Privacy Policy

Last Updated: July 26, 2018

WHO ARE WE?

Killi, Inc. (“we”, “us”, “our” or “Killi”) collects your personal and demographic information (the “Data”) directly from you (“you”, “your” or the “End User”), through our mobile application (the “App”). This Privacy Policy explains how we collect, use and disclose your information.

All capitalized terms not otherwise defined in this Privacy Policy shall have the same definitions ascribed to them in the Terms of Use.

WHAT DO WE DO?

The Services provided through the App allow you to be compensated for the sale of your personal information to various parties, including, but not limited to, brands, advertisers market researchers, banks and data management platforms (collectively, the “Purchasers”), in accordance with the Terms of Use. KI negotiates and brokers the transactions at fair market value.

Killi provides Services directly to you as the owner of the Data, by providing a medium to exchange your information with the Purchasers through the App. Purchasers can use the information collected by our proprietary technology in any way, including, but not limited to, commercial relationship management and marketing purposes.

We act solely as an intermediary between you as the End User and Purchasers. As such, we are not responsible for how Purchasers treat or use your Data and we hereby specifically disclaim any such responsibility. We encourage End Users to review the terms of use and privacy policies of Purchasers to understand their practices with respect to the collection, use and disclosure of your Data.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy from time to time. If we make changes to the Policy, we will notify you by revising the “Last Updated” date at the top of the Policy. The most current version of this Privacy Policy will govern our current use of your information and your use of our Services, the Website and/or the App, and will always be located here. We encourage you to review our Privacy Policy regularly to stay informed about our privacy practices. Your continued use of the Website and/or the App and/or any of the Services following a change or changes to this Privacy Policy, constitutes your binding acceptance of the change or changes.

YOUR DATA

What Data is Collected Through the App?

We do not store your personal identifiable information indefinitely, however we do store it temporarily in order to process, organize and anonymize it in order to be able to use and share it as part of the Services. We use an anonymized ID to recognize you. The type of Data that we collect from you may include:

  • Personal information such as email and phone number;
  • Device location (e.g., latitude/longitude coordinates), and time of day;
  • Demographics (such as gender, birth date, etc.);
  • Information about devices (e.g., make, model, OS, and other similar Information, but not phone number);
  • The information about the App permissions (e.g., deliver notifications, use location services, and other similar Information); and
  • Opinions of end users on brand-driven questions, such as brand awareness or quality.

 

What Data is Collected Through the Corporate Website?

When you visit our corporate Website www.killi.io or related websites (collectively, “Websites”), we may collect and store information related to the use of the Websites, such as IP Address or Mobile advertising ID, and information pertaining to devices, network, protocols and software and the date and time of visits. We will use this information to help us provide a more relevant and useful site experience to our Website visitors. This information is also used in the aggregate to perform statistical analyses of user behaviour and characteristics in order to measure interest in and use of the various areas of the Websites. In order to use some functions of these Websites, you may be required to register or provide personal information, such as your name and email address. This information will be used only for the purposes of providing you with the functionality you have registered for.

How Is Your Data Collected?

Killi collects Data through the App and the information collected from the App is stored on your mobile device.  Data collected through the Website is store on the Website. Once Killi obtains the Data collected through the App, and a Purchaser puts in a request for the Data, Killi will transmit that Data through an API, in encrypted form, via a HTTPS protocol to the Purchaser’s data management platform.

How Is Your Data Used and Shared?

The Data is collected to create a detailed user profile on your device. The visitor information can help build interest about you, which can lead to more data points collected. The Data is shared directly with potential Purchasers that are willing to compensate the End User at fair market value. The Data is also shared with Killi Inc.’s Partners that offer marketing attribution, analytics, SMS and push notification services. We make reasonable efforts to ensure that the Killi Inc.’s Partners adopt privacy policies that are compliant with the General Data Protection Regulations (the “GDPR”).

How Is Your Data Retained and Secured?

We understand how important protecting your privacy is, and we are committed to safeguarding the Data collected or accessed. We have implemented specific security procedures to protect the storage and disclosure of Data we gather. Access to Data is restricted to select employees or representatives. By default, Killi stores all user Data on your mobile device until the App is deleted. We may retain anonymized, non-personal Data (demographic information and interests) on Killi’s servers for an extended period of time, in order to generate market segments to advertisers and provide users with surveys. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

GENERAL DATA PROTECTION REGULATIONS (“GDPR”)

Opting In to Data Sharing

All data points collected from the App are automatically shared, unless otherwise stated by the App. For example, when your phone number and email address are first collected, it is for verification purposes and not to be shared. You will then have an opportunity to specifically opt in to allow those data points to be shared.

Opting Out of Data Sharing

To opt out of a data point from being shared you can simply go to the specific data point in your registered Account profile and select not to share it. Alternatively, if you would like to stop sharing all your data points and request all data used previously, be purged, you can delete your registered Account. Please refer to the Terms of Use for instructions on terminating your registered Account.

Preventing Future Use of Data

To delete your registered Account, you must contact support@killi.io and request that your registered Account be deleted. In order to process this request, and to verify that the owner of the registered Account is the party seeking the deletion, Killi will require that you provide your Public Key and Advertising ID (IDFA for iOS and AAID for Android).

 

YOUR TRANSACTIONS

How Do You View Your Transactions?

You can access your transaction activity history in your registered Account. If you would like details on which Purchasers have purchased your data, you can request a detailed list of Purchasers from support@killi.io. You will require your Public Key and your Advertising ID (IDFA for iOS and AAID for Android), for reference when making this request.

How Are Your Transactions Managed?

Killi stores all transactions on and off blockchain. We store all transactions in a ‘read only’ format on a publicly available ledger. Then, once a day, or after we have reached 10,000 transactions, we hash the transactions and store the hash on the blockchain, making our audit trail completely immutable and transparent to you. If you want to access the transactions, you can look up their Public Key in our ledger and go through the process of hashing the data, based on an algorithm we provide, and find the hashed transaction on the blockchain.

How Do You Opt Out of Sharing Your Data?

In the ‘profile’ tab of your registered Account, you have the option to edit any data point that you are sharing. Once you click ‘stop sharing’, the data point will no longer be shared with any advertisers it will only reside on your phone. This is with exception to IDFA and Location, which are required for using the App.

You can, however, refresh your IDFA at any point by doing the following:

  • Apple devices:
    • Opt out of app-based tracking for interest-based advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON’.  For iOS 6, you can do this by selecting Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON’. For iOS 7 and higher, you can do this by selecting Settings -> Privacy -> Advertising and toggling Limit Ad Tracking to ‘ON’. You can obtain further information on how to limit ad tracking on your iOS device or to reset your IDFA here:  IDFA Opt-Out.
  • Android devices:
    • Opt out app-based tracking for interest-based advertising by taking the following steps: (i) Open the Google Settings app on your device; (ii) Select “Ads”; and (iii) Opt out of interest-based ads. You can obtain further information about how identifiers on mobile are used for advertising and receive instruction for how to opt out of mobile advertising here: Google Privacy & Terms webpage.

 

GOVERNING LAW

We are based in Toronto, Ontario, Canada, and this Privacy Policy will be interpreted in accordance with the laws of the Province of Ontario. The information we collect may be transferred in or out of Canada and may therefore be subject to foreign laws. Please refer to our Terms of Use for more information on how we handle disputes arising out of the use of the Services or the interpretation and application of the Terms of Use and this Privacy Policy.

PRIVACY OFFICER

If you have questions concerning the Privacy Policy, or concerning the collection, use and disclosure of your personal information, please contact us at:

 

Attn: Privacy Officer
Killi, Inc.
409 King St. West
Suite 400
Toronto, ON
M5V 1K1
Email: privacy@killi.io

 

For additional information on your rights regarding the collection and use of your personal information, you can contact the Office of the Privacy Commissioner in your jurisdiction.