(last revised on February 17, 2023)
At Kenect, LLC (“Kenect” or “we”), we respect your privacy and are committed to protecting the information you share with us. This policy describes the types of information we may collect from you or that you may provide when you visit our website or use our mobile app, as well as our practices for collecting, using, maintaining, protecting, and disclosing that information.
1. HOW THIS POLICY APPLIES
This policy applies to information we collect:
• On our website, www.Kenect.com.
• In email, text, and other electronic messages between you and Kenect, or via telephone conversations between you and Kenect or via mail received from you by Kenect.
• Through mobile and desktop applications you download from our website, which provide dedicated non-browser-based interaction between you and our website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
• Any means other than as described above, including on any other website or mobile app operated by us or any third party, which does not include a link to this policy; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on our website or mobile app.
2. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of personal information from and about users of our website or mobile app, including:
• Contact information and registration details, such as name, address, email and telephone number.
• Unique identifiers, internet connection and preference information, such as your internet protocol (IP) address, browser type, usage details and navigation behavior from actions that you take on our website or mobile app.
• App usage details, which are automatically collected through your access to and use of the app, including traffic data, logs and other communications data and the resources that you access or use on or through the app.
Performance of advertisements, content views and engagement rates, and integrate with various platforms for posting and content-generation when contractually authorized.
• Mobile device and connection information, including your devices’ unique identifier, operating system, browser type, mobile network information and the device’s telephone number.
• Stored information and files on your mobile device, which may be accessed on your mobile device and may include metadata, photographs, audio and video clips, personal contacts and address book information.
We may collect this information directly from you, from third parties or automatically through various web and mobile technologies, including:
• Web or mobile app logging, which records and logs information about your internet connection, devices and usage, such as IP addresses, browser type, internet service provider, referring and exit pages, operating system, date and time stamp and clickstream data.
• Web beacons, which are small electronic files (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited our web pages, accessed or mobile app or opened an email and for other related website and mobile app statistics (for example, recording the popularity of certain content and verifying system and server integrity).
We may also collect personal information through mobile app technologies, including:
• Mobile cookies, which are the same as browser cookies but applicable to your mobile device.
Our website does not respond to web browser “Do Not Track” signals.
3. THIRD PARTY TRACKING
Some content or applications, including advertisements, on our website or mobile app are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use tracking technologies to collect information about you when you use our website or mobile app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online and mobile activities over time and across different websites, mobile apps and other online services. We do not control these third parties’ tracking technologies or how they may be used and we disclaim all responsibility and liability for any content once it is transmitted, copied or removed from our website, mobile app or other services. If you have any questions about an advertisement or other targeted content, or to opt out of third party content, you should contact the responsible provider directly.
The following third-parties automatically collect personal information about you when you visit our website or mobile application: Google Analytics.
4. HOW WE USE YOUR INFORMATION
We may use information that we collect about you or that you provide to us, including any personal information:
• To provide you with information, products, or services that you request from us.
• To improve and personalize the content on our website and mobile app.
• To administer our web services and mobile app.
• To track and gather demographic information about our user community as a whole.
To collect and monitor performance of advertisements, content views and engagement rates.
To integrate with various platforms for posting and content-generation.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• In an aggregated form that does not identify you individually.
• For any other purpose disclosed by us when you provide the information or with your consent.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please notify us at the address below. We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
5. LIMITED USE
We will only use your personal information for the purposes for which we have collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider de-identification, aggregation, and other forms of anonymization of personal information to be compatible with the purposes listed above and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.
If you wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact us via the information specified in the Contact section below.
PLEASE NOTE THAT WE MAY PROCESS YOUR PERSONAL INFORMATION WITHOUT YOUR KNOWLEDGE OR CONSENT, IN COMPLIANCE WITH THE ABOVE RULES, WHERE THIS IS REQUIRED OR PERMITTED BY LAW.
6. DATA RETENTION
We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.
7. HOW WE MAY DISCLOSE YOUR INFORMATION
We may share your information with third parties that provide services to help us with our business activities such as responding to your requests for more information. These business partners are authorized to use personal information about you only as necessary to provide these services to us.
We may also disclose, without restriction, aggregated information about our users that does not identify any individual.
In certain situations, we may be required to disclose your personal information:
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Kenect, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
8. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
• You may choose not to download our mobile app or delete if from your device.
• If you do not wish to have your personal information used by us to promote our own or third parties’ products or services, you can opt-out by contacting us at the address below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• If you do not want us to share your personal information with third parties for promotional purposes, you can opt-out by logging into your account profile page and adjusting your user preferences or contacting us at the address below.
9. ACCESSING YOUR PERSONAL INFORMATION
You can review and change your personal information by logging into our website or mobile app and visiting your account profile page. If this option is not available to you, you can request access to, correct or delete any personal information by contacting your account representative or contacting us at the address listed below. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
10. HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA”)
As a provider of services and technology to the healthcare industry, Kenect has implemented processes to address the HIPAA privacy and security requirements. Under HIPAA, each covered entity (health care provider, health plan, or health care clearinghouse) is required to provide or make available to you a Notice of Privacy Practices, depending on your interaction with the covered entity. To the extent that Kenect or one of its affiliates or subsidiaries is a covered entity, the required notice will be provided or made available to you directly by that covered entity. Any such notice is unrelated to the practices described in this policy. For more information regarding our compliance with HIPAA requirements, see our Terms of Service, available at https://kenect.com/terms-of-service.
11. YOUR CALIFORNIA PRIVACY RIGHTS
12. CHILDREN UNDER 13
Our website and mobile app are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through our website or mobile app. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org or 1221 S. Valley Grove Way, Suite 400, Pleasant Grove, UT 84062.
13. HOW WE PROTECT YOUR INFORMATION
We maintain reasonable administrative, technical and organizational measures designed to secure our systems and your personal information from unauthorized access, use or disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or mobile app, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile networks is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website or mobile app. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website or mobile app.
14. GEOGRAPHIC RESTRICTIONS
16. HOW TO CONTACT US
1221 S. VALLEY GROVE WAY, SUITE 400
PLEASANT GROVE, UT 84062
ATTN: PRIVACY TEAM
APPENDIX A: CALIFORNIA PRIVACY RIGHTS
Effective: January 1, 2023
Your California Privacy Rights:
Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) and certain other California privacy and data protection laws, as applicable, residents of California have the following rights with respect to their personal information.
Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information about You.
Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, including the following categories: (a) identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education information; and (k) inferences drawn from such information to create a consumer profile. You have the right to know the categories of personal information we have collected about you; the categories of sources from which we collect personal information; our business or commercial purpose for collecting, disclosing, sharing or selling personal information; the categories of third parties to whom we disclose, share or sell personal information, if any; and the specific pieces of personal information we have collected about you. Personal information includes “sensitive” personal as described below.
Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information about You.
Although we do not collect, disclose, share or sell “sensitive” personal information, it is defined as personal information that reveals: (a) your social security, driver’s license, state identification card, or passport number; (b) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) your precise geolocation; (d) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of your mail, email, and text messages unless we are the intended recipient of the communication; (f) your genetic data. “Sensitive” personal information also includes biometric information that is processed for the purpose of identifying you, information that is collected and analyzed concerning your health; or your sex life or sexual orientation.
You have the right to know the categories of “sensitive” personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting, selling or sharing “sensitive” personal information, the categories of third parties with whom we sell or share “sensitive” personal information, if any, and the specific pieces of “sensitive” personal information we have collected about you.
Right to Delete Your Personal Information
Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers, contractors and third parties to delete your personal information from their records.
We are not required to, and reserve our right to not delete your personal information if it is necessary to: (i) complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; (ii) help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; (vii) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; and (viii) comply with a legal obligation.
Right to Correct Inaccurate Personal Information.
Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to correct any inaccurate personal information in our records, and to have us direct our service providers, contractors and third parties to correct any inaccurate personal information from their records.
If we cannot verify your identity pursuant to the CCPA and its regulations we may deny a request to correct. In such event, we shall inform you that your identity cannot be verified.
In determining the accuracy of the personal information that is the subject of your request to correct, we shall consider the totality of the circumstances relating to the contested personal information. We may deny your request to correct if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
Right to Be Free from Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against you as an employee, applicant for employment or independent contractor.
How to Exercise Your Rights
Unless otherwise specified, to exercise any of your rights described in this Appendix A, please submit your request to us at email@example.com with the subject “CCPA Consumer Request.” You can also exercise these rights by clicking the following link: www.kenect.com/consumer-request-form. Alternatively, you can also contact us via the following toll-free telephone number 888-972-7422.
In order to verify your request, we may need you to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and a description of what right you wish to exercise along with any information to which your requests relates. If feasible, we will match the indemnifying information provided by you with the personal information that we already maintain about you.
You may designate an authorized agent to make a request under the CCPA on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require that you verify your own identity with us directly or provide us with a copy of the written permission given.
We reserve our right not to grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of personal information twice within a 12-month period. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
Your Right to Opt-Out of the Sharing of Personal Information
We may disclose your personal information to third parties for cross-context behavioral advertising purposes (“Share” or “Sharing”). You have the right to opt-out of the Sharing of your personal information and you may exercise your right by clicking the following link: www.kenect.com/do-not-sell-or-share-my-personal-information-form. If you exercise your right to opt-out of the Sharing of your personal information, we would refrain from Sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information.
Your Right to Opt-Out of the Sale of Personal Information
We may disclose your personal information to third parties in exchange for monetary or other consideration. Such disclosures are considered to be “Sales” under the CCPA. You have the right to opt-out of the Sale of your personal information and you may exercise your right by clicking on the following link: www.kenect.com/do-not-sell-or-share-my-personal-information-form. If you exercise your right to opt-out of the Sale of your personal information, we would refrain from Selling your personal information, unless you subsequently provide express authorization for the Sale of your personal information.
Your Right to Opt-Out by Using Opt-Out Preference Signals.
We will process any opt-out preference signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal information (“Opt-Out Preference Signal”). We shall treat the Opt-Out Preference Signal as a valid request to opt-out of the sale or sharing of personal information for your browser or device, and, if known, for you.
If the opt-out preference signal conflicts with other privacy settings that you have submitted to us, we will process the opt-out preference signal but may notify you of the conflict and provide you with the opportunity to consent to the sale or sharing of your personal information.
If the Opt-Out Preference Signal conflicts with your participation in a financial incentive program, we shall notify you of the conflict and request your affirmation that you intend to withdraw from the financial incentive program. If you affirm your intent to withdraw we shall process the Opt-Out Preference Signal. If you do not affirm your intent to withdraw, we will not process the Opt-Out Preference Signal.
Your Right to Limit the Use or Disclosure of “Sensitive” Personal Information
We do not collect any “sensitive” personal information. If we were to collect and use your “sensitive” personal information other than is necessary to provide our goods and perform our services, you would have the right to limit our use or disclosure of your “sensitive” personal information to that which is necessary to provide our goods and services to you.
Children’s Right to Opt-In to the Sale of Personal Information
We do not knowingly collect or sell the personal information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their personal information, we have established the following processes:
Minors between 13 and 16 years of age:
In the case of consumers between 13 and 16 years of age, we require the consumer to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which we have determined to be reliable for the purpose of verifying the consumer.
Minors under 13 years of age:
In the case of consumers who are less than 13 years of age, we require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require that the consumer’s parent or guardian verify the consumer’s identity, which we have determined to be reliable for the purpose of verifying the consumer.
We reserve the right to require additional information or not complete your request if we cannot verify your identity. If you are a parent or guardian seeking to opt-out on behalf of their child, please email us at firstname.lastname@example.org with the subject “Minor Opt-Out.”
Our Collection and Disclosure of Personal Information
Sources from Which We Receive Personal Information
We may receive personal information from the following categories of sources:
• You, the consumer
• Advertising networks
• Internet Service Providers
• Data Analytics Providers
• Government Entities
• Operating Systems and Platforms
• Social Networks
• Data Brokers
Third Parties with Whom We Share Personal Information
We routinely share personal information with the following categories of third parties:
• Advertising Networks
• Internet Service Providers
• Data Analytics Providers.
• Government Entities
• Operating Systems and Platforms
• Social Networks
• Data Brokers
• Service Providers
Individual consumers who reside in California and have provided us with their personal information may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at one of the following addresses: email@example.com with the subject “California Shine The Light Request” or Kenect, LLC, 1221 S. Valley Grove Way, Suite 400, Pleasant Grove, UT 84062,
Attn: Privacy Team. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
Minor’s Right to Remove Posted Content.
If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information that you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to firstname.lastname@example.org with the subject “Privacy Rights for Minors.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.