Last Revised: June 28, 2019
2. USER CONSENT
3. COLLECTION OF PERSONAL AND NON-PERSONAL INFORMATION
We collect Personal Information in connection with our Services. “Personal Information” means information that can be used to identify or contact an individual and may include, but is not limited to, your first and last name, by itself or combined with your unique user ID, password, gender, date of birth, address, email address, interests, hobbies, photos, phone numbers, your brand preferences, your Facebook, Twitter or other social media handles, any other personal profile or account information you choose to submit through our Services, and (if applicable) your company name and business contact information. Kosher Mobile or its third party payment transaction service providers may also collect credit, debit or other billing account information. If you choose to use our Services’ social networking functions to post information to Facebook, Twitter or another social networking site, we may collect your user ID and password information for that social networking site as necessary to make it easier for you to log in to the Services or to interact with your social networks in other ways (for example, to share Ad Content with your friends on those social networks). Specifically, and without limiting the generality of the foregoing, the Services may allow users to access “Facebook Connect” to interact with friends and to share on Facebook while using Kosher Mobile. Should you choose to use the Facebook Connect feature, Kosher Mobile may collect certain information about you from your Facebook account, which will be specified at the time you first agree to sign in using Facebook Connect. You can edit privacy settings for posts that appear on Facebook or disconnect the Facebook Connect service by using the privacy tools provided through Facebook. Kosher Mobile may also collect your telephone number, which we may use to verify users and prevent duplicative accounts.
Kosher Mobile may also collect non-Personal Information (“Non-Personal Information): aggregate, non-individually identifiable or demographic information. An example of non-Personal Information is system-related information such as IP addresses, click-through and other information related to your use of the Services (for example, we typically track each time you click on Ad Content from your mobile device lockscreen), browser and browser speed, bandwidth of your Internet connectivity, general location of your server, and the pages of our Site or Application that were viewed during a visit. We use this information to provide our Services, manage End User and Advertiser accounts as well as for internal purposes such as to diagnose problems, monitor traffic patterns and otherwise continually improve our Services. Please note that the Services may provide links to third party sites, such as links to the websites of Advertisers and other third-party organizations, businesses, and merchants who have agreed to make Ad Content and offers available to End Users through Kosher Mobile (including, but not limited to Tapsense Inc). We are not responsible for the privacy policies, practices or the content of websites owned by others that you may link to or that may be linked from the Services. Accordingly, we encourage you to review the privacy policies and terms of service of those websites so that you understand how those websites collect, use and share any Personal Information.
Location Data. Through the Services, Kosher Mobile may collect and process information about your actual location (“Location Data”). Kosher Mobile uses various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide Kosher Mobile with information on nearby devices, Wi-Fi access points and cell towers. Kosher Mobile uses your Location Data to deliver the Services, personalize content, tailor the Services to End Users, and as otherwise provided in Section 4 “Use of Personal and Non-Personal Information” below. The Kosher Mobile Services collect information about your location even when you are not actively engaging with the Services or when your device is idle. It is your responsibility to notify users on your account that we may collect and use Location Data from devices.
Your device is also capable of using optional content at your request or the request of a user on your account, offered by third parties that make use of a device’s location information (“Location-Based Services”). You should review the privacy policies of each third party offering Location-Based Service to learn how the location information will be used and protected.
Our directory assistance service (411) may use the location of a device to deliver relevant customized 411 information based upon the user's request for a listing or other 411 service. By using this directory assistance service, the user is consenting to our use of that user’s location information for such purpose. This location information may be disclosed to a third party to perform the directory assistance service and for no other purpose. Such location information will be retained only as long as is necessary to provide the relevant customized 411 information and will be discarded after such use.
4. USE OF PERSONAL AND NON-PERSONAL INFORMATION
5. DISCLOSURE OF PERSONAL AND NON-PERSONAL INFORMATION
If you are an End User, in order to effectively manage the Services, your Personal Information and non-Personal Information (including, without limitation, de-identified, aggregated Personal Information) will be disclosed to Partners, Advertisers, and other business partners to facilitate such account-related activities and to manage and improve our Services. We may also disclose your Personal Information to Advertisers where such sharing is required to deliver products or services you have requested (including but not limited to facilitating your receipt or acceptance of offers or fulfillment or redemption of offers). In addition, we may disclose Personal Information and non-Personal Information to companies, agents, contractors, service providers or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our Site, marketing of our products and services, conducting audits, and performing web analytics). We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues. We may also disclose non-Personal Information to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications. We do NOT sell, rent, share or trade your Personal Information to third parties for their own marketing purposes unless you have granted us permission to do so.We may, however, allow advertisers to request that their advertisements are directed at certain users (e.g., users in a certain geographic location, or age, gender and/or with certain interests). In the event that you interact with a certain Advertisement, the advertiser (or Kosher Mobile with which the advertiser works, for example, its ad agency or an advertising network) may determine certain characteristics about you.
Please note that technical limitations may, in some circumstances, prevent you from blocking the transmission of caller identification information when you make a call using your wireless device. If so, your billing name may be displayed along with your wireless number on outbound calls to other wireless and landline phones with Caller ID capability and may also be shown on the bill of the person receiving your call.
Please note also that if you choose to use our social networking function to post information to Facebook, Twitter or another social networking site, anyone who has access to your information through that other site will be able to see your information.
6. ACCESSING AND UPDATING PERSONAL INFORMATION
When you use our Services, we make good faith efforts to provide you with access to your Personal Information and to either correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Please e-mail us at email@example.com if you need assistance accessing or changing your Personal Information or if you would like to have your Personal Information deleted. Please be aware that if you delete your Personal Information, you may not be able to continue to use the Services. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.
Applicable laws require Kosher Mobile to take steps to protect certain information, known as “customer proprietary network information” or “CPNI” from unauthorized disclosure or use. Among other things, Kosher Mobile will require verification of your identity before you are permitted to access your account, whether to make changes to your service, including, but not limited to, suspending, deactivating, adding new service, or changing service, or to obtain usage details, account balances, or other details regarding your account or service. Consistent with applicable laws, Kosher Mobile will provide information relating to your service or account , including CPNI, upon the direction of any person able to provide information Kosher Mobile deems sufficient to identify such person as a Kosher Mobile subscriber.
7. COOKIES AND AUTOMATIC INFORMATION GATHERING TECHNOLOGIES
A) Tracking Technologies
B) Information Collected by Tracking Technologies: Targeted or Behavioral Advertising.
Targeted advertising (also known as behavioral advertising) uses information collected aboutan individual’s web browsing or mobile application behavior, such as the pages they have visited or the searches they have made to target advertising to the user based on this behavior. This information is then used to select which advertising should be displayed to a particular individual on websites or mobile applications. For example, if you have shown a preference for a certain product while visiting the Site, you may be served an advertisement from or about the Site for the same or a similar product when you visit a site other than the Site. The information collected is only linked to an anonymous ID (alphanumeric number); it does not include any information that could be linked back to a particular person, such as their name, address or credit card number. The information used for targeted advertising either comes from Tracking Technologies, our Services, or third parties. The information collected by the Tracking Technologies allows us or third-party advertisers to deliver, and gauge the effectiveness of, targeted advertisements, both on our Services and when you are browsing other websites. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative ( www.networkadvertising.org ), which offers a single location to opt out of ad targeting from member companies. In addition to the uses specifically set forth above, Kosher Mobile may use and disclose Non-Personal Information collected through the use of Tracking Technologies for any purpose in its sole discretion.
We do not knowingly collect Personal Information from individuals under 13 years of age. Nor do we authorize users who are less than 13 years old to use the Services (including, without limitation, the Application and Site). If we learn from the individual or from the individual’s parent or legal guardian that we have collected Personal Information about a person under the age of 13, we will make efforts to delete their Personal Information from our systems within a commercially reasonable period of time.
10. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to protecting the security of your Personal Information. We utilize reasonable information security measures to safeguard your Personal Information. For example, industry-standard encryption (Hyper Text Transfer Protocol Secure a/k/a “https”) is used to protect communications between our servers and our Users’ web browsers and mobile devices. Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security. You are responsible for keeping the username and password you use for accessing our Services confidential. We ask you not to your username or password with anyone. The information you provide and that we collect from you will be stored on our servers and/or other third party providers (e.g.,AWS)indata centers located in the United States. When you use our Site on your computing device, your information may be stored locally on that device as well. We retain information collected about you indefinitely for business, legal, or taxpurposes.
12. CALIFORNIA PRIVACY RIGHTS
13. PUBLIC MESSAGE BOARDS AND OTHER ONLINE FORUMS
Please note that when you choose to post messages and/or profile content on message boards and other online forums that we may make available through our Services, such content is viewable by third parties and, in the case of public online forums and any public profiles, is publicly viewable. Accordingly, you should exercise discretion with regard to what Personal Information you post on our Services and you should not post highly confidential or sensitive information. Kosher Mobile is not responsible for how third parties who view your Personal Information may use this information (such as to send you unsolicited messages).
14. NOTIFICATIONS FROM Kosher Mobile
Consistent with applicable laws, Kosher Mobile or its authorized agents may contact you by regular mail, predictive or autodialing equipment, email, text messaging, facsimile or other reasonable means to inform you about our services or other matters Kosher Mobile may believe to be of interest to you.
16. HOW TO CONTACT US
Kosher Mobile Inc.
Attn: Privacy Matters
215 3rd Avenue
Kirkland, WA 98033