Privacy policy.
Kinship U.S. Privacy Policy
This document discloses the privacy practices for Kinship ("Privacy Policy"). As part of the normal operation of Kinship’s app, website, software and services (the “Services”), we collect certain information about you. In general, we only share your personal information with third parties under very narrow circumstances mostly to provide services to you.
This Privacy Policy describes the information we collect about you, how Kinship may use such information, and what may happen to that information. By accepting the Terms of Service (located at: https://www.heykinship.com/terms-of-service), you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy and applicable law. This Privacy Policy is incorporated into and subject to the terms of the Kinship’s Terms of Service.
1. Minors. If you are a minor (under the age of 18), you may not use the Services.
2. Information We Collect.
(a) Your Registration Information. To fully use our Services, you will need to provide us with your contact information and certain other personal information.
(b) Your Content. Our Services allow you to link, upload and store your information, including without limitation, files, documents, messages, comments and photos, collaborate with others and share your information with others. To make that possible, we store, process, and transmit your content as well as information related to it.
(c) Your Usage of Our Services. We automatically track certain information about you based upon your use of our Services. We use this information to conduct internal research on our users' demographics, interests, and behavior to better understand and serve our users. This information is compiled and analyzed on an aggregate anonymized basis. This information may include the URL that you just came from, which URL you next go to, what browser you are using, and your IP address, among other things.
(d) Cookies. Cookies are small files that can be used to track a user's steps or automatically generate a user's password. Some features of our Website may only be available through the use of a cookie. Among other things, cookies allow you to enter your password less frequently during a session. Cookies can also help us provide information which is targeted to your interests. Cookies are stored on your hard drive. Most, but not all, cookies are automatically deleted at the end of a session. You may decline our cookies if your browser permits, although your use of the Site may then be restricted (as noted above).
(e) Your Correspondence. If you send us e-mails, letters or other personal correspondence, or if other users or third parties send us correspondence about your activities using the Services, we may collect such information into a file specific to you.
3. Our Use of Your Information.
(a) Verification. We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services.
(b) Administrative Notices, etc. We use your e-mail address, your mailing address, and phone number to contact you regarding administrative notices, new product offerings, and communications relevant to your use of the Services. In addition, we use the information we collect to enhance the safety and security of our products and Services and to verify your identity and prevent fraud or other unauthorized or illegal activity.
(c) We also collect information from and about the devices you use to access the Services. This includes things like IP address, the type of browser and device you use, the webpage you visited before you visited our site. Your device may also transmit location information to the Services.
(d) Recommendations. We collect information related to how you use our Services, including actions you take in your account (such as sharing, editing, viewing and moving files and folders). Our software uses your personal information to better understand your use of the Services and to provide certain recommendations to you in order to enhance your use of the Services.
(e) Billing and Support. We use your address and billing information to bill you and provide associated support.
(f) Dispute Resolution. We use information in the file we maintain about you, and other information we obtain from your current and past activities on the Site, to resolve disputes, troubleshoot problems, and enforce our Terms of Service.
4. Our Disclosure to Third Parties. We do not sell any personally identifiable information about you to any third party. Our practices are consistent with industry standards to protect your privacy. We cannot, however, promise that your personally identifiable information or private communications will remain private. For example, third parties may unlawfully intercept or access transmissions or private communications on our Website. The following describes some of the ways that your personally identifiable information may be disclosed.
(a) Investigations. We may disclose any information about you to law enforcement or other investigatory officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of activity that violates Kinship’s policies, is illegal, or may expose us to legal liability.
(b) Third-Party Service Providers. We may use third-party service providers to assist us in providing the Services. We impose contractual restrictions on the use by our service providers of information concerning you, and we do not permit service providers to sell your information to other third parties.
(c) Business Transfers. If ownership of all or substantially all of Kinship’s business changes, Kinship undertakes a corporate reorganization, or if some or all of Kinship’s assets are purchased or transferred, you expressly consent to Kinship’s transferring your information to the new owner, successor entity, or asset purchaser or transferee.
5. Disclosures You Make to Third Parties. Kinship does not control the privacy policies of third parties. When you disclose information to third parties on Kinship (or any other website) about yourself, you are subject to the privacy policies of that third party. It is your responsibility to find out about the privacy policy of any such third parties.
6. Additional Limits on Use of Your Google User Data. Notwithstanding anything else in this Privacy Policy, if you provide Kinship access to the following types of your Google data, Kinship’s use of that data will be subject to these additional restrictions:
(a) Kinship will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web and mobile app relationship assistant that allows users to store, read, and process information about their interpersonal relationships and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
(b) Kinship will not use this Gmail data for serving advertisements.
(c) Kinship will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for Kinship’s internal operations and even then only when the data have been aggregated and anonymized.
7. Retention of Your Information. Kinship will retain information you store on our Services for as long as your account exists or as long as we need it to provide you with the Services. If you delete your account, your credentials and personal information will be immediately erased. Residual data may take up to 30 days to be removed entirely and includes cached and temporary data.
However, Kinship may retain information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
8. Changes to Privacy Policy. Kinship reserves the right at any time to make changes, modifications, alterations and/or additions to this Privacy Policy. Kinship will notify you of any changes to this Privacy Policy by providing you with notice of such changes at your email address that you provided the Site as your primary contact information.
9. Questions about Privacy Policy. If you have any questions regarding Kinship’s Privacy Policy, please contact us at support@kinshipsystems.com.
10. Effective Date of Privacy Policy. The effective date of this Privacy Policy is [date].
11. How We Protect Your Personal Information. Kinship uses commercially practicable means to protect your personal information from being improperly accessed by third parties at any time, including without limitation, encryption processes in connection with financial information.
12. Governing Law. This Privacy Policy shall be governed by the laws of the State of New York without regard to its conflict of laws principles.
Kinship EU Privacy Policy
Who are we?
At Kinship Systems LLC ("Kinship", "we", "us", "our") we are committed to protecting and respecting your privacy, whilst striving to provide you with the very best user experience. We work very hard to keep your information safe and we want our website, our app and our services to be safe and enjoyable for everyone. We also recognise that it is important for you to understand how we use your personal information.
As part of the normal operation of Kinship’s app, website, software and services (the “Services”), we collect certain personal information about you.
This Privacy Policy (and any other documents referred to in it) describes the personal information we collect, how Kinship may process and use such information, and what may happen to the information of the users of our Services ("customers"), people who are considering using our Services, contacts of our customers that are input by our customers to the Services ("contacts"), and other visitors to our website. We aim to be transparent about our data practices regarding the personal data that we may collect, use, maintain and otherwise process. Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.
We have a legal duty to protect personal information that we collect under the UK Data Protection Act 2018 (the “DPA”) and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”) and the local legislation in each territory that we offer our Services. For the purpose of the DPA and GDPR, we (Kinship Systems LLC) are the data controller (in other words, the organisation that determines how your personal information is used). Our contact details are set out in part 13 of this Privacy Policy below.
This website is not intended for minors (under the age of 18) and we do not knowingly collect personal data relating to minors. If you are a minor, you may not use our Services.
2. What personal data do we collect about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The personal data that we collect from or about you includes the following:
(a) Your Registration Information when you sign up to use our Services. To fully use our Services, you will need to provide us with your name, email address, gender, payment details (such as billing address and card details) which will be processed by our third party payment provider, password and account details. In addition, there may be some optional functionality of the Services which you can access if you provide additional information such as your postal address, your date of birth, your current job role and employer and your employment history. Disclosure of this data is entirely optional and you will be able to remove it from the Services at any time.
(b) Your Content. Our Services allow you to link, upload and store information about your contacts, such as their name, contact details, their likes and dislikes, including without limitation, files, documents, messages, comments and photos ("Content"). Our Services may also allow you to collaborate with others and share your information with others. Essentially, we process any personal data that you input or share when using our Services. This may include the appointments in your Google calendar if you decide to link this to your account with Kinship. We think it's important to tell you that we can't and don't access your Content. By way of example, if you include the information of 100 contacts, we will know that you have 100 contacts, but we won't know (or have access to) their names, email addresses or any other information that you input to the Services about your contacts.
(c) Your Usage of our Services. Where you have given us permission to do so we track certain information about you based upon your use of our Services. We use this information to conduct internal research on our users' demographics, interests, and behaviour to better understand and serve our users. This information is compiled and analysed on an aggregate anonymised basis (and as mentioned above, we don't know anything about your Content, just that you have input something)). This information may include the technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, device types, operating system and information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed, searched for or purchased, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse the website
(d) Your Correspondence and Interactions with Us. If you send us e-mails, letters or other personal correspondence or provide us with any information on our website of via the Services, or if other users or third parties send us correspondence about your activities using the Services, we may collect such information into a file specific to you. We may also process your social media handle/username details if you engage with us on social media or fill in a survey.
3. How do we collect personal data about you?
We may collect personal data in a variety of ways, but essentially it is when you give it to us, which includes when you:
(a) Create an account with us
(b) Access our website
(c) Ask us to provide you with Services and use our Services
(d) Sign up to our newsletter or to receive marketing communications from us
(e) Contact our customer services team
(f) Fill in a survey
(g) Engage with us on social media (for example by mentioning/tagging us or by contacting us directly)
(h) Leave comments on our website or interact with other functionality of the Services where you provide us with data
If you are a contact of one of our customers, we receive your personal data when a customer gives it to us however we can't access that data to find out anything about you and we will never get in touch with you.
In addition, when using the Services you may provide us with personal data of your contacts (such as your business contacts, family and friends). We ask that you don't provide any sensitive information about contacts without either making the contact non-identifiable (i.e. so that we can't tell who they are) or notifying them that you are doing so. Please note that it is your responsibility to notify your contacts that we shall be processing their personal data and to direct them to this Privacy Policy on request.
To the extent that you use our Services for business use (i.e. as part of your job or to store information about work contacts not personal contacts) or if you otherwise assume the role of a data controller, then you will be responsible for complying with your own obligations under applicable data protection legislation.
4. How we use your personal data and our justifications for doing so
| How and why we use your personal data | What is our legal justification for processing your personal data |
|---|---|
| To provide you with the information and Services that you request or purchase from us (i.e. to complete certain tasks, processes, and to communicate with you regarding those Services that you purchase or request from us and respond to your questions and comments). | We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data in relation to an order for our Services and providing you with our Services. Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to measure customer satisfaction and troubleshoot customer issues or deal with your specific queries on social media). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights. |
| To measure how satisfied our customers are and provide customer service (including troubleshooting in connection with your use of the Services or when you ask us questions on social media). | |
| We may also recommend new ways to enjoy our Services to you. | |
| We may use your personal data to tell you about relevant products/services and offers ("marketing"). | We can usually only use your personal data to send you marketing messages if we have consent from you to do so or, in some cases, we can rely on a legitimate interest. You can ask us to stop sending you marketing messages by contacting us at any time at the contact details set out at part 13 of this Privacy Policy below. |
| To find out more about the users of our services as a whole (and not to find out more about you as an individual) to ensure that the Services that we offer are most likely to interest our customers |
We have a legitimate interest to make sure that we are providing you with the information that we think is most relevant to you.
Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights. |
| To monitor the use of our Services and ensure that it they are presented in the most effective and relevant manner for you and your device. | We have a legitimate interest to ensure that our Services work properly and that our products and services are high quality and efficient. |
| We may record calls you make to us and will use this data for training and quality assurance purposes (where your call is recorded we will tell you in advance). | We use data in this way for a variety of reasons. It may be pursuant to a legal obligation and it is also in our legitimate interests to review call recordings for quality control purposes. |
| To ensure that the personal and financial information that you provide to us is accurate | In some cases we will use your personal data because it's necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud or ensuring security of the site) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights. |
| To detect, investigate, report, and seek to prevent financial crime or other illegal activity | |
| To manage risk for us and our customers. | |
| To fulfil our legal and compliance-related obligations | |
| For administrative or business purposes, where you contact us for a particular reason other than those set out above, such as to report problems with our Services. |
We have a legitimate interest to respond to your contact for the purposes of administering our business.
Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights. |
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. How do we share your personal data?
Whenever we share your personal data, we put safeguards in place which require these other organisations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes unless you have given us your consent to do so. We do not sell your personal data to any third-party.
The following describes some of the ways that your personally identifiable information may be disclosed.
(a) Third-party service providers. We may use trusted third-party service providers to assist us in providing the Services. When you purchase our Services, the services provided by these third-party service providers include website and database hosting and our third-party payment platform provider. It is in our legitimate interests as a business to work with these service providers since we may not have the capabilities to provide these services ourselves. In each case, we will ensure that the service provider is only allowed to use your personal data in order to provide the services to us and for no other purpose.
(b) Investigations or to prevent crime and otherwise comply with laws. There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies, regulatory bodies or public authorities in order to prevent or detect crime. We will only ever disclose your personal data to these third parties to the extent we are required to do so by law.
(c) Business transfers or a change to our group structure. If ownership of all or substantially all of Kinship’s business changes, Kinship undertakes a corporate reorganization, or if some or all of Kinship’s assets are purchased or transferred, during any such process we may share your data with other parties. We will only do this if they agree to keep your data safe and private. If a change to our group happens, then other parties may use your data in the same way as set out in this notice.
(d) Other professional services. We also work with carefully selected third parties who assist us in providing you with a positive customer experience.
6. Disclosures of your personal data that you make to third-parties.
When you use our Services you are able to share your personal data with third parties. Kinship does not control the privacy policies of third parties and when you disclose information to third parties using our Services about yourself, you are subject to the privacy policies of that third party. It is your responsibility to make sure that you are happy with the privacy policy of any such third parties before you transfer them your personal data.
7. Retention of Your Personal Data
We will keep your personal information for limited and appropriate periods of time only and the applicable retention periods will always be linked to our purposes for processing your personal information. This means that the retention periods will vary according to the type of personal information.
For example, we will retain personal data that you store on our Services for as long as your account exists or as long as we need it to provide you the Services. If you end your subscription to use the Services, in order to provide continuity of the Services in case you decide to renew your subscription, we will retain the data related to your account (including your Content) for a period of one year (although if you do not renew your subscription within one year, we cannot guarantee this continuity). If you delete your account (which you can do from the app in your account menu), we will immediately erase your credentials and personal information. Residual data may take up to 30 days to be removed entirely and includes cached and temporary data.
However, if necessary, we may retain this information to comply with our legal obligations, resolve disputes, or enforce our agreements. Still, there will be no way to offer you continuity of the Services if you decide to rejoin the Services. You can also export all of your Content to a ZIP file before you decide to delete your account.
8. Security of Your Personal Data
We take the security of your information very seriously and have put physical, technical, operational and administrative strategies, controls and measures in place to help protect your personal information from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice, such as encryption processes in connection with financial information. We will always keep these under review to make sure that the measures we have implemented remain appropriate.
9. Where we Transfer and Store Personal Data
As we are based in the US and your data is processed on our US based servers, we will transfer your personal data outside of the UK, Switzerland and the European Economic Area (EEA) to the US, where local laws do not provide legal protection for your information in the same way as is applicable in the UK, Switzerland or the EEA. We will safeguard and process your personal data in accordance with the standards required of a data importer in the European Commission's Standard Contractual Clauses which can be found as the Annex here https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32004D0915&from=EN.
Whenever we send (or permit a third party to send) your personal data outside of the UK, Switzerland and the EEA, we will make sure that we take steps necessary to protect your data as required by applicable laws. For example, we may require the overseas recipient to enter into particular contract terms.
If you would like more information on how we protect your personal data when it is transferred outside of the UK, Switzerland and EEA, please use the contact details set out in part 13 of this Privacy Policy below.
10. Your rights in your personal information
You have certain rights in respect of the personal data that we hold about you. Details of these rights are set out below. To exercise any of these rights, please use the contact details set out in part 13 of this Privacy Policy below.
You have the right:
to ask us not to use your personal data for direct marketing purposes;
to ask to see what personal data we hold about you and to find out about the way that we process the data (and in some circumstances, you can ask us to provide a copy to a third party);
to ask us to correct or update any personal data which is inaccurate;
to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to use it;
to ask us to temporarily stop using your data if you don't believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it; and
not to be subject to decisions made solely on the basis of 'automated processing' (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.
11. Changes to this Privacy Policy.
Kinship reserves the right at any time to make changes, modifications, alterations and/or additions to this Privacy Policy – for example, if we need to reflect changes to the way that we use your personal information. Any changes we make in the future will be posted on our websites and, where appropriate, notified to you by e-mail. You should check back frequently to see any updates or changes to our Privacy Policy.
This policy was last updated on October 5, 2023.
12. Contacting us and Questions about this Privacy Policy.
We are very keen to hear from you, including if you have any questions, concerns, comments, requests or complaints regarding this Privacy Policy, our Services and/or our use of your personal information. You can contact us at any time by emailing support@kinshipsystems.com.