Kyros Insights Privacy NOTICE
Last Modified: July 19, 2021
This Privacy Notice (“Privacy Notice”) 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 Notice, or a revised version of this Privacy Notice, 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 Notice and consent to the data practices, including without limitation the collection and use of your personal data, described in this Privacy Notice. We reserve the right to refuse service to anyone for any reason at any time.
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.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
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 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:
We also collect web browsing data from visitors to our web site (www.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.
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:
Information We Collect Automatically
General Use. We use information collected as described in this Privacy Notice to provide you with the Services and/or the information and/or content that you have requested, and, in some cases, to contact you about our products, features and/or other services. We also use the information collected to take the following actions:
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.
When we collect your personal information, we include it in our information systems for the purpose(s) set forth in this Privacy Notice. We will use reasonable practices to protect your personal information from unauthorized access or disclosure.
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.
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 Notice 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 Notice 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.
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. You can make the following choices regarding your personal information:
Access To Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. We will provide this information in a portable format, if required. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
Changes To Your Personal Information. We rely on you to update and correct your personal information. Our Sites allow you to modify or delete your account profile. If our Sites do not permit you to update or correct certain information, you contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
Deletion Of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law, and as described in this Privacy Notice. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
Revocation Of Consent. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
Please address written requests and questions about your rights as set out in our Contact Us section below.
Note that, as required by applicable laws, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request:
If we do not receive both pieces of information, the request will be denied.
Retention of Your Personal Information. Please be aware that even after your request for a change is processed, Kyros may, for a time, retain residual information about you and may still email you non-commercial emails related to your account and your transactions through the Services. Following termination of Services, Kyros may retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice to a user. We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if a user chooses not to provide Company with requested information, a user may not be able to use and/or access all of the Services. User can request further details of retention periods for different aspects of your personal data by contacting us.
Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.
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 email@example.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 Notice. In general, changes will be made to this Privacy Notice to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Notice 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 Notice was last revised by referring to the date it was “Last Modified” above. If you disagree with any changes to this Privacy Notice and do not wish your information to be subject to the revised Privacy Notice, you will need to stop using the Services. Your continued use of the Services after any modification to this Privacy Notice will constitute your acceptance of such modifications and/or updates.
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 Notice 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.
Personal information that you submit through the Services may be transferred to countries other than where you live. We also store personal information locally on the devices you use to access the Services. Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. The following provisions may apply to you depending on where you are located.
How We Collect, Use, and Disclose your Personal Information
Under the CCPA and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights with respect to information we have collected about you that constitutes personal information under the CCPA
You also have certain rights regarding your information as described in the section Your Privacy Rights above. and you have the right to not be discriminated against for exercising these rights.
To exercise your data protection rights California residents contact us at firstname.lastname@example.org If you have questions, please contact us as described in the Contact Us section in our Privacy Notice. You may be required to provide additional information necessary to confirm your identity before we can respond to your request, and we will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within 45 days of receipt of your request, but if we require more time (up to an additional 45 days) we will notify you of our need for additional time. For requests that we not sell your information we will comply with your request within 15 days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.
For requests for a copy of the personal information we have collected during the 12 months prior to your request we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if (1) the information is necessary for us to (a) complete a transaction for you or otherwise perform a contract; or (b) detect, protect against, or prosecute security incidents, fraud or illegal activity; (2) we use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and (3) we are required to retain the information to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.
Selling Information. We do not sell your information for monetary consideration, and we do not disclose your information for other valuable consideration. If, in the future, we enter into arrangements that fall within the definition of a “sale” under the CCPA, we will update this Privacy Notice and our compliance with the CCPA.
During the past 12 months we have collected the following categories of information about California residents from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. This includes information about Site visitors, registered users, employees, vendors, suppliers, and any other person interacting with us either online or offline. Not all information is collected about individuals. For instance, we may collect different information from applicants for employment than from customers.
Categories of Personal Information That We Collect
To Whom We Disclose Personal Information for Business Purpose
Identifiers – this may include name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, social security number, driver’s license number, passport number, or other similar identifiers.
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Network activity data– this may include internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.
Professional/employment information – this may include occupation and professional references.
Education information – such as information contained in education records.
If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
Attn: Privacy Team
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.