Effective Date 11/24/2017. This policy was last updated in November 2017.
- Scope and Consent
- Information We Collect
Information Collection and Use
You can browse the Site without telling us who you are or revealing any personal information (i.e., name, email address, phone number, fax number, mobile telephone number and physical contact information) about yourself.
What information do we collect?
Kivu collects contact information provided voluntarily by website visitors. If you register with Kivu (e.g. to obtain our email newsletter), you choose to give us your personal information and are not anonymous to us. Kivu may collect the following information in a form as part of an inquiry such as registering for our email newsletter:
How do we use this information?
Where website visitors have a specific inquiry and provide their contact information, this information will be added to Kivu’s promotional mailing list, which is use for distribution of our email newsletter, occasional announcements, and promotional material.
Kivu occasionally sends email communications such as our email newsletter. To protect privacy, we offer a way to unsubscribe and opt not to receive future communications. If you wish to unsubscribe, please use the unsubscribe link provided at the bottom of the email communication or send an email to firstname.lastname@example.org with a subject of “Unsubscribe.” Any opt-out request will be processed as promptly as practicable.
Kivu does not sell, rent, exchange or otherwise disclose our mailing lists or information about visitors to this website.
Social Media Information: We may offer sign-on services that allow you to use third-party login credentials to access the Site. We also may offer services that allow you to share information with third-party social media websites such as Facebook, Google Plus, LinkedIn, Twitter, and others.
Technical Usage Information: When you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Sites such as the browser type, IP address, user language, the operating system, the presence/absence of “flash” plug-ins, screen resolution, connection type, and information that identifies the cookie, the pages you view and the length of your visit to the Site (“usage information”). We use tracking technologies (including cookies, flash cookies, web beacons/GIFs, embedded scripts, e-tags/cache browsers) to collect usage information.
We may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.
- Uses and Retention
(a) Operate Our Site: We use the information collected to (i) respond to your requests; (ii) provide customer service (e.g., to resolve disputes, problems with accessing the Site); (iii) personalize your experience; (iv) improve the Site; (v) provide you with a safe, efficient, and customized experience.
(b) Analyze and Aggregate Non-Personal Information: We use aggregate information about our users and non-personal information for statistical purposes, to analyze Site and user behavior, to prepare aggregated reports, and for our own marketing purposes.
(d) Communicate with You and Process your Requests: We use the information you provide to contact you, to comply with your stated communication preferences, or to provide other services requested by you, as described at the time when we collect the information from you, or to contact you for other purposes authorized by law.
In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
Information collected on the Site may be shared with:
(a) The Kivu Corporate Family. We may share the information we collect about you with the Kivu corporate family and their and our affiliates and subsidiaries. The information may be disclosed (i) to provide joint content and our services (e.g., registration, transactions, analytics and customer support); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) to guide decisions about our products, sites, applications, services, tools, and communications. Members of our corporate family will use this information to send you marketing communications and you will have the opportunity to opt-out in email communications.
(b) Service Providers and Other Third Parties. We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, fraud investigations, software development, email delivery, marketing communications, bill collection, payment processing, and site analytics and operations).
(c) Other Entities with your Consent. Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). On the Site, you may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third parties, or parties working on their behalf, to implement your request.
(d) Legal . We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to comply with such legal process, or to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
(f) Companies in the Mobile App Industry. If you access the Site through a mobile device or app, we may also share your information with carriers, operating systems and platforms.
(g) Social Networks: Please see Section 6 below.
- Your Choices
You can control how and when you want to receive notifications regarding electronic newsletters and marketing-related emails for services described on the Site by contacting us at email@example.com or by following the “unsubscribe” instructions within the notices.
- Information You Share on the Site
- Tracking Technologies (Cookies)
When you visit the Site, we and our business partners may use tracking technologies to enhance your online experience or customize our offerings.
You may encounter tracking technologies/cookies from our third-party service providers, that we have allowed on our site that assist us with various aspects of our Site operations and services, such as Google Analytics.
You also may encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page posted as a link from our Site, there may be a cookie placed by that web page).
- Accessing, Reviewing, and Changing Your Personal Information
- California and European Residents
(a) How Do We Respond to “Do Not Track Signals for California Residents”. California Business & Professions Code Section 22575(b)(as amended effective January 1, 2014) provides that California residents are entitled to know how Kivu responds to “Do Not Track” browser settings. Kivu does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
- Third Party Links
At our discretion, we may include links to third party products or services on this website. These third parties have independent and separate privacy policies. Kivu has no responsibility or liability for the content and activities of these linked sites. However, we seek to protect the integrity of this website and welcome feedback about these linked sites.
How do we protect your information?
We use many security measures to maintain the online and offline safety of your personal information.
We store and process your information on our servers located in the United States and around the world. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate.
- Children’s Privacy
The Site is a general audience site and it is not intended for children under the age of 13. We do not knowingly collect personal information via our websites, applications, services, or tools from users in this age group.
- International Transfer
As we operate internationally, and many of our computer systems are currently based in the United States, your personal information may be processed in the U.S. and elsewhere where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you provide information to us via the Kivu website, you consent to the collection and/or processing in the United States of your personal information and tracking technologies/cookies as described in this Policy.
- EU-U.S. Privacy Shield
Kivu (and its wholly owned European subsidiary Kivu Netherlands B.V.) participates in and has certified its compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. Kivu is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Frameworks, to the Frameworks’ applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List (https://www.privacyshield.gov/welcome).
Kivu is responsible for the processing of personal data it receives under the Privacy Shield Frameworks and subsequently transfers to a third party acting as an agent on its behalf. Kivu complies with the Privacy Shield Principles for all onward transfers of personal data from the EU or Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Kivu is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Kivu may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Kivu commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Kivu at:
Chief Privacy Officer
Kivu Consulting, Inc.
44 Montgomery Street, Suite 700
San Francisco, CA 94104
Kivu has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
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