Privacy

K9 TMRS Privacy Statement

Last updated: May 16, 2024

Introduction

This privacy statement describes how we use data in our apps, websites, and services. Some of the data we use is considered “personal data” under applicable law. However, even when we use personal data, we generally have no way of actually identifying you as an individual, and our users are essentially anonymous to us.

The specific categories of data that we collect, use, or otherwise process can vary from product to product, from one purpose to another, and in some cases based on your location. This privacy statement sets out when, how, and why we process your data (including but not limited to personal data), as well as your rights under applicable law.

Definitions

Many of these definitions are adapted (with changes) from the General Data Protection Regulation (or “GDPR”), the data privacy law which applies in the European Union. We use the GDPR as a guidepost because it applies directly to our European users and because we believe it sets the highest legal standard for user privacy. However, in some cases we have simplified definitions here for the purpose of clarity.

Personal data: “any information relating to an identified or identifiable natural person” as the GDPR says. This includes data such as your IP address, device IDs, advertising IDs, and location. Below where we describe how we process personal data, we also list the specific purpose for doing so, as well as our legal basis under the GDPR (as those terms are defined below).

Data controller: The person or company that decides whether and how to process personal data.

Data processor: Someone who processes personal data on behalf of a data controller.

Legal basis: the specific legal grounds we use for processing personal data. The GDPR sets out six specific grounds for processing personal data. The ones most relevant to our Applications are as follows:

Consent: When we process personal data based on your consent, that means you’ve expressly given us permission to do so.

Contractual grounds: When we process personal data because it is necessary to perform a contract, for example to provide you with a service as described in our Terms of Service or some other agreement.

Legitimate interest: When we process personal data based on legitimate interest, that means we have some use for the personal data (such as monetization, or ensuring that products work properly) which is in balance with your right to privacy.

Legal compliance: In some instances it is necessary for us to process personal data in order to fulfil other obligations under the law, for example detecting fraud, making sure you are who you say you are, etc.

Applications: the specific apps we offer, as mentioned below.

Monetization: making money. Nearly all of our Applications are free to download and use. Therefore we monetize our products in various ways, mostly by selling physical devices but also by advertising within the Applications themselves. The money we make helps us keep the lights on, pay the salaries of our staff, and continue developing. However, when we monetize our Applications, we never sell our users’ personal data to anyone.

Purpose: the specific reason or reasons we have for processing personal data.

Process or processing: collecting or using personal data. As defined in the GDPR, the word “processing” can mean doing almost anything with personal data. Below we have used it in this general sense when we have a general meaning in mind, and used more specific terms (like “store” or “share”) where appropriate.

Retention / retain: the time period for which we will continue to store data. In general, we do not process or store personal data longer than needed and therefore delete it after a certain period of time. Below we have included some more specific details on retention periods, which vary depending on the type of personal data at issue and the purpose for which it is processed.

Transfer: Personal data is “transferred” when it is sent or made permanently available to someone or some company outside the European Economic Area (or EEA - that is the European Union plus Norway, Iceland, and Liechtenstein).

Applications

Mobile App and Website Based on data such as Advertising ID, News Client ID, general location, and device information, some of our Applications serve targeted ads. These ads are provided by our monetization partners. You can always adjust your personalised ad choices in the application’s “Settings” menu or through your operating system’s settings. We may also combine this data with other elements – including categories of websites you search and visit, device information (model, release date, device IDs, hardware specifications, operating system, etc.), and categories of ads you have clicked on in our products - to build a better understanding of what our users are interested in.. Purpose: Improving our products and services, monetization. Legal Basis: Consent.

General Topics

Use of Cookies

We use cookies on our websites for session management and retaining your settings or preferences. We may also use third-party cookies to collect visitor statistics and measure our marketing campaigns. If you would like to reject third-party cookies, please configure your browser’s settings accordingly. Please refer to our Cookie Policy for more information.

International Data Transfers

As noted above, in different contexts we may share or make available data (including personal date) with third parties, such as our marketing and monetization partners. Where applicable, we insist that a legally valid mechanism is used to protect such transfer, including for example the European Union’s model contracts for the transfer of personal data to third countries (also known as the “standard contractual clauses”) to ensure adequate protection of your personal data.

Your Rights And Statement Updates

You have the right to make a request to access or delete any of your personal data that we might possess. You can make a request via the email listed below. You may be required to provide additional information to authenticate your request.

When we post changes to this privacy statement, we will include the date when the statement was last updated. If we significantly change this statement, we will notify you about the upcoming change via our website or using in-app notifications. We encourage you to review this statement periodically.

Contacts

If you have any questions about this statement or any privacy issues in our applications or services, feel free to contact our Data Protection Officer via email to [email protected]