KICKICO Privacy Policy

Last updated as of September 30, 2020

General purpose.

This Privacy Policy explains how KICKICO (“KICKICO” or “we”, “us”, “our”) collects, uses, shares, and protects personal and other types of information obtained when User (“you”) visit KICKICO.com (the “Site”). To provide you with our Services, we might need, including in cases when we are obliged by law, to collect your personal data. By accepting this Privacy Policy and using the Site, you consent to the data practices described in this Privacy Policy. If you do not agree with our practices, please do not use our Site and the Services. This Privacy Policy applies to the Site and all Services offered by KICKICO. Furthermore your access to and use of the Site and Services is also subject to the KICKICO Terms of Use.


We use the following legal basis for the personal data processing:

1) Consent: before using our Site and our Services you should read this Privacy Policy carefully and check the box for confirmation that you understand and agree with this Privacy Policy. If you do not agree with our practices, please do not use our Site and any services we provide. By consenting to this Privacy Policy you give us permission to process your personal data specifically for the purpose identified.

2) Contract: if you have entered into agreement with us, we have to store and process your personal data for the purposes of performance of such agreement.

Information we collect.

1) Personal information: We collect personal information which you provide to us in a variety of ways, including, but not limited to, when you visit our Site, create an account, go through the identification procedure, place an order, and in connection with other activities, services, features or resources we make available on our Site. Such personal information consists of: your full name (including former name and names in local language), username, email address, phone number (for SMS or Google Authenticator account will be used 2FA verification for improved security), your residential address and proof of residency (e.g. utility bill, bank account statement), country of residence and/or citizenship, date of birth, passport or any government-issued ID details (including number of the document, country of issue, date of issue and expiration, address etc.), details of any requests or transactions you make through the Service, and communications you send to us or submit to the Site (“Personal Data”);

2) Aggregate and anonymous data: Aggregate and anonymous data is information that does not identify you specifically, including data collected automatically when you enter our Site (“Non-Personal Data”). This may include cookies, pixel tags, web beacons, browser analysis tools and web server logs. This also includes information from the devices you use to access our Site or mobile platform, your operating system type or mobile device model, browser type, browser plug-in types and versions, domain and other system settings, as well as the language your system uses and the country (geolocation) and time zone of your device. Our server logs may also record the IP addresses of the devices you use to interact with the Site. We may also collect information about a website you were visiting before you came to our Site and any website you visit after you leave our Site, if this information is supplied to us by your browser. We may also use software tools, such as Java script, to measure and collect session information, including page response times, download errors and methods used to browse away from the page. This Non-Personal Data may be directly obtained by KICKICO or through third party services or payment providers. This service data helps us and our systems to ensure that our interface is accessible for users across all platforms and can aid during fraud cases or criminal investigations.

How we use Personal Data and Non-Personal Data.

We use Personal Data and Non-Personal Data to:

1) Fulfill our obligations under any contracts concluded with you, as well as to administering, processing and/or dealing with any matters relating to your use of or access to the Site, including identifying you for login to the Site and rendering you other Services which are provided by us or on our behalf;

2) Build, operate and improve our Site and the Services;

3) Perform monitoring, tracking and analysis of using the Site by you in order to provide you with a seamless experience, facilitating your use of the Site, and/or to assist us in improving your experience of using the Site;

4) Administering and/or processing any transactions or activities carried out by you on the Site or with our participation, including processing your applications, orders and payment transactions, implementing transactions and the supply of products and/or Services to you that you have requested;

5) Provide you customer support, communicate with you and send you additional information that may be interesting for you such as, for example, information on projects that we believe may be interesting for you based on your geographic location and your previous use of the Service;

6) Send you reminders, technical notices, updates, security alerts as well as support and administrative messages;

7) For marketing purpose provide you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events;

8) Carry out due diligence or other screening activities in accordance with legal or regulatory obligations applicable to us, the requirements or guidelines of governmental authorities which we determine are applicable to us, and/or our risk management procedures that may be required by law or that may have been put in place by us;

9) Prevent or investigate any fraud, unlawful activity or omission or misconduct, in a case of any suspicion of the aforementioned, and/or investigating complaints;

10) Manage our everyday business activities such as administering, processing and/or dealing with your relationship with us, as well as for administration of the Site and the Services.

When and why we disclose Personal Data and Non-Personal Data.

We do not sell, trade, or rent your personally identifiable information to third parties. We may share generally aggregated demographic information which is not linked to any personally identifiable information related to visitors and users of the Site and the Services with our business partners, trusted affiliates and advertisers for the purposes outlined above.


For the purpose of providing the services you requested we may share your Personal Data and Non-Personal Data with any member of our company group and to the following third parties:

(a) Service providers, banks and payment providers regarding Service obligations on transactions, and advisers who provide us with administrative, financial, research, operational, IT or other services, such as telecommunications, information technology, storage and archival, on contractual basis;

(b) Transaction counterparties, business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or with you;

(c) Advertisers and advertising networks that require the data to select and serve relevant ads to you and to others;

(d) Government agencies, including regulators, law enforcement and/or justice departments;

(e) To a third party, in the event that we transfer to it our rights and obligations under a contract;

(f) Any other third parties under and after your consent to share the information with them.


Except as provided herein, we will not display on the Site, or otherwise disclose your Personal Data to any third parties unless it is necessary to provide you the Services, when required by law, or if we believe in good faith that such action is reasonably necessary to:

(a) Comply with current judicial proceedings, a court order or legal process served on us;

(b) Protect and defend our rights, property and interests, including by enforcing our agreements, policies and Terms of Use;

(c) Respond to claims on violation by any submitted content the rights of third parties;

(d) Respond to your requests for customer service;

(e) Protect the rights, property or personal safety of KICKICO, its members and the public;

(f) 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;

(g) or for other purposes with your consent to the transfer of information.


If you have created an account at KICKICO, some information about you will be publicly available, such as:

(a) Your account name (nickname);

(b) Any information you choose to add to your profile (such as a picture, bio and/or your location);

(c) Projects you’ve backed;

(d) Projects you’ve launched;

(e) Any comments you’ve posted on the Site.

If you are a Backer, we will share your account name and the amount of your donation with the Project Creators. We will also share your payment information with our third-party payment processor. If you are a Project Creator, you will be asked to verify your identity before the project launch. Every Project Creator’s verified name will be publicly displayed on their profile and on any pages of the projects they launch.

We may share Non-Personal Data with analytics companies to learn information about how our users interact with the Site. This enables us to optimize our Site, improve performance of our system and databases, and improve quality of the Services we provide. See also “Third Party Analytics” below. We will never sell your Personal Data or Non-Personal Data.

How we protect your Personal Data.

We employ generally accepted industry standards to protect your Personal Data and we continuously strive to protect your information and privacy as much as we can. Unfortunately, no data transmission over Wi-Fi or the Internet can be 100% secure. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us online.

At the same time our data security measures include, but are not limited to PCI Scanning, pseudonymisation and TLS 1.3 encryption of personal data, internal data access restrictions, and strict physical access controls to database, servers and files.

Exchange of sensitive and private data between the Site and its Users is carried out under a SSL secured communication channel and is encrypted and protected with digital signatures. Our Site is functioning in compliance with Payment Card Industry Data Security Standard in order to create environment for Users as secure as possible.

We will take necessary measures for your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable if the purpose for which that Personal Data was collected is no longer requires storage and maintenance of such Personal Data, and also such retention is no longer necessary for any other legal or business purposes.

Personal Data that we collect from you can be transferred and stored outside the British Virgin Islands and/or EEA. The information we collect and store about you can be processed by our employees or employees of service providers outside the British Virgin Islands and/or EEA. Such employees, among other things, can process your requests, transaction details and provide technical support.

When storing or otherwise processing information by such third parties outside the British Virgin Islands and/or EEA, we guarantee that we will notify such third parties of our obligations under this Privacy Policy and will enter with them into relations that will impose obligations for them regarding your personal data, provided that they at least have level of protection as specified in this Privacy Policy.

Your rights.

You can use the following rights in relation to Personal Data:

(a) You can opt-out of receiving our emails by following the unsubscribe instructions included in each such email or by contacting us at ad@kickico.com.

(b) You may request that we provide you a copy of your Personal Data held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law);

(c) You may request us to rectify or update any of your Personal Data held by KICKICO that is inaccurate;

(d) You may request to delete your Personal Data, subject to applicable law. If you close your KICKICO account, we will mark your account in our database as "Closed", but will keep certain account information and Personal Data, including your request to erase, in our database for a period of five (5) years after request for deletion is received, or last transaction occurred or after any other using of KICKICO Services in accordance with legal requirements. However, if you close your account, your Personal Data will not be used by us for any further purposes, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy;

(e) To the extent the processing of your Personal Data is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of KICKICO's processing based on consent given before your withdrawal;

(f) In some cases, applicable law may give you the right to restrict or object to our processing of your Personal Data under certain circumstances. We may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

(g) If you are of the opinion that we do not process your Personal Data in accordance with the statutory regulations, you have a right of appeal to a competent supervisory authority.

Third party analytics.

This Privacy Policy regulates only the use and disclosure of information by KICKICO. We may use analytics services to help us analyze the information we have collected from you. These analytics services may use cookies, web beacons and other devices and technologies to track traffic data. Data that they collect typically includes, but is not limited to, your IP address, your ISP, the browser you use to visit our Site. This Privacy Policy does not apply to, and we are not responsible for, such technologies placed by third party analytics services.

Cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. A cookie in no way gives us access to the files on your computer or to any data about you, other than the data that you provide and some of the activities that you carry out on our Site.

We use cookies to improve the functionality of this Site and to track information about how the Site is used in order to continually improve it and personalise it to user’s preferences. Also we use cookies to identify you from other users on the Site and in order to remember you when you have logged in for a seamless experience.

Data collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on the Site by recognising and delivering more of the most desired features and information, as well as by resolving access difficulties.


We use the following types of cookies on our Site:

(a) Persistent cookie. A persistent cookie consists of a text file sent by a web server to a web browser, which allows us to collect and analyze (on an anonymous basis) traffic and use of this Site, monitor the system and improve operating performance, for example, store your preferences to enhance your subsequent visits. It will not be automatically deleted when the browser is closed but is stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date).

(b) Session cookie. A session cookie is essential to ensure the correct functioning of this Site and is used to manage registration/login and access to reserved features. It is stored temporarily during a browsing session will expire at the end of the user session, when the web browser is closed.

(c) Strictly necessary cookie. Strictly necessary cookies enable you to move around the Site and use features which you have explicitly requested. You can disable other forms of cookie whilst allowing strictly necessary cookies.


We may use third party service provider(s), such as Google Analytics, to assist us in better understanding the use of our Site by providing them information on cookies. Our service providers analyses this information and provides us with aggregate reports that will be used to assist us in better understanding our visitors' interests in our Site and how to better serve those interests. The data collected by our service providers may be linked to and combined with information that we collect about you while you are using the Site. Any our service provider is contractually restricted from using information they receive from our Site other than to assist us.

You can block or deactivate cookies in your browser settings. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set up and how to manage and block/disable them, visit www.allaboutcookies.org.

Please remember that disabling or deleting some or all cookies may prevent some web services (including this Site) from functioning correctly, and may lead to a less smooth or less personalised browsing experience.

We may update this cookie notice from time to time to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. If we do so, you will be notified when you first visit our Site after the change. You can also revisit this page if you wish to keep yourself informed.

How long we keep your Personal Data.

We will retain your Personal Data only for as long as it is necessary for us to do so, with regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In accordance with our record keeping obligations we will retain accounts and Personal Data for a period at least of five (5) years after our user closes his or her account and terminates legal relationships with us and/or from the end of the tax period in which the user conducts his or her last transaction.

In some circumstances we may retain your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, an investigation by the government or an investigation into possible violations of our terms and conditions, or in other cases to prevent possible harm based on our reasonable considerations.

Personal Data is stored for regulatory purposes only and your Personal Data that is no longer required will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access for relevant authorities.

Automated decision making and profiling.

Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data, for example processing using software code or an algorithm, which does not require human intervention.

KICKICO does not engage profiling or automated decision-making in respect of its users whose Personal Data it processes. However, we may do so in order to fulfill obligations imposed by law or to determine your individual risk level and whether a transaction or a user account presents a fraud or legal risk.

Children.

KICKICO Site and Services are not directed at users under the age of 21, and does not consciously collect any Personal Data from anyone under the age of 21. We request that all KICKICO users be at least 21 years old (or a legal age in your jurisdiction). If we become aware that a person under the age of 21 has provided us with personal information, we'll delete it immediately.

Modifications of this Privacy Policy.

We may occasionally modify the Privacy Policy to reflect changes in law or our personal data collection and use practices. If any changes are made to this Privacy Policy, the changes will be announced by posting on the Site. All changes will be effective upon posting on the Site. You can determine when the Privacy Policy was last revised by referring to the “Last updated” legend at the top of the page. You agree to be bound by any such changes if you continue to use the Site after such changes have been posted. We may change, restrict access to, suspend or discontinue the Site or the Service, or any portion thereof, at any time.

Questions about our Privacy Policy

If you have any questions or concerns regarding this Privacy Policy, or any other queries in relation to how we may manage, protect and/or process your personal data, you may contact us by e-mail at info@kickico.com.