“Personal Information” is defined as any information about an identifiable individual.
KABN NA takes commercially reasonable measures to help safeguard your personal information from loss, disclosure, alteration, misuse and unauthorized access, theft and destruction. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with adequate safeguards. As the internet is not 100% secure, KABN NA cannot guarantee the absolute security of your information. We do not accept liability for unintentional disclosure. KABN NA is not responsible for the security of information that you transmit to us over networks that the Company does not control, including the internet and wireless networks.
KABN NA retains information collected for no longer than is reasonably necessary to fulfill the purposes for which the Company collects information and to comply with the Company’s legal obligations.
If you have any questions about the security of your personal information, please contact us at firstname.lastname@example.org.
- Collection of Information
KABN NA collects the following types of information:
Information that you provide to KABN NA directly to deliver Services requested
When you use the Services to register an account with KABN NA, the Company will collect your email address. When you use the Services to verify your identity through KABN NA, the Company will collect information such as ID Documents (passport, driver’s license, ID card, etc…), document type, scan of the document, country, “selfie” photo, account ID, legal name, national ID number, gender, date of birth, mailing address, IP address, user name, blockchain address, email, local storage, user display settings, Google authenticators, audit logs, and device camera. When you use the Services to verify your identity, KABN NA may collect information such as Social Insurance Number, credit records, telephone number, IP Address and utility bills.
Facial Biometric Identity Verification
Facial biometric identity verification is accomplished by comparing two or more captured images of faces. The biometric identifiers used to complete this assessment are taken from the images that you submit.
Information we may collect from Third Parties
A cookie is a small text file that is placed and stored on your computer, mobile or other devices by webpages that you visit. The Cookies collect information in an anonymous form, including the number of visitors to the webpage, how the visitor found the webpage and recent webpages visited. All cookies used by KABN NA are in accordance with current regulations.
KABN may also use any of the following categories of Cookies.
- Essential Cookies
The Cookies are strictly necessary for the KABN NA website to function. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. These Cookies do not store any personally identifiable information.
- Analytics Cookies
These Cookies track information about visits to the website so that we can make improvements and report performance. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these Cookies collect is aggregated and anonymous.
- Functional or Preference Cookies
These Cookies enable the website to provide enhanced functionality and personalisation. They are used to remember information you have entered or choices you make (i.e. username or language) on the KABN NA website. They may be set by KABN NA or by third party providers whose services we have added to our pages.
- Use of Information
KABN NA may use the information collected from you for the following purposes:
KABN NA may use personal information to provide products, Services or information requested by you. Examples include to manage your individual information and account, help you efficiently access your information after you sign in, allow access to certain functionalities and features of the Company’s Services, and respond to your inquiries.
KABN NA may use personal information for the following administrative purposes:
- Verify your identity
- Process applications and transactions
- Validate your identity with third parties of your choosing and upon your direction
- Transfer your information that you choose to share with third parties upon your direction
- Measure interest in KABN NA’s Services
- Develop new products and Services or improve existing products and Services
- Monitor metrics such as total number of visitors, traffic, and demographic patterns applicable to the Services
- Send you Service-related emails (i.e., account verification, changes or updates to features of the Service, technical and security notice)
- Compliance with legal obligations and regulatory requirements (i.e., respond to legal process or request for information issued by government authorities)
- Prevent potentially prohibited or illegal activities
- Enforce KABN NA Terms and Conditions
- Sharing of Information
With Vendors and Service Providers
KABN NA may disclose your information to third party service providers that perform services on the Company’s behalf, such as web-hosting companies, analytics providers and information technology providers. KABN NA entrusts personal information to the following types of service providers:
- Providers of IT and related services
- Customer service activities
- Fraud prevention
- Providers of services you have requested
KABN NA has contracts with service providers that forbid them from using or disclosing personal information except as necessary to execute the contracted services on the Company’s behalf or to fulfil legal obligations.
With Law Enforcement or Government Authorities
KABN NA may disclose information as may be permitted or required by laws of any jurisdiction that may apply to the Company, as provided for under contract, or as KABN NA deems reasonably necessary to provide legal services. In these circumstances, the Company takes reasonable efforts to notify you prior to disclosing information that may reasonably identify you, unless prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances.
Change of Control
- Transfer of Data
KABN NA takes all reasonable steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located. KABN NA operates in North America, and through its Licensor and affiliated KABN companies, throughout the world and as we don’t necessarily store your data in your country of origin, we do transfer personal data from your country to the European Economic Area and to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. Some of these data transfers may include a transfer between KABN entities, to third party suppliers and to cloud based storage providers.
Any transfer we make is done using a variety of legal mechanisms, including contracts, to help ensure your rights and equivalent protections travel with your data. We want to ensure that data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data.
Ways in which we safeguard your data include, but are not limited to:
- Through the use of a transfer agreement which includes the current standard contractual clauses put in place by the European Commission for the transfer of personal data;
- For any transfer of data to a US based entity, we require that entity to be part of Privacy Shield which is the framework in place in the United States to safeguard data;
Other circumstances under which your data could be transferred include when it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interest for the purposes of the contract and where you have consented to the data transfer.
- Individual’s Data Rights
This section addresses how KABN NA handles requests pertaining to an individual’s rights as set out in the European Union’s General Data Protection Regulation (GDPR).
You may contact us at email@example.com to inquire about your right to view all of the personal data that KABN NA has collected about you. Requests to access personal data will be answered within one month of receipt. A representative of KABN NA will provide more details during correspondence.
You may contact us at firstname.lastname@example.org to request that KABN NA update or fix your personal data. Requests to rectify personal information will be answered within one month of receipt. A representative of KABN NA will provide more details during correspondence.
You may contact us at email@example.com to request that KABN NA erase all of your personal data on file. KABN NA is only able to provide the Services through collection, use, storage, and sharing of your personal data. Without your personal data, KABN NA is unable to provide the Services requested. A request for the erasure of personal data equates to a request to be deleted from all KABN NA systems. Requests to erase personal data will be answered within one month of receipt. A representative of KABN NA will provide more details during correspondence.
You may contact us at firstname.lastname@example.org to request that KABN NA restrict the processing of your personal data. Requests to restrict processing will be answered within one month. A representative of KABN NA will provide more details during correspondence.
You may contact us at email@example.com to request that KABN NA export all of your personal data on file. Personal data will be exported in a commonly used format. Requests to export data will be answered within one month. A representative of KABN NA will provide more details during correspondence.
- Third Party Services and Content
The third party vendors with which KABN NA shares your personal information are contractually required by the Company to keep this information confidential and may generally not use such information for any purpose other than to help the Company provide solutions to KABN NA customers.
KABN NA may use third party service providers to collect personal information on its behalf. These third party service providers may be located in countries where the privacy laws provide different levels of protection for personal information. If you would like more information about KABN NA’s use of these service providers, please contact us at firstname.lastname@example.org.
The Company retains personal information no longer than is necessary to fulfill the purpose(s) for which it was collected, except where you have given permission for a longer retention period or a longer period is permitted under applicable laws.
- Updates or Changes to KABN NA Policies
- Your Choices and Rights
Subject to local law, you may have certain rights regarding information that KABN NA has collected and that is related to you. Please contact KABN NA to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate or out of date. You can also ask to see what personal information KABN NA retains about you, and to erase your personal information. If you would like to exercise the rights you may have, please contact us at email@example.com.
Although KABN NA strives to provide individuals with access to their personal information, there may be instances where KABN NA may not provide access, including but not limited to: where the information would put another individual’s privacy at risk, where the access would reveal confidential commercial information, or the requested information contains legal privilege. If KABN NA determines that access should be limited in any specific instance, the Company will provide an explanation of why that assessment has been made and a contact point for any further concerns.
If you no longer wish to receive marketing communications, please contact us.
- Children’s Privacy
KABN NA does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 18. In the event that KABN NA learns that the Company has collected personal information from a child under the age of 18 without parental consent, KABN NA will delete that information as quickly as possible. If you believe that KABN NA might have any information from or about a child under 18, please contact the Company.
16.California Consumer Protection Act of 2018
We have adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA).
The terms “business,” “business purpose”, “personal information”, “processing”, and “service provider” have the meanings giving to them in the CCPA.
KABN NA also collects information in its capacity as a service provider to our clients, providing ID verifications, KYC/AML (“Know Your Customer” and “Anti-Money Laundering”) services and other related financial services. In that case, KABN NA receives personal information directly from individual customers and in some cases, from our clients where we have no direct relationship with the individuals whose personal information we process, and information is provided to us solely for the business purpose of providing those services.
Categories of Personal Information We Collect
The specific personal information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on the level of ID verification processed, however, KABN NA never sells or discloses your personal information to third parties.
In the past 12 months, we have collected and used for business purposes, personal information relating to California residents covered by this policy which may include:
Examples May Include
Name, alias, postal address, unique personal identifier, online
Personal Information categories described in California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
Protected classification characteristics under California or federal law
Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
Physical location or movements.
Professional or employment-related information
Current or past job history
Non-public education information (per the Family Educational Rights and Privacy Act
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student financial information
Inferences drawn from other personal information.
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Sources of Personal Information We Collect
- Information directly from you, the consumer, that you choose to provide, when you interact with us, for example, when you register for ID verification.
- Information provided by our clients in order for us to provide specific services as a service provider, or information from third parties, acquired at the direction of our clients in order to provide the services.
- Information from other sources, including service providers or publicly available sources.
We collect personal information to offer and administer our services and products. These include:
- To provide the products or perform services for our clients pursuant to a written agreement, including contacting you in the course of our ordinary commercial relationship, verifying client information, or similar activities as needed to provide services for or on behalf of our clients.
- For marketing purposes. For example, we may use your information to further discuss your interest in our services and to send you information regarding KABN KASH and other such services and opportunities. You may opt-out of receiving marketing communications and updates at any time.
- To improve our communications with you. Emails sent to you by KABN NA may include standard tracking, including open and click activities. KABN NA may collect information about your activity as you interact with our email messages and related content in order to verify or maintain the quality of our communications, or improve, upgrade, or enhance the services we provide.
- For security purposes, including detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
- For other business purposes, which will be disclosed at the time we collect personal information.
Disclosure/Sharing of Personal Data
In the preceding 12 months, we have not sold any personal information.
We share personal information for business purposes with the following categories of third parties:
- Our affiliates, as needed to operate our business and provide services.
- Service providers, such as vendors, consultants and other service providers who perform certain services on behalf of KABN NA, in which case we enter into a contract that describes the purpose of processing and requires the recipient to not use it for any purpose except performing the contract.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Subject to the CCPA and other applicable laws, you have the following rights concerning your data processed by KABN NA:
- Access: You have the right to request to access the personal information that KABN NA holds about you, including categories of information collected, categories of sources from which the information is collected, our business purpose for collecting information, and categories of third parties with whom we share your information.
- Deletion: You can request that KABN NA erase your personal data. However erasing your personal data will not allow us to further interact with you as a customer.
- Non-discrimination: KABN NA will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under the CCPA.
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