Privacy Policy

PRIVACY POLICY

Last updated: October 05:02, 2022

This Privacy Policy describes Xtok policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

  • Under The Personal Data Protection Bill, 2018 (the Republic of India), You can be referred to as the Data Principal which means the natural person to whom the personal data referred to Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Xtok AS Jernbanegata 29 2150 Årnes Norway

For the purpose of the GDPR, the Company is the Data Controller.

  • Application means the software program provided by the Company downloaded by You on any electronic device, named Kindda
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Account or Profile means a unique account created for You to access our Service or parts of our Service.
  • Website refers to Kindda, accessible from https://www.xtok.uk
  • Service refers to the Application or the Website or both.
  • Country refers to: Singapore.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.

For the purpose of the GDPR, Service Providers are considered Data Processors.

  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Facebook Fan Page is a public profile named “KinndaOfficial” specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/xtokapp
  • Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of the GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

For the purposes of the Personal Data Protection Act (Republic of Singapore), further referred as the “PDPA”, Personal Data means data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.

For the purposes of The Personal Data Protection Bill, 2018 (Republic of India), Personal Data means data about or relating to a natural person who is directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of the identity of such natural person, or any combination of such features, or any combination of such features with any other information.

  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Do Not Track (DNT) is a concept that has been promoted by competent regulatory authorities, for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

 

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address;
  • First name and last name;
  • Age;
  • Gender;
  • Username;
  • Phone number;
  • Address, State, Province, ZIP/Postal code, City, Country;
  • Language;
  • Profile image;
  • Social media account information;
  • User-generated content, including comments, photographs, videos, and virtual item videos that you choose to upload or broadcast on the Site (further referred as “User Generated Content” and/or “Contributions”);
  • Usage Data.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

  • Google;
  • Facebook;
  • Apple ID (for iOS devices only);
  • VK.com;
  • Other social media that may be added by Us from time to time.

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with your prior permission:

  • Information regarding your location
  • Information from your Device's phone book (contacts list)
  • Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

 

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

We may share your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to show advertisements to You to help support and maintain Our Service, to advertise on third party websites to You after You visited our Service, to contact You.
  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users and visitors of the Site: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

    Your Profile is fully visible to all registered users (“Users”) and third parties visiting the Site and/or downloading the Kindda app (“Visitors”) as well as customers of our Service, including but not limited through search engines that may impact availability of your Profile and view of certain fields in your Profile.
    Our Site allows viewing information including through posts, likes, follows and comments. So when you share a post publicly it can be viewed by everyone (subject to your settings) and third parties may see your publicly-shared content, including your name (surname, nickname), your photo (if you have provided one) as well other profile data.
    Any data that you include on your Profile and any content you post or your social actions you take (e.g., likes, follows, comments, shares, text, writings, video, audio, photos, graphics, suggestions, or personal information or other material), collectively referred as     "Contributions", will be seen by others subject to your privacy settings. When you like or re-share or comment on another user’s content, others will be able to view these actions and associate it with you.
    If you want to limit access to your Account and any data that you include on your Profile and any Contributions, you may change in settings your Profile from “public” to “private”. In case of the private profile your Account will be still available through search engines, but access to its data will be limited unless you accept other user’s connection request.

 

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data retained for 3 (three) years after User's Account was removed, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Personal Data that We processes for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain and delete your Personal Data as follows:

(i) Usage data will be retained indefinitely for the purpose of monitoring the historical performance of the Online Recourse.

(ii) Account data will be retained for a further 3 (three) years after you delete an Account, after which it will be deleted unless required for auditing or legal reasons.

In some cases it is not possible for Us to specify in advance the periods for which your Personal Data will be retained. In such cases, We will determine the period of retention based on the period the We needs to access the data for the provision of services, receiving payment, or other issues or any other auditing or legal reasons.  

User’s principal rights under data protection law are:

(a) The right to access.

This enables you to receive a copy of the Personal Data we hold about you;

(b) The right to rectification/correction.

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

(c) The right to erasure.

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it;

(d) The right to restrict or object to processing

This enables you to initiate the suspending of the processing of your Personal Data;

(e) The right to data portability.

We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format;

(f)  The right to complain to a supervisory authority; and

(g) The right to withdraw consent.

However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you have any concerns as to how your Personal Data is processed or you would like to exercise any right above you can contact us via email [email protected]

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by applicable law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation;
  • Protect and defend the rights or property of the Company;
  • Prevent or investigate possible wrongdoing in connection with the Service;
  • Protect the personal safety of Users of the Service or the public;
  • Protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

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