Last Updated: November 30, 2019
KMA will generally seek your consent for the collection, use or disclosure of your Personal Information at the time of collection, except as required or in cases authorized by law.
Your consent can be withdrawn at any time, subject to legal and contractual restrictions and reasonable notice. You may contact our Privacy Officer at [email protected]. Please note that if you choose to withdraw your consent, KMA may not be able to provide you with certain services.
In the course of operating the Platform, we may collect two types of information about our users: Personal Information and Technical Information.
(a) Personal Information
“Personal Information” is information about an identifiable individual. Personal Information includes but is not limited to your name, residential address, telephone number, fax number and e-mail address.
We only collect Personal Information that is necessary for the purposes of establishing, managing and maintaining our relationship with you. Personal Information is collected by us when you choose to provide it to us when registering for an KMA service, such as when you choose to subscribe to one of our services, enter one of our contests or promotions, choose to receive our newsletter, offers or other updates, or choose to participate in one of our surveys. In addition, if you choose to contact any of our customer service representatives, we may keep a record of that correspondence so that we may fully address the subject matter.
Generally, Personal Information is collected by us only when you directly provide it to us, such as when you provide us with your contact information or send us a question or comment, when you meet with us in person, or when you phone us with an inquiry. However, we may also receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that you have permitted them to share such information.
Business contact information such as the name, title, work address, work email address or work telephone number of a business or professional person or an employee of an organization is not considered Personal Information.
(b) Technical Information
When you use our Platform (including through your computer or mobile device), we gather certain technical information (“Technical Information”) automatically and store it in log files. This information includes Internet Protocol addresses (“IP Addresses”), unique device or mobile identifiers, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, clickstream data, log-in times, duration of time spent on our Platform, or navigation of our Platform while logged in. For example, our web servers may automatically collect Technical Information which is provided through your browser or stored on a cookie (as described below) or through a web beacon (as described below) when you choose to visit the Platform.
This Technical Information is of an anonymous nature. Aggregate information, such as demographic statistics of our users (e.g., average age or geographical allocation of our users), number of visitors and average time spent on the Platform, is also considered Technical Information.
As described more fully below, Technical Information is used on an aggregate basis and in a non-personally identifiable form, including: (i) for Platform and system administrative purposes; (ii) to improve the Platform; (iii) to conduct internal reviews of the number of visitors to the Platform; (iv) to help us better understand visitors’ use of our Platform; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Platform when necessary.
USE OF PERSONAL INFORMATION
Personal Information may be used by us for the following purposes:
(a) To provide you with the services and information you have requested from us, including your use of the Platform. We may from time to time use your Personal Information to contact you about changes, enhancements or similar notices related to our services.
(b) If you indicated that you were interested in receiving our newsletter, offers or information from KMA or certain of our selected sponsors or advertisers, KMA may send you such information electronically, such as by email. If at any time you would like to unsubscribe to such electronic communications, follow the directions posted at the bottom of the email or electronic communication.
(c) If you enter a contest or other promotion offered on a Platform, we may, under the rules of the contest/promotion, use your name and certain other information to administer the contest/promotion, such as contacting, announcing and promoting the winners of the contest/promotion.
We may also use your Personal Information to compile statistics. However, these statistics will not allow you to be identified.
Your Personal Information shall not be used for purposes other than those described above, except with your consent or as required or authorized by law.
DISCLOSURE OF PERSONAL INFORMATION
We will not sell or rent your Personal Information to anyone.
We will only disclose your Personal Information to third parties in the following circumstances:
(a) where you have specifically given us your consent to disclose your Personal Information for a designated purpose;
(b) to third parties who are acting on our behalf as our agents, suppliers or service providers, solely to enable us to more efficiently provide you with our services. Such entities act under strict contractual controls, requiring them to maintain the confidentiality of all such Personal Information and to use such information solely for purposes related to the provision of our services;
(c) as may be set out in the terms and conditions applicable to an KMA service, to facilitate the provision of such service, such as fulfilling legal requirements;
(d) as required by law, including by an order of any court, institution or body with jurisdiction or authority to compel the production of information, or in order to protect or defend a legal interest; or
(e) in connection with any contemplated or actual sale, merger or other disposal of all or part of our business or assets, or as part of a corporate reorganization or other change in corporate control, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In such circumstances, we will ensure that any transfer of Personal Information is subject to applicable law and reasonable data protection security protocols.
SPECIAL NOTE TO PARENTS
We do not knowingly track, collect, use or disclose the Personal Information of children under the age of 13, without the consent of a parent or guardian. If we learn that we have inadvertently collected Personal Information of a child under the age of 13 without parental or guardian consent, we will delete that information from our systems. If you are under 13 years of age, please do not submit or post any Personal Information on the Platform, without the consent of your parent or guardian.
LINKS TO OTHER PLATFORMS AND ADVERTISEMENTS
KMA will destroy, erase or make anonymous your Personal Information that is no longer required to fulfil the identified purposes, legitimate business purposes or legislative requirements.
Nevertheless, given the nature of the Internet, security and privacy risks cannot be eliminated and you should be aware of this before you provide your Personal Information through the Platform.
PROCESSING AND STORAGE OF PERSONAL INFORMATION
Your Personal Information may be transferred to, processed and/or stored in a foreign jurisdiction outside of the jurisdiction in which it was originally collected. As a result, your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction.
CORRECTING YOUR PERSONAL INFORMATION
We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information.
Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed by contacting our Privacy Officer as set out below.
If you decide at any time that you do not want to receive any newsletters or other electronic communications to which you have subscribed, you may choose to unsubscribe by following the instructions at the end of the electronic message.
ACCESS TO PERSONAL INFORMATION
If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information.
You may contact our Privacy Officer at the contact information below to request access to Personal Information that we have about you. We will respond to requests within 30 days.
QUESTIONS AND FURTHER INFORMATION
KMA USE OF TECHNICAL INFORMATION
Technical Information is collected or derived by us in the course of operating the Platform. For example, our web servers may automatically collect Technical Information which is provided through your browser or stored on a cookie or through a web beacon when you choose to visit the Platform.
Some information (for example, your location or preferred means of communication) is collected when you voluntarily provide it. Unless combined with Personal Information, this information does not identify you personally.
Technical Information is used generally by KMA to monitor and improve the operation of the Platform, to perform statistical analyses of the collective characteristics and behaviour of our users, to measure user demographics and interests regarding our services, to describe our services to third parties such as prospective business partners and advertisers and to analyze how and where best to use our resources. No Personal Information will be disclosed during these activities.
KMA may also use Technical Information to inform our sponsors and advertisers as to the performance of a particular sponsorship (such as a contest) or advertisement. In such case we may disclose to those third-party sponsors and advertisers the overall aggregate demographics available regarding, for example, who participated in a contest or who saw and “clicked” on an advertisement. No Personal Information will be disclosed to these sponsors and advertisers as part of this process; only information in an anonymous, aggregate form will be disclosed.
(a) IP addresses
An IP Address is the unique number which is assigned to every direct Internet access point. Many IP Addresses can generally be associated with certain Internet service providers or large organizations. IP Addresses do not contain any Personal Information. When you, through your browser, request a web page or similar Internet information from another computer on the Internet, your browser automatically provides that computer with an IP address to which it will send the requested information.
KMA may use your IP Address to display more appropriate and relevant content such as content and advertising based on your geographic area. Aggregate information derived from IP Addresses may be reported by KMA to our advertisers and partners. For example, KMA may report to our advertisers the estimated total number of users accessing a particular KMA Platform from a specific province.
KMA may use your IP Address to facilitate the diagnoses and remedy of a technical problem on our Platform reported by you or our technical team.
A “cookie” is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any Personal Information about you, such as your name and address. Since cookies are only text files, they cannot run on your computer, search your computer for other information, or transmit any information to anyone.
(a) monitor usage and improve the operation and performance of the Platform and make the Platform easier and more convenient to use. For example, cookies help us remember who you are through your browser settings so that we can offer and provide more personalized services (e.g. language preference). Cookies also allow us to save preferences for you so that you will not have to re-enter them the next time you visit the Platform;
(b) measure aggregate user traffic and demographic statistics related to the Platform and advertisements (e.g., number of users, average time spent, average age and similar statistics). This information helps us to better understand when to update, change or offer new services and provides us with details as to the performance of third party advertisements and content. This information may be reported, in aggregate form only, to our current and prospective sponsors, advertisers and business partners. No Personal Information will be disclosed in such reports; and
(c) serve advertisements provided by KMA and/or third party advertising providers used by KMA.
(c) Web beacons, pixel tags, clear GIFs or other similar technologies
The Platform may contain electronic images known as “web beacons”, sometimes called single-pixel gifs, pixel tags, clear GIFs or other similar technologies that allow KMA to count users who have visited Platform pages and to deliver co-branded services. These technologies may be used in connection with some parts of our Platform and HTML-formatted e-mail messages.
These technologies are not used to access your Personal Information; they are a technique used to compile aggregated statistics about Platform usage. They collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which they reside. Certain parts of the Platform may also contain web beacons placed there by our advertising partners or web analytics service providers to help KMA determine the effectiveness of our Internet advertising campaigns.
They may be used to, among other things, track the actions of Platform users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about our Platform usage and response rates.