14 th of June 2021
KIRA values your privacy and treats privacy seriously. We recognize the importance of maintaining the confidentiality of personal information.
This Privacy Policy applies to any and all services, applications, platforms, websites, or other affiliated ventures offered by KIRA.
Throughout this Policy, "KIRA", and "We" refers to https://kira.network managed by KIRA GLOBAL PTE. LTD. and its affiliates.
KIRA Global PTE. LTD. is the controller for the purposes of the General Data Protection Regulation (the "GDPR") in respect of KIRA.
KIRA may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act ("PDPA"). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.
"You" or "Users" refers to you, our users and everyone who uses, subscribes to, publishes through, joins, or visits KIRA.
The "KIRA Service" refers to the applications, platform, website and services controlled, operated or produced by KIRA.
By using the KIRA Service, you expressly consent to the information handling practices described in this Policy.
Your use of the KIRA Service and any personal information you provide through the KIRA Service are subject at all times to this Privacy Policy and the Terms of Service.
PERSONAL DATA
- As used in this Policy:
"customer" means an individual who (a) has contacted us through any means to find out more
about any goods or services we provide, or (b) may, or has, entered into a contract with us for
the supply of any goods or services by us; and
"personal data" means data, whether true or not, about a customer who can be identified:
(a) from that data; or (b) from that data and other information to which we have or are likely
to have access.
- Depending on the nature of your interaction with us, some examples of personal data which
we may collect from you include your name and identification information such as your NRIC
number, contact information such as your address, email address or telephone number,
nationality, gender, date of birth, marital status, photographs and other audio-visual
information, employment information and financial information such as credit card numbers,
debit card numbers or bank account information.
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the
context so permits).
1. Collection of the Information
Your privacy is important to us and We have taken steps to ensure that We do not collect more information from You than is necessary for us to provide You with our services and to protect your account.
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your " authorised representative") after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Information You Provide: You may provide to KIRA certain information (often called " personally identifiable" information), such as Your name, nationality, date of birth, email address, credit card number, postal mailing address, and telephone numbers. You may provide us with this information if you use certain services or products from the KIRA Service, enter contests or sweepstakes, or otherwise use the features and functionality of the KIRA Service.
If You are registered as a provider, in addition to the information mentioned above, We may also collect Your identity information, tax registration number and information about Your business, such as the information about Your business license.
If You contact our contact center, We may record Your conversation with us and collect additional information to verify Your identity. In connection with any transaction and payment services, information, including but not limited to, virtual currency addresses, bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders may be collected.
We record details of users' activities with the Service. We log technical information about Your use of the Services, including the type of browser and version You use, last access time of Your account, the Internet Protocol (IP) address used to create the account and the most recent IP address used to access the account, the web pages or sites that You visit just before or just after You use the KIRA Service, the pages or other content You view or otherwise interact with on the KIRA Service, and the dates and times that You visit, access, or use the KIRA Service.
We also may use these technologies to collect information regarding Your interaction with e-mail messages, such as whether You opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about You.
We record users' browsing activities on our platform including but not limited to IP addresses, browsing patterns, behavioral patterns and equipment information. In addition, We gather statistical information about visitors including, but not limited to, browser software, operating system and version, mobile network information, software and hardware attributes, pages viewed, number of sessions and unique visitors.
Third Party Web Beacons and Third Party Buttons: We may display third-party content on the KIRA Service, including third-party advertising. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with Your viewing of the third party content on the KIRA Service. Additionally, We may implement third party buttons that may function as web beacons even when You do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by KIRA. Information collected by a third party in this manner is subject to that third party's own data collection, use, and disclosure policies.
Information from Other Sources: We may obtain information from third parties and sources other than the KIRA Service, such as our partners and advertisers.
From time to time, we collect information about our users and prospective users during trade shows, industry events and other functions. The information We may collect at these events includes, but not limits to, user name, address, phone number and e-mail address.
2. Use of the Information
KIRA collects and processes personal information about You only where We have a legal basis for doing so under applicable data protection law, including under the GDPR and the PDPA. The legal bases will depend on the purpose for which We process Your personal information. This means We collect and use Your personal information only where:
- We need it to provide the Services, and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by Your rights and interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process Your personal information to comply with a legal obligation. We may use Your e-mail address or mobile number for administrative communications such as notifying You of major KIRA Service updates, and to send privacy or security related notices. KIRA uses all of the information that We collect to understand the usage trends and preferences of our Users, to improve the way the KIRA Service works and looks, to create new features and functionality. We may use Your e-mail address to send You newsletter or marketing e-mails. We will ask for Your consent in line with the applicable law when You first provide Your personal information.
3. Your Rights
If You have consented to our use of personal information about You for a specific purpose, You have the right to change Your consent at any time. In certain circumstances, You have rights under the GDPR and the PDPA in relation to Your personal information.
- Request access to Your personal information. You may have the right to request access to any personal information We hold about You as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of personal information, and the existence of any automated decision making.
- Request correction of Your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information We hold about You.
- Request erasure of Your personal information. You may have the right to request that personal information held about You is deleted.
- Request restriction of processing Your personal information. You may have the right to prevent or restrict processing of Your personal information.
- Request transfer of Your personal information. You may have the right to request transfer of personal information directly to a third party where this is technically feasible.
These data privacy rights do not apply to KIRA where We process Your personal information as a data processor on behalf of our partners. Where this is the case, any request to exercise Your data privacy rights should be directed to our partners (i.e. the data controllers).
4. Disclosure of the Information
KIRA does not share personally identifiable information about You with other organizations for their marketing or promotional uses without Your prior express consent. Please be aware, however, that any personally identifiable information that You voluntarily choose to display on any publicly available portion of the KIRA Service, becomes publicly available and may be collected and used by others without restriction.
KIRA may disclose automatically collected and other aggregate non-personally-identifiable information (such as non-identifiable User usage data, referring / exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to assist those parties in understanding the usage and demographic patterns for certain content, services, advertisements, promotions, or other functionality on the KIRA Service.
We may disclose some limited User information to affiliated companies or other businesses or persons to:
- e-mail providers, located in the United States, in to provide e-mail services;
- cloud services providers, like Google and Amazon, located in Ireland, to store certain personal data and for disaster recovery services, as well as for the performance of any contract We enter into with You;
- provide website hosting, maintenance, and security services;
- conduct data analysis and create reports;
- offercertainfunctionality; and
- assist KIRA in improving the KIRA Service and creating new services features.
We generally contractually require that these parties process such information in compliance with this Privacy Policy, authorize only a limited use of such information, and require these parties to use reasonable confidentiality measures. KIRA may disclose User information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws or respond to a court order, judicial or other government orders. We shall require any third party, including without limitation any government or enforcement entity, seeking access to data We hold to have obtained a court order, or proof they are statutorily empowered to access Your data and that their request is valid and within their power.
KIRA also reserves the right to disclose User information that We believe, in good faith, is appropriate or necessary:
- to take precautions against liability;
- protect KIRA from fraudulent, abusive, or unlawful uses;
- to investigate and defend ourselves against third-party claims or allegations; to assist government enforcement agencies;
- to protect the security or integrity of the KIRA Service; or
- to protect the rights, property, or personal safety of KIRA, our Users, or others.
In the event that KIRA is acquired by or merged with a third-party entity, We may transfer or assign the information that We have collected from Users as part of that merger, acquisition, sale, or other change of control.
5. Your Choices and Access to Your Personal Information
If You decline to share Your personally-identifiable information with KIRA. We may not be able to provide to You some of the features and functionality found on the KIRA Service. You may view, update, correct, or delete Your user information and preferences by contacting [email protected]
To protect Your privacy and security, We take reasonable steps to verify Your identity before granting You account access or making corrections to Your information.
YOU ARE RESPONSIBLE FOR MAINTAINING THE SECRECY OF YOUR UNIQUE PASSWORD AND ACCOUNT INFORMATION AT ALL TIMES.
6. Advertisers and Third Parties
KIRA allows other companies, including third-party ad servers or ad networks, to serve advertisements within the KIRA Service. These third-party ad servers or ad networks may use technology to send, directly to Your browser, the advertisements that appear within the KIRA Service and they automatically receive Your IP Address and other log file information when this happens. Such third-party ad servers may also use other technologies (such as cookies, javascript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content.
KIRA does not provide Your personally identifiable information to these third-party ad servers or ad networks without Your consent. However, please note that if an advertiser asks KIRA to show an advertisement to a certain audience or audience segment and You respond to that advertisement, the advertiser or ad-server may conclude that You fit the description of the audience that they were trying to reach.
You should consult the respective privacy policies of these third-party ad servers or ad networks. This Privacy Policy does not apply to, and We cannot control the activities of, such other advertisers or web sites. KIRA reserves the right to add or remove third-party ad networks or ad servers in its discretion and We may not at all times list such updated ad network or ad server partners in this Privacy Policy.
Except as otherwise expressly provided otherwise, this document addresses only the use and disclosure of information We collect from You or that You disclose to us. If You disclose Your information to others besides KIRA, whether they are users of the KIRA Service or on other sites or services, different rules may apply to their use or disclosure of the information You disclose to them. KIRA does not control the privacy policies of third parties, and You are subject to the privacy policies of those third parties where applicable. We encourage You to ask questions before You disclose Your personal information to others.
7. Data Security
KIRA uses commercially reasonable physical, managerial, and technical safeguards intended to preserve the integrity and security of Your personal information. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Our Service has security measures in place to protect against the loss, misuse and unauthorized alteration of the information under our control. More specifically, our server uses SSL (Secure Sockets Layer) security protection by encrypting Your Personal Data to prevent individuals from reading these Data as they travel over the Internet.
Please be aware that no security measures are perfect or impenetrable. No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while We try to protect the information We hold for You, We cannot guarantee the security of any information You transmit to us and You do so at Your own risk. We cannot and do not guarantee that information about You will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
8. Retention of the Information
We retain the data You provide to us for as long as You have Your account with us and thereafter for such period as You may have questions or a claim in relation to our services, notwithstanding any superior retention period that We may be obliged to observe in accordance with legal requirements applicable to us.
Except where prohibited by law, this period may be extended beyond the end of the particular relationship with us but only for so long as We are contractually bound to do so, or so far as is necessary for audit or other accounting purposes. In some circumstances You can ask us to delete Your data as set out below.
When Personal Data are no longer needed We have procedures either to destroy, delete, erase or convert it to an anonymous form. After You have terminated Your use Services, We may store Your information in an aggregated and anonymized format.
9. Minors
Protecting the privacy of young children is especially important. For that reason, KIRA does not knowingly collect or maintain personally identifiable information from persons under 18 years-of-age. If KIRA learns that personally-identifiable information of persons less than 18- years-of-age has been collected on or through the KIRA Service, community submission form or otherwise, then KIRA will take the appropriate steps to delete this information. If You are the parent or legal guardian of a child under 18 who has become a KIRA Service member, then please contact KIRA at [email protected] to have that child's account terminated and information deleted.
10. Сookies
Cookies and Automatically Collected Information: We may track Your activities using cookies and similar technologies.
KIRA may use automatically collected information and cookies to:
(a) remember Your information so that You will not have to re-enter it during Your visit or the next time You access the KIRA Service; (b) provide customized third-party advertisements, content and information; (c) monitor and report on the effectiveness of third-party marketing campaigns; (d) monitor and report aggregate usage metrics such as total number of visitors and pages accessed; and (e) track Your entries, submissions, and status in any promotions or other activities.
If You want to delete any cookies that are already on Your computer, please refer to the help and support area on Your Internet browser for instructions on how to locate the file or directory that stores cookies.
Please note that by deleting our cookies or disabling future cookies You may not be able to access certain areas or features of Services. Please note that refusing cookies does not mean You will no longer receive online advertising. It means that the company or companies from which You opted out will no longer deliver adverts tailored to Your web preferences and usage patterns.
11. Transfers Of Personal Data Outside Of Singapore
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
We take appropriate steps to ensure that recipients of Your Personal Data are bound to duties of confidentiality and We implement appropriate measures to ensure Your Personal Data will remain protected in accordance with this Privacy Policy, such as standard contractual clauses. When transferring personal information, We rely on different adequacy measures, where the recipient is not established in a country ensuring an adequate level of protection within the meaning of Regulation (EU) 2016/679, such as the United States, the transfers will be covered by the standard data protection clauses adopted by the European Commission or by another appropriate safeguard mechanism such as the Privacy Shield Framework.
12. Changes and Updates to this Privacy Policy
This Privacy Policy may be revised periodically without further notice to You and this will be reflected by the "LAST UPDATED" date found at the top of this page. Please revisit this page to stay aware of any changes. Your continued use of the KIRA Service constitutes Your agreement to this Privacy Policy and any future revisions.
For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information You have provided to us, We will make reasonable efforts to notify You and obtain Your consent before implementing revisions with respect to such information.
13. KIRA Contact Information
For any questions, inquiries, or complaints, please contact us at: [email protected]