Kazoo Technology (Hong Kong) Limited is committed to protecting and respecting your privacy. Welcome, and thank you for your interest in Kazoo Technology (Hong Kong) Limited ("Kazoo", "we," or "us"), our web site at kazootechnology.com (the "Site"), our downloadable mobile application (the "App") and other services provided by us and on which a link to this Privacy Policy is displayed, and all other communications with individuals through written or oral means, such as email or phone (collectively, together with the Site and App, our "Service").
This Privacy Policy ("Policy") describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information. By visiting the Site, or by using the App, you accept the privacy practices described in this Policy.
This Policy is incorporated into, and is subject to, the Kazoo Terms of Service.
1. Definitions
"User" means an individual who navigates on our Site or uses our App or interacts with us through other communications methods.
"Personal Data" means any information relating to an identified or identifiable natural person.
2. User Data
"User Data" means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the App stores within the Service.
3. The Information We Collect on the Service
In order to provide a better service to you, we collect different types of information from or through the Service.
User-Provided Information
When you use our Service, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on our Site or App. For example, when you register for an Account, check out on our Site or send us customer service-related requests.
"Automatically Collected" Information
When a User uses the Service, we may automatically record certain information from the User's device by using various types of technology, including cookies, "clear gifs" or "web beacons." This "automatically collected" information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a User's interaction with email messages, such as whether the User opens, clicks on, or forwards a message. This information is gathered from all Users.
4. How We Use the Information We Collect
We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:
Operations
We use the information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process User Data solely in accordance with the directions provided by the applicable User.
Improvements
We use the information to understand and analyze the usage trends and preferences of our Users, to improve the Service, and to develop new products, services, feature, and functionality. Should this purpose require Kazoo to process User Data, then the data will only be used in anonymized or aggregated form.
Communications
We may use a User's email address or other information to contact that User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the User Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under "Your Choices".
Cookies and Tracking Technologies
We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User's information so that the User will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service.
Analytics
We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users' and Visitors' activity on our Site. We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
5. To Whom We Disclose Information
Except as described in this Policy, we will not intentionally disclose the Personal Data or User Data that we collect or store on the Service to third parties without the consent of the applicable User. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
Service Providers
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or User Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
Non Personally Identifiable Information
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Users' interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
Law Enforcement, Legal Process and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
Change of Ownership
Information about Users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.
6. Your Choices
Access, Correction, Deletion
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the "How to Contact Us" section. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Kazoo's Data Protection Officer at privacy@kazootechnology.com. You also have a right to lodge a complaint with data protection authorities.
Navigation Information
You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
Opting out from Commercial Communications
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the "How to Contact Us" section.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
7. Third-Party Services
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators' policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties' privacy and security policies before providing them with information.
8. Third Party Cookies
We may use third-party web analytics services on our Service to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies described in this Policy to collect usage and device data may be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Service, including by noting the third-party website from which you arrive to our Site, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the official Google Analytics Opt-out Browser Add-on.
9. Cookies Policy
Cookies are pieces of code that allow for personalisation of the overall experience on a website by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes.
We use the following types of cookies:
Strictly Necessary Cookies
These cookies are essential in order to enable you to navigate the Service and use its features. Without these cookies, services you have asked for cannot be provided.
Performance Cookies
These cookies collect anonymous information on how people use the Service. For example, we may use Google Analytics cookies to help us understand how customers arrive at our Service, browse or use our Service and highlight areas where we can improve such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not include personal information from which an individual can be identified.
Functionality Cookies
These cookies remember choices you make such as the country you visit our Service from, language and search parameters. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and relevant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Behaviourally Targeted Advertising Cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator's permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
10. Minors and Children's Privacy
Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at privacy@kazootechnology.com and request that we delete that child's Personal Data from our systems.
The Service is not intended to be used by minors, and is not intended to be used to post content to share publicly or with friends. To the extent that a minor has posted such content on the Service, the minor has the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as indicated in the "How to Contact Us" section. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.
11. Data Security
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the "How to Contact Us" section.
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
12. Data Retention
We only retain the Personal Data collected from a User for as long as the User's account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
- The contents of closed accounts are deleted within 3 months of the date of closure;
- Backups are kept for 3 months;
- Billing information is retained for a period of 7 years as of their provision to Kazoo in accordance with the Hong Kong accounting and taxation laws.
13. Settings
Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.
14. Data Transfer
We may transfer, process and store Personal Data we collect through the Services in centralized databases and with service providers located in the U.S. The U.S. may not have the same data protection framework as the country from which you may be using the Services. When we transfer Personal Data to the U.S., we will protect it as described in this Privacy Policy.
If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your User Data and Personal Data outside of those regions to the United States for storage and processing by our service providers listed in the Kazoo Terms of Service. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to the U.S. Also, we may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
15. Data Controller and Data Processor
Kazoo does not own, control or direct the use of any of the User Data stored or processed by User via the Service. Only the User is entitled to access, retrieve and direct the use of such User Data. Kazoo is largely unaware of what User Data is actually being stored or made available by a User to the Service and does not directly access such User Data except as authorized by the User, or as necessary to provide the Service to Users.
Because Kazoo does not collect or determine the use of any Personal Data contained in the User Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, Kazoo is not acting in the capacity of data controller in terms of the European Union's General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter "GDPR") and does not have the associated responsibilities under the GDPR. Kazoo should be considered only as a processor on behalf of its Users as to any User Data containing Personal Data that is subject to the requirements of the GDPR. Except as provided in this Privacy Policy, Kazoo does not independently cause User Data containing Personal Data stored in connection with the Service to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on behalf of Kazoo in connection with Kazoo's provision of Services to Users. Such actions are performed or authorized only by the applicable User.
The User is the data controller under the Regulation for any User Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.
Kazoo is not responsible for the content of the Personal Data contained in the User Data or other information stored on its servers (or its subcontractors' servers) at the discretion of the User nor is Kazoo responsible for the manner in which the User collects, handles disclosure, distributes or otherwise processes such information.
16. Changes and Updates to this Policy
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
17. How to Contact Us
Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at privacy@kazootechnology.com. If you have any concerns or complaints about this Policy or your Personal Data, you may contact Kazoo's Data Protection Officer by email at privacy@kazootechnology.com.
