KiwiSign Privacy Policy
KiwiSign, IdeaSeat and its subsidiary companies and affiliates (“KiwiSign”) are committed to and have a long-standing policy of maintaining the privacy and security of your personal information. Personal information is information about an identifiable individual (as defined by applicable privacy or data protection laws).
The KiwiSign Privacy Policy describes KiwiSign’s practices with respect to the processing of your personal information which includes the collection, use, processing, transfer, storage or disclosure of your personal information, except where a KiwiSign subsidiary or affiliate has published its own separate privacy policy. In addition, agreements or notices associated with a particular KiwiSign product, service, software or website (“KiwiSign Offering”) may provide additional information about KiwiSign’s processing of your personal information (“Notice”). The application of the KiwiSign Privacy Policy remains subject to applicable laws including legislation, regulations and the orders of courts or other lawful authorities, other lawful requests or legal processes. Where applicable, the KiwiSign entity with whom you have entered an agreement is the data controller of your personal information.
- Accountability
KiwiSign is responsible for personal information under its control, including the onward transfer of personal information to a third party for processing on KiwiSign’s behalf.
- Purposes for Using Your Personal Information
When you use a KiwiSign Offering, correspond with KiwiSign, enter a contest sponsored by KiwiSign or otherwise interact with KiwiSign, KiwiSign may process your personal information for the following purposes:
to understand and meet your needs and preferences, and to provide you with KiwiSign Offerings, e.g.:
- for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, repair, refurbishment, replacement, upgrade or update of KiwiSign Offerings;
- to ensure KiwiSign Offerings are technically functioning as intended and to help identify and troubleshoot issues;
- to understand your use of the network or KiwiSign Offerings by interpreting network performance and use metrics
- to fulfill or enforce Notices applicable to a KiwiSign Offering;
- to manage or respond to your inquiries;
to develop new and enhance existing KiwiSign Offerings including to communicate with you about them using various means, e.g. to make available or send to you:
- upgrades or updates, or notices of upgrades or updates of KiwiSign Offerings or third party content or related products, services and software;
- notices of promotions and upcoming events;
to manage and develop our business and operations, e.g.:
- to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect KiwiSign property;
- to allow for business continuity and disaster recovery operations;
- to enforce KiwiSign’s legal rights;
- for statistical purposes;
to meet legal and regulatory requirements and to respond to emergency situations, e.g.:
- to respond to court orders, warrants or other lawful requests or legal processes;
- to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or
for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.
- Consent
Before using KiwiSign Offerings, you may be required to agree to an applicable Notice that may contain additional information regarding KiwiSign’s processing of your personal information. Your agreement to the Notice or use of KiwiSign Offerings indicates your consent for KiwiSign to process your personal information for KiwiSign’s identified purposes.
If you provide KiwiSign with personal information about another person, you are responsible for ensuring you have that individual’s consent to do so. All personal information provided to KiwiSign is subject to this policy.
a) When Obtaining Consent is Not Required
In certain circumstances, your personal information may be processed without your consent depending on the jurisdiction and any applicable laws. For example, KiwiSign may not seek consent:
- in the case of an emergency where the life, health or security of an individual may be threatened;
- when legal, medical, or security reasons make it impossible or impractical to seek consent;
- when personal information is necessary to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect KiwiSign property;
- when disclosure is to a lawyer representing KiwiSign;
- to collect a debt;
- to comply with a subpoena, warrant or other court order, lawful request or legal process; or
- as may be otherwise required or permitted by law.
b) Children
KiwiSign does not knowingly possess or process personal information from individuals under the age of 13 without the consent of their parent or legal guardian. KiwiSign requires purchasers and registrants of its products and services to be above 18 years of age.
c) Aggregated or Anonymous Information
KiwiSign reserves the right to process, sell, trade or rent aggregated or anonymous information that is not associated with or linked to an identifiable individual.
- Types of Personal Information Processed
The types of personal information that KiwiSign may process can vary. For example:
a) Account and membership information: Personal information processed could include your name, postal address, email address, telephone number, KiwiSign ID, device identifier information such as your KiwiSign PIN, airtime service provider information, communications with KiwiSign and any recorded complaints. KiwiSign may also process your account credentials, passwords, profile information and other personal information you provide to facilitate the KiwiSign Offerings you use.
b) Applications:In some cases, KiwiSign may process personal information about applications used on your device including Third Party Offerings (i.e. applications, products, services, software, websites or content provided by a third party, including an airtime service provider or application developer, that may be used in conjunction with KiwiSign Offerings, but are not offered, operated or supported by KiwiSign). Also, if you choose to use Third Party Offerings with your KiwiSign account or device, certain personal information may be collected and disclosed to the third party, or from the third party to KiwiSign, in order to facilitate or improve the services and functionality provided.
c) Cloud-based or back-up data: If you use a cloud-based or back-up and restore service provided by or on behalf of KiwiSign, personal information including contacts, email addresses, calendar, memo, tasks, display pictures, status messages, media files and other on-device information may be sent to KiwiSign in order to facilitate or improve the use, remote access and restoration of that data on your device through the service provided.
d) Cookies or similar technologies: A cookie is a small text file or piece of data that is downloaded to and stored on your computer or device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes the cookie. As part of KiwiSign’s Offerings, KiwiSign may use different types of cookies or similar technologies (“Cookies”) from time to time. Certain Cookies are necessary to facilitate your use of KiwiSign Offerings (such as when you use a shopping basket) or to protect both you and KiwiSign when you sign-in to certain services (such as storing your credentials to make it easier whenever you want to use KiwiSign Offerings or to confirm that you are logged in). Other Cookies are more performance-related such as for analytics or contextual purposes to help us understand how users engage with KiwiSign Offerings so we can provide new and enhanced KiwiSign Offerings (such as which pages or features are most popular). Some Cookies are more function-related and help personalize your experience and make KiwiSign Offerings easier to use (such as your language or jurisdiction preferences), or to help KiwiSign display personalized content to you. Other Cookies or similar technologies may be used for targeted advertising purposes (e.g. certain KiwiSign Offerings may be supported by advertising revenue and display advertisements and promotions which may be targeted against non-personally identifiable attributes or aggregate data collected by KiwiSign, and KiwiSign or our service providers may place such advertising on KiwiSign Offerings). Anonymized or aggregated information about usage of KiwiSign Offerings may be provided in a form that does not personally identify you to our service providers as part of analytics services and to help manage online advertising. Most browsers are initially set to accept Cookies, but you can usually change your browser settings to refuse Cookies or to indicate when a Cookie is being sent. You can typically remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain KiwiSign Offerings as they may not work well or at all with Cookies disabled. Please visit the section below on “Withdrawing Your Consent” for more information on managing KiwiSign’s use of Cookies.
e) Financial information: If you purchase a product, service, software or customer support directly from KiwiSign or our service providers, KiwiSign may process credit card or other payment information and use it to facilitate billing and credit services and conduct credit checks, as applicable. Similarly, KiwiSign may process payment or other financial information when you use Near Field Communications functionality.
f) General usage data: In some cases, personal information that includes technical properties and general usage information of software and hardware utilized in conjunction with a KiwiSign Offering might be processed when you use such products, services or software (e.g. type of web browser, referring or exit web pages, operating system version, hardware model of your device or personal computer platform, IP address), or when you use a KiwiSign troubleshooting tool (e.g. basic usage statistics or information about your device includingevent logs, application configurations, battery life, radio or Wi-Fi signal levels, device reset and memory or system performance information).
g) Quality assurance and customer service: Your customer service telephone calls with KiwiSign and KiwiSign’s service providers may be recorded or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to KiwiSign Offerings.
h) Third party information: If necessary to fulfill KiwiSign’s identified purposes, KiwiSign may combine the information you submit to KiwiSign with information obtained from other sources or Third Party Offerings. For example, KiwiSign may receive personal information about you from third parties involved in providing you with the products, services, software and websites you are utilizing, such as from your airtime service provider to facilitate the wireless services you are utilizing or in some cases from a Third Party Offering vendor regarding applications used on your device. KiwiSign treats all such personal information in accordance with this Privacy Policy and the terms and conditions between KiwiSign and such third parties, if any. However, the third party’s own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is a KiwiSign service provider.
Some of this information would not by itself identify you to KiwiSign or be personally identifiable and is therefore considered non-personal information. If KiwiSign combines any such non-personal information with other personal information available to KiwiSign, the combined information will be treated as personal information in accordance with this Privacy Policy.
- Processing Your Personal Information
a) Retention
KiwiSign retains personal information as long as necessary for the fulfillment of KiwiSign’s identified purposes or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for KiwiSign’s identified purposes, or required by applicable laws, KiwiSign will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Consistent with good business practice, KiwiSign continues to evolve our controls, schedules and practices for information and records retention and destruction which apply to your personal information.
b) International operations and onward transfers
KiwiSign has an international presence, with offices and facilities in multiple jurisdictions. Except where a KiwiSign subsidiary or affiliate has its own separate privacy policy, all of KiwiSign’s international operations and onward transfers are subject to this Privacy Policy.
You agree that, to be able to better serve you and facilitate the use or functioning of KiwiSign Offerings, your personal information may be collected, used, processed, transferred or stored by or on behalf of KiwiSign in multiple jurisdictions including Canada, the United States, the European Economic Area, and any other country where KiwiSign or our service providers have offices or facilities, including countries which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of KiwiSign.
Given the international nature of our business, KiwiSign may also be required to disclose or otherwise provide access to your communications data, including the contents of your communications, and other personal information under the laws of countries where KiwiSign, our service providers, affiliates and data are located. By using KiwiSign Offerings, you consent to our compliance with applicable laws including any legal process that KiwiSign believes requires that we produce or provide access to your communications data and other personal information.
c) Marketing communications from KiwiSign
KiwiSign may communicate information, surveys, marketing materials, advertisements or customized content which has been personalized to try to make it more relevant to you as part of your existing business relationship with KiwiSign. For example, we may do so where you have not unsubscribed from receiving such communications and it is permitted by law, where you have explicitly agreed to receive such communications, where you use free services which rely upon advertising (including targeted advertising based on profile information), or through utilizing aggregated data or data that has been made anonymous. KiwiSign may ask you from time to time if you would like to receive from KiwiSign or authorized third parties selected by KiwiSign additional announcements, news, offers or event invitations regarding KiwiSign and KiwiSign Offerings. You may also choose to provide KiwiSign with personal information in response to various KiwiSign promotions. If you agree to participate in contests, surveys, giveaways, reviews, or other promotions that KiwiSign sponsors or co-sponsors, please ensure that you read the Notice that may be associated with these initiatives in order to obtain further details about how your personal information will be managed. An unsubscribe mechanism is included with every KiwiSign marketing or commercial communication. Please visit the section below on “Withdrawing Your Consent” for more information on managing marketing or commercial communications from KiwiSign.
d) Service-related communications from KiwiSign
KiwiSign may also send you certain service-related communications. For example, KiwiSign may send a welcome email or message when you first activate a KiwiSign. Offering to inform you about the service and its terms, to notify you of important changes, to tell you how to manage your credentials or account, to provide service infrastructure notifications or information about upgrades or updates, to provide warranty information, product recall information, safety or security information, or for surveys of current or former users. Because such service-related communications are important to your use of KiwiSign Offerings, you may not opt-out of receiving these communications.
e) Information sharing
In accordance with this Privacy Policy, KiwiSign may share your personal information within KiwiSign and with our service providers. KiwiSign may also share your personal information with our financial, insurance, legal, accounting or other advisors that provide professional services to KiwiSign. KiwiSign may also share your personal information in a manner consistent with this Privacy Policy with third parties involved in providing KiwiSign Offerings to you including, but not limited to, airtime service providers, authorized resellers, distributors, merchants of record or payment processors, subcontractors or entities participating in KiwiSign’s supply or repair chains.
KiwiSign uses contractual or other means to provide a comparable level of protection while the personal information is being processed by our service providers. It is KiwiSign’s policy to enter into confidentiality obligations with any third party that obtains confidential information including personal information from KiwiSign. For example, except where KiwiSign is required or permitted by law to disclose personal information, our service providers to whom we provide your personal information typically agree to hold the personal information in confidence and only use the it for the purposes for which it was provided or to comply with applicable laws.
In the event of the sale of all or a portion of KiwiSign’s assets, KiwiSign may provide personal information to the third party purchaser.
KiwiSign may utilize third parties (e.g. advertising networks) to target advertisements at non-personally identifiable attributes or aggregated data that is derived from profile data processed by KiwiSign, and provide such third parties with general statistics relating to the advertisements delivered. Please visit the section below on “Withdrawing Your Consent” for more information on managing marketing or commercial communications from KiwiSign.
f) Third Party Offerings
KiwiSign does not own or operate all the applications or services that you download and use on your device or through other KiwiSign Offerings. When you download or utilize Third Party Offerings, personal information from your device or other KiwiSign Offerings may be accessed by such third parties. For example, a Third Party Offering might access on-device data such as contacts, calendar entries, email, location-based information, or it may access or share files or data stored on the device (including with additional Third Party Offerings). You should review the privacy policies and any agreements with such third parties to understand how your personal information will be processed by those entities, as KiwiSign is not responsible for your dealings with third parties or their applications, products, services or software. KiwiSign does not directly control how such third parties process the personal information they collect in connection with the Third Party Offerings you use.
In some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.
- Accuracy of Your Personal Information
KiwiSign takes reasonable steps to ensure that personal information is sufficiently accurate, complete and up-to-date. KiwiSign also depends on you to update or correct your personal information whenever necessary.
- Safeguarding Your Personal Information
KiwiSign continues to evolve our physical, organizational and technological measures used to protect your personal information.
a) Your obligations to safeguard your personal information
You have an obligation to safeguard your personal information. You can reduce risk of unauthorized access to your personal information by using common sense security practices. For example, you are responsible for utilizing appropriate security measures to control access to your device and computer system, such as creating a strong password that cannot be easily guessed by others (e.g. by including punctuation marks, numbers, capital and lowercase letters, and choosing a password of an appropriate length and which does not include your name or account name), using different passwords for different services and using up-to-date antivirus software.
As noted above, in some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.
If you return, sell, discard, or transfer your device or other KiwiSign product to another person or entity (such as providing your device to KiwiSign or another entity for repair, refurbishment or replacement), you should ensure that the device and any associated accessories and peripherals are removed or securely wiped of any personal information or other sensitive data they might contain (e.g. SIM cards, microSD cards).
- Withdrawing Your Consent
At any time, you may withdraw your consent for KiwiSign to process your personal information in accordance with this Privacy Policy, subject to legal or contractual restrictions and reasonable notice. If you refuse to provide KiwiSign with the personal information it requires or later withdraw your consent to use and disclose this information, KiwiSign may no longer be able to provide you with your KiwiSign Offerings.
You may withdraw your consent at any time by notifying the Privacy Office at KiwiSign at support@KiwiSign.com.
Marketing or commercial communications: You may unsubscribe from receiving marketing or commercial communications about KiwiSign or KiwiSign® products, services and software by:
- clicking the unsubscribe link at the end of any marketing or commercial communication from KiwiSign;
Cookies: As noted above, you may also opt-out of KiwiSign’s use of Cookies through one of the following methods:
- Change your browser settings to refuse Cookies or to indicate when a Cookie is being sent.
- Remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain KiwiSign Offerings as they may not work well or at all with Cookies disabled.
a) Changes to this Privacy Policy
KiwiSign will occasionally update this Privacy Policy so that it remains relevant and current with changing technologies, applicable laws, our evolving business practices and the needs of our users. KiwiSign encourages you to periodically review this Privacy Policy to stay informed of how KiwiSign manages your personal information.