Last Updated: 01/19/2020
- Information we collect
- How we use Personal Information about you
- When we share Personal Information about you
- How we protect Personal Information about you
- Storage, access and deletion of your Personal Information
- Your rights under the GDPR (for EEA Data Subjects)
- Our legal basis for processing (for EEA Data Subjects)
- Advertising choice
- Links to third-party websites
1. INTRODUCTION & WHAT THIS POLICY COVERS
You may use the notification settings of Facebook Messenger to limit or block notifications from Khonsu. You may disable your ability to interact with the Services by blocking the Khonsu account from Facebook Messenger, for details, see: https://www.facebook.com/help/messenger-app/204908296312159.
Khonsu does not knowingly collect Personal Information from children under the age of 16. If you are under the age of 16, please do not use the Services. If you have reason to believe that a child under the age of 16 has used our Services, please contact us, and we will take steps to delete that information from our databases and servers.
2. INFORMATION WE COLLECT
Khonsu, in order to provide its Services, receives and deals with user Information as follows:
2.1 Information you provide. When using our Services you may choose to give us Personal Information in the following ways:
- User submitted information: when accessing or using the Chatbot, submitting online forms on our websites, interacting with customer support, speaking with a Khonsu agent, or if you create an account with us, you may choose to provide Personal Information which we shall collect (“User Submitted Information”). User Submitted Information can include your email address, first and last name, your location, travel preferences and other personally identifiable information that you choose to provide us with. Khonsu also collects and stores your interaction history, including transcripts of your interactions with the Chatbot, any questions sent to customer service and the corresponding recommendations.
- A special note about location information: Khonsu does not automatically collect or generate precise geographic location data. In your use of the Services we may ask for your current location to provide recommendations that are near you. Should you choose to provide this information, we will store this data for as long as necessary to provide you with accurate results. We may also store landmark and itinerary information that you may choose to provide us with through your use of the Services to help better provide future Services to you, or to improve the overall efficacy of the Services provided. As an example, we may store the hotel name and address you give us to better facilitate search and transportation results.
2.2 Information we obtain automatically. We automatically collect information about you and how you use our Services, including Personal Information, during your interactions with our Services. This information is as follows:
For more details, please see, https://www.facebook.com/privacy/explanation.
- Log Data and Recommendation Information: The Services automatically record information created by your use of the Services. This data includes information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. Log data is received when you interact with the Services. This data is used to provide the Services and to measure, customize, improve, and maintain and improve the Service.
- Interactions with Third Party Links: Khonsu may keep track of how you interact with links across the Services, including user interaction with third-party services and applications through the redirecting of clicks or through other means. For example, we may track if you click on a link to get restaurant reviews. We may share this information with third-party service providers but only in an aggregated and anonymized form.
2.3 Information from other sources. We also collect information including Personal Information about you and your use of the Services from other sources such as:
- Payment service providers: if you make a purchase in the Services, Khonsu may collect the billing and financial information necessary to process the charges; and/or do so on behalf of the relevant payment service providers. Purchases of third-party services are subject to the policies applicable to the third parties.
- Third-party services providers: Khonsu uses a variety of third-party services to help its provision of the Services, such as hosting and other services. These third-party service providers may collect information sent by your browser as part of a web page request, such as cookies or your IP address, location, and devices’ unique identifiers.
3. HOW WE USE PERSONAL INFORMATION
We are not in the business of selling your Personal Information. You agree that Khonsu and its Service Providers may use your Personal Information only for the purposes of:
- providing, personalizing and improving the Services provided to you;
- contacting you as part of customer support;
- contacting you as part of customer support;
- to send you updates or information about the Services;
- managing your account and relationship with the Services and improving your experience when you use them;
- improving the Services through research, surveying, and engaging with you, for example, by sending you communications for these purposes;
- marketing and promotion of the Services;
- processing payments;
- preventing and detecting fraud;
- creating reports, analysis or similar services for the purposes of our research and our business development;
- debug and repair errors in our Services in order to maintain and improve the quality and security of our Services;
4. WHEN WE SHARE PERSONAL INFORMATION
Khonsu may share your Personal Information with:
- Service Providers. We may establish a business relationship with other businesses that we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions and to process payments and purchases authorized by you. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
- For Legal Process and Protection. We may disclose Personal Information to third parties involved in legal process or protection matters, including government authorities, where we believe that access, use, preservation or disclosure of such information is reasonably necessary, including:
- To comply with applicable law, regulation, legal process or to respond to lawful requests or legal process.
- To enforce or apply agreements, or initiate, render, bill, and collect for Products and Services (including disclosure to collection agencies to obtain payment for our Products and Services).
- To protect the rights, interests, property, or safety of Khonsu and our affiliates, agents, service providers, customers, and others.
- In connection with claims, disputes, or litigation.
- To protect users of our Services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such Services, and other fraudulent activity.
- In an emergency.
- Business Transfer. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
5. HOW TO PROTECT YOUR PERSONAL INFORMATION
We use a variety of commercially reasonable security measures designed to protect your Personal Information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use while it is under our control.
6. STORAGE, ACCESS, AND DELECTION OF YOUR PERSONAL INFORMATION
- Access and Deletion. You may request access to the specific pieces of Personal Information we have collected about you and you can ask us to delete your Personal Information at any time by contacting us at email@example.com. Subject to the foregoing, please note there may be some cases where we do not delete Personal Information as permitted by applicable law, for example, Personal Information that is necessary for a legal defense. If you request that we delete your Personal Information, certain Services may no longer be available to you or may be affected in other ways. Khonsu shall not be liable to you or any person for the deletion or failure to store any Personal Information including User Submitted Information arising from your decision to delete your Personal Information.
- Verification of Your Identity. For your protection—to prevent unauthorized access to data and ensure that you are the person who is making the request—we must verify your identity before we can fulfill your request for access or deletion. You will receive verification options via email after a submitted request for data access or deletion. Failure to provide suitable verification documentation will result in the request being denied. Once your identity is verified your request will be fulfilled within 7 to 45 days.
7. YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a “data subject” under applicable data protection law in the European Economic Area (EEA), you will have the following rights in relation to Personal Information that we hold about you:
- Right to Access. To request confirmation of whether we process Personal Information relating to you, and if so, to request a copy of that Personal Information.
- Right to Rectification. To request that we rectify or update any Personal Information that is inaccurate, incomplete or outdated.
- Right to Erasure. To request that we erase your Personal Information in certain circumstances, such as where we collected Personal Information on the basis of your consent and you withdraw your consent.
- Right to Erasure. To request that we restrict the use of your Personal Information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your Personal Information.
- Right to Withdraw Consent. Where you have given us consent to process your Personal Information, to withdraw your consent.
- Right to Data Portability. To request that we provide a copy of your Personal Information to you in a structured, commonly used and machine readable format.
To exercise your rights as set out above or please contact our Data Protection Officer at Khonsu at firstname.lastname@example.org. Please note that we will ask you to verify your identity for the security of your personal information before responding to such requests as set forth in Section 6.
8. OUR LEGAL BASIS FOR PROCESSING (FOR EEA DATA SUBJECTS)
Khonsu has a legitimate business interest in operating and improving its business and the services it offers and may collect, store, use, process and disclose your Personal Information (and you consent to us doing so) for the following purposes:
- To provide you with information, products or Services that you request from us
- To improve our Services in order to better serve you
- To enable us to respond promptly to your customer service requests
- To facilitate payment transactions
- To review our services or products
- To communicate with you as a follow up to any queries via live chat, email or phone
- To provide the Services, information or products you have requested or to carry out the transaction(s) you have authorized (or we may disclose this information to our vendors and processors to undertake this activity on our behalf)
- For research and development in order to improve our service and product offerings
9. ADVERTISING CHOICE
We use email and targeted online advertising to send you product and services updates, promotional offers and other marketing communications based on the information we collect about you, such as your email address, general location, and purchase and website browsing history.
You can also partially manage targeted ads on your mobile devices through your system settings. Resetting your device advertising ID does not opt-out your device from targeted ads, but data associated with your prior advertising ID will not be linked to your new identifier through the device. Also, if you reset your device advertising ID your prior opt-out choices made through the links above will not apply to the new ID. To maintain your opt-out choices, you will need to opt-out again. Please note these opt-outs will not impact “contextual” advertisements (e.g., a sporting goods advertisement on a sports-themed website) or ads we place on our own websites and apps based on your activity on those properties.
- Ads on Social Media: We may work with certain social media websites or platforms (such as Facebook or Twitter) to serve targeted ads to you as part of a customized social media campaign. You can opt-out of receiving customized ads on your social media platforms by changing your ad preferences on those platforms. We do not control those platforms or your ad preference settings on them and recommend regularly visiting your ad preference settings to ensure that they remain accurate.
- Cookies Choice: Most web browsers can be set to reject cookies or provide notice when cookies are placed on your device. Each browser is different, so check the "Help" menu of your browser settings to learn how to change your cookie preferences. If you reject cookies, certain functions on our websites may not work properly, and your ability to use some areas of our websites may be limited.
10. LINKS TO THIRD PARTY WEBSITES
These technologies are used to provide the Services to the users, offer advertising that is of interest to them, and improve the Services, making it easier to use our applications, games and our web platform.
What are cookies?
Cookies and these other technologies are small files or devices that are downloaded into the computer or device, for instance, a mobile device, that you use to access and/or use certain websites or online services. Cookies are used to store and retrieve data on your surfing habits, your device, your connection time, to analyze the operation of the website, etc., in order to provide certain services, offer advertising or implement improvements or new services.
What kinds of cookies do we use? Khonsu and other third parties use the following cookies:
- Technical cookies: they allow users to surf through a website, platform, or application and use the different options or services therein, such as controlling the exchange and communication of data, identifying the session, accessing restricted access sites, using security elements while navigating, storing content to broadcast video or audio, or sharing content through social networks.
Khonsu may use this type of cookies to recognize your device, for example by identifying your IP address, and to collect data such as your device’s model, operating system and screen size, other applications installed on your device, time and date, subject of advertisements you clicked or scrolled over, and other information about how you use the Services.
- Customization cookies: they allow you to access the service with some predefined general characteristics based on a series of criteria in your terminal such as language, the browser you use to access the service, the regional settings from which you access the service, etc.
Khonsu may use this type of cookies to store access information so that you don’t have to repeatedly log in; to allow the Services to interact with a third party social network or platform where you have chosen to allow such interaction; to allow payment processes when you submit payment instructions; to enable Khonsu and third parties to provide you with more customized services; and to collect other information about use of our Services.
- Analysis cookies: they allow to monitor and analyze user behavior on the websites and/or services to which these cookies are associated. The information gathered using these cookies is used to measure the activity on the websites, applications, or platforms, as well as to develop navigation profiles for the users of certain websites, applications, or platforms, with the purpose of making improvements based on the analysis of the usage data of the users of the service.
- Advertising cookies: they allow management of advertising included by third parties, such as Facebook and our advertising partners, in a web platform or our Services. These cookies are used to limit the frequency and organize how users receive these ads.
- Behavioral advertising cookies: they allow management of advertising included in a website, application, or platform. These cookies store information on user behavior that is obtained through continuous observation of their surfing habits, which allows profiling to display advertising that might be of interest to the user.
In particular, Khonsu uses the following third party cookies to collect information with statistical purposes about your use of the web platform and to include advertising in our Services:
- Google Analytics: provided by Google, Inc., is a company whose headquartered in 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, which is used to provide statistics and analysis about the number of visits, their duration, your socio-demographic data (language, location, Internet supplier...), etc.
Disabling or Blocking Cookies
You may allow, block or disable the cookies installed in your device in your browser settings on your computer or mobile device. Internet browsing settings are usually preset to accept cookies by default, but they can be easily deactivated by changing the browser's settings.
Cookies are used to improve the Sites and apps' usability and functionality, therefore, if you wish to deactivate said cookies, some of the Services' features may not work correctly. Alternatively, if you do not wish such data collection as described in this section, you must stop using the Services.
Here are some useful links with instructions on how to delete, enable and manage cookies depending on the browser you use: