LAST UPDATED ON 1.8, 2018
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.
- 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.
- 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
• 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.
- 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
(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
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.
- 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
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.
- 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.
- 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
- 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
Please also note that we may require certain identification means for facilitating such
rights in your favor, as a part of our protection means.
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.
- 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.
- 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
- 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.
- 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.