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This Privacy Policy describes how Kit, Inc.(“Kit,” “we,” or “us”) collect, use, disclose, and otherwise process information about creators and others who obtain services from us. This Privacy Policy applies to information we collect when you access or use our websites and services (collectively, our “Services”) and when you otherwise interact with us, such as at events, through our customer support channels, or on social media. We may provide different or additional notices of our privacy practices for certain offerings, in which case those notices will supplement or replace the disclosures in this Privacy Policy. Note that this policy does not apply to our processing of personal information about subscribers to our creators’ newsletters. If you are a creator and interested in learning about how we process personal information about your subscribers, please read our Data Processing Addendum.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
The information we collect about you depends on how you interact with us. In this section, we describe the categories of information we collect and the sources of this information.
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information directly from you when you create an account, make a purchase, fill out a form, submit or post content through our Services (including newsletters and other user-generated content), sign up for marketing communications from us, request customer support, or otherwise communicate with us. The types of information that we collect directly from you include your name, email address, phone number, username, profile photo, date of birth, gender, title, and any other information you choose to provide. If you make a purchase from us, we work with a third-party payment processor to process your payment information.
Information We Collect Automatically
We automatically collect information about your interactions with us or our Services, including:
Information We Collect from Other Sources
We obtain information from other sources. For example, we may collect information from identity verification services, data brokers, advertising networks, data analytics providers, mailing list providers and third-party user login authentication services such as Gmail, Facebook, etc.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.
We use the information we collect to provide, maintain, and improve Services for our creators.
We also use the information we collect to:
We engage others to provide analytics services, serve advertisements, and perform related services across the web and in mobile applications. To do this, Kit and these partners may use cookies, pixels, SDKs, and similar technologies to collect information about your use of our Services and other websites and mobile apps, including your device identifiers, IP address, web browser and mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, order information, items added to cart, and conversion information. This information is used to deliver advertising targeted to you on other companies’ websites and mobile apps, understand the effectiveness of this advertising, analyze and track data, determine the popularity of certain content, and better understand your activity. You can opt out by visiting https://preferences-mgr.truste.com/.
In addition to ad targeting activities that rely on cookies and similar technologies, we work with advertising partners to translate other identifiers, such as your email address or phone number, into a unique identifier (called a hashed value) that such partners can then use to show ads that promote Kit that are more relevant to you across the web and in mobile apps.You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices or www.youronlinechoices.eu (if you reside in Europe).
We disclose information about you as described in the Targeted Advertising and Analytics section above and in the following scenarios:
We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.
We store personal information associated with your account for as long as your account remains active. If you close your account, we will delete personal information related to your account within 30 days. We store other personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.
Account Information
You can access, correct, and delete certain information stored within your Kit account at any time by logging in and navigating to the settings menu.
Cookies and Similar Tracking Technologies
Kit uses cookies and similar tracking technologies, as described above. You can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect some of the functionality of our Services, such as maintaining your session across different pages of our websites.
Communications Preferences
You may opt out of receiving text messages or promotional emails from Kit by following the instructions in those communications or by managing your notifications in your account settings menu. If you opt out, we may still send you non-promotional emails, such as those about your account, subscribers, and purchases.
Individuals Residing in California and other U.S. States
Some U.S. states have enacted privacy laws that grant their residents certain rights and require specific disclosures (“State Privacy Laws”). While Kit generally falls below the thresholds to be subject to these laws, we nevertheless provide the information below in the interests of providing transparency to our Creators and to the extent the State Privacy Laws apply to Kit. To the extent that the California Consumer Privacy Act (CCPA) applies, this section also serves as our California notice at collection. Note that when we process the personal information of subscribers to your newsletters, we do so as a processor to you and subject to our Data Processing Addendum and not this Privacy Policy.
Additional Disclosures
Our Privacy Policy explains how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices. As required by certain State Privacy Laws, we use the tables below to explain this same information.
Use and Disclosure of Personal Information for Business Purposes
| Category of Personal Information | Categories of Recipients | Use of Personal Information |
| • Identifiers (such as name, phone number, email address, username) • Demographic data (such as gender) • Commercial information (such as records of services purchased and purchase history) • Internet or other electronic network activity information (such as browsing history and information regarding interactions with our Services) • Audio information (such as call recordings) • Professional or employment information (such as job title, employer) • Inferences (such as approximate location inferred from IP address) | • Vendors and Service Providers (e.g., companies that assist us with web hosting, payment processing, email delivery services, fraud prevention, customer service, analytics, and marketing) • Other Users / the Public (e.g., other users that participate in the Creator Network, subscribers and other members of the public that view your homepage and profile) • Integration Partners (e.g., apps in the Kit App Store) | • Provide, maintain, and improve the Services; • Process and fulfill your orders, calculate and collect fees, and make payments; • Develop new products and services; • Personalize your experience with us; • Send you technical notices, security alerts, support messages, and other transactional or relationship messages; • Send you marketing communications; • Monitor and analyze trends, usage, and activities in connection with our products and services; • Detect, investigate, respond to, prosecute, and help protect against security incidents and other malicious, deceptive, fraudulent, or illegal activity, and help protect the rights and property of Kit and others; • Comply with our legal and financial obligations; and • To create de-identified and aggregate data that cannot reasonably be linked to you. |
We generally do not collect information that is considered “sensitive” under State Privacy Laws and we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
As described in the Collection of Information section above, we collect personal information from various sources, including directly from you, automatically when you access or use our Services, and from third-party sources.
We retain personal information as described above.
Sales, Sharing, and Targeted Advertising Activities
We disclose certain categories of personal information to show you targeted ads on third-party properties and expand the reach and effectiveness of our own marketing campaigns. These disclosures may be considered “sales,” “sharing,” or use of personal information for “targeted advertising” under State Privacy Laws, and the table below covers the categories of personal information we disclose for these purposes and the categories of third parties that receive it.
| Category of Personal Information | Category of Third Parties |
| Identifiers | Advertising and marketing networks, social networks |
| Commercial information | Advertising and marketing networks, social networks |
| Internet or other electronic network activity information | Advertising and marketing networks, social networks |
We do not engage in sales, sharing, or targeted advertising using personal information about consumers we know to be under the age of 18.
You may opt out of these disclosures and use of your information for targeted advertising purposes by visiting https://preferences-mgr.truste.com/ or by visiting our websites with a legally recognized universal opt-out signal enabled, such as the Global Privacy Control.
Your Rights under State Privacy Laws
Access, Correction, and Deletion
You may have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information.
To request access, correction, or deletion of your personal information, send us an email to [email protected]. To authenticate your request, we will verify you using information we already have, such as relating to your prior transactions.
Nondiscrimination
We will not discriminate against you for exercising your privacy rights.
Appeals
If we deny your request, you may appeal our decision by contacting us at [email protected]. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.
Authorized Agents
If you reside in California, you may have the right to designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may contact the individual who is the subject of the request to verify their own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please email us at [email protected].
International Transfers
Kit is based in the United States, and we and our service providers process and store personal information on servers located in the United States and other countries. Whenever we make restricted international transfers of personal information, we take steps to ensure that your personal information receives an adequate level of protection (by putting in place appropriate safeguards, such as contractual clauses) or ensure that we can rely on an appropriate derogation under data protection laws. Where relevant, you may request access to any safeguard which we use to transfer your personal information outside of the European Economic Area, the United Kingdom, or Switzerland (although we may need to redact data transfer agreements for confidentiality reasons).
For personal information about EEA, Swiss, and UK individuals, Kit complies with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks and the UK Extension to the EU-U.S. Data Privacy Framework (collectively, the “Frameworks”), each as set forth by the U.S. Department of Commerce. As described in our Frameworks certification, Kit has certified that it adheres to the Frameworks Principles with regard to the processing of personal information received from the EEA, Switzerland, and the UK in reliance on the Frameworks. In accordance with the Frameworks, we remain responsible under the Onward Transfer Principle for personal information that we disclose to third parties for processing on our behalf. To learn more about the Frameworks or to view our certification, please visit the Frameworks website. The Federal Trade Commission has jurisdiction over Kit’s compliance with the Frameworks.
Kit commits to resolve Frameworks Principles-related inquiries and complaints about our processing of personal data under the Frameworks, and EEA, Swiss, and UK individuals with such inquiries or complaints can contact us at: [email protected]. If we are unable to resolve any complaint, you can submit a complaint to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgement of your Frameworks Principles-related complaint from us, or if we have not addressed your Frameworks Principles-related complaint to your satisfaction, please visit here for more information or to file a complaint. The services of JAMS are provided to you at no cost.
In certain circumstances, the Frameworks provide the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Framework Principles.
Individuals in Europe
If you are located in Europe, this section applies to you.
Legal Basis for Processing
When we process your personal data as described in this Privacy Policy, we do so in reliance on the following lawful bases:
Data Subject Requests
You have the right to (1) access your personal data, including in a portable format, (2) request erasure of your personal data, and (3) request correction of inaccurate personal data. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please email us at [email protected].
If you have a concern about our processing of personal data, we encourage you to contact us in the first instance. However, if we are not able to resolve it, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in the European Union: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
CONTACT US
If you have questions about this Privacy Policy, please contact us at [email protected].