Privacy Notice

Introduction

At Kin, your privacy and the security of your personal data is enormously important to us.

We want to transparently explain

  • why we process your personal data and how we do that including what we do to protect it.
  • the controls and choices you have around when and how you choose to share your personal data.
  • your rights and who to contact if you have any concerns.

We endeavour to implement and maintain the highest standards with regard to privacy and adopt policies in line with the highest level of compliance – UK GDPR & EU GDPR.


1. Contact Us

Data Controller

The Data Controller of Kin Family is Todos Media Limited. We are a UK company registered with

If you need to contact us you can chose to do that via

If you have any concerns regarding how we are processing your personal data we’d like the opportunity to address them – Please contact us via support@kin.family

If you believe we have not addressed your concerns you can contact the Information Commissioners Office  https://ico.org.uk/your-data-matters/

Or  https://ico.org.uk/make-a-complaint/your-personal-information-concerns/

2. Why we process Personal Data

Why we process Personal Data

To provide various Kin Family services we process personal data – based upon the relationship you have with us. For Example this could be

  • A paid subscriber to Kin
  • A subscriber on the free plan to Kin
  • A website visitor

The Personal Data we process will vary according to the services you subscribe to and the functionality you use.

The lawful basis we process data under GDPR is either

  • Consent
  • Contract
  • Legal Obligation
  • Legitimate interest

There are two further grounds – vital interest & public interest, but we only process data under one of these lawful basis when required.

When we need to process what is classed as special category data e.g. data revealing racial or ethnic origin etc. we will only do so if we have a lawful exemption such as your explicit consent.

3. Your Rights

Giving you Choice and control

At Kin we aim to process data in line with the principles of fair and transparent processing and this Privacy Notice is aimed at informing you of the purposes of processing operations and your rights.

We aim to supplement this by highlighting to you at points where we request / collect personal data in a timely manner and appropriate format Under data protection law, you have rights including:

  • Your right of access - You have the right to ask us for copies of your personal information.
  • Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
  • Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances. If we are processing on the basis of consent you can withdraw your consent at any tme.
  • Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

To learn more about these right please visit the the Information Commissioners Office ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Please contact us at

If you wish to make a request. You are not required to pay any charge for exercising your rights. If you make a request, the designated period to respond to you is one month but we aim try to respond to you as quickly as feasible.

We regularly review the methods we adopt to support and facilitate your data rights.

4. Data Purposes

Personal Data we process & Why

We process personal information when you use our products and services based upon three broad categories:

  • Customer Account Data - Personal information about customers (or potential customer) of the Kin services. This is so that we can communicate with you and to administer your account if you subscribe to our services.
  • Customer Content Data – the posts, stories, events, pictures, memories and other types of content you upload to the platform. (See T’s&C’s 3.2 for more information on the shareable content)
  • Customer Usage Data - Information of how you use or interact with Kin services through our Applications. This data provides us with the ability to provide the personalised services to you and those you chose to share your Customer Content Data with.

The extent of the data processed and the purpose for our processing will depend upon the relationship you have with Kin – for example we will not process Customer Content Data if you are not a subscriber.

We ask for certain Customer Account Data information, such as your contact details, when you visit our website or sign up for an account with us through our applications.

When you download our application various categories of data will be requested – Further detail regarding this is available at

  • Apple Store reference to privacy info on store

  • Google Play Store reference to privacy info on store

We use Customer Usage Data and Customer Content to provide services to you and to carry out necessary functions of our business as a communications service provider.

As a subscriber to Kin Services, or when you visit our website, we collect some information automatically in order to help us analyse and report information on how you use our services in order to improve the functionality offered for users. For example to prevent and investigate fraud, abuse, or security incidents.

We do not sell your end users’ personal information and we do not share your end users’ information with third parties for those third parties’ own business interests.

A summary of our Data Processing purposes is provided below

Summary of Data Processing purposes

Purpose of processing

Category of Data

Examples of Data Types

Lawful Basis

To fulfil a query, request for services and/or to administer our services

Customer Account Data, Content Data, Usage Data

  • Subscription type
  • Posts
  • Login Information

Performance of a contract or agreement

To fulfil a query, request for services and/or to administer our services

Customer Account Data, Content Data, Usage Data

  • Financial Information
  • Company Accounting etc

Legal Obligation

Marketing messages about our products and services.

Customer Account Data

  • Email Address
  • Mobile Phone Number

Consent

Segmentation and analysis of app use and website performance

Customer Account Data, Content Data, Usage Data

Our Legitimate interest e.g. Business Performance

5. Children

Processing Children’s Data

The Kin Service is not intended for children (under the age of 13 - or the minimum legal age allowed to use our products in your country) and we do not knowingly collect data relating to children.

6. How we Manage your Data

How we manage & store your personal information

We are committed to protecting our users’ personal data and to help protect the security of your personal data.

In order to do this we

  • implement robust technical and organisational measures including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
  • limit access to your personal data to employees, and any third parties who we contract need to know.
  • regularly assess our Technical and Organisational Measures to ensure they are appropriate.

Data Transfers

In order to carry out the activities specified in this Notice and enable global access to our services we store and distribute content and data in systems and data centres that we use around the world.

Personal data collected within the United Kingdom, European Union and Switzerland transferred to and processed by third parties located in an external country subject to privacy laws that are different from those in the country you live in

Where Kin directly or through third party data processors we contract with need to do this Kin shall

  • ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

Who manages & processes data

To provide the Kin Service we use third party data processors to provide elements of services for us.

For our data processors we have contracts in place with them to ensure that they process the data provided to them only for the purposes we have instructed them to. We also specify that they implement specific data minimisation practices and that they will hold data securely and retain it for the period we instruct.

In selecting suppliers and during the contract Kin regularly review and assess the third parties we use to ensure that they abide with the principles of the UK GDPR.

7. Data Retention / Deletion

Data Retention & deletion

We keep your personal data only as long as

  • necessary to provide you with the Kin Service
  • and for legitimate and essential business purposes, such as maintaining the performance of the Kin Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.

We will delete specific personal information you request unless we are legally allowed or required to maintain certain personal data – where it prevents us from carrying out necessary business functions, such as:

  • If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
  • Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
  • Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
8. Cookies

Cookies and related technologies

As you interact with our app and our website, we use cookies, server logs and other similar technologies. Cookies are small text files that are placed by the app or website onto your device - They are widely used in order to make apps and websites work efficiently, as well as to enabling the provision of information to us.

There are various ways of categorising cookies (and similar technologies) e.g. based upon how long they are being set (temporary or permanent) and the organisation setting them (1st or 3rd party).

To learn more about cookies, please visit https://www.allaboutcookies.org. Most web browsers will allow you to turn off cookies. If you want to know how to do this please look at the menu on your browser, or look at the instruction on https://www.allaboutcookies.org/manage-cookies/. Unfortunately, turning off cookies may mean some of our website optional functionality does not work and may restrict use of the site.

Prior to us setting non-essential cookies we will provide a clear on-screen notification about them and give you information and the choice if you accept or decline them.

If you would like to change your cookie preferences, please use the “Cookie Settings” option in the website footer.

The table below explains the cookies we use and why.

Non Essential Cookies

We use cookies to achieve various business purposes for which we request your consent prior to setting them

Google Analytics cookies

_ga

_gat

_gid

730 days

Temporary – Just browser session

1 day

Application

Set By

Purpose /Info

Cookies

Duration

Web & Web App

Kin

Google Analytics cookies gather information for us about how people use our app or our website.

These reports provide useful information which helps us to manage the website and improve our users’ experience of the site.

Find out more about Google Analytics, at https://support.google.com/analytics/answer/6004245

Facebook

Kin

Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.

_fbp & fr

3 months

Facebook

Kin

Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.

tr

Temporary – Just browser session

Necessary

Cookies that are essential to provide the online service

Application

Set By

Purpose /Info

Cookies

Duration

Web

Kin

Manage Cookie Preference

@@scroll#

Temporary – Just browser session

Web

Kin

Manage Cookie Preference

nAdvertisementCookies

nAnalyticsCookies

nCookieConsent

nFunctionalCookies

365 days
9. Other Info

Links to other websites

Through the Kin app or our website content that links to third-party websites may be displayed for example in a post in the Kin App. If you click on a link external to the Kin Service, please understand that you are leaving the Kin Service and we do not control or be held responsible for the privacy practices and content of any third parties. Any personal data you provide will not be covered by this Notice and we encourage you to read their privacy notices to understand how they collect and process your personal data.

Changes to this Notice

This Privacy Notice was last updated on 18/01/2021 and you can print a PDF copy of it for your Records Previous versions of the Privacy Notice are available below

We may occasionally make changes to this Policy. When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Kin Service or by sending you an email and/or a device notification.

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