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PLEASE READ THIS PRIVACY POLICY STATEMENT CAREFULLY. This privacy policy statement (“Privacy Policy”) explains how Kefi Holdings, LLC, a Delaware limited liability company, and/or its subsidiary and affiliated entities (collectively, “Kefi”, “we”, “us”, or “our”) may collect information about you and your child, who may be under the age of 13 or 18, through the Kefi services, including the various mobile applications, websites, SMS, APIs, email notifications, applications, buttons, widgets, features, ads, commerce services and online services, that are operated by Kefi and link to this Privacy Policy (collectively, the “Services”) and how this information may then be used, shared, disclosed, transferred, and/or stored.
The Services expressly include any Kefi top-level-domain as well as any Kefi redirects to Kefi or PlayKefi branded areas and sub-domains of third-party websites (as such websites and top-level-domains may be renamed from time to time). This Privacy Policy applies only to the Services and does not apply to those portions of the Services that do not display or link to this Privacy Policy or that have their own privacy policy statement or to information we may collect from you or about you in other ways, including through emails, texts and/or phone calls you may send and/or make to us. We may update this Privacy Policy from time to time by posting the updated terms on the Services (including on our mobile applications and/or websites). You are responsible for periodically reading this Privacy Policy. If you register, subscribe, create an account, purchase a product or service, participate in an online survey, or otherwise interact or access the Services after we have updated this Privacy Policy, you acknowledge that you have read the updated terms and consent to our revised privacy practices.
This Privacy Policy describes our privacy practices, including what information we may collect from you through the Services, and what we may then do with this information. If you are a child (who may be under the age of 13 or 18), please be sure to get your parents or legal guardians to review and discuss this Privacy Policy with you, and get their permission, before using the Services.
By using the Services, you acknowledge that you have read this privacy policy statement and consent to our privacy practices as described in this statement, including our use and disclosure of Personal Information (as hereinafter defined) for the purposes described below. You further affirm your consent by becoming a registered member and/or account holder of Kefi or submitting content or materials to or through the Services. This statement is not intended to and does not create any contractual or other legal right in or on behalf of any person.
Residents of the State of California, please also read the California Residents – Your Privacy Rights section below to understand additional rights you may have pursuant to California Civil Code Section 1798.83.
IF YOU DO NOT CONSENT TO OUR PRIVACY PRACTICES AS DESCRIBED IN THIS PRIVACY POLICY STATEMENT, PLEASE DO NOT REGISTER, SUBSCRIBE, CREATE AN ACCOUNT, PURCHASE A PRODUCT OR SERVICE, PARTICIPATE IN AN ONLINE SURVEY, OR OTHERWISE INTERACT OR ACCESS the Services.
IF YOU ENCOUNTER A SCREEN OR PAGE THAT REQUESTS INFORMATION YOU DO NOT WANT TO SHARE WITH US, DO NOT ENTER THE INFORMATION AND DO NOT PROCEED WITH THAT SCREEN OR PAGE.
Some of the Services are intended for children, who may be under the age of 13 or 18, and other parts of the Services are targeted for users of all ages. We recognize the need to provide further privacy protections with respect to children visiting or using the Services. Our privacy practices are guided by the United States’ Children’s Online Privacy Protection Act of 1998, as well as data privacy laws in the United States and other applicable countries. Children should always check with their parents or legal guardians before entering any information on any website or mobile application and we encourage parents and legal guardians to talk about what information their children should and shouldn’t share online and/or through mobile application, and other restrictions about the online and mobile application release of Personal Information to anyone they don’t know. We hope that our privacy practices as described in this Privacy Policy will remove any concerns that parents and legal guardians may have about their children visiting or using the Services.
When we intend to collect Personal Information from children, we take additional steps to protect children’s privacy, including:
For additional information about our practices in the United States and Latin America regarding children’s Personal Information, please read our Children’s Privacy Policy.
Personal information (“Personal Information”) is information that can be used to identify, locate, or contact a single person, such as a person’s name, address, telephone number, or email address. It also includes other information that may be associated with Personal Information.
You may be asked to provide your Personal Information anytime you register, subscribe, create an account, purchase a product or service, participate in an online survey, or otherwise interact or access the Services or are in contact with us. We may share this Personal Information with and use it consistent with this Privacy Policy. We may also combine it with other information to provide and improve our products, services, content, and advertising.
We will not use children’s Personal Information we collect, if any, for marketing or online advertising.
Here are some examples of the types of Personal Information we may collect and how we may use, share, disclose, transfer and store it.
We seek to ensure that any unaffiliated third-parties will not use your Personal Information for any purpose other than that for which they are responsible. However, we cannot guarantee that they will not use it for any other purpose.
Internet Protocol (IP) address. Your “IP address” is a number that lets computers attached to the Internet know where to send you data, such as the screens and pages of the Services that you view. We use this information to deliver our screens and pages to you upon request, to tailor the Services to the interests of you and our other visitors, and to measure traffic to and within the Services.
In some of our email and text messages, we use a “click-through URL” linked to content on the Services and/or third-party websites. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on the Services and/or a third-party’s website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email or text messages.
You can enable or disable location services when you use the Services at any time, through your mobile device, computer, tablet or other machine settings.
Non-Personal Information does not identify you personally. If you do provide us with Non-Personal Information, we may collect, use, share, disclose, transfer and store it for any purpose.
Aggregated data is considered Non-Personal Information for the purposes of this Privacy Policy. If we do combine Non-Personal Information with Personal Information the combined information will be treated as Personal Information for as long as it remains combined
We do not behaviorally target advertising to children under the age of 13.
Kefi will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Kefi will also retain data collected automatically either generated by the use of the Services or from the Services infrastructure itself (collectively, “Usage Data”) for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Services, or we are legally obligated to retain this data for longer time periods.
Your information, including Personal Information, may be transferred to, and maintained on, computers and/or servers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Kefi will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place unless there are adequate controls in place including the security of your Personal Information, data and other information.
Kefi may disclose your Personal Information in the good faith belief that such action is necessary to:To comply with a legal obligation;
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your mobile device and/or web browser.
As a registered member or account holder of Kefi, you can review and update your profile at anytime by logging-in and visiting your personal account.
In addition, a parent or legal guardian can review or request deletion of any Personal Information we have about their child, or request that there be no further collection or use of their child’s information, by contacting us. We take steps to verify the identity of anyone requesting information about a child, to ensure that the person is in fact the child’s parent or legal guardian, and appreciate your cooperation with those steps. Some of the Services are directed at children under the age of 13, and other parts of the Services are targeted for users of all ages.
If you are a parent or legal guardian and you are aware that your child has created an account that you have not consented to, please contact us so that we can take steps to terminate your child’s account with us. If you are a parent or legal guardian and you are aware that that we have collected Personal Information from your child without your consent, please contact us so that we can take steps to remove that information from our servers.
We may communicate with our registered members and account holders on a regular basis via email. For example, we may use your email address to confirm your request, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional.
However, we do provide you with the opportunity to opt-out of:
We may employ third-party companies and individuals to facilitate the Services (“Service Providers”), to provide the Services on our behalf, to perform Services-related services or to assist us in analyzing how the Services are used.
These third-parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of the Services.
We may use third-party Service Providers to show advertisements to you to help support and maintain the Services.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information
The payment processors we work with are:
The Services may contain links to third-party websites. While we endeavor to work with third-parties that share our respect for user privacy, we are not responsible for the websites or privacy practices of such third-parties. We may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on the Services. Such third-parties may gather information about your visit to the Services or other third-party websites and applications, monitor your access to or market products or services to you, monitor the ads you view, click-on, or interact with, when they were delivered, and the screens and pages that they are on.
We do not endorse these parties, their content, or any products and services they offer. You are responsible for knowing when you are leaving the Services to visit a third-party website or application, and for reading and understanding the terms of use and privacy policy statements for each such third-party.
Please note that a separate privacy policy may apply to third-party services you use to access our content. We strongly encourage you to familiarize yourself not only with this Privacy Policy, but any other privacy policies or agreements that may govern your use of services.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
No data transmissions over the Internet are completely secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us or others over the Internet. You transmit such information at your own risk.
Once we receive your transmission, we make reasonable efforts to ensure the security of our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls or secure server software.
If we learn of a breach of our security system or processes, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services, or providing Personal Information to us through them, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. In the event of a breach, we may post a notice on the Services or send you an email or text at the email address and/or mobile phone number you provided.
YOU MAY HAVE ADDITIONAL RIGHTS TO RECEIVE WRITTEN NOTICE OF SECURITY BREACHES UNDER APPLICABLE LAW OF YOUR JURISDICTION.
You can also help us protect information about you by:
Please read our Terms and Conditions to understand the terms that apply to your use of the Services. By using the Services, you acknowledge that you have read our Terms and Conditions and consent to them. You further affirm your consent by creating an account with us or submitting content or materials to or through the Services.
If you have any questions or concerns about Kefi’s Privacy Policy or data processing, please contact us.
If you are a child (who may be under the age of 13 or 18), please remember to ALWAYS check with your parents or legal guardians before posting contacting us or sending anything to us.
Notwithstanding anything to the contrary and/or the following sections of this Privacy Policy (Legal Basis for Processing Personal Information Under General Data Protection Regulation (GDPR) and/or Your Data Protection Rights Under General Data Protection regulation (GDPR)), the Services are designed for and targeted to United States audiences, and subject only to applicable provisions of the General Data Protection Regulation (the “GDPR”), are governed by and operated in accordance with the laws of the United States. While users from countries other than the United States may access certain of the Services, notwithstanding anything to the contrary and subject only to applicable provisions of the GDPR, we make no representation that the Services are operated in accordance with the laws or regulations of, or governed by, other nations. If you are located outside of the United States, you use the Services at your own risk and initiative and notwithstanding anything to the contrary and subject only to applicable provisions of the GDPR, you, not us, are responsible for compliance with any applicable local and national laws. Please be aware that notwithstanding anything to the contrary and subject only to applicable provisions of the GDPR (if any), any Personal Information and other information you provide to us or we obtain as a result of your use of the Services shall be collected in the United States and/or transferred to the United States and subject to United States law.
Notwithstanding anything to the contrary and subject only to applicable provisions of the GDPR (if any), we make no representation that the Services are operated in accordance with the laws or regulations of any other nations. Notwithstanding anything to the contrary and subject only to applicable provisions of the GDPR (if any), information collected through the Services (including without limitation Personal Information) may be stored and processed in the United States or any other country in which we or our Service Providers maintain facilities. Notwithstanding anything to the contrary and subject only to applicable provisions of the GDPR (if any), our Service Providers may transfer information that we collect about you, including without limitation Personal Information, across borders and from your country or jurisdiction to other countries or jurisdictions, some of which may not have the same data protection laws as your jurisdiction. Notwithstanding anything to the contrary and subject only to applicable provisions of the GDPR (if any), by using the Services and providing us with information directly or indirectly, you consent to the transfer of information (including without limitation Personal Information) to the United States or to any other country in which our Service Providers maintain facilities for processing by us in accordance with this Privacy Policy. Consequently, to the full extent permitted by law, you hereby waive any claims relating to the processing of your Personal Information or other information in accordance with this Privacy Policy that may arise under the laws and regulations that apply to you in or of any other country or jurisdiction.
If you are from the European Economic Area (EEA) and solely to the extent we are subject to applicable provisions of the GDPR, Kefi’s legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.
Kefi may process your Personal Information because:
If you are a resident of the European Economic Area (EEA) and solely to the extent we are subject to applicable provisions of the GDPR, you may have certain data protection rights. Kefi aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.
If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances (subject to the foregoing section of this Privacy Policy, Notice for Internal Users and solely to the extent we are subject to applicable provisions of the GDPR), you may have the following data protection rights:
Please note that the foregoing (i) is subject to the foregoing section of this Privacy Policy, Notice for Internal Users and is applicable solely to the extent we are subject to applicable provisions of the GDPR, and (ii) we may ask you to verify your identity before responding to such requests.
Subject to the foregoing section of this Privacy Policy (Notice for Internal Users) and solely to the extent we are subject to applicable provisions of the GDPR, you may have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on the Services, prior to the change becoming effective and update the “effective date” set forth below in this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
This Privacy Policy is effective as of, and was last updated and posted on, February 1, 2019.
If you have any other questions about our information handling practices, including our practices with respect to children’s Personal Information, or would like further information regarding the Services that are directed to children under 13 years of age, please contact us at:
California Residents – Your Privacy Rights
(As provided by California Civil Code Section 1798.83)
A California resident who has provided Personal Information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed Personal Information to any third-parties for the third-parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California customer, the business is required to provide a list of all third-parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed.
However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy statement) a policy of not disclosing customer’s Personal Information to third-parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of Personal Information and providing a cost free means to exercise that right.
As stated in our privacy policy statement, we do not share information with third-parties for their direct marketing purposes unless you affirmatively agree to such disclosure — typically by opting-in to receive information from a third-party. To prevent disclosure of your Personal Information for use in direct marketing by a third-party, do not opt-in to such use when you provide Personal Information on, to or through the Services. Please note that whenever you opt-in to receive future communications from a third-party, your information will be subject to the third-party’s privacy policies and practices. If you later decide that you do not want that third-party to use your information, you will need to contact the third-party directly, as we have no control over how third-parties use information. You should always review the privacy policies and practices of any party that collects your information to determine how that entity will handle your information.
California customers may request further information about our compliance with this law by contacting us. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.