Last updated: April 23, 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Platform and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Platform. By using the Platform, You agree to the collection and use of information in accordance with this Privacy Policy.
As of the above date, Keenee does not meet the thresholds for applicability of the various State Privacy Laws. However, in preparing for such laws to become applicable to Keenee’s Platform and business, Keenee will use reasonable efforts to comply with your requests under such laws. We will review Our privacy practices annually and update this Privacy Policy accordingly.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for You to access our Platform or parts of our Platform.
- Business and Controller have the meanings assigned to them under the applicable State Privacy Law and may be used interchangeably in this Privacy Policy. Generally, a Business or Controller is the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the applicable state.
- CCPA means the California Consumer Privacy Act as amended by the California Privacy Rights Act.
- Consumer has the meaning set forth in the applicable Sate Privacy Law.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Device means any device that can access the Platform such as a computer, a cellphone or a digital tablet.
- Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
- Keenee (referred to as either “Keenee”, “We”, “Us” or “Our” in this Agreement) refers to Keenee Corporation, One Boston Place, Suite 2600, Boston, MA 02108. For the purpose of the GDPR, Keenee is the Data Controller.
- Mobile App means the Keenee mobile application available on the Apple App Store and Google Play.
- Personal Information has the meaning assigned to the term Personal Information or Personal Information under the applicable State Privacy Law and generally is any information that relates to an identified or identifiable individual.
- Platform means the Website and the Mobile App.
- Platform Provider means any natural or legal person who processes the data on behalf of Keenee. It refers to third-party companies or individuals employed by Keenee to facilitate the Platform, to provide the Platform on behalf of Keenee, to perform services related to the Platform or to assist Keenee in analyzing how the Platform is used. Platform Providers are Service Providers or Processors under applicable State Privacy Laws.
- Sale and Share have the meanings assigned to them under the applicable State Privacy Law.
- Service Provider or Processor has the meaning assigned to them under the applicable State Privacy Law. Service Providers and Processors are generally companies that work with Personal Information to provide services solely for the benefit of a Business or Controller under a written contract.
- State Privacy Laws means the CCPA, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act and other state privacy laws that become effective from time to time.
- Usage Data refers to data collected automatically, either generated by the use of the Platform or from the Platform infrastructure itself (for example, the duration of a page visit).
- Website refers to Keenee, accessible from https://keenee.com
- You means the individual accessing or using the Platform, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Platform.
Collecting and Using Your Personal Information
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Types of Data Collected
Personal Information
While using Our Platform, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Address, State, ZIP/Postal code, City
- Usage Data
Usage Data
Usage Data is collected automatically when using the Platform.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Platform that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Platform by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Platform or when You access the Platform by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Platform and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Platform. The technologies We use may include:
- Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Platform. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Platform may use Cookies.
- Flash Cookies. Certain features of our Platform may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Platform. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
- Web Beacons. Certain sections of our Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Keenee, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Privacy Policies website article.
We use both Session and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies
- Type: Session Cookies
- Administered by: Us
- Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
- Cookies Policy / Notice Acceptance Cookies
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
- Functionality Cookies
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
- Examples: Cookie Consent WordPress plugin
- Tracking and Performance Cookies
- Type: Persistent Cookies
- Administered by: Third-Parties
- Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
- Examples: Facebook, Google Analytics, Wisepops
- Mobile App Tracking Technologies
- Type: Persistent mobile app technologies
- Administered by: Third-Parties
- Purpose: bugtracking
- Examples: Sentry, Instabug
- Mobile App Advertising and Analytics
- Type: Persistent mobile app technologies
- Administered by: Third Parties
- Purpose: We use these technologies to track user behavior to help us understand where users come from and how our advertising is performing.
- Examples:
- Facebook (with Advertiser Tracking Enabled)
- Google Play Store
- Apple App Store Analytics
- Google Firebase
- Google Analytics
- Google BigQuery
- App Radar
Opting Out of Data Collection
You may disable cookies other than strictly necessary cookies using the cookie consent banner at the top of our website.
You may disable mobile device tracking technologies using the privacy settings on your mobile phone.
You may disable browser cookies in your browser or set your browser to warn you when a cookie is being sent. You may lose some features or functionality when you disable cookies. Remember, also, that disabling cookies is browser specific. If you log on using Microsoft Edge, you must also disable cookies in Safari, Google Chrome, Firefox or other browsers if you use those browsers at a different time.
You can prevent the collection of the data generated by Google Analytics in relation to your use of our website and the processing of this data by downloading and installing the browser plug-in, with more information regarding how you can opt out of Google Analytics data collection as instructed here: https://tools.google.com/dlpage/gaoptout. This link provides instructions for installing an opt-out cookie on your device. As a result, the collection of data by Google Analytics is prevented in future for the Site and for this browser as long as the opt-out cookie remains installed in your browser.
You may opt-out of Facebook’s collection and sharing of information here: https://www.facebook.com/settings?tab=ads.
You may also opt-out of information sharing from other third party websites to us through their privacy policies.
Use of Your Personal Information
Keenee may use Personal Information for the following purposes:
- To provide and maintain our Platform, including to monitor the usage of our Platform.
- To manage Your Account: to manage Your registration as a user of the Platform. The Personal Information You provide can give You access to different functionalities of the Platform that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the rental or service orders for the Goods and Services You have rented or purchased or of any other contract with Us through the Platform.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Us about our Platform users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Platform, products, services, marketing and your experience.
We may share Your personal information in the following situations:
- With Platform Providers: We may share Your personal information with Platform Providers to monitor and analyze the use of our Platform, to contact You.
- With Service Providers: We may share Your personal information with Service Providers who are providing services to Keenee to assist with our provision of the Platform.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Keenee assets, financing, or acquisition of all or a portion of Our business to another company.
- With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Information
Keenee will retain Your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Keenee will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Platform, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Information
Your information, including Personal Information, is processed at Keenee’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
Keenee will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Disclosure of Your Personal Information
Business Transactions
If Keenee is involved in a merger, acquisition or asset sale, Your Personal Information may be transferred. We will provide notice before Your Personal Information is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, Keenee may be required to disclose Your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
Keenee may disclose Your Personal Information in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of Keenee
- Prevent or investigate possible wrongdoing in connection with the Platform
- Protect the personal safety of Users of the Platform or the public
- Protect against legal liability
Security of Your Personal Information
The security of Your Personal Information is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Information, We cannot guarantee its absolute security. We use encryption technology for passwords, and registration information. Our Website uses Transport Layer Security (TLS) which uses encryption to protect transfers of personal information. You will know that a webpage within our Website uses TLS when you see the padlock symbol 🔒 or “https” in the URL. Information that you disclose by use of this site (as with any site that is non-secure), by posting a message or using e-mail, potentially could be collected and used by others. This may result in unsolicited messages from third parties or use of such information by third parties for their own purposes, legal or illegal. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or from our services, and you do so at your own risk. Once we receive your transmission, we use commercially reasonable efforts to ensure its security on our systems. We limit access to your personal information to those employees who reasonably need access to such information in order to provide and improve our services and process your information appropriately.
Privacy under State Privacy Laws
This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies to all visitors, users, and others who reside in the State of California. This section also provides additional information required under other State Privacy Laws.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from Consumers within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.
- Category A: Identifiers.
- Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
- Collected: Yes.
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
- Collected: Yes.
- Category C: Protected classification characteristics under California or federal law.
- Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Collected: No.
- Category D: Commercial information.
- Examples: Records and history of products or services purchased or considered.
- Collected: No.
- Category E: Biometric information.
- Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
- Collected: No.
- Category F: Internet or other similar network activity.
- Examples: Interaction with our Platform or advertisement.
- Collected: Yes.
- Category G: Geolocation data.
- Examples: Approximate physical location.
- Collected: No.
- Category H: Sensory data.
- Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
- Collected: No.
- Category I: Professional or employment-related information.
- Examples: Current or past job history or performance evaluations.
- Collected: No.
- Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
- Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Collected: No.
- Category K: Inferences drawn from other personal information.
- Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Collected: No.
Under CCPA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from You. For example, from the forms You complete on our Platform, preferences You express or provide through our Platform.
- Indirectly from You. For example, from observing Your activity on our Platform.
- Automatically from You. For example, through cookies We or our Platform Providers set on Your Device as You navigate through our Platform.
- From Platform Providers. For example, third-party vendors to monitor and analyze the use of our Platform, or other third-party vendors that We use to provide the Platform to You.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
- To operate our Platform and provide You with our Platform.
- To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Platform.
- To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Platform, We will use that personal information to respond to Your inquiry.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Information” section.
If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Sale of Personal Information
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category F: Internet or other similar network activity
Share of Personal Information
We may share Your personal information identified in the above categories with the following categories of third parties:
- Platform Providers
- Our affiliates
- Our business partners
- Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You
Sale of Personal Information of Minors Under 16 Years of Age
We do not knowingly collect personal information from minors under the age of 16 through our Platform, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.
Your Rights under the CCPA
The CCPA and other State Privacy Laws provide Consumers with specific rights regarding their personal information:
- The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
- The right to request. You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
- If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
- The right to say no to the sale of Personal Information (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
- The right to delete Personal Information. You have the right to request the deletion of Your Personal Information, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Platform Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Platform Providers to:
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
- The right to object to subprocessing. Certain states permit you to object to the use of certain subprocessors.
Making Requests Regarding Data Protection Rights
As stated above, Keenee does not currently meet the thresholds for applicability of the various State Privacy Laws. However, Keenee will endevour to comply with requests and will revisit this Privacy Policy and update it as state privacy laws become applicable. If you would like to make a request regarding the above rights, You can contact Us:
- By email: info@keenee.com
- By mail: 251 Little Falls Drive Wilmington. DE 19808
Only You, or a person registered with the applicable Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if we cannot:
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.
For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.
We do not process privacy requests sent to us using third party services that have not complied with our verification process. This is because such services often request that we click on hyperlinks which we will not do for data security reasons. These services are also susceptible to spoofing and other phishing attacks. One of our highest priorities is to treat your information safely and securely. If you live in a state that permits you to make a privacy request using a third party agent, please have them contact us using the information above and we will take steps to identify them and ensure that they are your agent.
Do Not Sell My Personal Information
You may have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.
The Platform Providers we partner with (for example, our analytics or advertising partners) may use technology on the Platform that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.
Website
You can opt out of receiving ads that are personalized as served by our Platform Providers by following our instructions presented on the Platform:
- The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA’s opt-out platform http://www.youronlinechoices.com/
- The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again. You can also opt out of cookies using our cookie consent tool.
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Platform does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Children’s Privacy
Our Platform does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Information, please contact Us. If We become aware that We have collected Personal Information from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
Our Platform may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Platform, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
- By email: info@keenee.com
- By mail: One Boston Place, Suite 2600, Boston, MA 02108