy Policy applies to the processing of information about members and other individuals that we collect when you use our “Platform,” which means any website, application, or services we offer, or when you communicate with us. For information about choices that we offer under this policy, please see “Your Choices” below. This Privacy Policy does not apply to the information that you may provide to third parties, such as members, and others with whom you may share information about yourself. For more information about the scope of our Privacy Policy, please see Section 4.6.

To make this Privacy Policy easier to understand, we have provided summaries. These summaries are not part of the official policy. Even though we have provided summaries, it is important for you to read the entire policy carefully.

1. Collection of Information
2. Use of Information
3. Sharing of Information
4. Additional Details
5. Your Choices
6. Data Rights
7. Contact Us

 

1. COLLECTION OF INFORMATION

Summary: We collect information about you when you:

• Create an account;
• Use the Platform;
• Attend an event;
• Visit our website; and
• Communicate with us.

We also collect information, such as usage statistics, by using cookies, server logs, and similar technologies.

If you elect to use certain features, we also collect information through other sources, such as social media services, invitations, and imported contacts.


1.1 Information You Provide to Us

We collect information that you provide directly to us. For example, we collect information that you provide when you create an account, choose interests or groups, fill out a form, or communicate with us. The types of information that we may collect include your name, username, password, email address, postal address, phone number, payment method data, photos, choices of interests and groups, and any other information that you choose to provide. Information about your gender and interests is optional. Your choice of groups is optional, but we are required to process this information in order to administer your account, and to indicate that you are a member of the groups that you join. See Section 2 to learn how we will use the information that you provide to personalize our recommendations and other content to you.

On occasion, the information that you give us when you join a group may imply information about your beliefs, political views, health conditions; or your sexual identity. This, and other kinds of sensitive information, is given special protection.


1.2 Information We Collect Automatically When You Use the Platform

When you use our Platform, we automatically collect information about you, including:

• Log Information: We collect log information about your use of the Platform, including the type of browser that you use; the time, duration and frequency of your access; Platform pages viewed; your IP address; and the page you visited before visiting our Platform.
• Device Information: We collect information about the computer or mobile device that you use to access our Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Location Information: We may collect information about the location of your device each time you use our Platform based on your consent to the collection of this information. For further information see Section 5.2.
• Information Collected by Cookies and Other Tracking Technologies: We and our service providers collect information using various technologies, including cookies and pixel tags (which are also called clear GIFs, web beacons, or pixels). Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, and track usage of our Platform. Pixel tags are electronic images that may be used in our Platform or emails, and track usage of our Platform and effectiveness of communications. You can learn more about the types of cookies we and our service providers use by reading our Cookie Policy in Section 4.5.
• Other Information: With your permission, we may collect other information from your device, such as photos from your camera roll, contacts of individuals you wish to find or connect with, or calendar information you want to manage via the Platform.


1.3 Information We Collect From Other Sources

We may collect information about you from other sources, such as through certain features on the Platform you elect to use, but only where these third parties either have your consent or are otherwise legally permitted or required to disclose your information to us. Examples include:

• Social Media Services. If you register or log into your account through a third-party social media service, we will have access to some of your third-party account information from that service, such as your name and other information in that account and used for purposes such as improving your Kudos Knowledge recommendations. We may also have access to third-party account information if you use the Platform feature to share a link.
• Invitations. If another member sends you an invitation through our Platform, we may receive certain personal information, such as your name, email address, or phone number. If you are an invited guest, we will automatically send you an invitation to our Platform, and, if unanswered, a one-time follow-up invitation. Kudos Knowledge stores this contact information only to send these invitations and evaluate their success. You may unsubscribe from future invitations using the instructions in those messages. You may also contact us at privacyenq@KudosKnowledge.com to request that we remove this information from our database.
• Member Content. We may receive information about you when you or another member uploads photos or posts other content to the Platform. For further details about the rights over this information available to individuals, see Section 6.
• Information from Other Third-Party Sources. In order to provide you with more tailored recommendations, we may obtain information about you from publicly and commercially available sources and other third parties as permitted by law. For more information about the data that we obtain from these providers, please contact us at privacyenq@KudosKnowledge.com.

 

2. USE OF INFORMATION

Summary: We use information about you to:

• Operate, improve, promote, and protect Kudos Knowledge and our Platform;
• Communicate with you; and
• Personalize content.


2.1 Operating our Platform

We may use information about you for various purposes related to operating our Platform, including to:

1. Provide, maintain, and improve our Platform, including to process transactions, develop new products and services, and manage the performance of our Platform;
2. Display information about you, for instance, your list of interests, which will be visible on your profile;
3. Personalize the Platform, for example, to suggest content in which we think you may be interested (including content given special protection under EU law or that relates to sensitive topics such as health, political opinions, religion, and sexual identity);
4. Allow you to share information about your use of the Platform through a third-party social media service, if you connect your account through that service (which you can turn off at any time) and to provide you with better recommendations;
5. Monitor and analyze trends, usage, and activities in connection with our Platform; and
6. Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of Kudos Knowledge and others; to enforce compliance with our policies; and to comply with applicable law and government requests.
7. Perform accounting and administrative tasks, and enforce or manage legal claims.


2.2 Communicating With You

We may use information about you for various purposes related to communicating with you, including to:

1. Respond to your comments, questions, and requests, and provide customer service;
2. Communicate with you, in accordance with your account settings, about products, services, and events offered by us and others, to provide news and information that we think will be of interest to you, to conduct online surveys, to contact you about events on our Platform that are being held near your location, and to otherwise communicate with you in accordance with Section 2.3;
3. Notify you about communications of other members, in accordance with the communication preferences that you indicate in your account; and
4. Send you technical notices, updates, security alerts and support, and administrative messages.


2.3 Advertising And Other Uses

We may use information about you for various other purposes, including to:

1. Provide content, features, or sponsorships that match member profiles or interests;
2. Facilitate contests and other promotions;
3. Combine with information that we collect for the purposes described in this Privacy Policy; and
4. Carry out any other purposes described to you at the time that we collected the information.


2.4 Legal Basis for Processing

Our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.

1. We process information about you in order to provide our services in accordance with our Terms of Service, for example to allow you to join groups and to allow us to send you important service updates.
2. We also process information about you where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Platform).
3. Sometimes you provide us with sensitive information about you; for instance, the mere fact of joining a certain group may indicate information about your health, religion, political views, or sexual identity. Joining such groups, or posting information on the Platform about these topics is entirely voluntarily and done with your explicit consent.
4. In some cases, we may also have a legal obligation to collect information about you, or may otherwise need the information to protect your vital interests or those of another person.
5. We may also process information to comply with a legal requirement or to perform a contract.

 

3. SHARING OF INFORMATION

Summary: We do not share information about you in any way other than as described in this Privacy Policy.

We may disclose information about you:

• to members or social media services, subject to the choices you may make via the Platform;
• to our third-party service providers who help us to operate or improve our Platform; and
• to authorities to comply with legal obligations and to protect and defend our rights and property.

We may also share de-identified or aggregated information.


3.1 Through Our Platform

We share some of the information that we collect by displaying it on our Platform according to your member profile and account settings. Some information, such as user name, is always public. Some information, such as interests, is public by default, but can be hidden on our Platform. Some information, such as group memberships, will always be visible to other members of that Kudos Knowledge group, and may be public, depending on the settings of that group. We recommend that you check the group settings and what information will be available before joining the group to ensure that you are happy with the information that is visible to others.


3.2 With Our Service Providers

We may use service providers in connection with operating and improving the Platform to assist with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations.


3.3 Following The Law And Protecting Ozecom

We may access, preserve, and disclose information about you to third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Kudos Knowledge or others.


3.4 Social Sharing And Other Tools

The Platform may offer social sharing features and other integrated tools which let you share actions that you take on our Platform with third-party services, and vice versa. Such features let you share information with your friends or the public, depending on the settings you have chosen with the service. The third-party services’ use of the information will be governed by the third-parties’ privacy policies, and we do not control the third-parties’ use of the shared data. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please review the privacy policies of the services that provide these features.

 

3.5 Other Situations

We may de-identify or aggregate information about you and share it freely, so that you can no longer be identified. We may also share information about you with your consent or at your direction or where we are legally entitled to do so.

 

4. ADDITIONAL DETAILS

Summary:

• With your permission, we may allow others to use technologies that collect information about you to provide analytic services, and to serve ads for Kudos Knowledge. You may be able to disable the collection or use of this information.
• We may transfer data to other countries and in this case we ensure appropriate safeguards are employed.
• We use commercially reasonable efforts to protect your personal information and have implemented technical and organizational measures in line with industry best practices. We cannot guarantee these controls will provide absolute security.
• This Privacy Policy is periodically updated, and does not apply to third parties.

4.1 Analytics and Advertising Services Provided by Others

With your permission, we may allow others to use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Platform and other websites and online services. See our Cookie Policy for details about these technologies and the information that they collect, use, or share, including how you may be able to control or disable these services.


4.2 Transfer Of Information To Other Countries

Information about you may will be transferred to, and processed in, other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. We have taken appropriate safeguards to require that your information will remain protected in accordance with this Privacy Policy.


4.3 Data Security

We store the personal information you provide and we employ technical and organizational measures designed to appropriately protect your information that is under our control and that we process on your behalf from unauthorized access collection, use, disclosure, copying, modification or disposal, both during transmission and once we receive it. We store all information that you provide to us in secure computer systems which can only be accessed by authorised officers. We use industry standard encryption technologies when transferring and receiving data. All data is stored on dedicated servers. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure.

We train employees regarding our data privacy policies and procedures, and permit authorized employees to access information on a need to know basis, as required for their role.

We take a number of steps to protect personal information from misuse, loss, unauthorised access, modification or improper disclosure. This includes instructing staff who handle personal information to respect the confidentiality of Customer’s personal information and the privacy of individuals.

Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential. If you would like to update or change your password, you may select the “Forgot your password?” link on the login page. You will be sent an email that allows you to reset your password.


4.4 Data Retention

We retain certain information that we collect from you while you are a member of the Platform, and in certain cases where you have deleted your account, for the following reasons:

• So you can use our Platform;
So ensure that we do not communicate with you if you have asked us not to;
• To provide you with a refund, if entitled;
• To provide accurate accounting information to other members about the groups that they organize or administer, and associated memberships;
• To better understand the traffic to our Platform so that we can provide all members with the best possible experience;
• To detect and prevent abuse of our Platform, illegal activities and breaches of our Terms of Service; and
• To comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it.


4.5 Cookies

What Cookies Are. Cookies are small data files which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow us to recognize your device.

How We Use Cookies. Cookies serve a variety of functions, like enabling us to remember certain information you provide to us as you navigate between pages on the Platform. We use cookies for the following purposes:

• Authentication: We use cookies to recognize you if you are logged in to our Platform. This lets us personalize your experience on or with the Platform in the ways described below. In addition, we may employ third-party services that may use cookies to help you sign into their services from our Platform.
• Security: We use cookies to support or enable security features we have deployed, and to help us detect malicious activity and violations of our Terms of Service. These cookies help us prevent fraudulent use of login credentials.
• Services, features, and preferences: We use cookies to provide functionality and help us deliver our products and services according to your preferences. For example, we use cookies to know which language you prefer, what your communications preferences are, to show you personalized views related to your interests and groups, and in order to help you fill out forms on the Platform.
• Performance, Analytics and Research: We use cookies to help us analyze how the Platform is being accessed and used, and enable us to track performance of the Platform. This helps us to understand, improve, and research features and content on the Platform. We may also use other services, such as Google Analytics or other third-party cookies, to assist with analyzing performance on our Platform. As part of providing these services, these service providers may use cookies and the technologies described below to collect and store information about your device, such as time of visit, pages visited, time spent on each page of the Platform, links clicked and conversion information, IP address, browser, mobile network information, and type of operating system used.
• Kudos Knowledge ads: We partner with third party publishers, advertising networks and service providers to manage our ads on other sites. Our third party partners may set cookies on your device or use the technologies described below to gather information about your activities on the Platform and other sites and online services you use, in order to provide you with Kudos Knowledge ads that match member profiles or interests. For example, if you visit our Platform and also use a social media platform, you may see a Kudos Knowledge ad on those social media platforms.
• Third party advertisers: We may work with advertisers, and advertising service providers to serve ads that may be relevant to you based on your inferred interests, location or other information collected about you, which may use a cookie or the technologies described below, placed by Kudos Knowledge or the third party (although we would not share any other information that identifies you with an advertiser) on our Platform, or on a third party website or online service. The placing of these technologies on your device may enable you to be identified across multiple websites and online services.

Duration of Cookies. Some cookies, known as “session cookies”, will stay on your device only for as long as you are accessing our Platform. Others, known as “persistent cookies”, are stored on your device for longer periods.

Other Technologies

Use of Other Technologies. We may allow others to provide analytics services and serve advertisements on our behalf. In addition to the uses of cookies described above, these entities may use other methods, such as the technologies described below, to collect information about your use of the Platform and other websites and online services.

Pixels tags. Pixel tags (which are also called clear GIFs, web beacons, or pixels), are small pieces of code that can be embedded on websites and emails. Pixels tags may be used to learn how you interact with our site pages and emails, and this information helps us and our partners provide you with a more tailored experience.

Device Identifiers. A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyze and improve the performance of the Platform and ads delivered.

Local storage. Local storage is an industry-standard technology that enables the storage and retrieval of data on a computer, mobile phone or other device. Local storage may be used to store member preferences on devices.

Opting Out

Cookies. Most devices and web browsers are set to accept cookies by default. If you prefer, you may be able to remove or reject cookies. You can learn more about how to block cookies by visiting allaboutcookies.org. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Platform.

Targeted Advertising. Third parties that use cookies and other tracking technologies to deliver targeted advertisements on third party websites may offer you a way to prevent such targeted advertisements by opting out at the websites of industry groups such as the Digital Advertising Alliance, or if located in the European Union, the European Interactive Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Your device may also include a feature that allows you to opt out of having certain information collected through apps used for behavioural advertising purposes. Note that even if you choose to opt out of receiving targeted advertising, you may still receive advertising, although it should not be tailored to your interests or activities.

 

4.6 Policy Scope

This Privacy Policy does not apply to information that you provide to third parties, such as other members, including group organizers and network administrators, and others with whom you may share information about you. Our Platform may direct you to a third-party service, such as social media services, or a portion of our Platform may be controlled by a third party (typically through the use of a frame or pop-up window separate from other content on our Platform). Disclosure of information to these third parties is subject to the relevant third party’s privacy policy. We are not responsible for the third-party privacy policy or content, even if we link to those services from our Platform or if we share information with these third parties.

Kudos Knowledge is a data controller. Members, including group organizers and network administrators, are directly responsible for complying with all requirements of applicable EU privacy laws in connection with the information that they obtain and process for the purposes of managing their contacts, or organizing groups, or administering networks

 

4.7 Revisions To This Policy

We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by publishing the most current version and revising the date at the top of this page. If we make any material change to this policy, we will provide additional notice to you, such as by sending you an email or displaying a prominent notice on our Platform.

 

5. YOUR CHOICES

Summary:

• You can review and change information about you or deactivate your account in your account settings, but we may retain certain information.
• You can remove photo tags if you wish.
• With your consent, we will use information about your location. You can deactivate this feature at any time.

You have the right to opt out of receiving Kudos Knowledge’s promotional messages, but you may still receive other non-promotional communications.


5.1 Your Choices: Account Information

You may update or correct your account information by editing your account settings or by sending a request to privacyenq@KudosKnowledge.com as described in Section 6. You may deactivate your account by editing your account settings or by sending an email to privacyenq@KudosKnowledge.com. You will also be able to choose what information others see about you and who may contact you by using the Privacy Settings section in your Account.


5.2 Your Choices: Location Information

When you first access the Platform, we will collect information about your location, which we use to make better recommendations for groups and events in your area, and to improve our Platform. If you do not want us to collect information about your location, then you can prevent this:

• If using a mobile app, by changing the settings on your device.
• If using our website, your location data will be obtained via a cookie. Please refer to our Cookie Policy for additional information on how to manage our use of cookies.

Note that our Platform or its features may no longer function properly if you do.

Your mobile device settings may also give you the option to choose whether to allow us to view your location on a continuous basis, when only using the app, or never. Allowing us to view your location when you are not using the app allows us to provide you with recommendations on a regular basis. Please refer to your device’s guide for additional information on how to adjust location services.


5.3 Your Choices: Promotional Communications

You can control messages that you receive from Kudos Knowledge, other members, and third parties by selecting the unsubscribe link in the message that you receive, or by adjusting the communication preferences in your account settings. We will also send you a link to these settings when you first sign up and in subsequent messages. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.


5.4 Your Choices: Photo Tagging

You can tag photos of yourself and others. When a photo has been tagged it means that the name of that person will appear alongside the photo, and the tagged photo will appear on the tagged member’s group profile.

We will notify you when another member has tagged your account in a photo or when additional comments are added to such photos. You can also report inappropriate content to Kudos Knowledge. Please inform guests who are not members of this Privacy Policy and their rights regarding their personal information should a photograph be posted on the Platform.

 

6. DATA RIGHTS

Summary:

• You may have the right to exercise your data protection rights, including to request that Kudos Knowledge deletes, amends, or provides you access to your information.
• You have the right to opt out of receiving Kudos Knowledge’s promotional messages, but you may still receive other communications.
• You can complain to your local data protection authority about the use of your information.

We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to privacyenq@KudosKnowledge.com.

Rights that you may have, depending on the country in which you live, include:

• Accessing, correcting, updating, or requesting deletion of your information.
• Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
• Opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we send you. Additionally, you may update your email preferences by changing the settings in your account.
• Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.

Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

 

7. CONTACT US

Summary:

• If you have any questions, you can contact us at privacyenq@KudosKnowledge.com.

Under European data protection law, the controller of your information is Kudos Knowledge Pty Ltd.

If you have any questions or complaints about this Privacy Policy or how we use your information, please contact privacyenq@KudosKnowledge.com.

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