December 14, 2018
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This Privacy Policy describes how Keepsafe Software Inc. (“Keepsafe”) handles personal information we collect about users of our website at www.getkeepsafe.com and our mobile applications (collectively, the “Service”).
Personal Information We Collect
How We Use Your Personal Information
How We Share Your Personal Information
Third Party Sites and Services
Changes to this Privacy Policy
Additional Information for European Union Users
Personal Information We Collect
Information You Give Us
We collect personal information you give us, such as:
Account information. We collect personal information when you create an account, such as your email address and password, as well as your phone number if you provide one to enable two-factor authentication or if you use our telephony service.
Account content. If you have a Service account, you can use and store different types of data in the Service, such as photos and videos, files, messages and other content.
Transaction information. When you order paid versions of the Service we collect information necessary to complete the transaction, including your name, payment information and billing information.
Forum content. You may post messages and other content in help forums or message boards within the Service. This information is stored within the Service and other users can see it.
Contact details. We collect the contact details you share with us when you
communicate with us, which may include your email address, phone number, postal address or social media handles.
Feedback and correspondence. You may share information with us when you respond to surveys, request customer support or otherwise interact with us.
Contact details for parties you invite. If you decide to invite someone else to create an account on the Service, we will collect your and the third party’s names and email addresses to send an email and follow up with the third party. You or the third party may contact us at support@getkeepsafe.com to request deletion of the other party’s information. By inviting someone else to use the Service, you confirm that you have that person’s permission to do so.
Device data. You may choose to give us permission to access certain data on or components of your device, such as your photos, contacts, microphone and camera. You can always disable this access in your device’s settings.
Sensitive personal information
We will never ask you to send us or submit to the Service any information related to racial or ethnic origin; political opinions or union membership; religious or other beliefs; your health, biometric or genetic information; information about your sexual preference or sexual orientation; or information about your criminal background.
Information we collect automatically
Device and usage information. We use server logs, cookies and similar technologies to automatically collect information about your computer or device and how you interact with the Service. For example, we may record your application version, browser type, computer or mobile operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer or mobile device when you use the Internet, which may vary from session to session) and your unique device, application or advertising identifiers. In addition to information about your device, we collect information about how you interact with the Service, such as the page that referred you, your search terms, pages or areas of the Service you use or share, the time and duration of visits, features you used and links you clicked on.
See the VPN Service section below to learn more about information we collect when you use that service.
Cookies. See our Cookie Notice for more information about how the Service and third party analytics providers and advertisers use cookies and similar technologies to collect your information when you use the Service.
Phone information. If you use the telephony or text messaging services available in some of our mobile applications, we may collect information related to your use of these services, such as the phone numbers you call and message and from which you receive calls and messages, the content of text messages, number of minutes used, number of text messages sent, and amount of data plan consumed.
Information We Collect from Other Sources
When you use our My Number Lookup service, you can request that we send you personal information associated with your phone number that we collect from publicly available and commercially available sources. We do not use this information for any purpose other than to provide it to you when you use the service, we do not share it with any third parties (except for our service providers as described below under How We Share Your Personal Information) and we do not retain it for longer than is necessary provide the service.
Advertising
If you use an ad-supported version of the Service, advertising companies use cookies and similar technologies to collect information about how you use it, and to serve you ads tailored to your interests in the Service and elsewhere. See our Cookie Notice for more information.
How We Use Your Personal Information
We will only use your personal information in ways that are compatible with the purposes listed below for which it was collected or as subsequently authorized by you.
To provide the Service
We use your personal information to provide and support the Service. As part of providing the Service we may send you service announcements, technical notices, updates, security alerts and support-related messages through the Service or by email. We may also communicate with you in response to your support requests, questions or feedback.
To provide the VPN Service
If you are using the Keepsafe Virtual Private Network (VPN) Service (the “VPN Service”), we route all of your Internet traffic through a network provided by Keepsafe and its service providers (the “Keepsafe Network”). We use your IP address to establish and maintain an encrypted tunnel between your browser or device and the Keepsafe Network. We also use your IP address and the IP addresses of websites, services, and applications you view or use to perform automated rules-based traffic management for the purposes of maintaining and improving the VPN Service. The Keepsafe Network is a “no log” network, which means that Keepsafe does not store your IP address when you are using our VPN Service or any information, including IP addresses, about the applications, services or websites you view or use while connected to our VPN Service. However, we do collect information about your aggregate bandwidth usage.
For research and development
We use the information we collect to better understand your interests and the Service, make improvements to the Service and to develop new features and services.
To send you marketing communications
If you use the Service, request information from us, or participate in our surveys, promotions or events, we may send you Keepsafe-related marketing communications. You can always opt out of these communications by following the opt-out instructions in the message or by contacting us.
To create anonymous data
We may create aggregated and other anonymous data from our users’ personal information. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties to operate, understand and improve our Service, develop new services and for other lawful business purposes.
For security, compliance, fraud prevention and safety
We may use your personal information as we believe appropriate to investigate or prevent violation of the law or our Terms of Service; to secure the Service; to protect our, your or others’ rights, privacy, safety or property; and to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
For compliance with law; legal claims
We may use your personal information as we believe appropriate to (a) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities, (b) where permitted by law in connection with a legal investigation and (c) to prosecute or defend legal claims
With your consent
In some cases we may ask for your consent to collect, use or share your personal information with your consent, such as when we request access to your photos or other data through prompts in your mobile operating system.
How We Share Your Personal Information
Affiliates
We may share some or all of your personal information with our subsidiaries, joint ventures, or other companies under common control, in which case we will require those entities to honor this Privacy Policy.
Service providers
We may employ third party companies or individuals to provide services that support the Service (such as customer support, hosting, payment processing, website and mobile app analytics and email delivery). We authorize these service providers to use your personal information only as necessary in connection with providing their services to us. If we learn that a service provider is using or disclosing personal information in a manner contrary to this Privacy Policy, we will take reasonable steps to stop it.
For compliance with law; legal claims; security, compliance, fraud prevention and safety
We may disclose information about you as we believe appropriate to government or law enforcement officials or private parties (a) for the security, compliance, fraud prevention and safety purposes described above; (b) as required by law, lawful requests or legal process; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
Business transfers
We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization, sale of assets or in the event of bankruptcy.
Your Choices
Access, correct or delete
If you have an account, you can access and update the personal information in your profile. Registered users may also contact us to request deletion of your account and personal information. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request, such as where we need to retain your information for security, compliance, fraud prevention and safety, to comply with law or for legal claims. If we decline your request, we will tell you why, subject to legal restrictions. Once we process your request you will not be able to access your account or use the Service. When we delete any information, it will be deleted from our active database, but where permitted by law, may remain for a period of time in our backup files or other instances where deletion is not practicable.
Marketing communications
You may opt out of marketing-related communications by following the opt-out prompt in the message, or by contacting us. You may continue to receive service-related and other non-marketing communications.
Security
We use a variety of industry-standard technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. However, security risk is inherent in all information technology. Thus, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If you believe the security of the Service or your personal information has been compromised, contact us immediately.
International Data Use
Keepsafe is headquartered in the United States and has affiliates and service providers in other countries. Your personal information may be collected, used and stored in the United States or in other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
Third Party Sites and Services
The Service may link to or integrate with other websites and services operated by third parties, including social media platforms, advertising services and other websites and applications. These links and integrations are not endorsements of, or representations that we are affiliated with, any third party. We do not control third party websites, applications or services and we are not responsible for their actions. Third party websites and services follow different rules regarding their collection, use and sharing of your personal information and we encourage you to read their privacy policies to learn more.
Children
The Service is not directed to anyone under the age of 16. A parent or guardian who becomes aware that a child has used the Service may contact us and we will attempt to delete the child’s personal information as soon as possible.
Changes to this Privacy Policy
We may modify this Privacy Policy at any time. If we make material changes to this Privacy Policy we will notify you by email (if we have your email address) or another reasonable manner through the Service. Any modifications to this Privacy Policy will be effective when posted (or as otherwise indicated at the time of posting).
If you object to an update of this Privacy Policy, you must notify us and ask to deactivate your account and delete your personal information prior to the effective date of the update. Continued use of the Service after an update to this Privacy Policy will indicate your acceptance of the update.
Contact Us
If you have any questions or concerns about our Privacy Policy, please contact us at:
Keepsafe, Inc.
427 Bryant Street
San Francisco, California 94107
United States of America
Attention: Privacy
privacy@getkeepsafe.com
Additional Information for European Union Users
Personal information
References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller
Keepsafe, Inc. is the controller of your personal information and can be reached using the contact details in the Contact Us section above.
EU representative
Our EU representative is:
Keepsafe Europe GmbH
Liebigstraße 43, c/o Meilinger
80538 München, Germany
Attention: Privacy
privacy@getkeepsafe.com
Legal bases for processing
Your country only allows us to use your personal information on certain “legal bases”. We generally rely on the following legal bases:
| Processing purpose (click link for details) | Legal basis
|
| To provide the Service
|
You have entered a contract with us and we need to use your personal information to provide services you have requested or take steps that you request prior to providing services. If you do not provide information indicated as required or mandatory within the Service, or that is otherwise necessary to provide a requested service or feature within the Service, it will not be available to you. |
| For research and development To send you marketing communications To create anonymous data For security, compliance, fraud prevention and safety |
These processing activities constitute our legitimate interests. When we rely on our legitimate interests to process your personal data, we consider and balance potential impact on you and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where the impact on you overrides our interests (unless we have your consent or are otherwise required or permitted to by law). |
| For compliance with law; legal claims Sharing your personal information as described in this Privacy Policy |
Processing is necessary to comply with our legal obligations or the activities constitute our legitimate interests. |
| With your consent | Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated at the time consent is requested. |
Note that different legal bases may apply to the same personal information when processed for different purposes. For example, we may rely on consent where required by law or your mobile operating system to access photos on user’s device, but we may rely on performance of a contract when we store or use the photos to provide the Service, or on legitimate interests if we had to review it to investigate a complaint that the photo contained content that violated our Terms of Service.
Data export
If we transfer your personal information out of the European Economic Area in a manner that requires us to apply additional safeguards to your personal information under European data protection legislation, we will do so. Please contact us for information on any such transfers or the safeguards applied.
Retention
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including to satisfy legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.
Your rights
You may ask us to take the following actions:
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Export. Export a machine-readable copy of your personal information that you can use with a different service.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the legal basis of processing your personal information if that processing adversely impacts your legal rights.
To request one of these actions, contact us using the details in the Contact Us section above. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, please contact us. In addition, you may submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here
Cookie Notice
Cookies are small data files stored on your computer or mobile device by a website. They transmit information about your use of the site to its operator or to third parties that placed the cookie.
Our sites and applications use both session and persistent cookies to enable you to sign in and use our sites and applications, store your preferences and settings within them; analyze how they perform, personalize your experience with them, provide interest-based advertising and for other lawful purposes. We may also use other similar technologies for these purposes, such unique device identifiers, and third party software embedded in our mobile applications. In some cases, these cookies and similar technologies are used by third parties.
The cookies and similar technologies used in our sites and mobile applications are as follows:
| Type | Description | Third Party |
| Essential | Essential to provide you with services available through our sites and to enable you to use some of their features.
We cannot provide the services our users request without them.
|
None |
| Functionality | Allow our sites to remember the choices you make when you use our sites.
Intended to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our sites.
|
None |
| Analytics | Collect information about traffic to our sites and mobile applications, and how our users use them, such as the number of visitors, the websites that referred them, the pages they visited, what time of day they visited, whether they have visited before, what features they used and other similar information. We use this information to help operate and improve our sites and mobile applications. | Google Analytics. Learn more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our sites by downloading and installing the browser plugin available here.
Amplitude. Learn more at www.amplitude.com. |
| Advertising | Used by advertising companies to collect information about how you use our sites and mobile applications and other sites and applications over time. These companies use this information to show you ads they believe will be relevant to you within our sites and mobile applications and elsewhere, and to measure how the ads perform. | Mopub, a division of Twitter. See Mopub’s privacy policy here: https://www.mopub.com/legal/privacy/
|
Disabling cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com. If you do not accept our cookies, you may experience some inconvenience on our sites. For example, you may not be able to store preferences in our sites. If you disable cookies, certain features of our website may not work.
Limiting mobile application tracking. Most mobile devices provide settings that will let you limit collection of your information for advertising. To learn more see http://www.networkadvertising.org/mobile-choice.
For more information about how we collect, use and share your personal information, see our Privacy Policy.