Privacy Notice


Privacy Notice

 

Last Updated: June 19, 2020

 

This Privacy Notice discloses how we collect, use, share, or otherwise disclose information that we collect about you through the Key Ring Application and website www.keyringapp.com (collectively, the “Key Ring App”) and our services (“Services). As for who “we” are, we are Key Ring (“Key Ring”, “we”, “us”, or “our”). We take your privacy seriously.

 

Please read this Privacy Notice carefully. By visiting and using the Key Ring App or our Services, you agree that your use of the Key Ring App and Services, and any dispute over our privacy practices, is governed by this Privacy Notice and our Terms of Use. Because the Internet is an evolving medium, we may need to change our Privacy Notice from time to time, in which case we’ll post the revised Privacy Notice on the Key Ring App and update the “Last Updated” date to reflect the date of the changes. By continuing to use the Key Ring App or Services after we post any such changes, you accept the Privacy Notice as modified.

 

How We Collect Information

 

                Information that You Provide to Us

 

We may collect and store information, including personally identifiable information (such as your name, zip code, gender, or email address) or other information (such as loyalty or gift card information) that you voluntarily supply to us while on the Key Ring App or using our Services. Some examples of this type of information include information that you electronically submit when you contact us with questions and information that you electronically submit when you complete an online registration form to access and use certain features of the Key Ring App or create an account. If you decline to supply or provide us with certain information while using the Key Ring App, you may not be able to use or participate in some or all of the features offered through the Key Ring App.

 

                Information We Collect Automatically as You Use the Key Ring App or Services

 

We also collect and store non-personally identifiable information that is generated automatically as you navigate through the Key Ring App or use our Services. We may use standard, documented mobile APIs, cookies and similar technologies, and/or third-party ad-serving software (collectively, “information tracking technology”), to collect non-personally identifiable information about users and activity, and we may use this information to, among other things, serve targeted advertisements on the Key Ring App. The information collected allows us to analyze how users use the Key Ring App and to track user interests, trends and patterns, thus allowing us to deliver more relevant advertisements to users.

 

By showing how and when visitors use the Key Ring App, information tracking technology helps us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. It also prevents you from having to re-enter your preferences on certain areas of the Key Ring App where you may have entered preference information before. The Key Ring App or its third-party service providers also may use web beacons (single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users, including those who open HTML-formatted email messages. For both the Key Ring App registered accounts and users without registered accounts, we employ information tracking technology to collect the following information:

 

Non-Personal Information: This is information that, when used in isolation, is not able to identify a natural person, such as an IP address.

 

Device-Related Information: We collect device-related information such as your operating system, identifiers assigned to your device (such as the advertising identifiers assigned by platform providers), SSID, push notification tokens (depending on your settings, see “Your Choices,” below), and the like.

 

Usage Data: We collect information about your application usage, including actions taken such as adding a card or shopping list, completing a shopping list item, time stamps, selections for deleting or sharing a card, and the like.

 

Device Location Information: If permitted by your device, and with your consent, we may collect your location information for the purposes of improving our Services. For more details, please see “Your Choices” below.

 

For more detailed information, see our California Privacy Rights Notice, below.

 

We may also collect information about you and your friends who visit the Key Ring App from any social network you may have connected to the Key Ring App from to provide you a more personalized experience.

 

The information we collect may be collected directly by us, or it may be collected by a third-party website hosting provider, or another third-party service provider, on our behalf.

 

How We Use Information

 

We use the information we collect from you in a variety of ways, including, for example, to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customize features and advertising that appear on the Key Ring App, deliver our content or Services to you, measure traffic, measure user interests and traffic patterns, recognize you as a user, measure promotional effectiveness, help ensure that your account security is not compromised, mitigate risk and prevent fraud, promote trust and safety across the Key Ring App, make our services more useful to you, tailor the experience with us, ensure our Services meet your interests and needs, facilitate communication between us and you, enforce our agreements with you, provide you information we think may interest you such as company news and information about certain products and promotions, deliver marketing materials to you, display third-party advertisements that may interest you, respond to government-issued or other legal requests, and improve the Key Ring App and the Services.

 

In addition, we may use any information submitted by or collected from you via the Key Ring App for any purpose related to the Key Ring App, including to contact you for user service purposes, to inform you of important changes, administration information, or additions to the Key Ring App or Services, and to send you administrative notices and any other communications that we believe may be of interest to you.

 

How We Share Information

 

We may share your information with our affiliates, third-party service providers, and contractors, for purposes related to Key Ring App administration and our Services. We may share your information in response to a request for information if we believe disclosure is in accordance with, or required by, applicable law; if we believe your actions on the Key Ring App are inconsistent with our user agreements or policies or to protect the rights, property or safety of us or others; in connection with, or during negotiations of any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; between and among our current or future parent, subsidiary and/or affiliated companies; with our business partner; with your consent or at your direction; as required to do so by law, in compliance with a legal process or in the good-faith belief that such action is necessary to investigate, protect or to defend the rights, safety or property of us, our customers or the public; to investigate or enforce perceived violations of our Terms of Use or this Privacy Notice; as evidence in litigation in which we are involved; and for fraud protection purposes.

 

If you do not wish your personally identifiable information to be used or shared for these purposes, please contact support@keyringapp.com to request deletion of your information.

 

Your Choices

 

Disabling Cookies

If you want to limit the non-personally identifiable information that is automatically collected while you use the Key Ring App, most Web browsers allow you to disable cookies. To disable cookies using Internet Explorer, select “Internet Options” under the Tools menu and click on “Privacy.” Select “High” or “Block All Cookies.” To disable cookies using Mozilla Firefox, select “Options” under the “Tools” menu. If you choose to disable cookies, you may not be able to use or participate in some or all of the features offered.

 

Opting Out for Device Location Data

When you first download or open the Key Ring App, you may be asked to consent to the collection of location information from your device. If you consent to the collection of this information but later wish to withdraw your consent, you may do so at any time by either changing the settings on your mobile device or deleting the mobile application.

 

Other Options for Opting Out

You can turn off push notifications and limit ad tracking through the settings on your mobile device.  You can opt out of receiving our emails by using the unsubscribe link provided in the email. If you need further assistance or want to delete your account, please contact us at support@keyringapp.com.

 

Links and Third-Party Relationships

 

The Key Ring App may include links to other websites and may provide access to products and services offered by third parties. We are not responsible for the privacy practices or contents of such other websites. When you access another website or purchase products or services from a third party, use of any information you provide is governed by the privacy notice of the operator of the site you are visiting or the provider of such products or services. Please read the privacy statements of each website you visit as this Privacy Notice only applies to information collected by us through the Key Ring App or our Services. Any links to other websites are for your convenience and do not signify our endorsement of such websites or their contents.

 

Notice to Residents in Countries Outside the United States

 

The Key Ring App and our Services are intended for use by residents of the United States only. We do not provide any products or services to non-U.S. residents. If you live outside of the United States, you are not permitted to use the Key Ring App or our Services. Do not register or submit your email or any information to us.

 

If you are located outside of the United States, be advised that any information you provide to us will be transferred to and stored in the United States and that, by submitting information to us, you explicitly authorize its transfer and storage within the United States. We will treat personal information according to this Privacy Notice regardless of where it is processed or stored.

 

California Privacy Rights Notice

 

This portion of the Privacy Notice applies solely to California consumers (“consumers” or “you”). We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  The purpose of this Notice is to provide you with a description of our online practices regarding the collection, use, disclosure, and sale of personal information and of the rights you have regarding your personal information. As used in this Notice, any terms defined in the CCPA have the same meaning when used in this Notice.

 

                Shine the Light

 

Pursuant to Section 1798.83-.84 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, what types of personal information, if any, the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. To access this information, please contact us by emailing support@keyringapp.com with “CA Shine the Light Request” in the subject line. Please note that, under the law, we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any requests that are not sent to the above-designated email.

 

                California Consumer Privacy Act (“CCPA”)

 

                Your Right to Know About the Personal Information We Collect About You

 

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 (“personal information”). The Sections above titled “How We Collect Information,” “How We Use Information,” and “How We Share Information” set forth the categories of personal information that we collect and process about you, a description of each category, and the source of how we obtain each category, which are also set forth further below.

 

                Your Rights and Choices

 

Under California Laws, California residents can exercise three privacy rights (Disclosure and Access; Deletion; and “Do Not Sell My Personal Information”) (collectively, “Rights”). Since we do not sell information, based on our understanding of the definition of “sell” in the CCPA, that right will not be discussed in any more detail. These Rights are not absolute and are subject to certain exceptions, including certain applicant/employment data/relationships and business-to-business (B2B) data/relationships. Further, and by way of example as to the limitations of some of the Rights, we cannot disclose or permit access to specific pieces of personal information if the disclosure or access would present a certain level of risk to the security of the personal information, your account with us, or the security of our systems or networks.

 

A record concerning the requests may be maintained pursuant to our legal obligations. Further, we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

 

                                Disclosure and Access Requests

 

With respect to your right to know the categories of Personal Information we collect about you, under the CCPA we are permitted to refer you to our general practices outlined in this Privacy Notice, because our response would be the same for all consumers and this Privacy Notice discloses all the information that is otherwise required to be in a response to a request to know such categories. Specifically, in the prior 12 months, we have collected the following categories of Personal Information (“PI”):

 

Category of PI

Specific Information

Source

Business Purpose

Third Party to which Disclosed

Identifiers

Name, and/or email address, (only for registered accounts and only if provided)

 

Zip code (only if provided)

 

Device ID, IP address, and device-related information such as SSID

Directly from you, other than device ID, IP address, and device-related information, which are collected indirectly from you, through your use of the Key Ring App

To provide you with our Services, communicate with you, and/or to improve the Key Ring App

Not disclosed (although a third party may collect device ID in their SDK)

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Name, and/or email address, (only for registered accounts and only if provided)

 

Zip code (only if provided)

Directly from you

To provide you with our Services, communicate with you, and/or to improve the Key Ring App

Not disclosed

Protected classification characteristics under California or federal law.

Gender (only for registered accounts and only if provided)

Directly from you

To provide you with our Services, communicate with you, and/or to improve the Key Ring App

Not disclosed

Commercial Information

Loyalty and/or gift card information you provide

Directly from you

To provide you with our Services, communicate with you, and/or to improve the Key Ring App

Not disclosed

Internet or other similar network Activity

Your interactions with the Key Ring App, including device-related information such as operating system

Indirectly from you, through your use of the Key Ring App

To provide you with our Services, communicate with you, and/or to improve the Key Ring App

Not disclosed

Geolocation Data

Your location (latitude/longitude)

Indirectly from you, through your use of the Key Ring App (if you consented)

To provide you with our Services, communicate with you, and/or to improve the Key Ring App

Not disclosed

Inferences drawn from other personal information.

Inferences drawn from the information listed above

Indirectly from you, through your use of the Key Ring App

To provide you with our Services, communicate with you, and/or to improve the Key Ring App

Not disclosed

 

                                Specific Pieces of Information Request

 

In order to view and/or access the specific pieces of personal information we collected about you (also called a data portability request), please contact us at support@keyringapp.com.

 

When a request for disclosure is made, we will first take steps to verify your identity to protect your privacy and security. For requests to disclose specific pieces of personal information collected, we will have the requestor provider at least three pieces of information so that we may verify the requestor’s identity to a reasonably high degree of certainty and additionally provide a signed declaration under penalty of perjury that the requestor is the consumer whose personal information is the subject of the request. We are required to retain the signed declarations as part of our record-keeping obligations for 24 months.

 

Please note additionally that we are only required to fulfill a Disclosure request from a consumer twice per every 12-month period. If you submit a request in excess, it may be denied or you may be charged for fulfilling your request.

 

                            Deletion Request Rights

 

You have the right to request that we delete personal information that we collected about you and retained, subject to certain exceptions. In order to request deletion of the personal information we collected about you, please contact us at support@keyringapp.com.

 

Given the type of personal information we collect, for requests to delete personal information collected, we will have the requestor provide at least two pieces of information so that we may verify the requestor’s identity to a reasonable degree of certainty. We are required to retain the requests to delete for a period of 12 months as part of our record-keeping obligations.

 

A deletion request may be denied, in full or in part, if retaining the information is necessary for us or our service providers to:

 

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

If you need further assistance exercising the Disclosure and Deletion rights described above, please contact us by emailing us at support@keyringapp.com.

 

                            Request Made Through Agents

 

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, verify the agent’s identity, and we may need you to verify your identity directly with us. (The verification requirement does not apply if the consumer has provided the authorized agent with legal power of attorney under California Probate Code Sections 400 to 4465.) Authorized agents can contact us through the email address above.

 

                            Non-Discrimination

 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

 

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  •  

    Children’s Privacy Statement

     

    This Children’s Privacy Statement explains our practices with respect to the online collection and use of personal information from children under the age of 13, and provides important information regarding their rights under federal law with respect to such information.

     

    • The Key Ring App is not directed to children under the age of 13 and we do NOT knowingly collect personally identifiable information from children under the age of 13 as part of the Key Ring App. If we become aware that we have inadvertently received personally identifiable information from a user under the age of 13 as part of the Key Ring App, we will delete such information from our records.
    • Because we do not collect any personally identifiable information from children under the age of 13 via the Key Ring App, we also do NOT knowingly distribute such information to third parties.
    • We do NOT knowingly allow children under the age of 13 to publicly post or otherwise distribute personally identifiable contact information through the Key Ring App.
    • Because we do not collect any personally identifiable information from children under the age of 13 via the Key Ring App, we do NOT condition the participation of a child under 13 in the Key Ring App’s online activities on providing personally identifiable information.

     

    How To Make Changes to Your Information

     

    If you have an account with us, you can make changes to your account information by logging in and using the account tools available. If you have any questions about modifying your account, please email us at support@keyringapp.com.  

     

    Security

     

    Key Ring uses commercially reasonable technical, administrative, and physical safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your information.  We also cannot guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

     

    Questions Regarding Privacy

     

    If you have any questions about this Privacy Notice, our privacy practices, or your dealings with us, you can contact support@keyringapp.com.