Kitely

Privacy Policy

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Privacy Policy Our Privacy Policy explains how Kitely collects, uses, and discloses information about you. The terms "Kitely", "we", "us", and "our" refer to Kitely Ltd. We use the terms "Kitely Services" or "Services" to refer to our products, software, services or web site. We use the terms "you", "your", and "user" to refer to any person using Kitely Services. We use the term "Virtual World" to refer to a 3D virtual environment that can be visited by avatars belonging to our users or users of third-party service providers (such as other OpenSim grid operators). We use the term "Admin User" to refer to a user who manages other users' use of our Services using an Organization. We use the terms "Virtual Grid" and "Organization" to refer to Services that enable Admin Users to manage groups of users and Virtual Worlds. We use the term "Managed User" to refer to a user whose access to our Services is managed by an Organization. We use the term "Independent User" to refer to a user whose access to our Services isn't managed by an Organization. Why do we store any information at all? We care about your privacy and aim to minimize the amount of information we keep about you. However, we can't provide services that require information without storing that information. For example, we can't display a comment that was posted on our forums if we don't store that comment, the time it was posted and the identity of the user who posted it. But why do we track who changes some types of information and when? The answer is we can't fix bugs or protect the security of our system if we don't keep records of when information was modified and by what or whom. Otherwise, if something happens to your account we won't be able to detect it and we'll have no way to investigate why it happened. In addition, we can't comply with laws that regulate the storage of some types of information, such as transaction records, without storing detailed records for those types of activities. Admin Users also need to have access to this kind of information in order to effectively manage their Organization and support its users. To be clear, there are several reasons why we keep information but we never keep records of events and communications held inside Kitely Services for longer than we have to. We also do not share the information we collect with third parties unless we are required to do so by law or sharing that information is required for providing the Services you used. For example, we'll show people your name and what you wrote if you post that information to our forums, but we won't create a profile of your posts and sell it to some advertiser. As another example, our system will save the private chat messages you send inside Virtual Worlds, but only for as long as is required to deliver these messages to the avatars you sent them to. In addition, our system won't keep a record of you having sent these messages if that record isn't required for providing any of the Services you elected to use. This isn't an exhaustive list of why we keep records, but it's important that you keep this in mind as your read our privacy policy. You can read the complete list of reasons we collect data in the "How do we use this information?" section below. What kinds of information do we collect? We collect different kinds of information from or about you, depending on which Kitely Services you use. Things you do and information you provide We collect the content and other information you provide when you use Kitely Services, including when you create an account, modify your account, upload and post content, and message or communicate with others. This can include information in or about the content you provide, such as where it was posted to and when, and the copyright and licensing information of that content. We also collect information about how you use our Services, such as the time and duration of your visits to Kitely-hosted Virtual Worlds, and the groups your avatar joins. Information about transactions you are involved with We collect information about all the transactions you are involved with via Kitely Services, both ones made using Kitely Credits and ones made using PayPal. This includes information about the PayPal account identifiers and the identity of the PayPal account owners that are involved in a transaction. This does not include the billing information that you and the other party to the transaction provided PayPal, as that information is kept securely by PayPal and is never shared with us. Things others do and information they provide We collect content and information that other people provide when they use Kitely Services, including information about you, such as when they send you messages, send you friend or group invites, or mention you as the creator of some content they uploaded into our system. If you access parts of our Services that are managed by an Organization then that Organization may also enter information about you into our Services. For example, if you are a Managed User then the Admin User who creates your Kitely account will need to provide us with some of the same information you would be asked to provide us if you were to create an Independent User account yourself. Your networks and connections We collect some information about the people and groups you are connected to and how you interact with them, such as your group messages, who visited your Kitely-hosted Virtual Worlds, and the comments you exchange with other people on Kitely Market product listings. Your device information We collect information from or about the computers, phones, or other devices you use to access Kitely Services. We may collect this information manually by asking you for it when you make a support request, and we may collect it automatically, depending on the need and the permissions you've granted our Services to do so. We may associate the information we collect from your different devices to help us provide you with a consistent service across all these devices. The device information we collect varies depending on the device, but may includes such things as: <ul> <li>Device attributes such as the device's operating system, hardware version, settings, file and software names and types, and device identifiers.</li> <li>The geographical locations of the devices from which you're trying to access our Services.</li> <li>Connection information such as the name of your ISP, browser type, time zone, and IP address.</li> </ul> Information from third-party providers that use Kitely Services We collect information when you access Kitely Services via third-party services that use our API. This includes information about your use of our Services via those APIs, as well as information the third-party service provider shares with us about you. An Organization may define events relating to your use of the Organization's Virtual Worlds and use our API to keep track of when those events occur. For example, a school Organization may track its users' completion of school assignments that take place inside the school's Virtual Grid. Information from third-party providers that Kitely Services uses We have access to some of the information that is gathered about your activities on Kitely Services by third-party components that are integrated into our Services, such as Google Analytics and DISQUS. While some of your interactions with these components may include providing them with your personal information, we do not keep copies of the personally identifiable information that these third-parties may collect about you. You can configure what information these components collect about you on their respective websites and apps. How do we use this information? We want to provide you with the best service that we possibly can and we use the information we collect to help us provide you with that service. This is what we use this information for: To provide and improve our Services As mentioned previously, we store information first and foremost in order to provide the Services you elect to use that require that information to work. Some parts of our Services are personalized. We use the information we collect in order to provide you with those personalized experiences, such as showing you a personalized Kitely Market homepage based on your previous activity in Kitely Market. Some parts of our system enable you to get reports of who interacted with your account. For example, your account history includes the list of users who have visited your Kitely-hosted Virtual Worlds, when they did so and for how long. Similarly, your purchase history and sales history pages include a list of your Kitely Market transactions with other users. We also use the information we collect to troubleshoot our systems, conduct audits, conduct surveys, research how our Services are used, test features in development, evaluate and improve existing Services, and develop new Services and features. Finally, if you choose to use Services that are managed by an Organization then we need to store the information that the Organization needs for its use of our Services. To communicate with you We use the information we collect to be able to provide you with useful responses when you contact us for help. We also use that information to inform you about problems we've detected relating to your Kitely account or your use of our Services. Depending on your account privacy settings, we may also use your information to send you marketing information, send you information about our Services, and let you know about changes to our policies and terms of service. To provide statistics and usage analytics Some parts of our Services provide you with aggregate an anonymized statistics about how people use these Services. For example, Kitely Market merchants can view analytics regarding how people have interacted with their Kitely Market products and ads. If you choose to use Services that are managed by an Organization then that Organization may also get some statistics and usage analytics that relate to your use of those Services. To protect our users and our Services from harm We use the information we collect to preserve your safety and the security of our Services. For example, we use that information to investigate suspicious activity, abuse reports, and other potential violations of our terms or service. We may then use that information to respond to those violations by, for example, contacting the people involved and, if needed, suspending, deleting or banning the offending parties and/or content from Kitely Services. If you choose to use Services that are managed by an Organization then that Organization may use the information that we provide it to protect its users and Virtual Worlds in similar ways. How is this information shared? We implement a variety of security measures to maintain the safety of your personal information while it is being accessed and stored. That said, enabling people to connect and communicate with others is a key aspect of our Services. We enable this sharing of information in the following ways: People you communicate or interact with When you communicate using our Services, you choose who you share that information with. For example, when you share information in the publicly-accessible sections of our forums, anyone visiting that part of our forums can view your account name, account profile, and the information you shared. When you post to a group, anyone belonging to that group may see similar information. Finally, when you send a private message to someone, only that person will see that message. Any information which is shared in publicly-accessible parts of Kitely Services will be viewable by anyone accessing Kitely Services, even as anonymous visitors to our website. Some of your interactions with other users are recorded in both your and their Kitely accounts. For example, your visits to other users' Virtual Worlds are logged both in your and in their account history pages. Similarly, your purchases from Kitely Market will be recorded both in your purchase history page and in the sales history pages of the users whose Kitely Market stores you bought those items from. Other than for the reasons explained previously, Kitely doesn't keep records of communications held inside Virtual Worlds. However, some Virtual Worlds you may visit with your Kitely avatar (that are hosted by us or on third-party systems) may contain third-party scripts that will record your avatar's activity and/or communications. In addition, avatars who are party to communications you participate in may be recording or transcribing these communications without your approval. Furthermore, anyone who you shared information with may be keeping records of that information without your approval. Kitely has no way to prevent the creation of these recordings nor are we able to protect the information that they contain. Finally, an Organization whose Virtual Worlds you visit may use our API to record certain events relating to your activity inside those Virtual Worlds. We will handle the information that is stored on our system using our API as per our Privacy Policy but, as stated above, information may be recorded by people in other ways we don't control. Therefore do not use Kitely Services to share any sensitive information or information that you or others wish to keep private. Kitely will not be able to protect that information inside Kitely Services and we'll be unable to control its distribution outside Kitely Services. People that see content others share about you Other people may use Kitely Services to share content about you. For example, people may share a photo that includes your avatar participating in an event, or share information about you that you shared with them. If you believe that what was shared inside Kitely Services violates our terms of service then please ask the person who shared it to remove it and, if they don't comply with your request, then report the incident to your Admin User or to us. Third-party systems that are integrated with our Services Third-party systems that use, or are integrated with, Kitely Services may receive information about you, your activities in Kitely Services or what you share via their systems. For example, when you post a comment on our forums using the DISQUS comments system we use, the company that operates DISQUS will store your comment and various other identifiers as per its own privacy policy and terms of service. Other examples of Kitely Services that are provided by third-party controlled systems are our wiki (Atlassian) and the website analytics system we use (Google Analytics). Vendors, service providers and other partners We do not sell, trade, or otherwise transfer your personal identification information to others for reasons not listed in our Privacy Policy. This does not include trusted third parties who assist us in operating or developing our Services, conducting our business, or servicing you, so long as those parties agree to adhere to strict confidentiality obligations in a way that is consistent with this Privacy Policy and the agreements we enter into with them. However, non-personally identifiable information may be provided to other parties for marketing, advertising, or other uses. How do we protect information? Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are legally or contractually required to keep the information confidential. We do not keep the billing information that you configured for your PayPal account. That information is kept securely by PayPal and is never shared with us. When you buy or sell items in Kitely Market you will only share your PayPal account identifiers with Kitely. We will act as a middleman in the transaction and the other party will only ever see our own PayPal account identifiers. You can therefore securely buy and sell items on Kitely Market without sharing any part of your billing information with the other party to your transactions. When you interact with an Organization as an Independent User, or a Managed User who isn't managed by that Organization, we will only share the publicly accessible parts of your account profile with that Organization. For example, an Organization whose Virtual Worlds you visit will be able to see your account name and the name of your avatar in its Visits logs, but that Organization won’t receive your email address, age range or account maturity rating. How can you manage or delete information about yourself? You can manage the information you share when you use our Services using the edit and delete functions that are provided in the places where you posted that information. For example, you can manage information you post to our forums, on the forums. Similarly, if you are an Independent User, you can manage information relating to your Kitely account using your account Settings page. As an Independent User, you can also use the account Settings page to download information associated with your account. Furthermore, as an Independent User, you can use the account Settings page to delete your account at any time. When you delete your account, we delete things you have posted, such as your photos and status updates. If you do not want to delete your account, but want to temporarily stop using our Services, then contact us and we'll deactivate your account instead. We plan to add the aforementioned functionality for Managed Users as well. Until that happens, you can contact us to get the information that is associated with your account. If you wish to delete your account then contact your Organization's Admin User. Let us know if that person fails to remove you from our system in a timely manner. Keep in mind that information that others have shared about you is not part of your account and will not be deleted when you delete your account. How long do we store information? We retain information for the minimum amount of time needed to satisfy the purpose for which the information was collected: <ul> <li>Information that you provided us that is crucial for the operation of the services you've opted to use will not be removed until it has completed serving it purpose (e.g. the chat message has been delivered to all the required recipients) or it has been manually deleted by all the people who've gotten a copy of that information for that purpose.</li> <li>Information relating to Kitely Credits transactions and PayPal transactions will be stored indefinitely in order to comply with anti-money laundering and accounting regulations.</li> <li>For security reasons, information that contains personal identifiers of deleted accounts may be kept internally for up to 30 days before it is removed from Kitely Services. However, this information may be kept indefinitely if we have a good faith belief that doing so would be required to comply with legal requests such as a search warrant, court order, or subpoena. Similarly, this information may be kept indefinitely to prevent repeat abuse or other violations of our terms of service.</li> <li>We keep automatic backups for up to 90 days after the information has been removed from our Services. A copy of anything that is removed from Kitely Services may therefore continue to exist in our backups for an additional 90 days before it is completely deleted from our system.</li> </ul> Do we use browser cookies and other storage technologies on your device? Cookies are small files that websites can use to store information on your device through your web browser. Such browser cookies and similar technologies (which we'll refer to collectively as "Cookies") are used by the website to recognize your browser and remember certain information relating to your use of that website. You can delete our Cookies at any time. You can also configure your browser to disable Cookies. However, many parts of our Services won't work properly or at all if your browser is configured to prevent our website from storing our Cookies on your device. We use Cookies to: <ul> <li>Verify your account and determine when you're logged into our Services and from what device. We can't log you into our website without them.</li> <li>Help us keep your account, data and the Kitely Services secure. For example, we use Cookies to help us track hacking attempts into our system and other violations of our terms of service.</li> <li>Help us compile aggregate data about site traffic and site interaction so that we can improve our existing Services and develop new ones.</li> <li>Enable the functionality that helps us provide our Services.</li> <li>Improve our site performance or accessibility.</li> </ul> Our Cookies are used when you access Kitely Services directly or via a third-party that uses Kitely Services. How do we respond to legal requests and prevent harm? We may access, collect, process, preserve, and disclose your information and any information associated with you if we're required to do so by law or in a good faith belief that such access, collection, processing, preservation or disclosure is reasonably necessary to: <ul> <li>Satisfy any applicable law, regulation, legal process or enforceable governmental request. This may include responding to legal requests both from Israel and the United States (where we operate), or from other jurisdictions, if we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.</li> <li>Enforce our terms of service, including investigation of potential violations of these terms.</li> <li>Detect, prevent, or otherwise address fraud, security or technical issues (including, without limitation, the filtering of spam).</li> <li>Protect against imminent harm to the rights, property or safety of Kitely, its users or the public as required or permitted by law.</li> </ul> What about third party links? Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies and terms of service. We therefore have no responsibility or liability for the content and activities of these linked sites. We also allow you to use your Kitely avatar to visit Virtual Worlds that are operated and owned by third parties outside Kitely Services. These other Virtual Worlds may also have their own privacy policies and terms of service. We therefore have no responsibility or liability for your data, quality of service, loss of data, loss of service, and activities while using your Kitely avatar to visit Virtual Worlds that are not operated and owned by us. Nonetheless, we seek to protect the integrity of our site and virtual world and welcome any feedback about these sites or Virtual Worlds. How to ensure that you are compliant with the European Union's General Data Protection Regulation (GDPR) We've designed our Services to comply with the GDPR. When you use our Services it is our responsibility to ensure GDPR compliance for the information that we collect. All of the information that we provide to you via our user interface is handled in a GDPR-compliant manner. If you work in, or are a resident of, a European Union member state and believe that Kitely is not responding to its GDPR obligations relating to your personal data then you have the right to lodge a complaint with the relevant supervisory authority, subject to applicable law. For you yourself to remain compliant with the GDPR you need to consider what personal data belonging to other people you export from Kitely. For example, you may create GDPR obligations for yourself if you use our Reports feature to save data from Kitely to your own device, or if you save a chat log to disk. In order for your use of other people's information to remain GDPR-compliant: <ul> <li>Do not keep data that contains other people's information for more than 30 days after it has been copied from our Services, unless you have a legal requirement to do so (e.g., you may keep your store's Sales History report for accounting purposes, even though it contains the names of the people who bought from your store).</li> <li>Do not share other people's information with third parties unless you can ensure that the third parties will handle the data in a GDPR-compliant manner.</li> <li>Ensure that anyone who received a copy of other people's information that you exported from our Services will delete that data within 30 days of when you exported it.</li> </ul> None of this applies to information about you that you export from Kitely Services, because you have full ownership of your own personal data. Please note that this guidance is intended to help you avoid issues that we know you may encounter. If you intend to use other people's information outside of Kitely Services then you should seek independent legal advice about your status and obligations under the GDPR. Nothing in our Services is intended to provide you with, nor should it be used as a substitute for, legal advice. How will we notify you of changes to this policy? We can update this privacy policy at any time. When we do so, we will update the policy revision date at the bottom of this page. If it's a significant change then we'll also notify you by email (but only if you've enabled the "News and updates" email notification type.) How to contact us If you have any questions or remarks about this privacy policy, our practices, or your dealings with our Services, then please use our contact page to contact us. Policy revision date This document was last updated on January 11, 2019.