Privacy Policy
This Privacy Policy applies to Knoso, our iOS mobile application (our “App”). In the below policy, we inform you about the scope of the processing of your Personal Information.
General Information
- What law applies?
In principle, we will only use your Personal Information in accordance with the applicable data protection laws, in particular Ariz. Rev. Stat. §§ 18-551–552 (the Data Breach Law) (“DBL”) and the EU’s General Data Protection Regulation (“GDPR”).
- What is Personal Information?
Personal Information is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address and device ID.
- What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means. The term is broad and covers virtually any handling of data.
- Responsible for data processing
The responsible party within the meaning of the DBL, and the GDPR is Knoso, LLC a Arizona based limited liability company (“Knoso”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please feel free to email us using [email protected].
- The Legal Bases for processing Personal Information
In accordance with good practice, and the GDPR, we have to have at least one of the following legal bases to process your Personal Information: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.
Processing of Automatically Collected Data
- Downloading the App
The App can be downloaded from the Apple “App Store” a service of Apple Inc. Downloading it may require prior registration with the Apple App Store and/or installation of the respective App store software.
- Installing the App
As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which Personal Information Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.
- Device information
Apple may collect information from and about the device(s) you use to access the App, including hardware and software information such as IP address, device ID and type, device-specific and App settings and properties, App crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.
- Authorizations and Access
We may request permission to access your Internet Connection, your Network, your push notifications and your Coarse Geo-location. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our App may not function as intended.
- Push messages
When you use our App, you will receive so-called push messages from us, even if you are not currently using our App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device. Insofar as you consent to the use of push messages, consent is the legal basis for the processing.
- Google Firebase Services
We use the Google Firebase developer App and related features and services provided by Google. We use the following Google Firebase services in our Platform: a) Firebase Analytics, b) Firebase Crashlytics, c) Firebase Firestore database for data storage and cloud functions, d) Firebase Authentication to ensure secure access, e) Firebase Cloud Messaging for Push Notifications. By integrating Google services, Google may collect and process information (including Personal Information). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google collects and processes. Firebase’s key security and privacy information can be found here: https://firebase.google.com/support/privacy. The legal basis is the implementation of the user contract for the use of the App.
- Google Analytics for Firebase
Our App uses the web analytics service Google Analytics for Firebase, which uses tracking technologies to track your use of our App. In this respect, information is generated about, among other things, the number of users and their sessions, the session duration, the operating system used by the users, their device model, the region from which our App is accessed, the first start of our App, our App execution and any updates.
In order to provide the relevant data for analysis, Firebase Analytics uses your a) device’s advertising ID, b) an App instance ID (a randomly generated number that identifies a single app installation), c) and the IP address, which is shortened (IP masking) before being processed on Google’s servers (which may be located outside the UAE/EEA) to generate the usage analysis. You can object to the use of Firebase Analytics at any time by disabling the sending of usage statistics in your device settings (Reset Advertising ID). We have no influence on these data processing operations.The basis for processing is our legitimate interest and your consent.
Advertising
Advertisers and third parties also may collect information about your activity on our App, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our app and on third-party sites and applications. If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only). In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices.
Data processing by us
- Contacting us
Personal Information is processed depending on the contact method. In addition to your name and email address, IP address or telephone number, we usually collect the context of your message which may also include certain Personal Information. The Personal Information collected when contacting us is processed for the purpose of dealing with your request and the legal basis is your consent. The use of your IP address takes place exclusively in the context of law enforcement and security measures in compliance with our legal requirements.
- Account Registration
If you register, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form. The entry of your data is encrypted so that third parties cannot read your data when it is entered. The basis for this processing is our legitimate interest and to fulfill our contractual obligations. Of course you can delete your account at any time using the Delete Account Feature in our App.
- When using our services in general
We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations.
- Use of our social networking services
If you wish to use our social networking services and its features, we process the Personal Information you voluntarily provide for the purpose of providing our social networking services. Depending on how you use our services, you may provide images, contact information, company information, location data etc. and upload content such as text, photographs etc. This content will be made public and may be viewed and otherwise accessed by others.
Some of the Personal Information you provide may be considered “special” or “sensitive”. This includes Personal Information concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data. You have choices about the data you provide and how you share it. You don’t have to provide Personal Information or Special Category Data; however, information about you helps you to get more from our Services. It’s your choice whether to include Personal Information or Special Category Data and to make that information available to us. Please do not share information that you would not want to be available. The legal basis for the processing of your Personal Information and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent.
In providing our social networking services and publishing our content we may process images and facial-related information from our service users, participants and representatives. Images and facial-related information are used and processed solely for the purpose explicitly consented to and we do not collect, use, or store any images and facial-related information for the purpose of recognising faces outside of this purpose. The legal basis is your consent.
Of course, we also process your chats and communications with other users as well as the content you publish, as necessary for the operation of our social networking services. In addition to the information, you may provide us directly, we receive information about you from others. Users may provide information about you as they use our social networking services, for instance as they interact with you. The legal basis is the fulfillment of the user contract for the use of the platform as well as your consent.
We also share some users’ information with service providers and partners who assist us in operating our social networking services. You share information with other users when you voluntarily disclose information on the service (including your profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.
In addition to the information you provide to us directly, we receive information about you from others, including other users who provide us with information about you when they use our social networking services. For example, we may receive information about you from other users when you contact them about us. We collect information about your activities on our social networking services, such as how you use them (e.g., the date and time you logged in, features you used, searches you performed, clicks and pages you were shown, content you clicked on) and how you interact with other users (e.g., users you connect and interact with, the time and date of your exchanges). The legal basis is the fulfillment of the user contract for the use of the platform as well as your consent.
General principles
- Automated decision-making
Automated decision-making including profiling does not take place.
- Do Not Sell
We do not sell your Personal Information.
- Sharing
We will not disclose or otherwise distribute your Personal Information to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions. In addition, we may disclose your Personal Information: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if our App or Knoso LLC (or a part of our App or Knoso LLC) is sold to or merged with another company; or if we have reason to believe that disclosure is necessary to protect our App or Knoso LLC.
- International Transfer
We may transfer your Personal Information to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Information when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Information we transfer.
- Data Security
Our data processing is subject to the principle that we only process the Personal Information that is necessary for the use of our services. In doing so, we take great care to ensure that your privacy and the confidentiality of all Personal Information are always guaranteed.
Nonetheless, databases or data sets that include Personal Information may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Information may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
Your rights and privileges
- Privacy rights
You can exercise the following rights:
- Right to information
- Right to rectification
- Right to deletion
- Right to data portability
- Right of objection
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you wish to exercise any of your rights, please contact us.
- Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
- Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
- Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Information or to make a correction requested by you, we will tell you why.
- Complaint to a supervisory authority
If you believe that the processing of your Personal Information is not lawful, you can lodge a complaint with a data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any supervisory authority
- COPPA (Children Online Privacy Protection Act)
When it comes to the collection of Personal Information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.
- CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.
- Telephone Consumer Protection Act (TCPA)
If we process your Personal Information for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalized direct advertising per SMS.
- Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.
Changes
We may update this policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
Questions?
If you have any questions or if you wish to exercise your rights, please feel free to email us using [email protected]
Effective Date
This Privacy Policy was last updated on Tuesday, December 12th 2023.