KYROS INSIGHTS PRIVACY POLICY

LAST MODIFIED: JANUARY 14, 2019

1.1 Introduction and Purpose

This privacy policy (“Privacy Policy”) applies to L2 Ventures LLC d/b/a Kyros Insights (hereinafter “Kyros,” “we”, “us”, or “our”), and our services, website, applications and any sites Kyros may have now or in the future (collectively the “Services”), and outlines our principles for collecting, using and protecting information that we maintain about any person whose personal data is being collected, held or processed by us including without limitation clients and/or site visitors (hereinafter the “Individuals” or “you”). This Privacy Policy, or a revised version of this Privacy Policy, shall be displayed on our website, www.kyrosinsights.com.

By using the Services in any manner, you indicate to Kyros that you have read and accept our Privacy Policy and consent to the data practices, including without limitation the collection and use of your personal data, described in this Privacy Policy. If you do not accept this Privacy Policy or do not meet or comply with the provisions set forth herein, then you may not use the Services.

If required by applicable law, we will seek your express consent to process personal data (i) provided by you and/or (ii) collected during your use of the Services. Any consent shall be entirely voluntary. In the event you do not provide consent to us to process your personal data, then you may not access and/or use the Services.

1.2 Kyros Privacy Policy Statement

Our privacy commitments are fundamental to the way we do business every day. We apply our privacy principles to everyone who has a relationship with us.

  • We will protect your privacy and keep your personal information safe. We minimize personal identifiers or use encryption and other security safeguards to protect Individuals’ data.
  • We will not sell your personal information to anyone, for any purpose.
  • We will fully disclose our Privacy Policy in plain language and make our Privacy Policy readily accessible to you.
  • You have the right to request access to the personal information we have about you.
  • You have the right to demand correction of the personal information we have about you in our systems.
  • You have the right to demand that Kyros discontinues the collection and processing of your personal information.
  • You have the right to demand that Kyros deletes all of your data from our systems.
  • You have the right to choose an alternate provider of similar services. Kyros will facilitate data migration to the alternate provider.
  • You have the right to submit comments or questions regarding this Privacy Policy to the contact information provided in this Privacy Policy.

1.2.1 Data Processing Purposes Specification

We collect de-identified personal information about participants in loyalty programs of our clients. Kyros conducts analysis on loyalty program participants to provide meaningful insight to the operators of loyalty programs about the spending and reward remittance habits of the participants. Kyros provides the Services to clients, so that clients may:

  • Improve financial reporting and decrease financial risk with an accurate understanding of:

    a) loyalty program financial liabilities, and

    b) forecasted Return on Investment (ROI);

  • Fine tune marketing efforts to loyalty program members, in accordance with Individuals’ consent to receive special offers.

We also collect web browsing data from visitors to our web site (kyrosinsights.com) to provide our website managers with insight into what topics, functions and subpages generate more interest than others. We may utilize this analysis to revise website content and update functionality.

1.2.2 Information We Collect

When you use the Services, you may provide Kyros with two main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you browse and use the Services. We collect information from you when you (a) use and/or access the Services, (b) open and/or respond to our emails, (c) contact Kyros, and/or (d) visit any page online that displays our content.

Personal Information You choose to Provide - We may ask for certain personal information from you for the purpose of providing to you content and/or Services that you request. We collect personal information such as your contact information (including name, telephone number, email and address); and/or (ii) preferences and behavior (such as record of comments, responses and questions asked).

De-Identified Personal Information – Kyros’ clients provide de-identified personal information about the participants of their loyalty programs. The personal information is minimized to the extent that Kyros cannot infer the identity of the Individuals whose data is stored in, and/or processed by its information systems. Kyros collects the following data elements on Individuals:

  • Member ID#
    • Tokenized
  • Information of Transactions for the Member ID# which may contain:
    • Transaction Date
    • Type of transaction
    • Value of transaction (points and/or currency).
    • Source of transaction
  • Member Personal Information Attributes which may include:
    • Country of residence
    • Date of birth
    • Gender
      • Whether the program participant has the client’s co-branded credit card and brand (Visa, Mastercard, American Express, etc.) – Yes or No
      • Kyros DOES NOT collect credit card details related to program participants.

Information We Collect Automatically –

  • Web Browsing Activity: We may also collect information that cannot be used to easily identify you, such as information about your computer hardware and software. Like the operators of most web sites, we may use tracking software and similar technology, which automatically collects information about your use of the Services, your computer hardware and software. This information may be used by us for the operation of the Services and to provide general statistics regarding use of the Services. Many commercial web site operators collect this information in similar ways.
  • Cookies: A “cookie” is a tiny data file that resides on your computer, mobile phone, or other device, and allows Kyros to recognize you as a user when you return to our website using the same device and web browser and enables Kyros to collect information about how you use the Services. Information gathered through cookies may include the date and time of visits, the pages viewed, and time spent at using the Service. Cookies allow web site operators to better customize visits to the site to the visitor’s individual preferences. Although most web browsers automatically accept cookies, you can usually change your browser to prevent or notify you whenever you are sent a cookie. If you do not agree to our use of cookies, you should set your browser settings accordingly or not use the Services. Kyros uses cookies and web log files for the following, which may include without limitation (i) to track usage and trends, (ii) to improve the quality of the Services, (iii) to customize your experience and/or (iv) to compile anonymous, aggregated information that allow us to understand how the Services are used. Cookies are categorized by how long they are stored and their function. You may remove or block cookies using the settings in your browser, but in some cases that may impact your ability to use our Services and/or user experience while using the Services. The cookies Kyros uses are as follows:
    • Persistent Cookies: Persistent cookies remain on a visitor’s device for a set period of time specified in the cookie. They are activated each time that the visitor visits the Services that created that particular cookie.
    • Session Cookies: Session cookies are temporary and deleted from your computer when you close your web browser. They allow Kyros to link the actions of a user while using the Services.
    • Strictly Necessary Cookies: Strictly necessary cookies are essential to navigate around the Services and to use its features.
    • Functionality Cookies: Functionality cookies allow Kyros to operate the Services in accordance with your choices, such as ‘remembering’ you in between visits.
  • Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
  • Aggregate: We may collect non-identifying and statistical information about the use of the Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on, system configuration information, and/or other interactions with the Services. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual. We use analytic software to gather statistics and usage trends for product and service improvement purposes. The Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.
  • Other Tracking Technologies: We may supplement information you provide to us with information from other sources, such as information to validate and/or update your address and/or other demographic information. This information is used to maintain the accuracy of information on the Services and for internal analysis. We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further used to track online movements of our users. Clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to your personally identifiable information.
  • Third Party Services: To support the services we provide to you, we may use services hosted by third parties. These services may collect information sent by a browser as part of a web page request, including ‘Internet Protocol’ addresses, browser software, and/or clickstream patterns. If such third-party services collect information, they do so anonymously without identifying individual visitors. However, we may link the information we record using tracking technology to personal information we collect. They may collect and store the same type of information and use it similarly to Kyros, as described above.

1.2.3 How We Use Information Collected

  • operate, maintain and improve the Services;
  • aggregate responses, activity and behavior of Individuals;
  • answer questions and respond to your requests;
  • populate reports and insights for clients;
  • perform analytics and conduct research;
  • send you reminders, support and marketing messages;
  • collect feedback from you about third-party products and/or services;
  • inform you about products, events and/or other promotional purposes;
  • manage our administration of the Services;
  • improve the design and content of the Services;
  • analyze programs, products and services we offer; and
  • use information for other purposes about which we notify you.

The information collected in the aggregate enables Kyros to better understand your use of the Services as well as provide feedback to help companies better understand their products and/or services.

1.2.4 Information Protection

When we collect your personal information, we include it in our information systems for the purpose(s) set forth in this Privacy Policy. We will use reasonable practices to protect your personal information from unauthorized access or disclosure.

  • We limit personal information access to those employees, affiliates and service providers who need it to fulfill our processing purpose(s).
  • We protect information, at rest, during processing, or in transit, using safeguards that comply with applicable Federal, state and international data privacy laws. Kyros has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. Security and data privacy controls may be administrative, physical and technical in nature. We use commercially reasonable measures to secure the Services and protect the information that may be shared over these sites. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We work hard to secure your personal information from unauthorized access to and/or unauthorized alteration, disclosure and/or destruction of information we hold. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Since the internet is not a completely secure environment, Kyros cannot warrant the security of any information you transmit to Kyros or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards; however, Kyros implements and maintains appropriate technical, security and organizational measures to protect personal data against unauthorized or unlawful processing and use, and against accidental loss, damage, destruction, theft or disclosure. Please do your part to help Kyros. You are responsible for maintaining the secrecy of your account information, and for controlling access to emails between you and Kyros, at all times. Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing the Services. We are not responsible for the functionality, privacy and/or security measures of any other organization.

1.2.5 Information Sharing and Disclosure

Service Providers: We may share your personally identifiable information as well as information from tools like log files, and device identifiers and location data (such as usage data, referring/exit pages and URLs, platform types, number of clicks, etc.), with employees, contractors, and/or agents that help Kyros provide the Services to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services. We strive to use commercially acceptable means to protect your personal information. If Service Providers acquire confidential or proprietary information belonging to Kyros or its users, such information is required to be handled in confidence and may not be disclosed to unauthorized third parties. Service Providers who violate our security and safe maintenance of data policies are subject to appropriate discipline including, but not limited to, termination. We will not share your personally identifiable information in ways unrelated to those described in this Privacy Policy without providing you with an opportunity to opt out of such use or otherwise prohibit such unrelated use. Kyros does not sell customer lists or customer information for marketing purposes with unaffiliated third parties.

Compliance with Laws: Kyros will not disclose your personal information to third parties except as set forth in this Privacy Policy and in the following circumstances: (i) to investigate and defend Kyros members against any third party claims and/or allegations and/or otherwise to protect Kyros from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services and/or (v) to protect the security and/or integrity of the Service.

Business Transfers: If we sell or otherwise transfer part or all of Kyros or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.

1.2.6 Your Privacy Rights

Generally. Depending on the situation, Kyros may obtain consent to the collection of personal information in different ways. In the event express consent is required, it will be obtained in writing. Implied consent may be obtained when you approach us to obtain information, inquire about or request Services from us. We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to Kyros, and you can limit the communications that Kyros sends to you. If you visit the Services and volunteer personally identifiable information, you can opt out of receiving notifications, and you may review, modify, update, and/or delete such personally identifiable information by contacting us at privacy@kyrosinsights.com. Please be aware that even after your request for a change is processed, Kyros may, for a time, retain residual information about you in its backup and/or archival copies of its database. Please be aware that we may still email you non-commercial emails related to your account and your transactions through the Services. Following termination of Services, Kyros may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, and/or audit purposes and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide Kyros with requested information, you may not be able to use and/or access all of the Services.

Your California Privacy Rights. Under California Consumer Privacy Act (“CCPA”), California residents are entitled to receive the right to access and obtain a copy of your personal information. You may write us and ask for records of any and all personal information. The CCPA requires businesses to disclose (1) the categories of personal information the business collected about Individuals, (2) the categories of sources from which personal information is collected, (3) the business or commercial purpose for collecting or selling personal information, (4) the categories of third parties with whom the business shares personal information, and (5) the specific pieces of personal information the business has collected about the Individual. Kyros will provide personal data to the requestor within thirty (30) days following confirmation of receipt of the request.

Note: Kyros will honor and respond to personal data access requests from a single individual up to two (2) times per calendar year.

Exceptions: The following exceptions may prevail with respect to fulfillment of data access requests:

  • Kyros may not provide personal data to an Individual, if management determines that we cannot identify the individual in our systems because the data we have has been de-identified to the extent that identification is not possible.
  • Kyros may not provide personal data to an Individual, if the Individual is involved in a civil or criminal proceeding with Kyros.

1.2.7 Service Eligibility and Changes

Children and Minors. Kyros does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected personal information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information, please contact us at privacy@kyrosinsights.com. By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Services.

Changes to Privacy Policy. In general, changes will be made to this Privacy Policy to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Policy at any time, with or without advance notice, so please review it periodically. We will update the ‘Last Modified’ date above and may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. You can determine when this Privacy Policy was last revised by referring to the date it was “Last Modified” above. If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, you will need to stop using the Services. Your continued use of the Services after any modification to this Privacy Policy will constitute your acceptance of such modifications and/or updates.

1.2.8 Data Transfers

Please be aware that our Services are subject to United States laws, including those governing privacy and security of your information. By using the Services, you agree and consent (and represent that you have the authority to provide such consent) to the information collection, use and sharing practices described in this Privacy Policy and understand that the laws of the United States related to the foregoing may differ from those of other countries and may not be as protective as the laws in the country where you reside. Regardless of the laws in place in such countries, we will treat the privacy of your information in accordance with this Privacy Policy.

1.2.9 Other Website and Services

We are not responsible for the practices employed by any websites and/or services linked to and/or from our Services, including the information and/or content contained therein. Please remember that when you use a link to go from our Services to another website and/or service, our Privacy Policy does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on our Service, are subject to such third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your personal information. If you are using a third-party website and/or service and you allow them to access your personal information, you do so at your own risk.

1.2.10 Language and How to Submit Requests or Questions to Kyros

Language. The governing language of this Privacy Policy is English, which shall prevail over any other languages used in any translated document.

Requests or Questions. Individuals may submit data access requests, questions about this Privacy Policy or general privacy feedback to Kyros, by sending email to: