PRIVACY POLICY

Effective Date: May 23, 2018

Kano Applications Inc. (“KANO”, “we” or “us”) is a British Columbia company. This Privacy Policy applies to KANO’s games, websites and services (collectively, the“Services”).

As an essential part of our business, we collect and manage information. In doing so, we observe Canadian privacy legislation and are committed to respecting and protecting our users’ privacy and rights.

This Privacy Policy explains how we collect, manage, use, store and share information of yours when you access and use the Services and your rights with respect to the collection, correction and/or deletion of that information.

Except as described in this Privacy Policy, we will not use or share your information with anyone. However, this Privacy Policy does not apply to information we collect by other means (including offline) or from other sources.

    

1. PERSONAL INFORMATION WE COLLECT ABOUT YOU

    

In this Privacy Policy, your personal information means information about you as an identifiable individual and includes things such as your name, telephone number, address, email address or other location data, identification number, online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity (collectively, “your personal information”).

We may collect certain of your personal information when you access or use the Services, including as follows:·
- when you create an account for the Services, we may collect your full name, email address and password;
- when you sign-up for a KANO newsletter, we may collect your name and email address;
- when you connect the Services to a social media account (such as Facebook, Google or Apple), we may collect your full name, email address, profile picture, age range, gender, other information you make public on the social media account and your friend list (unless you affirmatively revoke such collection);
- when you create an account for the Services or connect the Services to a social media account (such as Facebook, Google or Apple), your personal information may be linked to otherwise non-personally identifiable information such that we may collect information about how you use the Services or items you purchased at online stores associated with the Services;
- when you use the Services, we may collect your geo-location data, which we associate with your personal information and non-personally identifiable information;
- when you contact us for support regarding the Services, we may collect your full name, email address and, if required, Facebook information and associate this personal information with non-personally identifiable information (such as information about your computer or mobile device); and
- when you voluntarily complete surveys, provide feedback or participate in competitions relating to the Services, we may collect your full name and email address.

Although the Services may allow you to visit as a guest and remain anonymous, some Services may require you to provide us with your personal information. In these situations, if you choose not to provide us with all of your personal information that we request then you may not be able to access all content and features of the Services.

    

2. NON-PERSONALLY IDENTIFIABLE INFORMATION WE COLLECT ABOUT YOU

    

We may also collect other, non-personally identifiable information about you (such as statistical data) from you directly or from third parties (collectively, “other information”), including: - metrics and other types of statistical data, which could be derived from your use of the Services (e.g., how you interact with the Services);
- information about how you access the Services (e.g., computer operating system and web browser, type of mobile device and unique device identifier, device settings, SDK version, mobile advertising identifier (Apple IDFA, Google Advertising ID or Android ID), MAC address, IP address, Wi-Fi information, your “click path” through the Services and the web site or advertisement that was linked to or from the Services); - diagnostic information concerning the Services (e.g., logs, error reports and events and the type, number, date and page relating to this information); or
- apps you have installed and enabled and how you use those apps.

Although your computer or mobile device may allow you to turn off the collection of some of this other information, if you do so then you may not be able to access all content and features of the Services.

    

3. COOKIES AND TRACKING TECHNOLOGIES

    

Cookies and other tracking technologies (such as beacons, tags, scripts and clear gifs) (collectively, “Tracking Technologies”) are files that are sent by a service through your browser to your computer or mobile device, if your browser is enabled to accept them, in order to store certain information on your computer or mobile device and communicate with a service while you are online.

We may use Tracking Technologies in analyzing trends, administering the Services, tracking your movements through the Services and gathering demographic information about our user base as a whole. We may also use Tracking Technologies to remember users’ settings and for authentication and analytics. Our partners, affiliates, analytics or third-party service providers may also use Tracking Technologies for the same or similar purposes. We may receive reports based on the use of these Tracking Technologies by such companies on an individual and aggregated basis.

You can control the use of Tracking Technologies at the individual browser level, as Internet browsers will allow you to erase them from your computer hard drive, block their acceptance or receive a warning before they are stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage them

.You may still use the Services if you block Tracking Technologies, but some portions of the Services may not function properly.

    

4. HOW WE USE YOUR INFORMATION

    

We use your personal information in a variety of ways in providing the Services and operating our business, including:
- Operations: operating, maintaining and providing all features of the Services, establishing and maintaining your account on the Services and protecting its security, responding to your comments and questions and providing user support (e.g., hosting and displaying information, providing updates or addressing technical issues) in order to fulfil our contractual obligations.
-  Communications: contacting you:
- for administrative purposes, such as customer service issues (e.g., providing customer support, resolving customer issues, informing you of changes to the Services, like outages, suspensions or other material changes); or
- if you have given your consent, for promotional or marketing purposes, such as serving you advertisements on the Services that are provided by us or by third parties we work with or, if you signed up for any KANO newsletter, contacting you for KANO news, promotional purposes or market research. You have the ability to opt out of receiving any promotional communications as described below in section 6. - Improvements: generating and analyzing information about our users so we can better understand them and how they use the Services, drawing rends and predictions based on this information and developing, improving or expanding the Services and users’ experience with the Services.

    

5. HOW WE SHARE YOUR INFORMATION

    

Sharing internally at KANO:
In order to use your personal information for operations, communications or improvements as noted above, we may share your personal information with our parent companies, affiliates, subsidiaries or contractors.

Sharing with Third Parties:
We use third parties to provide services on our behalf (such as serving advertisements, fulfilling a purpose you requested of us (e.g., billing services), providing customer support and feedback, analyzing Services functionality and technical issues, sending useful notifications to user devices, tracking use of the Services and generating reports and data models that we use to improve the Services). We may share your personal information with these third parties and they may collect information from you (including your personal information) to perform these services.
These third party services may be embedded into the Services (such as through an API or SDK) or may take the form of Tracking Technologies, which enable these third parties to collect information on our behalf.

Information collected by third parties is governed by the applicable third party’s privacy policy, which may provide for broader information collection than what we collect. These third parties may use your personal information internally and disclose your information to others, and we strongly recommend that you read each third party privacy policy carefully before providing your personal information.

Please contact us as set out in the “HOW TO CONTACT US” if you would like a list of third parties that we use and their corresponding privacy policies.

‍Sharing that we’re Required To Do:
We will share your personal information if we are required to do so by applicable law or under a legal proceeding or if we reasonably believe, in our sole discretion, that sharing is necessary (a) to comply with applicable law or reasonable requests of law enforcement, (b) to enforce the KANO Terms of Use and other applicable policies, guidelines and requirements described more fully in section 19 below or (c) to exercise or protect the rights, property or personal safety of KANO, our users or others.

Sharing on a Change of Control:
We may sell, assign or transfer your personal information as part of a transaction in which we buy or sell, assign or otherwise transfer KANO (including its shares) or its products, services, assets or businesses. In addition, we may also sell, assign or transfer your personal information in connection with mergers, acquisitions, corporate divestitures, bankruptcies, dissolutions, reorganizations, liquidations or similar transactions or proceedings involving all or part of KANO.

You will be notified via email and/or a prominent notice on our website at https://www.kanoapps.com/privacy-policy of any change in ownership or uses of your personal information.

    

6. ADVERTISING

    

If you have given your consent, the Services may contain advertisements served by third parties. These advertisements may use various Tracking Technologies to collect your personal information (such as demographics, location and device information) in order to serve you appropriate advertisements and to recognize your computer or mobile device each time a third party serves you an advertisement. Based on this information, third parties may be able to resolve your identity across multiple devices (e.g., matching your IP address across multiple devices) in order to target advertisements to you based on your online behavior. This information is collected, used and disclosed in accordance with the terms of the applicable third party privacy policy, as described in section 5 above.

You may be able to opt-out of mobile behavioral advertising by accessing the settings on your computer or mobile device and selecting the appropriate advertisement tracking settings.

    

7. LINKS TO OTHER WEBSITES

    

We are not responsible for the practices that other websites or services employ that are linked to or from the Services. Our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service (including those that have a link or advertisement on the Services) are subject to that third-party’s own rules and policies.

    

8. SERVICE COMMUNICATION FEATURES

    

Your personal information such as your username and profile picture on the Services may be visible to other users of the Services. We recommend you exercise discretion when selecting your username and profile picture and when using the Services.

If you choose to make any of your personal information publicly available on the Services (such as within our chat areas, instant message service, message boards or during use of the Services), it will be available to others, who can collect that information and which may result in unsolicited messages. We are not responsible for protecting any of your personal information that you may disclose to third parties through our Services (e.g., sending your telephone number to another user through the chat service). To the extent that you create a public profile that may be available to others on our Services, you are solely responsible for its content and accuracy.

To edit, change or delete any of your personal information that you make available through a public profile, please follow the instructions provided in the Services or contact us as set out in the “HOW TO CONTACT US”.

If you remove any of your personal information that you have made public on the Services, copies may remain viewable in cached and archived pages of our Services or if other users have copied or saved that information.

    

9. YOUR RIGHTS

Right to be Informed:
This Privacy Policy, together with our other policies, guidelines and requirements set out in section 19, fulfil our obligation to tell you about the ways in which we use your personal information as a result of accessing or using the Services.

Right to Access: You have the right to request access to and obtain a copy of any of your personal information we hold about you. This is known as “Subject Access Request”. In order to comply with your request, we may ask you to verify your identity. To make a Subject Access Request, please contact us as set out in the “HOW TO CONTACT US” section below.

Right to Rectification:
We want to make sure that your personal information is accurate and up to date. You have the right to ask us to correct any of your personal information we hold about you. If any of your personal information that we hold about you is inaccurate, please contact us as set out in the “HOW TO CONTACT US” section below.

Right to be Forgotten: You have the right to ask that we erase all of your personal information that we hold about you, except to the extent that retention is necessary for our legitimate business purposes, required by applicable law, in the control of a third party or where deletion is not technically feasible.
If you wish to have us erase your personal information, please contact us as set out in the “HOW TO CONTACT US” section below.

Right to Restrict Processing:
If you wish us to restrict the use of your data, please contact us as set out in the “HOW TO CONTACT US” section below.

Right to Data Portability:
If you wish to move, copy or transfer your personal information that we hold in electronic form to another organization, please contact us as set out in the “HOW TO CONTACT US” section below.

Rights related to Automated Decision-Making: If you would like to object to automated decision making without any individual involvement, and to the profiling of your data, please contact us as set out in the “HOW TO CONTACT US” section below.

    

10. STORAGE AND PROCESSING

    

While KANO is a Canadian company, the data you provide through the Services is stored and processed by third parties in countries around the world. By accessing and using the Services, KANO and its third party service providers may use and process your personal information in accordance with the Privacy Policy in any country of our or their choosing, which may cause your data, including your personal information and other information, to be subject to privacy protections and legal rights that may not be equivalent to those in your country. We have suitable safeguards in place and are continuously developing and implementing administrative, technical and physical security measures to protect your data.

    

11. RETENTION

    

We retain your personal information for as long as your account is active or as needed to provide the Services. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

    

12. HOW WE PROTECT YOUR INFORMATION

    

KANO is concerned with protecting your privacy and your personal information, and we maintain a comprehensive data management and security programme and take precautions against possible breaches in the Services. We employ a security technology known as a secure-socket-layer, or SSL, to protect the transmission of critical account information through the Services. However, we cannot ensure or warrant the absolute security or safety of any information (including your personal information) you transmit to KANO or guarantee that your personal information in the Services may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. Your use of the Services is at your own risk.

KANO urges you to take steps to keep your personal information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your account and closing your web browser.

    

13. COMPROMISE OF PERSONAL INFORMATION

    

If your personal information is compromised as a breach of security, KANO will promptly notify you in compliance with applicable law.

    

14. CHILDREN’S PRIVACY

    

KANO takes the responsibility of protecting the privacy and personal information of children very seriously. KANO complies with the U.S. Children’s Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet.

If you are UNDER AGE 13
If you are under the age of 13, you may not create an account with or use the Services. We will not knowingly collect, maintain or disclose any personal information from children under the age of 13. If we learn that a child under the age of 13 has provided us with personal information, we will delete that information as quickly as possible. If you believe that we might have information from or about a child under age 13, please contact us.

If you are BETWEEN AGE 13 AND 18
If you are between the age of 13 and 18, please have your parent or guardian read this Privacy Policy and get his or her permission before you provide any of your personal information and before you sign up for or use the Services.

Never tell anyone online anything private about yourself or your family or share your personal information (such as your phone number and address) unless your parent or guardian has approved the sharing of that information. Understand that certain social media platforms that you use to access the Services may have this information visible. Wherever possible, use screen names to protect your identity.

Some areas of the Services may have special rules for children under the age of 18. When you are in those areas, you must follow those rules.

INFORMATION FOR PARENTS/GUARDIANS
We encourage parents and guardians to spend time online with their children to become familiar with the types of content available on the Internet, including our Services. Parents and guardians should regularly oversee their children’s use of e-mail and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids.

If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, please contact us as set out in the “HOW TO CONTACT US” section below and we will take reasonable steps to remove that information from the KANO database at your request.

    

15. DATA CONTROLLER

    

KANO processes your personal information as a controller, as defined in the GDPR.

    

17. COMMUNICATION PROCEDURES

    

We communicate with our users primarily by email, whether as required by law or for marketing and other business related purposes.

If you would like to change the email preferences we associate with you (e.g., unsubscribing from receiving certain types of email) then you may do so by clicking a link within emails that we send to you or by contacting us as set out in the “HOW TO CONTACT US”.

If you would like to opt out of receiving push notifications from KANO, then, to the extent permitted, you may do so by changing the notification settings on your computer or mobile device.

We reserve the right to determine how we provide notifications to you (such as Service messages, written or hard copy notices or through conspicuous posting of notices on the Services), but you may opt out of certain means of notification as described in this Privacy Policy.

    

18. OTHER IMPORTANT AGREEMENTS THAT GOVERN YOUR USE OF the SERVICES

    

In addition to the Privacy Policy, your rights and obligations concerning our Services are governed by the KANO Terms of Use. When you sign up to use our Services, please review each agreement carefully, as you must agree to be bound by each agreement before you may use the Services.

    

19. HOW TO CONTACT US

    

You can contact us at any time to:
- request access to your personal information we have about you;
- correct any of your personal information we have about you; or
- delete any of your personal information we have about you.

If you have any questions or comments about this Privacy Policy or information we collect or hold about you, please contact us:
- By email at privacy@kanoapps.com
- By mail at:
KANO Applications Inc.
Attn: Legal/Privacy Officer
500 - 844 Courtney St.
Victoria BC, V8W 1C4
CANADA
We will keep confidential all of your personal information you provide to us via email or mail concerning the Privacy Policy or KANO’s information collection practices.