Kred Privacy Policy

This Privacy Policy sets out the manner in which Kred Education Inc. (“Kred”, “we”, “us”, “our”) collects, uses, discloses, protects and otherwise handles the personal information of our customers (“Personal Data”) when they interact with Kred, including by using the Kred Platform and associated applications (“Kred”). This Privacy Policy is intended to meet our duties under the “California Consumer Privacy Act” or “CCPA” and any other applicable privacy laws.

The Privacy Policy covers both our “online” (e.g., web and mobile services, including any web sites operated by us such as www.kredapp.com, mobile applications, including Kred Rewards, however accessed and/or used, whether via personal computers, mobile devices or otherwise) and “offline” (e.g., collection of data through mailings, telephone, or in person) activities owned, operated provided or made available by Kred.  Our “online” and “offline” activities are collectively referenced as the “Services”. This Privacy Policy also applies to your use of interactive features or downloads that: (i) we own or control; (ii) are available through the Services; or (iii) interact with the Services and post or incorporate this Privacy Policy. 

Collection of Personal Information

We believe you should be informed about what data we collect from you and how we use it and have outlined that below. We also believe you should have control over both and also explain how you can access this information and exercise your rights.

As a baseline we want you to know that Kred uses Personal Information (defined below) to provide, support and enhance the services we provide to our customers. We do not sell Personal Information to third parties. 

Information You Provide Us.  We may ask you to provide us with certain categories of information such as personal information, which is information that could reasonably be used to identify you personally, such as your name, e-mail address and mobile number (“Personal Information”).  We may collect this information through various forms and in various places through the Services, including account registration forms, contact us forms or when you otherwise interact with us.  When you sign up to use the Services, you create a user profile, including contact information. When you add a credit card (“Card”) to your Kred account, we will collect information necessary to facilitate your use of the Card through Kred.  

Information We Collect As You Access And Use Our Services.  In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services (“Usage Information”).  This Usage Information may include the browser that you are using, the URL that referred you to our Services, all of the areas within our Services that you visit, and the time of day, among other information. We may use Usage Information for a variety of purposes, including to enhance or otherwise improve the Services.  In addition, we may collect your IP address or other unique identifier (“Device Identifier”) for your computer, mobile or other device used to access the Services (any, a “Device”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier.  Usage Information may be non-identifying or may be associated with you.  Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information.

In addition, if you use Kred, we may collect behavioral data related to your behavior and interests which we infer or assume based on your online activity on the Kred app.

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will constitute or be considered Personal Data as this data does not directly or indirectly reveal your identity.

No Special Categories of Personal Data. We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and generic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Information Collected by Cookies on Our Website.  When you visit our website, we may place cookies or similar technologies on your Device to enable us to recognize your Device when you are visiting our website.  Cookies are data files placed on a Device when it is used to visit our website.  They may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages, which allows us to improve our Services, offer targeted products and services to you, and collect and analyze information about your access and use of our website.

We may permit certain third parties to place cookies through our website to provide us with better insight about the use of our website and user demographics and to provide relevant promotions to you.  We cannot control the use of cookies (or the resulting information) by third-parties, and use of third party cookies is not covered by our Privacy Policy.

By accessing or using our website, you consent to the placement of cookies on your Device(s) as described in this Privacy Policy.  If you prefer not to receive cookies, you may set your browser to deny or accept the use of cookies, and cookies can be disabled or controlled by setting a preference within your web browser or on your Device. If you choose to disable cookies, some features of the website may not function properly or may result in an inability for us to provide customized service for you.

Use of Information

We will only use or disclose Personal Data where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

  • to conduct user surveys in order to enhance the provision of our services;
  • to contact our users directly about products and services that may be of interest;
  • to analyze, improve and customize our Services;
  • to provide customer and technical support for our Services;
  • to send you receipts, announcements, newsletters, promotional materials and other information about our Services and third-party offers that we think may be of interest to you;
  • to contact you about any issues related to our Services or your use of the Services; or
  • to collect fees and other amounts owed in connection with our Services.  

We will not use or disclose Personal Data for any additional purpose, except as follows:

  • if you request or authorize it;
  • to complete a transaction or provide a service requested by you;
  • to our third-party service providers that provide services on our behalf;
  • to comply with applicable laws, rules and regulations and governmental or quasi-governmental requests, court orders and subpoenas;
  • to protect our rights, property and safety or the rights, property and safety of our users and others;
  • if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g. in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the assets transferred) or in the event of bankruptcy;
  • to merchants, third-party payment processors, and other third-party service providers to process transactions authorized by you through Kred.

We do not and will not sell user lists or personal information to any third parties and have not done so in the past 12 months.

Data Retention

We retain Personal Information only as long as necessary to provide the services and meet any legal obligations. Additionally, we automatically delete all student points awarded after one year and we delete any accounts that are inactive for more than twelve months. 

Decision to Receive Communication. 

You may opt-out of receiving any “push” notifications from us through Kred, and you may opt not to receive promotional emails from us.  Please note, however, that we may still send you non-promotional communications about your relationship with us.

Securing Personal Information

We are committed to ensuring the security of user Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

The following security measures will be followed to ensure that your Personal Information is appropriately protected: the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access); employing the same security requirements as we use for our app(s) and website(s); and contractually requiring any third-party service providers to provide comparable security measures.

 

We will use appropriate security measures when destroying your Personal Information such as deleting electronically stored information in accordance with applicable rules and regulations.

 

We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security. It is important to note that no method of electronic transmission or storage is 100% secure.  Therefore, we cannot guarantee absolute security of your Personal Information.  You also play a role in protecting your Personal Information.  Please safeguard your username and password for your Kred account and do not share them with others.  If we receive instructions using your account log-in information, we will assume that you have authorized the instructions.  You agree to notify us immediately of any unauthorized use of your Kred account or any other breach of security related to our Services.  We reserve the right, in our sole discretion, to refuse to provide our Services, terminate Kred accounts, and to remove or edit content.

 

Access to your Personal Information

You are responsible for maintaining the accuracy of your Personal Information.  If your Personal Information changes, or if you no longer desire to use our Services, you may correct, delete inaccuracies, or amend information at any time by updating your Kred account profile via Kred.

 

Subject to applicable laws, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information.  Otherwise, we will retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by applicable law.

 

 

Privacy and Children

Our Services are not directed, or intended to be used by, minors under the age of 13.  We do not knowingly collect Personal Information from children under the age of 13.  If you are under the age of 13, do not use our Services or submit any information to us.  If you are a parent or guardian of a child under the age of 13 and believe he or she disclosed Personal Information to us, please contact us at privacy@kred.com.

 

 

Changes to this Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes to our information practices.  Any changes will be effective immediately upon posting of the revised Privacy Policy.  If we make material changes, we will notify you by email (sent to the email address specified in your Kred account) or by way of a notification on the Kred app. We encourage you to periodically review this page for the latest information on our privacy practices.

 

Your rights relating to your Personal Data

By law you have the right to:

 

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

 

  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

 

  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).

 

  • Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes. 

 

  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

 

  • Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

  • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Services. We will advise you if this is the case at the time you withdraw your consent.

 

How to exercise your rights

If you want to exercise any of the rights described above or per any applicable laws, please contact us at: privacy@kredapp.com or call us at +1(773-425-2596). Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints. If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: privacy@kredapp.com. We will reply to your complaint as soon as we can.

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