This Privacy Policy (“Policy”) will describe how we, Kinner Lake Ltd (“Company”, “we” or “our”) collect and process information while users (“you” or “user”) are using, installing or browsing (as applicable) our following products and services (collectively “Services”):
  1. Our informative website available at https://kinner-inc.com/ (“Website”);
  2. Our add-on browser extensions and any feature or service offered or provided therein, including search pages (“Extension”).
    This Policy explains what information we may collect from our users, how such information may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Information (as such term is defined below), among others, under the following legislation:
  1. The EU General Data Protection Regulation (“GDPR”), which shall apply to you in the event you are a resident of the European Economic Area (“EEA”); and
  2. The California Consumer Privacy Act of 2018 ("CCPA") which shall apply to you in the event you are a “California resident”, as defined under the CCPA.

In the event you are a California resident and the CCPA apply to you – please review our CCPA Privacy Notice.

If you have any questions about this Policy, please contact us at: privacyteam@kinner-inc.com

Please note that this Policy is incorporated in the Terms and Conditions. PLEASE READ THIS POLICY CAREFULLY BEFORE USING OUR SERVICES AND ANY FEATURE PROVIDED THEREIN.

The Information We Collect and Purpose of Processing

    When using our Services, we may collect certain data from you, which can be classified as follows:
  1. Personal Information - information that identifies an individual or may with reasonable effort identify an individual;
  2. Non-Personal Information - non-identifiable information gathered and processed through use of the Extension.

Note that, we process different types of Personal Information based on the type of Services you use (e.g., our Website or Extension).

Subject to the GDPR, we process Personal Information based on the following lawful basis, and as applicable: (i) consent – where required under applicable law we will request your consent to process Personal Information; (ii) contract – if and when you sign up for any of our Services, we may process Personal Information in order to perform such contract with you; (iii) legitimate interest - we have a legitimate interest in processing certain Personal Information such as IP address for operation purposes, as detailed below.

    Specifically, see below the details regarding the information we collect and process:
  1. Online Identifiers – upon installation and use of the Extension, we collect and process certain online identifiers such as your IP address. This information is collected and processed for the purpose of operating and providing the Extension and its features and services, as well as customizing and improving our Extension. In addition, it will be used to provide the advertisements incorporated therein (where applicable). For example, the IP address will be used in order to determine the country level geolocation and display relevant advertisements. Furthermore, we process this information for the purpose of auditing and tracking usage statistics and traffic flow, detecting fraud, security or technical issues in connection with the Extension and for internal analytical and statistical purposes.
  2. Search Queries and Browsing History - upon installation and use of the Extension, we collect some of your search history in order to provide the services under the Extension (including the enhanced search results – meaning the offering of relevant advertising based on the users’ searches). Please note that this information is deleted after a short period following collection.
  3. Contact Details – we will collect your contact details solely if and when you will choose to provide us with such information when you contact us, for example through the online form available in the Website. We will use and process such information for the sole purpose of providing you with the support you have requested or response to your questions. We nay also store the contact history in order to improve our services, and resolve disputes (where applicable).
  4. Technical Information - Upon installation and use of the Extension, certain Non-Personal Information will be collected and processed by us. This information will include the type of operating system, device type, default browser; your aggregated use of the Extension (meaning if you have installed the Extension; language and the time stamp and approximate geographical location).
  5. Recruitment - If you are interested in working with us, you may voluntarily send us your CV through the means of communications we make available on our Website. In the event you send us your CV, note that, your provision of Personal Information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

When Will We Share Information We Process With Third Parties?

    We will share Personal Information collected and processed by us solely in the following events, and to the extent needed:
  1. Online identifiers we have collected might be shared for the purpose of operating the Extension and providing the services and features thereunder. This will include calculating payments and detect fraud, security or technical issues in connection with the Extension.
  2. We may share Personal Information with our service providers in order to enable them to perform requested services on our behalf.
  3. The Extension may include third party’s features such as search feed. These third parties may be shared with online identifiers and search queries in order to provide personalized search results.
    Information regarding Oath’s (feed provider) data collection privacy can be found at its privacy policy available at: https://policies.oath.com/us/en/oath/privacy/products/searchservices/index.html. In addition, opt out information which will enable you to limit data collection by Oath is available here https://aim.yahoo.com/aim/us/en/optout/. Information regarding Bing’s (Microsoft) privacy policy is available at: https://privacy.microsoft.com/en-us/privacystatement. In addition, opt out information which will enable you to limit data collection by Bing is available here: https://about.ads.microsoft.com/en-us/resources/policies/personalized-ads.
  4. We may share Personal Information in the event required in order to comply with any applicable law or permitted by it, regulation, legal process or governmental request. Furthermore, we may share or disclose Personal Information in the event we believe it is needed for the purpose of defending our rights or enforcing our policies.
  5. We may share Personal Information in the event of a corporate transaction which may include merger, asset sale, etc. Furthermore, we may share Personal Information with our parent company and subsidiaries, or other entities under a common control. We will obligate these entities, including any acquiring company to act as in this Privacy Policy when it comes to processing Personal Information.
  6. We may share Personal Information where you have requested us to do so or otherwise provided your consent.

Cookies and Other Tracking Technologies

We and our service providers may use certain cookies and other common tracking technologies such as web beacons, pixels, user agent, etc. These tracking technologies are basically small pieces of information assigned to the device on which our Extension was installed by you and they can be used for different purposes, for example: enabling you to navigate between pages efficiently, enable automatic activation of certain features, as well as customizing your experience by providing you with applicable content (e.g. advertisements). For more details regarding the use of cookies, you may review the information available here: www.allaboutcookies.org. We may also gather some information automatically, for example usage data, and store it in log files.

The table details specifics the cookies and other tracking technologies (ours and third party’s) we currently use, purpose of use, their Privacy Policy and opt-out controls:

Third Party Purpose Privacy Policy
Google Analytics Analytic, Measurement and Performance https://tools.google.com/dlpage/gaoptout https://www.google.com/policies/privacy/partners
Open Weather Functionality (an API used to provide the weather according to your location if you use the applicable Extension) https://openweather.co.uk/privacy-policy

For additional information of our use of Google products, click here.

Cookies Opt-Out

Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. By following the instructions of your device preferences, and by adjusting the privacy and security settings of your web browser, you may remove cookies, however, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited.

Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful: https://support.google.com/chrome/answer/95647?hl=en (Chrome); https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); http://www.opera.com/help/tutorials/security/cookies/ (Opera); https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); https://support.apple.com/kb/PH21411 (Safari); https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge);

You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services like the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page;

Opt-out provided by Business Partners

Our business partners (meaning, search feed providers) may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies of their applications to learn more about the privacy practices of our business partners. Please note, however, that we are not responsible for the privacy practices of our business partners, and other third parties.

In addition, as detailed above, we may offer Oath search feed as part of our Extension and thus it may include cookies on its behalf - more information is available here: https://policies.oath.com/us/en/oath/privacy/products/searchservices/index.html

It is important to note that disabling cookies will not prevent the display of advertisements; it just means such advertisements will not be customized. In addition, note that, if you choose to disable cookies, some features of the Extension may not operate properly.

Third Parties’ Content and Linked Digital Assets

The content available through the Extension (e.g., search results and advertisements) may link to third party content and other digital assets such as websites. Once you interact with such content or links, these third parties’ privacy practices will apply and not ours, thus, we encourage you to review their privacy policy. We are not, and will not be held responsible to privacy practices established by third party providers.

Data Retention and Security Measures

We highly respect your privacy rights and thus, we make best efforts to protect your Personal Information from unauthorized use, processing, access and disclosure, etc. As part of our efforts protecting your Personal Information, we ensured to have in place security measures, which adhere to industry standards including physical, technical and administrative measures, as required under applicable law. In the event required under applicable laws if we will become aware of a security breach that may affect your Personal Information, we will take reasonable efforts to notify you and the applicable authority.

The Personal Information collected by us will be retained solely for as long as required to provide the features of our Extension and operate our business (such as calculating payments and detecting fraud. In addition, if required, we will retain Personal Information if needed to comply with our legal obligations, resolve disputes and enforce our agreements.

Data Subject Rights Related to Personal Information

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make informed decisions about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Information, according to applicable data protection and privacy laws.

Privacy laws differ from jurisdiction to jurisdictions, each of which may provide you with different rights regarding your Personal Information. For your convenience, please see below a list of rights that you may be entitled to exercise in accordance with the applicable data protection laws that apply to you.

  1. The right to be informed – for the purpose of ensuring fair and transparent processing, you have the right to be provided with information regarding our data collection and privacy practices, as described in this Policy.
  2. The right to access your information - you have the right to request a confirmation that we process your Personal Information, and under some circumstances, be provided with a copy of your Personal Information that we process.
  3. The right to be forgotten - you have the right to require the erasure of certain Personal Information, if specific conditions are satisfied (if the Personal Information is no longer needed for the original purpose and there is no new lawful basis for continued processing); if you have exercised your right to withdrawn consent (in the event applicable), or to object to the processing and we have no overriding grounds for the continued processing; the Personal Information is processed unlawfully; or erasure of Personal Information is necessary to comply with applicable legislation. Please note that this right is not absolute. We may not accept a request under certain circumstances, among others where we must retain the applicable Personal Information in order to comply with our legal obligations or defend against legal claims, etc.
  4. The right to object & do not sell my Personal Information (to the extent the CCPA apply) - you have the right to object to our processing of your Personal Information, in the event the legal basis for processing is our legitimate interests. Notwithstanding the above, we will be permitted to continue the processing of such Personal Information if our legitimate interests override your rights, or when the processing is necessary to establish, exercise or defend a legal claim, etc.; Under the CCPA you have the right to opt out of the sale of Personal Information.
  5. The right to object - you have the right to object to processing of Personal Information, in the event that our legal basis for processing is our legitimate interests. Notwithstanding the above, we will be permitted to continue the processing if our legitimate interests override your rights, or when processing is necessary to establish, exercise or defend a legal claim or right, etc.;
  6. The right to restrict processing - you may be entitled to limit the purposes for which we process your Personal Information. This right is applicable when: the accuracy of the Personal Information is contested; the processing of the Personal Information is unlawful and you requests restriction instead of erasure; the Personal Information is no longer needed for the original purpose it was collected, however it is still required to establish, exercise or defend legal rights; or there are overriding grounds in the context of an erasure request;
  7. Rectification (to the extent GDPR apply) - you have the right to require to update Personal Information which is not correct;
  8. Data Portability - you have the right to have your Personal Information "port" to a third-party, however note, the GDPR and CCPA apply differently to this right, thus, we will handle this according to the jurisdiction you are subject to;
  9. The Right to Non-Discrimination (in the event the CCPA apply) - you have the right not to be discriminated against for having exercised your rights under the applicable laws.
  10. File a complaint - You may also be entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy.

If you wish to submit a request to exercise any of your rights, please fill our designated form available here, and send it to: privacyteam@kinner-inc.com. Note that, we will require certain information from you in order to verify your identity and locate your information. This may take reasonable time, and subject to applicable law requirement (for example, one (1) month under the GDPR; or ten (10) - forty five (45) days under the CCPA), unless otherwise required or permitted under applicable law. At any time, you have the right to contact your local data protection authority. If we require more time, we will inform you of the reason and extension period in writing. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Further, note that under the CCPA your rights only apply to the Personal Information collected 12 months prior to the request and you are not entitled to submit more than 2 requests in a 12 months period.

Please not that, privacy related legislation in your jurisdiction may include additional or different rights than the rights stated above. Such rights may also apply to your Personal Information that we process.

Transfer of Information

We may store or process your Personal Information in the European Economic Area as well as the United States or in other territories. In the event transfer of your Personal Information is required in order to operate our business, provide you with our services, etc., will take appropriate measures to ensure that your Personal Information receives an adequate level of data protection upon its transfer outside your jurisdiction, as required under applicable laws.

Children’s Data

We do not knowingly process Personal Information of children under the age of 16. If you are aware or you believe that we have collected or we process child’s Personal Information, please contact us at: privacyteam@kinner-inc.com

Do Not Track

The Extension does not respond to Do Not Track signals. Information regarding “Do Not Track” is available here: http://www.allaboutdnt.com/.

Revisions of this Privacy Policy

We may revise the provisions under this Policy at our sole discretion and at any time, without notice. However, in the event of a material change that we believe will materially affect your rights, we will make best efforts to provide a notification, as shall be required under applicable laws. Any revisions will be effective as of the date stated below under “Last Updated”.

Further Questions?

If you have any general questions about this Policy, your rights regarding your Personal Information and our privacy practices, please contact us at any time, as follows:

Kinner Lake Ltd.
50 TOWN RANGE
GX11 1AA GIBRALTAR
hello@kinner-inc.com

Last Updated: March 30th, 2020