Privacy Policy
Last updated: January 2024
Introduction
Welcome to the KYG Trade Attestation Platform and Marketplace™ (the “Platform”). The Platform is provided and controlled by KYG Trade, Inc. (“KYG Trade”, “We” or “Us”). We are committed to protecting and respecting Your privacy. This Privacy Policy describes Our 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.
This page informs You of Our policies regarding the collection, use, and disclosure of personal data, which KYG Trade obtains from users, when users interact with or otherwise use the Platform and any related services and mobile applications. This Privacy Policy also explains how Your personal data is used, shared and protected, what choices You have relating to Your personal data, and how You can contact KYG Trade. Please read this policy carefully to understand this entire Privacy Policy before submitting information to Us or using Our Platform, an associated social media platform, a mobile application, or one of Our other products or services. Whenever You submit information via Our Platform or otherwise to Us, whether online or offline, You consent to the collection, use and disclosure of that information in accordance with this Privacy Policy.
This policy applies only to information We collect on the Platform and in email, text, and other electronic communications sent through or in connection with the Platform. This policy generally describes:
1. The types of information We may collect or that You may provide to Us when You purchase, download, install, register with, access, or use the Platform.
2. Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy DOES NOT apply to information that:
1. We collect offline or on or from any other KYG Trade applications or websites, including websites You may access through this the Platform.
2. KYG Trade obtains from You in KYG’s capacity as an employer or potential employer, including Your personal information;
3. You provide to or is collected by any third party, as some other third parties that collect information may have their own privacy policies, which We encourage You to read before providing information on or through them.
This Privacy Policy is subject to Our Platform Terms of Service (“Terms of Use”). If You do not agree with Our policies and practices, do not download, register with, or use this Platform. By downloading, registering with, or using this Platform, You agree to this PRIVACY POLICY. 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. We may update this Privacy Policy from time-to-time, as specified in the “Changes to This Privacy Policy” section below. Your continued use of this Platform after We revise this policy means You accept those changes, so please check the policy periodically for updates. In the event of a conflict between this PRIVACY POLICY and any of the TERMS OF USE, the TERMS OF USE shall govern.
Only persons age 18 or older have permission to access Our Platform. The Platform does not address anyone under the age of 18 (“Children”). The KYG Trade Platform is not directed to children under the age of 18. As a result, the Platform does not request or knowingly collect personal data from individuals under the age of 18. If You are not 18 or older, You should not visit or use Our Platform. If KYG Trade learns that personally identifiable information of persons under 18 years of age has been collected on the Platform without verified parental consent, KYG Trade will take appropriate steps to delete the information. California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Our California Privacy Rights Section herein below for more information.
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 the plural.
Definitions
Account means a unique account created for You to access Our Service or parts of Our Service.
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to KYG Trade, Inc., 220 Newport Center Dr., Suite 11391, Newport Beach, CA. 92660.
For the purpose of the GDPR (General Data Protection Regulation), the Company is the Data Controller.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
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.
Country refers to: California, United States
Data Controller, for the purposes of the GDPR, 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.
Device means any Device that can access the Service such as a computer, a cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by Us regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
Personal Data is any information that relates to an identified or identifiable individual. For the purposes for 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.
Platform is the KYG Trade Attestation Platform and Marketplace™.
Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal information to another business or a third party for monetary or other valuable consideration.
Service refers to the KYG Trade Platform and Marketplace and API.
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 analyzing 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.
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).
Website refers to KYG Trade, accessible from www.kygtrade.com.
You (referred to as either "You" or "Your" in this Agreement) 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 in circumstances where You are the individual using the Service.
Collecting and Using Your Personal Data
1. What Information Do We Collect?
KYG Trade collects information directly from You when You provide such information to KYG Trade, when You create an Account and use the Platform, and automatically when You access or use the Platform. We also collect information You share with Us from third-party providers, and technical and behavioral information about Your use of the Platform. We also collect information contained in the messages You send through Our Platform. More information about the categories and sources of information is provided below.
a. Information You Choose to Provide
For certain activities, such as when You download, access, register with, use, or upload User Content to the Platform, fill in forms in the Platform, or when You enter a contest or promotion sponsored by us, when You report a problem with the Platform, or contact Us directly, You may provide some or all of the following information.
§ Personally-Identifiable 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:
o Email address
o First name and last name
o Postal address, City, State, Province, ZIP/Postal code
o Telephone Number
o Login and Account information (including screen name, password and unique User ID)
o Usage Data
o Financial Information (e.g., financial institution information, payment information, etc.)
§ Non-identifying Personal Details. While using Our Service, We may ask You to provide Us with certain Personal details that are about You, but individually do not identify You, such as:
o Gender
o Hometown
o Date of birth
o Marital status
o Household composition
o Purchase history
§ Personal Preferences. While using Our Service, We may ask You to provide Us with certain Personal preferences including Your marketing preferences, Your opt-in choices and communication preferences, information to verify Your Account, payment information (where required for the purpose of payment).
§ Records and copies of Your correspondence (including email addresses and phone numbers), if You contact Us via email, text, and other electronic communications sent through or in connection with the Platform.
§ Your responses to surveys that we might ask You to complete for research purposes, and information You share through surveys or Your participation in challenges, sweepstakes, or contests such as Your gender, age, likeness, and preferences.
§ Your search queries on the Platform
You may also provide information for publication or display ("Posted") on public areas of the Platform (collectively, "User Content"), including but not limited to comments, photographs, images, videos, and audio files, that You choose to upload or broadcast on the Platform. Your User Content is posted, submitted, transmitted, or otherwise made accessible to others at Your own risk. Although You may set certain privacy settings for such information, please be aware that no security measures are perfect or impenetrable. Additionally, We cannot control the actions of third parties with whom You may choose to share Your User Content. Therefore, We cannot and do not guarantee that Your User Content will not be viewed or otherwise accessed by unauthorized persons.
b. Automatically Collected Information
When You download, use, or otherwise access the Platform, the Platform may use technology to automatically collect certain information from You, including internet or other network activity information such as Your IP (Internet Protocol) address, geolocation-related data (as described below), unique Device identifiers, browsing and search history (including content You have viewed in the Platform), and Cookies (as defined below). If You do not want Us to collect this information do not download the Platform or delete it from Your Device.
§ Usage Data. When You access and use the Platform, We may automatically collect certain details of Your access to and use of the Platform, including traffic data, location data, logs, User Content that You generate through and broadcast on the Platform, and other communication data and the resources that You access and use on or through the Platform. Usage Data is collected automatically when using the Service. Usage Data may include information such as: traffic data, location data, logs, the pages of Our Platform that You visit, the time and date of Your visit, the time spent on those pages User Content that You generate through and broadcast on the Platform, and other communication data and the resources that You access and use on or through the Platform.
§ Device Information. We may collect information about the Device You use to access the Platform and Your internet connection, including the Device's unique Device identifier, IP address, model of the Device, operating system, browser type, mobile network information, time zone setting, screen resolutions, application and file names and types, and the Device's telephone number (if applicable).
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.
§ Location Information. This Platform collects real-time information about the location of Your Device, including location information based on Your SIM card and/or IP address, and time zone.
§ Stored Information and Files. The Platform also may access metadata and other information associated with other files stored on the Device You utilize to access the Platform. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
When You upload User Content, You automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about Your User Content that will not always be evident to the viewer. In connection with Your User Content, the metadata can describe how, when, and by whom the piece of User Content was collected and how that content is formatted. It also includes information, such as Your Account name, that enables other users to trace back the User Content to Your user Account. Additionally, metadata will consist of data that You chose to provide with Your User Content, e.g. any hashtags used to mark keywords to the video and captions.
§ Messages. We collect and process, which includes scanning and analyzing, information You provide in the context of composing, sending, or receiving messages through the Platform’s messaging functionality. That information includes the content of the message and information about when the message has been sent, received and/or read, as well as the participants of the communication. Please be aware that messages sent to other users of the Platform will be accessible by those users and that We are not responsible for the manner in which those users use or disclose messages or message content.
c. Information Collection by and from Third-Party Services
KYG Trade allows You to create an Account on Our Platform and log in through the following Third-party Social Media Services:
Apple
Facebook
Google
Microsoft
Twitter
If You decide to register through or otherwise grant Us access to a Third-Party Social Media Service, KYG Trade 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 KYG Trade through Your Third-Party Social Media Services account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving KYG Trade permission to use, share, and store it in a manner consistent with this Privacy Policy.
Additionally, when You use the Platform or its content, certain third parties may use automatic information collection technologies to collect information about You or Your Device. These third parties may include, but are not limited to:
Advertisers, ad networks, and ad servers.
Analytics companies.
Social Networks.
Your mobile Device manufacturer.
Your mobile service provider
These third parties may use tracking technologies to collect information about You when You use this Platform. The information they collect may be associated with Your personal information or they may collect information, including personal information, about Your online activities over time and across different websites, applications, and other online services websites. These third parties may use this information to provide You with interest-based advertising or other targeted content.
KYG Trade does not control these third parties tracking technologies or how they may be used. If You have any questions about an advertisement or other targeted content, You should contact the responsible provider directly. For information about how You can opt-out of receiving targeted advertising from many providers, such information is provided herein below.
2. Tracking Technologies and Cookies
KYG Trade may use cookies and other similar technologies (e.g. web beacons, tags, scripts, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages You click on and how You use the Platform, track the activity on the Platform, store certain information, enhance Your experience using the Platform, improve the Platform, and provide You with targeted advertising on the Platform and elsewhere across Your different Devices.
Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from Your computer or Device. Cookies are small files which, when placed on Your Device, enable the Platform to provide certain features and functionality. It may be possible to refuse to accept all cookies by activating the appropriate setting on Your browser or Device or to indicate when cookies are being sent. However, if You select this setting You may be unable to access certain parts of Our Platform. Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile Device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both session and persistent Cookies for the purposes set out below:
a. Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
b. Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
c. Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.
3. Use of Your Personal Data
KYG Trade collects the Information detailed herein for the purpose of identifying and communicating with You, to fulfill and enforcing Our Terms of Use, responding to Your requests/inquiries, servicing Your purchase orders, improving and administering Our Platform, and allowing You to use its functionalities. KYG Trade may also use Your information to, among other things, show You suggestions, promote the Platform, and customize Your experience.
KYG Trade may use the information detailed herein, that we collect about You or that You provide to us, including any personal information, for the following purposes:
§ To provide, maintain, and improve Our Platform and Content, including monitoring the usage of Our Service.
§ To detect, prevent, mitigate, and investigate technical issues.
§ To detect, prevent, mitigate, and investigate abuse, fraud, security breaches, and potentially prohibited or illegal activities on the Platform.
§ To comply with legal, regulatory, or contractual requirements.
§ To enforce Our terms, conditions, and policies.
§ To ensure that You are old enough to use the Platform (as required by law).
§ To manage Your Account: to manage Your registration as a user of the Service including expiration and renewal notices. 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 fulfill requests for products, services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit Your feedback.
§ 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.
§ To allow You to participate in interactive features of the Platform.
§ To allow You to post information and other User Content on the Platform.
§ To support the social functions of the Platform, including to permit You and other users to connect with each other through the Platform and for You and other users to share, download, and otherwise interact with User Content posted through the Platform.
§ To customize the content You see when You use the Platform.
§ To deliver targeted marketing, service updates, and promotional offers based on Your communication preferences.
§ To understand how You use the Platform, including across Your Devices.
§ To monitor usage of the Platform.
§ For any other purposes disclosed to You at the time We collect Your information or pursuant to Your consent.
§ To fulfill any other purpose for which You provide the collected information.
§ To inform Our algorithms.
§ To combine all the information We collect or receive about You for any of the foregoing purposes.
The usage information We collect helps Us to improve Our Platform and to deliver a better and more personalized experience by enabling Us to:
§ Estimate Our audience size and usage patterns.
§ Store information about Your preferences, allowing Us to customize Our Platform according to Your individual interests.
§ Speed up Your searches.
§ Recognize You when You use the Platform.
KYG Trade may also use Your information to contact You about Our own and third parties' goods and services that may be of interest to You. If You do not want Us to use Your information in this way, please check the relevant box located on the form on which We collect Your data and/or adjust Your user preferences in Your account profile.
KYG Trade may further use the information We collect to display advertisements to Our advertisers' target audiences. Even though We do not disclose Your personal information for these purposes without Your consent, if You click on or otherwise interact with an advertisement, the advertiser may assume that You meet its target criteria.
KYG Trade may make full use of all information that is de-identified or otherwise not in personally identifiable form. We may also make full use of all User Content You submit to us, in accordance with Our Terms of Use.
4. Sharing or Disclosure of Your Personal Data
We are committed to maintaining Your trust, and while KYG Trade does not sell personal information to third parties, We want You to understand when and with whom We may share the information We collect for business purposes.
We may disclose aggregated information about Our users, and information that does not identify any individual or Device (de-identified information), without restriction. In addition, We may disclose personally identifiable information that We collect, or You provide in accordance with the Privacy Policy and Our Terms of Use, including in the following instances:
§ To Our parent, subsidiary, or another affiliate of Our corporate group. We may share Your information with Our affiliates, in which case We will require those affiliates to honor 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.
§ To contractors, service providers, business partners, and other third parties We use to support Our business and operations (e.g., delivery services, financial institutions, fulfillment services, technical support, advertising, public relations, media and marketing services, sweepstakes, promotions, campaigns and contest-related services, call-in centers, e-commerce and other web-related services such as web hosting and web monitoring services and event-related services such as online and offline data capture), and who are to keep personal information confidential and use it only for the purposes for which We disclose it to them.
With third parties for research and development purposes.
§ To a buyer or other successor in the event of a sale, financing, merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of KYG Trade's assets, or other transfer of Our brand or company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by KYG Trade about Our Platform users is among the assets transferred.
§ With Your consent. We may share information for other purposes pursuant to Your consent or with Your further direction. If You choose to engage in public activities on the Platform, or with other users, You should be aware that any information You share may be viewed, read, collected, used by other users, and may be distributed outside the Platform. You should use caution in disclosing personal information while engaging in public areas and with other users. We are not responsible for the information You choose to submit. 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.
§ To fulfill the purpose for which You provide it.
§ For any other purpose disclosed by Us when You provide the information.
§ For legal reasons to comply with any court order, law, subpoena, law enforcement request, legal claims, or legal process, including to respond to any government or regulatory request, and to protect and defend the rights, interests, safety, and security of KYG Trade, the Platform, Our affiliates, users, or the public. KYG Trade may also share Your information to enforce any terms applicable to the Platform, to exercise or defend any legal claims, and comply with any applicable law.
§ To identify, contact, or bring legal action against to someone who may be causing injury to or interfering with KYG Trade’s or other’s rights or property.
In connection with disciplinary actions/investigations regarding Your use of the Platform or Service.
§ To enforce Our rights arising from any contracts entered into between You and KYG Trade, including but not limited to the Terms of Use.
§ If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of KYG Trade, Our customers, Our affiliates, users, or the public. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may use Email Marketing Service Providers to manage and send emails to You. For example, Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/. We may use third-party Service Providers to provide better improvement of Our Service. For example, We use an invisible captcha service named reCAPTCHA. which is operated by Google. The reCAPTCHA service may collect information from You and from Your Device for security purposes. The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/. You may notify KYG Trade that You do not want Your personal data shared in this way by indicating such preference through the process detailed herein. Apart from the purposes listed above, KYG Trade will not knowingly share information about You with other third parties for their independent use without Your prior consent.
5. Transfer of Your Personal Data
The recipients of Your personal data, and more generally these disclosures, may be located in the United States or other jurisdictions that might not provide a level of protection equivalent to the laws in Your jurisdiction. Your information, including Personal Data, 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. If You are located outside United States and choose to provide information to us, please note that We transfer the data, including Personal Data, to the United States and process it there.
Via Your consent to this Privacy Policy, followed by Your submission of personal data to us, represents Your agreement to the transfer of that data in accordance with this Privacy Policy. KYG Trade 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.
Your Rights and Choices about Collection, Use and Disclosure of Your Personal Information
1. Data Collection
We strive to provide You with choices regarding the personal information You provide to us. This section describes mechanisms We provide for You to control certain uses and disclosures of Your information.
a. Tracking Technologies. You can set Your browser to refuse all or some browser cookies, or to alert You when cookies are being sent. You may choose whether or not to allow the Platform to collect information through other tracking technologies by Opting Out. If You disable or refuse cookies or block the use of other tracking technologies, some parts of the Platform may then be inaccessible or not function properly.
Because each browser is different, please consult the instructions provided by Your browser. Please note that You may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile applications function, You may need to take different steps to disable Cookies used for targeted advertising in a browser and to disable targeted advertising for a mobile application, which You may control through Your Device settings or mobile application permissions. In addition, Your choice to disable cookies is specific to the particular browser or Device that You are using when You disable cookies, so You may need to separately disable cookies for each type of browser or Device.
Some browsers transmit "do-not-track" signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
b. Location Information. You can choose whether or not to allow the Platform to collect and use real-time information about Your Device's location through the Device's privacy settings. If You block the use of location information, some parts of the Platform may become inaccessible or not function properly.
c. Interest-Based Advertising: If You wish to opt out of the use of Your personal information for interest-based advertising purposes (Promotion by KYG Trade, Targeted Advertising by KYG Trade, Disclosure of Your Information for Third-Party Advertising and Marketing), You may do so by following the instructions below:
o Website: You can opt out of receiving ads that are personalized as served by Our Service Providers by following Our instructions presented on the Service. The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by Your browser, You will need to opt out again.
§ From Our "Cookie Consent" notice banner
§ Or from Our "CCPA Opt-out" notice banner
§ Or from Our "Do Not Sell My Personal Information" notice banner
§ Or from Our "Do Not Sell My Personal Information" link
o Mobile Devices: Your mobile Device may give You the ability to opt out of the use of information about the applications You use in order to serve You ads that are targeted to Your interests.
§ "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
§ "Limit Ad Tracking" on iOS devices
§ You can also stop the collection of location information from Your mobile Device by changing the preferences on Your mobile Device.
o Emails: You may opt-out of receiving any, or all, communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We do not control third parties' collection or use of Your information to serve interest-based advertising. However, these third parties may provide You with ways to choose not to have Your information collected or used in this way.
There are also general resources for opting out of interest-based advertising available on the websites of the Network Advertising Initiative and the Digital Advertising Alliance. You may also opt-out from participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://Youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.Youronlinechoices.eu. Similarly, You can adjust Your advertising preferences on Your mobile Device at the Device level. For example, to adjust Your advertising preferences in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking. To adjust Your advertising preferences in Android, visit Settings > Google > Ads > Opt out of interest-based ads.
2. Accessing, Correcting, and Managing Your Personal Data
a. Information Security: The security of Your data is important to KYG Trade, and We have implemented measures designed to secure Your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. But, remember that no website, mobile application, database or system, or method of transmission over the Internet, or method of electronic storage is 100% secure or “hacker proof.” The safety and security of Your information also depends on You. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. You can help keep Your data safe by taking reasonable steps to protect Your personal information against unauthorized disclosure or misuse. Any transmission of personal information is at Your own risk. We are not responsible for the circumvention of any privacy settings or security measures We provide.
Where We have given You (or where You have chosen) a password for access to certain parts of Our Platform, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone, and We urge You to be careful about giving out information in public areas of the Platform like message boards. The information You share in public areas may be viewed by any user of the Platform.
b. Retention of Your personal data: We retain Your personal data for as long as necessary to fulfill the purposes described in this policy, unless otherwise required by law. For example, We keep Your account profile information for as long as You keep Your Platform account, but We may keep other information longer to comply with legal obligations. Where required, We will anonymize or dispose of the information We collect when We no longer need it for the uses described above.
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. Further, KYG Trade will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, 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.
c. Processing Personal Data: We may process Personal Data under the following conditions, and will gladly clarify the specific legal basis that applies to such processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
§ Consent: You have given Your consent for processing Personal Data for one or more specific purposes. Where We have obtained Your consent for the processing of Your personal data, You have the right to withdraw Your consent at any time. If You have a request regarding Your personal data, please contact us.
§ Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
§ Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
§ Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
§ Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
§ Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
d. Managing Your Personal Data, Content, And Notifications: You may contact us, as provided below, to learn about how to access, review, correct, update, transfer, or delete the information about You in Our records. We may need to retain certain information for recordkeeping purposes, to complete any transactions that You began prior to Your request, or for other purposes as required or permitted by applicable law. You may have the right to request:
§ access to Your personal data;
§ an electronic copy of Your personal data (portability);
§ correction of Your personal data if it is incomplete or inaccurate; or
§ deletion or restriction of Your personal data in certain circumstances provided by applicable law;
§ transfer to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
You may exercise Your above rights of access, rectification, correction, deletion, restriction, or transfer by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible.
If You have registered for an account You may access, review, and update certain personal information that You have provided to Us by logging into Your account and using available features and functionalities.
You may also send Us an email at info@kygtrade.com to request access to, correct, or delete any personal information We have collected about You or that You have provided to us. We will respond to Your request consistent with applicable law and subject to proper verification. And We do not discriminate based on the exercise of any privacy rights that You might have. Please note that We cannot delete Your personal information except by also deleting Your user account. We may not accommodate a request to change information if We believe the change would violate any law or legal requirement or cause the information to be incorrect.
You may request removal of Your posted User Generated Content on the Platform, but please note that removal may not encompass all possible locations, for example, back-ups or sharing by other users initiated prior to removal. If You delete Your User Content from the Platform, copies of Your User Content may remain viewable in cached and archived pages or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Content, is governed by Our Terms of Use.
We would like to keep in touch with You in ways that You find to be beneficial. If You don’t want Us to use Your contact information to communicate with You, to send You marketing information for promotional purposes, to provide You with customized and relevant advertising, or to keep You signed into Your account, please tell Us so when You provide Your contact information. You can also let Us know Your preference by contacting Us as specified in the “Contact Us” section below, by accessing Your account via Our site, or by following the instructions to unsubscribe in various communications that We may send You. Keep in mind that these particular preferences do not mean that We might not contact You for other reasons, such as those related to an order You placed, an inquiry You made, a message that a friend or acquaintance requested be delivered, a legally required notice and so on.
We keep some of Your data even after You close Your account. If You choose to close Your account, Your personal data will generally stop being visible to others on Our Platform. We generally delete closed account information within a reasonable time period of account closure as defined in Our Terms of Use, except as noted below. We retain Your personal data even after You have closed Your account if reasonably necessary to comply with Our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill Your request to “unsubscribe” from further messages from us.
We will retain de-personalized information after Your account has been closed. Information You have shared with others will remain visible after You closed Your account or deleted the information from Your own profile or mailbox, and We do not control data that other parties copied out of Our Platform. Group content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.
3. California Privacy Rights.
If You are a California resident, California law may provide You with additional rights regarding Our use of Your personal information. To learn more about Your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.
In summary, under California Law, California residents, that have an established business relationship with KYG Trade, maintain:
§ The right to notice. The right to know about the personal information a business collects about them and how it is used and shared;
§ The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third party for the third party's direct marketing purposes.
§ The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting Our "Do Not Sell My Personal Information" section or web page.
§ The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
o The categories of Personal Data collected
o The sources from which the Personal Data was collected
o The business or commercial purpose for collecting or selling the Personal Data
o Categories of third parties with whom We share Personal Data
o The specific pieces of Personal Data We collected about You
§ The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
§ The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
o Denying goods or services to You
o Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
o Providing a different level or quality of goods or services to You
o Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
a. California’s Shine the Light Statute (Civil Code Section § 1798.83) permits users of Our Platform that are California residents with an established business relationship with Us to request certain information regarding Our disclosure of personal information to third parties for their direct marketing purposes.
As such, if You are a California resident, once a calendar year, You may be entitled to obtain information about the personal information that We shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which We shared customer information for the immediately prior calendar year. To request a notice, please submit Your request to info@kygtrade.com. KYG Trade will respond to such written requests within a reasonable period of time, but not to exceed 180 days from the date received. Please note that We are required to respond to each customer only once per calendar year.
b. California Privacy Rights for Minor Users (California Business and Professions Code Section 22581) allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. All requests must be labeled "California Removal Request" on the email subject line. All requests must provide a description of the User Content You want to be removed and information reasonably sufficient to permit Us to locate that User Content. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and We may not be able to respond if You do not provide adequate information. Please note that Your request does not ensure the complete or comprehensive removal of the material. For example, materials that You have posted may be republished or reposted by another user or third party.
To request the removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account. Be aware that Your request does not guarantee the complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If You have any questions about this Privacy Policy, You can contact us:
By email: info@kygtrade.com
By mail: 220 Newport Center Dr., Suite 11391, Newport Beach, CA 92660