PRIVACY NOTICE

LAST UPDATED ON 1.8, 2018

  1. Introduction
    Kirobo Ltd. (“Kirobo”, “we” or “us”) has created this Privacy Notice to demonstrate
    our firm commitment to secure and trustworthy internet commerce and the individual’s
    right to privacy. This Privacy Notice sets Kirobo privacy policies and practices in
    relation to information that is collected by us through Kirobo website [kirobo.io] (the
    “Website”), which includes access and use of our designated web-based platform
    which offers you unique protection of your cryptocurrency funds (the “Platform”).
    WE STRONGLY URGE YOU TO READ THIS PRIVACY NOTICE AND MAKE
    SURE THAT YOU FULLY UNDERSTAND AND AGREE TO IT. IF YOU DO NOT
    AGREE TO THIS NOTICE, PLEASE DISCONTINUE AND AVOID BROWSING
    AND/OR MAKE ANY OTHER USE OF THE WEBSITE.
  2. Your Consent
    With respect to any of your Personal Information which Kirobo collects or otherwise
    processes, Kirobo will act to obtain your consent. In the event that the processing and
    collection of your Personal Information is required for us to provide you with our
    Services or otherwise make available the Platform to you, or otherwise comply with
    applicable law, your use of the Website and/or Platform (as applicable), will be deemed
    as your consent.
  3. For What Purposes Do We Use Your Information?
    We will use your Personal Data in the scope and manners to which we receive your
    consent; for complying with applicable law; and based on our legitimate interests in
    maintaining and improving our Websites and the content included thereto,
    understanding how our Website is used, improving our customer service and support
    operations, and protecting and securing our users, ourselves and our Website.
    Accordingly, we use Personal Data for the following purposes:
    • To verify your identity, and examine your eligibility to subscribe for our KBO
    tokens required to make use of our services;
    • To facilitate, operate, and provide our Website;
    • To provide our users with customer care, assistance and technical support;
    • To further develop, customize and improve the Website and your user
    experience, based on personal or general experiences and difficulties;
    • To contact our users (via e-mail, or any other available channels) with general
    or personalized service-related messages (such as purchase confirmations or
    system maintenance notices); to contact our users with promotional messages
    (such as updates, new features and services, newsletters, etc.); and to facilitate,
    sponsor and offer certain events and promotions;
    • To support and enhance our data security measures, including for the purposes
    of preventing and mitigating the risks of fraud, error or any illegal or prohibited
    activity;
    • To create aggregated statistical data, inferred non-personal data or anonymized
    or pseudonymized data (rendered non-personal), which we or our business
    partners may use to provide and improve our respective services; and
    • To comply with any applicable laws and regulations.
    Promotional Communications. We may also contact you via the email you provide
    us with in order to notify you about new services, events and special opportunities or
    any other information we think you will find valuable.
    If you wish not to receive such promotional communications, you may notify us at any
    time by contacting us, or by following the “unsubscribe”, “stop” or “change e-mail
    preferences” instructions in the promotional communications you receive.
  4. How Do We Collect Your Information?
    We collect two main categories of data (and to the extent it may enable the identification
    of a specific person, or is linked to such potentially identifying data, we will deem it as
    “Personal Data”):
    (a) Data Automatically Collected or Generated. When you visit, interact with or
    use our Website and/or the Platform, we may collect or generate technical data
    about you. We collect or generate such data either independently or with the
    help of third party services, including through the use of “cookies” and other
    tracking technologies (as further detailed in our “cookies policy” see kirobo.io
    website
    Such data consists of connectivity, technical or aggregated usage data, such as
    IP address, non-identifying data regarding the device, operating system,
    browser version locale and language settings used, the cookies and pixels
    installed on such device, and the activity (clicks and other interactions) of users
    of our Website.
    We do not use such data to learn a person’s true identity or contact details, but
    mostly to have a better understanding on how our users typically use browse
    our Website. The use of such technical and device data also helps us to optimize
    our ad management and our users’ viewing experience, and to improve the
    overall user experience and functionality of our Website and the Platform.
    (b) Data Received From You. You may provide us Personal Data voluntarily, such
    as your name, e-mail address, phone number, location, financial information,
    and location when you contact us, or when filling out applicable KYC, AML
    forms or any other form we reasonable require, including other information we
    require in order to verify your eligibility to use our services via the Platform
    (collectively: the “Forms”).
    If you choose to give us your e-mail address, we will communicate with you via
    e-mail. We do not share your e-mail address with others outside Kirobo.
    Depending on how your e-mail application is set up, information about your
    actions, use of the email sent by us, may be transmitted automatically when you
    receive, open and/ or click on an e-mail from Kirobo. In any event, you may opt
    out from receipt of any additional e-mails from Kirobo, at any time.
  5. How Do We Retain and Store Your Information?
    Kirobo Ltd. is based in a jurisdiction which is considered by the European Commission
    to be offering an adequate level of protection for the Personal Data of EU Member State
    residents.
    While privacy laws may vary between jurisdictions, Kirobo has taken reasonable steps
    to ensure that your Personal Data is treated by its Third Party Affiliates in a secure and
    lawful manner, and in accordance with common industry practices, regardless of any
    lesser legal requirements that may apply in their jurisdiction.
    In general, we retain your Personal Data for a period of 36 months. However, may retain
    your Personal Data, such as the Personal Data included under your KYC forms and
    AML forms for a longer period for legal and accounting purposes (i.e., as required by
    laws applicable to our record and bookkeeping, and in order to have proof and evidence
    concerning our relationship, should any legal issues arise following your
    discontinuance of use).
    Please note that except as required by applicable law, we will not be obligated to retain
    your data for any particular period, and are free to securely delete it for any reason and
    at any time, with or without notice to you.
  6. Who Do We Share Information With?
    We may share your data (including Personal Data) with certain third parties, including law
    enforcement agencies, and our affiliates – but only in accordance with this Privacy Notice:
    (a) Compliance with Laws, Legal Orders and Authorities. We may disclose or
    allow government and law enforcement officials access to certain Personal Data, in
    response to a subpoena, search warrant or court order (or similar requirement), or
    in compliance with applicable laws and regulations, including for national security
    purposes. Such disclosure or access may occur with or without notice to you, if we
    have a good faith belief that we are legally compelled to do so, or that disclosure is
    appropriate in connection with efforts to investigate, prevent, or take action
    regarding actual or suspected illegal activity, fraud, or other wrongdoing.
    (b) Service Providers and Business Partners. We may engage selected third party
    companies and individuals to perform services complementary to our own (hosting
    services, data analytics services, e-commerce, user engagement services, e-mail
    distribution and monitoring services, and our business, legal, financial and
    compliance advisors) (collectively, “Third Party Affiliates”). These Third Party
    Affiliates may have access to your Personal Data, depending on each of their
    specific roles and purposes in facilitating the purposes of our Services, and may
    only use it for such purposes.
    Currently, we engage the following third Party Affiliates:
    (A) YOTI/ Or another similar supplier
    (B) legal advisors
    (C) financial consultants
    (D) Kirobo General Counsel
    WHILE SUCH THIRD PARTY AFFILIATES HAVE PROVIDED THEIR
    ADHERENCE WITH THE GENERAL DATA PROTECTION RULES (GDPR),
    WHERE APPLICABLE, YOU ARE URGED TO REVIEW THE APPLICABLE
    PRIVACY NOTICES AND PRACTICES OF SUCH THIRD PARTY
    AFFILIATES, IN ORDER TO BETTER UNDERSTAND HOW TO EXERCISE
    YOUR RIGHTS UNDER THE GDPR WITH RESPECT TO THE PERSONAL
    INFORMATION MAINTAINED BY SUCH THIRD PARTY AFFILIATES.
    (c) Protecting Rights and Safety. We may share your Personal Data with others, if
    we believe in good faith that this will help protect the rights, property or personal
    safety of Kirobo, any of our users or any members of the general public.
    For the removal of doubt, Kirobo may share your Personal Data in additional manners,
    pursuant to your explicit approval, if we are legally obligated to do so, or if we have
    successfully rendered such data non-personal and anonymous. We may share or otherwise
    use non-personal data in our sole discretion and without the need for further approval.
  7. Security Measures
    Kirobo maintains physical, electronic and procedural safeguards to help guard your
    Personal Data. We restrict access to personally identifiable information to those persons
    who need to know that information to provide products or services to you and any persons
    you have authorized to have access to such information. While we strive to protect your
    personal information, we cannot guaranty the security of any information you transmit to
    us.
  8. Your Rights Regarding Your Personal Information
    We care about your privacy rights. Please note that you may have certain rights
    regarding the manner of collection, processing and usage of your personal information
    pursuant to applicable privacy laws (such as the EU GDPR). Under the GDPR (to the
    extent applies to you) you may be eligible for the following rights:
    o The right to have your personal information deleted, to the extent that, and other
    than in connection with our compliance with a legal obligation / our exercise
    of a legal defense.
    o The right to access the Personal Data collected and processed;
    o The right to rectify untrue or incorrect Personal Data;
    o The right to object to us processing your Personal Data;
    o The right to have your Personal Data exported at your request, which we will
    make efforts to comply with within reasonable time, and provide you with such
    complied data by form of an electronic medium of our choice.
    Please note that the above list contains a summary of the main rights you may have
    under the GDPR. Under no circumstances shall the above be deemed as an exhaustive
    list.
    Please also note that we may require certain identification means for facilitating such
    rights in your favor, as a part of our protection means.
  9. Children
    This Website is directed towards and designed for use by persons aged 16 and older. We
    do not solicit or knowingly collect Personal Data from children under the age of 16. If we
    nevertheless receive Personal Data from an individual who indicates that he or she is, or
    whom we otherwise have reason to believe is, under the age of 16, we will delete such
    information from our systems.
  10. Links to Third Party Websites
    The Website may contain links to other websites. While we try to link only to websites
    that share our respect for privacy, please be aware that Kirobo is not responsible for the
    privacy practices or the content of other websites. Websites that are accessible by
    hyperlinks from the Website may use “cookies.” We encourage you to read the privacy
    statements provided by other websites before you provide personally identifiable
    information to them.
  11. Changes to this Privacy Notice
    This Privacy Notice may change over time as we modify or expand our service. If we
    decide to change our Privacy Notice, we will prominently post those changes on this
    page. Other where your opt-in consent is required under applicable law, your continued
    use of the Website after we post such notice constitutes your agreement to any such
    changes.
  12. Legitimate Interest
    Other than where we receive your opt-in consent, all Personal Data collected by us is
    required for us to provide you with the applicable services under the Platform.
  13. Contacting Us
    If you have any questions about this Privacy Notice, or in the event that you wish to
    exercise certain rights you are eligible for with respect to your Personal Date, please
    contact us via the information below. We welcome your questions and suggestions
    about our Privacy Notice.
    [email protected]