Effective: November 25, 2019
1. Collection Of Information
2. Use Of Information
3. Sharing Of Information
4. Additional Details
5. Your Choices
6. Data Rights
7. Contact Us
Summary: We collect information about you when you:
Create an account;
Use the Platform;
Attend an event;
Visit our website; and
Communicate with us.
We also collect information, such as usage statistics, by using cookies, server logs, and similar technologies.
If you elect to use certain features, we also collect information through other sources, such as social media services, invitations, and imported contacts.
1.1 Information You Provide to Us
We collect information that you provide directly to us. For example, we collect information that you provide when you create an account, choose interests or groups, fill out a form, or communicate with us. The types of information that we may collect include your name, username, password, email address, postal address, phone number, payment method data, photos, choices of interests and groups, and any other information that you choose to provide. Information about your gender and interests is optional. Your choice of groups is optional, but we are required to process this information in order to administer your account, and to indicate that you are a member of the groups that you join. See Section 2 to learn how we will use the information that you provide to personalize our recommendations and other content to you.
On occasion, the information that you give us when you join a group may imply information about your beliefs, political views, health conditions; or your sexual identity. This, and other kinds of sensitive information, is given special protection. Posting personal or sensitive information about yourself or others is against our Community Guidelines.
1.2 Information We Collect Automatically When You Use the Platform
When you use our Platform, we automatically collect information about you, including:
Log Information: We collect log information about your use of the Platform, including the type of browser that you use; the time, duration and frequency of your access; Platform pages viewed; your IP address; and the page you visited before visiting our Platform.
Device Information: We collect information about the computer or mobile device that you use to access our Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Location Information: We may collect information about the location of your device each time you use our Platform based on your consent to the collection of this information. For further information see Section 5.2.
Other Information: With your permission, we may collect other information from your device, such as photos from your camera roll, contacts of individuals you wish to find or connect with, or calendar information you want to manage via the Platform.
1.3 Information We Collect From Other Sources
We may collect information about you from other sources, such as through certain features on the Platform you elect to use, but only where these third parties either have your consent or are otherwise legally permitted or required to disclose your information to us. Examples include:
Social Media Services. If you register or log into your account through a third-party social media service, we will have access to some of your third-party account information from that service, such as your name and other information in that account, and used for purposes such as improving your Koin recommendations. We may also have access to third-party account information if you use the Platform feature to share a link. See this article for more information on how to enable or disable the connection between our Platform and your third-party account.
Invitations. If another member sends you an invitation through our Platform, we may receive certain personal information, such as your name, email address, or phone number. If you are an invited guest, we will automatically send you an invitation to our Platform, and, if unanswered, a one-time follow-up invitation. Koin stores this contact information only to send these invitations and evaluate their success. You may unsubscribe from future invitations using the instructions in those messages. You may also contact us at email@example.com to request that we remove this information from our database.
Member Content. We may receive information about you when you or another member uploads photos or posts other content to the Platform. For further details about the rights over this information available to individuals, see Section 6.
Information From Other Third-Party Sources. In order to provide you with more tailored recommendations, we may obtain information about you from publicly and commercially available sources and other third parties as permitted by law. For more information about the data that we obtain from these providers, please contact us at firstname.lastname@example.org.
Summary: We use information about you to:
Operate, improve, promote, and protect Koin and our Platform;
Communicate with you; and
2.1 Operating our Platform
We may use information about you for various purposes related to operating our Platform, including to:
Provide, maintain, and improve our Platform, including to process transactions, develop new products and services, and manage the performance of our Platform;
Display information about you, for instance, your list of interests, which will be visible on your profile;
Personalize the Platform, for example, to suggest content in which we think you may be interested (including content given special protection under EU law or that relates to sensitive topics such as health, political opinions, religion, and sexual identity);
Allow you to share information about your use of the Platform through a third-party social media service, if you connect your account through that service (which you can turn off at any time) and to provide you with better recommendations;
Monitor and analyze trends, usage, and activities in connection with our Platform; and
Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of Koin and others; to enforce compliance with our policies; and to comply with applicable law and government requests.
Perform accounting and administrative tasks, and enforce or manage legal claims.
2.2 Communicating With You
We may use information about you for various purposes related to communicating with you, including to:
Respond to your comments, questions, and requests, and provide customer service;
Communicate with you, in accordance with your account settings, about products, services, and events offered by us and others, to provide news and information that we think will be of interest to you, to conduct online surveys, to contact you about events on our Platform that are being held near your location, and to otherwise communicate with you in accordance with Section 2.3;
Notify you about communications of other members, in accordance with the communication preferences that you indicate in your account; and
Send you technical notices, updates, security alerts and support, and administrative messages.
2.3 Advertising And Other Uses
We may use information about you for various other purposes, including to:
Provide content, features, or sponsorships that match member profiles or interests;
Facilitate contests and other promotions;
Carry out any other purposes described to you at the time that we collected the information.
2.4 Legal Basis for Processing
Our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.
We process information about you in order to provide our services in accordance with our Terms of Service, for example to allow you to join groups, or to display your profile to other members, and to allow us to send you important service updates.
We also process information about you where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Platform).
Sometimes you provide us with sensitive information about you; for instance, the mere fact of joining a certain group may indicate information about your health, religion, political views, or sexual identity. Joining such groups, or posting information on the Platform about these topics is entirely voluntarily and done with your explicit consent.
In some cases, we may also have a legal obligation to collect information about you, or may otherwise need the information to protect your vital interests or those of another person.
We may also process information to comply with a legal requirement or to perform a contract.
We may disclose information about you:
to members or social media services, subject to the choices you may make via the Platform;
to our third-party service providers who help us to operate or improve our Platform;
to authorities to comply with legal obligations and to protect and defend our rights and property; and
to an affiliate or successor entity as part of a corporate transaction.
We may also share de-identified or aggregated information.
3.1 Through Our Platform
We share some of the information that we collect by displaying it on our Platform according to your member profile and account settings. Some information, such as user name, is always public. Some information, such as interests, is public by default, but can be hidden on our Platform. Some information, such as group memberships, will always be visible to other members of that Koin group, and may be public, depending on the settings of that group. We recommend that you check the group settings and what information will be available before joining the group to ensure that you are happy with the information that is visible to others. For more information, see this article on Account Privacy and Visibility and this article on Group Content Visibility.
3.2 Group Networks
If you are a member of a group, this group may now or in the future become part of a network of groups known as a “Koin Pro” network. Members who administer a Koin Pro network, known as “network administrators” have access to the content within their groups. Network administrators find it helpful to have access to the email addresses of organizers and other members of groups within their networks, to easily communicate with and administer the groups. Therefore, we may ask if you want to share your email address with your group’s network administrator. See this article for more information about Network Administrators, Organizers, and their Members.
3.3 With Our Service Providers
We may use service providers in connection with operating and improving the Platform to assist with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations.
3.4 Following The Law And Protecting Koin
We may access, preserve, and disclose information about you to third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Koin or others.
3.5 Social Sharing And Other Tools
The Platform may offer social sharing features and other integrated tools which let you share actions that you take on our Platform with third-party services, and vice versa. Such features let you share information with your friends or the public, depending on the settings you have chosen with the service. For more information, see this article on Sharing Koins on Social Media and this article on Connecting your Social Media Account. The third-party services' use of the information will be governed by the third-parties’ privacy policies, and we do not control the third-parties’ use of the shared data. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please review the privacy policies of the services that provide these features.
3.6 Affiliate Sharing And Merger, Sale, Or Other Asset Transfers
If Koin is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates.
3.7 Other Situations
We may de-identify or aggregate information about you and share it freely, so that you can no longer be identified. We may also share information about you with your consent or at your direction or where we are legally entitled to do so.
With your permission, we may allow others to use technologies that collect information about you to provide analytic services, and to serve ads for Koin. You may be able to disable the collection or use of this information.
Koin is based in and governed by U.S. law and we will be processing, transferring, and storing information in and to the U.S. and other countries.
We use commercially reasonable efforts to protect your personal information and have implemented technical and organizational measures in line with industry best practices. We cannot guarantee these controls will provide absolute security.
4.1 Analytics and Advertising Services Provided by Others
4.2 Transfer Of Information To The U.S. And Other Countries
We employ technical and organizational measures designed to appropriately protect your information that is under our control and that we process on your behalf from unauthorized access collection, use, disclosure, copying, modification or disposal, both during transmission and once we receive it. We train employees regarding our data privacy policies and procedures, and permit authorized employees to access information on a need to know basis, as required for their role. We have protections against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure.
Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential.
4.4 Data Retention
We may temporarily block your account if you have not logged in for six months or more. You may contact us if you wish to reactivate your account.
We retain certain information that we collect from you while you are a member of the Platform, and in certain cases where you have deleted your account, for the following reasons:
So you can use our Platform;
So ensure that we do not communicate with you if you have asked us not to;
To provide accurate accounting information to other members about the groups that they organize or administer, and associated memberships;
To better understand the traffic to our Platform so that we can provide all members with the best possible experience;
To detect and prevent abuse of our Platform, illegal activities and breaches of our Terms of Service; and
To comply with applicable legal, tax or accounting requirements.
When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it.
4.5 Policy Scope
Koin is a data controller. Members, including group organizers and network administrators, are directly responsible for complying with all requirements of applicable EU privacy laws in connection with the information that they obtain and process for the purposes of managing their contacts, or organizing groups, or administering networks
4.6 Revisions To This Policy
You can review and change information about you or deactivate your account in your account settings, but we may retain certain information.
With your consent, we will use information about your location. You can deactivate this feature at any time.
You have the right to opt out of receiving Koin’s promotional messages, but you may still receive other non-promotional communications.
5.1 Your Choices: Account Information
You may update or correct your account information by editing your account settings or by sending a request to email@example.com as described in Section 6. You may deactivate your account by editing your account settings or by sending an email to firstname.lastname@example.org. You will also be able to choose what information others see about you and who may contact you by using the Privacy Settings section in your Account.
5.2 Your Choices: Location Information
When you first access the Platform, we will collect information about your location, which we use to make better recommendations for groups and events in your area, and to improve our Platform. If you do not want us to collect information about your location, then you can prevent this:
If using a mobile app, by changing the settings on your device.
Note that our Platform or its features may no longer function properly if you do.
Your mobile device settings may also give you the option to choose whether to allow us to view your location on a continuous basis, when only using the app, or never. Allowing us to view your location when you are not using the app allows us to provide you with recommendations on a regular basis. Please refer to your device’s guide for additional information on how to adjust location services.
5.3 Your Choices: Cookies
5.4 Your Choices: Promotional Communications
You can control messages that you receive from Koin, other members, and third parties by selecting the unsubscribe link in the message that you receive, or by adjusting the communication preferences in your account settings. We will also send you a link to these settings when you first sign up and in subsequent messages. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.
You may have the right to exercise your data protection rights, including to request that Koin deletes, amends, or provides you access to your information.
You have the right to opt out of receiving Koin’s promotional messages, but you may still receive other communications.
You can complain to your local data protection authority about the use of your information.
We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to email@example.com.
Rights that you may have, depending on the country in which you live, include:
Accessing, correcting, updating, or requesting deletion of your information.
Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
Opting out from receiving marketing communications that we send you at any time. You can exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we send you. Additionally, you may update your email preferences by changing the settings in your account.
Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
Complaining to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available here.
Note that Koin is a controller of your information. Other members, such as group organizers and network administrators, may also act as controllers of your information. You should contact these members if you have any questions about how they use information that you have provided to them.
If you have any questions, you can contact us at firstname.lastname@example.org.
Under European data protection law, the controller of your information is Koin, Inc.