Kyros Insights Privacy NOTICE
Last Modified: July 19, 2021

1.1   Introduction and Purpose

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.

1.2   Kyros Privacy Notice 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 Notice in plain language and make our Privacy Notice 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 Notice to the contact information provided in this Privacy Notice.

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:
    1. loyalty program financial liabilities, and
    2. 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 (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.

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
      • Kyros DOES NOT collect personal identifiable information (e.g. name, social security numbers, credit card numbers)
    • 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

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:

  • 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 Notice. 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. Kyros uses 256- bit AES encryption for data at rest and SSL with 128-bit or higher AES encryption for data in transit.

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             Who We Share Your Information With

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.

1.2.6             Your Privacy Rights

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:

  1. A completed notarized written notice indicating that you have authorization to act on the consumer’s behalf signed by you and the consumer.
  2. If you are a business, proof that you are registered with the appropriate Secretary of State to conduct business in California.

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.

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 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.

1.2.8             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 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.

1.2.9              Other Jurisdictions

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.

  • Canada. Personal information maintained and processed by us and our affiliates and third-party service providers in the U.S. and other foreign jurisdictions may be subject to disclosure pursuant to a lawful access request by U.S. or foreign courts or government authorities. We will not provide your information to third parties for marketing purposes without your prior consent. For more information about our privacy practices; to access, update or correct inaccuracies in your personal information; or if you have a question or complaint about the manner in which we or our service providers treat your personal information, please contact us as set forth in the Contact Us section of our Privacy Notice.
  • European Economic Area (EEA) and the United Kingdom (UK). Transmission Of Information To Other Countries. Kyros is located in the United States. The Services are hosted in, provided from the United States, and intended for those visiting the United States. Our service providers and other third parties you may interact with in connection with our Services may be located in the United States and other countries around the world. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. To the extent personal information is collected and subsequently transferred out of the EEA, the transfer will take place consistent with:
     
    • The Standard Contractual Clauses. We transfer, in accordance with Article 46 of the General Data Protection Regulation (GDPR), personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.
    • Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding, enforceable commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.
    • Complaints. If you are a resident of the EEA, and believe we process your information in scope of the GDPR you may direct your questions or complaints to the Office of the Data Protection Commissioner. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. To exercise your privacy rights set forth in this Privacy Notice, you may contact us as set forth in the Contact Us section of our Privacy Notice.
  • Nevada. This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing customers, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by emailing us at privacy@kyrosinsights.com or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: AGCinfo@ag.nv.gov
  • Texas. If you have a complaint, first contact us by visiting our Site at https://www.kyrosinsights.com. If you still have an unresolved complaint regarding the company’s money transmission or currency exchange activity, please direct your complaint to the Texas Department of Banking: 2601 North Lamar Boulevard, Austin, TX 78705-4294; 1-877-276-5554 (toll free); dob.texas.gov
  • Virginia. This Section is only applicable to you if you are a resident of the state of Virginia in the US (“Virginia Residents”).   If you have a complaint, first contact us by visiting our Site at https://www.kyrosinsights.com or contacting as set out in our Contact Us section below. We will respond within 45 days of receipt of your request, and such time may be extended for an additional 45 days if it is reasonably necessary. We will notify you of any extension within the initial 45-day period. If you are not satisfied with our responses, you have the right to appeal. We will respond within 60 days of receipt of your appeal. If you still have an unresolved complaint, please direct your complaint to the Virginia Attorney General at service@oag.state.va.us or call (804)786-2071.
  • Vermont. In accordance with Vermont law, we will not share information we collect about you with companies outside of Kyros except as required or permitted by law. For example, we may share information to service your accounts, complete requested transactions, or to provide rewards or benefits to which you are entitled.
  • California – California Consumer Privacy Act (“CCPA”). This Section is only applicable to you if you are a resident of the state of California in the US (“California Residents”) and only applies to personal information for which Kyros is a “Business” (as defined in the CCPA), but does not apply to personal information we collect from you in the course of our provision of services to you where you are an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. It applies to personal information we collect from California Residents on or through our Services and through other means (such as information collected offline or in person).

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

The Types of Information We Collect section describes the personal information we may have collected about you, including the categories of sources of that information. We collect this information for the purposes described in the Our Use of Your Information section. We share this information as described in the Sharing Of Information section. Kyros uses cookies, including advertising cookies, as described in our Cookie Policy.

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 privacy@kyrosinsights.com 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.

  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Government entities
  • Internet service providers
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and banks
  • Product and service fulfillment companies
  • Social media platforms & networks

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Advertising networks
  • Affiliates or subsidiaries
  • Business partners
  • Data analytics providers
  • Government entities
  • Internet service providers
  • Operating systems and platforms
  • Other Service Providers
  • Payment processors and banks
  • Product and service fulfillment companies
  • Social media platforms & networks

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.

  • Affiliates or subsidiaries
  • Data analytics providers
  • Government entities
  • Internet service providers
  • Operating systems and platforms
  • Other Service Providers
  • Social media platforms & networks

Professional/employment information – this may include occupation and professional references.

  • Government entities
  • Other Service Providers

Education information – such as information contained in education records.

  • Government entities
  • Other Service Providers

 

1.2.10           Contact Us to Submit Requests or Questions to Kyros

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.

privacy@kyrosinsights.com.

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.