• This Privacy Policy ("Policy") describes how Kefey LLC and its group of companies and brands in the United States and UAE ("Kefey," "we," "us", or “our”) collect, use, share and otherwise process personal information in connection with our websites, applications, and other online platforms which link to or display this Policy or personal information we collect in person, by phone, via emails or other offline methods (collectively, the “Platform”).
• This Policy is not, however, a contract and does not create any legal rights or obligations.
• The Kefey group of companies and brands includes: Kefey LLC (USA), Kefey Life FZCO (UAE), and other companies that may be acquired or folded into our company.

• When we use the term “personal information” in this Policy, we mean:
• Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you.
• It does not include:
• Aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you or a particular household.
• Publicly available information from government records.
• Information about job applicants, employees and other personnel.
• Information about the employees and other representatives of third-party entities who we may interact with in a commercial context.

TYPES OF PERSONAL INFORMATION WE COLLECT, HOW WE USE IT, HOW WE SHARE IT, AND SOURCES OF INFORMATION

• The table below describes our data practices in the last 12 months.
• In addition to information contained in this Policy, we may disclose personal information for other purposes described to you in a separate notice presented at the point of collection.
• In the first column, we list the categories of personal information we have collected.
• In the second column, we describe how each category of personal information may be used by us or our service provider or contractors on our behalf.
• In the third column, for each of the categories of personal information, we identify the categories of recipients to whom we have disclosed for a business purpose.
• In the fourth column, for each of the categories of personal information, we identify the categories of “third parties” to whom we have “sold” or “shared” for targeted or behavioral advertising.
• For purposes of this Policy, when we use the term “third party”, we mean entities that are not service providers or contractors providing services on behalf of Kefey and that are not entities with whom you interact with directly.
• For purposes of this Policy, “targeted or cross-context behavioral advertising” means when we display advertisements to you based on information we obtain about you through nonaffiliated websites or online applications to predict your interests.

 

Information

Category of Personal Information	Use Cases	Categories of Recipients (Business Purposes)	Categories of Third Parties (Sold/Shared for Targeted Advertising)
Identifiers (name, email address, etc.)	Provide our products and services; Improve our products and services; Understand your interests; Respond to your requests; Communicate with you; Determine eligibility; Marketing & interest-based advertising; Security, legal, and infrastructure purposes; Internal business purposes; As otherwise permitted by law or as we may notify you	Service Providers or Contractors; Platform Users; Research Organizations; Marketing/Advertising/Media Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Marketing Mix Measurement Providers; Payment Processing Vendors; Data Management Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	Business Partners; Online Advertising Networks; Analytics Vendors; Social Media Networks
California Customer Records (e.g., birthdate, payment info)	Provide our products and services; Improve services; Understand your interests; Respond to questions; Communicate with you; Determine eligibility; Security and compliance; Internal business purposes	Service Providers or Contractors; Platform Users; Research Agencies; Marketing Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Payment Processing Vendors; Data Management Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	N/A
Commercial Information (shopping history, hobbies, interests, behavior)	Provide services; Improve services; Understand interests; Marketing & advertising; Security, legal, and infrastructure purposes; Internal business purposes	Service Providers or Contractors; Platform Users; Marketing Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Marketing Mix Measurement Providers; Payment Vendors; Data Management Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	Business Partners; Online Advertising Networks; Analytics Vendors; Social Media Networks
Internet / Network Information (IP, device info, analytics data)	Provide services; Improve services; Understand interests; Marketing & advertising; Fraud prevention; Security & legal purposes; Internal business purposes	Service Providers or Contractors; Platform Users; Research Agencies; Marketing Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Marketing Mix Measurement Providers; Payment Vendors; Data Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	Business Partners; Online Advertising Networks; Analytics Vendors; Social Media Networks
Geolocation Data (from device or IP estimate)	Provide services; Improve services; Understand interests; Respond to requests; Communicate with you; Determine eligibility; Marketing & advertising; Security & compliance; Internal business purposes	Service Providers or Contractors; Platform Users; Research Agencies; Marketing Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Marketing Mix Measurement Providers; Payment Vendors; Data Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	Business Partners; Online Advertising Networks; Analytics Vendors; Social Media Networks
Protected Classification Characteristics (California / US law)	Provide services; Improve services; Understand interests; Respond to requests; Communicate with you; Determine eligibility; Marketing purposes; Security & compliance; Internal business purposes	Service Providers or Contractors; Platform Users; Research Agencies; Marketing Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Payment Vendors; Data Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	Business Partners; Online Advertising Networks; Analytics Vendors; Social Media Networks
Sensory Information (audio, electronic, visual, call recordings, etc.)	Provide services; Improve services; Understand interests; Respond to requests; Communicate with you; Determine eligibility; Marketing purposes; Security & compliance; Internal business purposes	Service Providers or Contractors; Platform Users; Research Agencies; Marketing Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Payment Vendors; Data Platforms; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	N/A
Other Personal Information (social media posts, info you submit)	Provide services; Improve services; Understand interests; Respond to requests; Communicate with you; Marketing purposes; Advertising; Security & compliance; Internal business purposes	Service Providers or Contractors; Platform Users; Research Agencies; Marketing Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Data Management Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	Business Partners; Online Advertising Networks; Analytics Vendors; Social Media Networks
Inferences & Consumer Profiles (predictions about interests/preferences)	Provide services; Improve services; Understand interests; Marketing & advertising; Internal business purposes	Service Providers or Contractors; Platform Users; Research Agencies; Marketing Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Payment Vendors; Data Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities	Business Partners; Online Advertising Networks; Analytics Vendors; Social Media Networks

 

·       In addition to the uses above, we may use or disclose your personal information if we take part in or are involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our company assets, during negotiation of, in connection with or as an asset in such a corporate business transaction, or in the event of insolvency, bankruptcy, or receivership.

Sources of Information

·       We collect the types of personal information listed in the tables above in the following ways:

·       Directly From You.
When you interact with our Platform (including one of our websites, sending us an email, registering for an account or subscription, purchasing products through the Platform, or call our Consumer Services Team) or interacting with Kefey LLC / Kefey Life FZCO social media pages or other third-party platform, we may collect the personal information you share with us.

·       Automatically When You Interact with Our Platform, Our Emails Or Advertisements.
Subject to your device settings, Kefey LLC / Kefey Life FZCO will automatically collect certain personal information when you interact with our Platform on any device, when you click on sponsored links or third-party ads to visit our Platform, and we may also collect personal information about you over time and across different websites, apps and devices when you use our Platform, using tracking technologies such as cookies, beacons, pixels, flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Platform.

·       We explain more about our use of cookies and other tracking technologies in the section called “Tracking Technologies, Interest-Based Advertising and Third Party Tracking” below.

·       Our Affiliates.
We may receive personal information from our Affiliates.

·       From Third Parties.
We may receive personal information about you from third-party sources. For example, this may include receiving personal information from:

o   (i) our business partners, including marketing partners, medical professionals, third-party diagnostic/laboratory providers, analytics vendors, and companies that co-sponsor our promotions;

o   (ii) online advertising networks and publishers. We may also receive profile information from online publishers, which includes items such as household status, income, educational information, etc. The information that we receive is dependent upon the online publisher;

o   (iii) social media sites, including without limitation, Facebook, Twitter, YouTube, Pinterest, Snapchat, Tik Tok and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site;

o   (iv) third party sites, including those that allow you to integrate your third-party account with your Kefey LLC / Kefey Life FZCO account;

o   (v) family, friends and others who provide your personal information to us because they think you may be interested in our products and services or they want to share a product or service with you;

o   (vi) companies that provide personal information to supplement what we already know about you, including data analytics firms and data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information; or

o   (vii) publicly available sources, including social media sites and public databases.

·       By Combining Personal Information.
For example, we may combine personal information that we collect offline with personal information we collect through our Platform, combine personal information we collect about you from the different devices you use to access our Platform, or combine personal information we get from third parties with personal information we already have about you.

CHILDREN UNDER 13

·       Our Platform is intended for adults.

·       We do not knowingly collect or solicit any information from anyone under the age of 13 though our Platform.

·       In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible.

·       If you believe that we might have collected personal information from a child under 13, please contact us at hello@kefey.co

TRACKING TECHNOLOGIES, INTEREST-BASED ADVERTISING AND THIRD-PARTY TRACKING

Cookies & Other Tracking Technologies:

·       We automatically collect certain types of usage and device information when you visit our Platform, read our emails, or otherwise engage with us.

·       We typically collect this information through use of cookies (a small text file sent from a website and stored on your device), web beacons or pixels and similar tracking technologies, and we may utilize third party services to collect this information.

·       For example, these tracking technologies may collect information about your device and its software, such as your IP address, browser type, device type, date and time stamp, unique device ID, and about the way you engage with our Platform.

·       Examples include: the site from which you came and the site to which you are going when you leave our website, the pages you visit, how frequently you access our Platform, whether you open emails or click the links contained in emails, whether you access our Platform from multiple devices, the products you view and click on, and similar actions you take.

·       You can learn more about how to control cookies in our “Your Privacy Choices” section below.

·       We use this information collected through tracking technologies:

o   to allow you to browse our Platform and use its features,

o   to provide custom, personalized content and information (including targeted content and advertising),

o   to measure the effectiveness of our advertising,

o   to recognize you across multiple devices,

o   to remember your preferences,

o   to monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors,

o   to identify errors and resolve them,

o   to analyze Platform performance,

o   to improve our Platform,

o   and otherwise enhance our Platform and your user experience.

Interest-Based Advertising:

·       We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests.

·       This means that we permit third party online advertising networks, social media companies, and other third party services to collect information about your use of our websites and Platform over time so that they may play or display ads on our Platform, on other websites, apps, or services you may use, and on other devices you may use.

·       Advertisers use advertising identifiers such as cookies, hashed email or phone number, or mobile advertising identifiers, to support their delivery of interest-based advertising.

·       To learn more about these advertising IDs, you can visit: https://www.aboutidentifiers.org/

·       To learn more about your choices regarding interest-based advertising, visit the “Your Privacy Choices” section below.

·       We learn from groups of consumers sharing similar interests.

·       We may place you in a group of consumers who show the same interests (sometimes these are called “look alike audiences”).

·       We may infer these things about you based on:

o   your activity on certain webpages,

o   links you click on our Platform and other websites you visit,

o   mobile applications you use,

o   or our brand emails you view and links you click in the emails.

·       We may also use other information we have collected (such as from retail partners and other third parties).

·       We group together information to help us learn about general trends, habits or characteristics about a group of consumers who act similarly online or offline.

·       We then use this information to send this group information we believe will be relevant product offers or information.

·       We link information to an advertising identifier, which may be device specific (such as a cookie, mobile ad ID, or hashed email address or hashed phone number).

·       This information may be supplemented with information such as products you buy offline or information you provide directly to us on our Platform.

·       We generally do this in ways that will not directly personally identify you (they are “masked” by a number identifier instead of associated with information like your name).

·       If we personally identify you, we will do so in accordance with applicable laws.

·       We may know you across your devices (such as computers, phones, tablets) because we associate device-specific identifiers.

·       We assume that the same person or household owns certain devices based on certain activities, such as connecting the devices to the same WiFi network.

·       We share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices or serve you ads on social media you may use.

·       We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

Google Analytics and Advertising

·       We use Google Analytics to better understand how our users interact with our Platform.

·       Our ability to use and share information collected by Google Analytics about your visits to our sites is restricted by:

o   Google Analytics Terms of Use

o   Google Privacy Policy

·       To understand how Google uses data when you use our partners' sites or apps, visit: Google Partner Sites Policy.

·       You may opt out of Google Analytics at any time by visiting: Google Analytics Opt-out Tool.

·       We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as:

o   Remarketing with Google Analytics

o   Marketing 360

o   Google Display Network Impression Reporting

o   DoubleClick Campaign Manager Integration

o   Google Analytics Demographics and Interest Reporting

·       These features enable us to use:

o   first-party cookies (such as the Google Analytics cookie), and

o   third-party cookies (such as the Doubleclick advertising cookie),

o   or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service.

·       You may control your advertising preferences or opt-out of certain Google advertising products by visiting:

o   Google Ads Preferences Manager

o   NAI’s Opt-Out Tool

Pixels

·       Pixels are small objects embedded into a web page but are not visible.

·       They are also known as:

o   "tags"

o   "web bugs"

o   "pixel gifs"

·       We use pixels to:

o   deliver cookies to your computer,

o   monitor our website activity,

o   make logging into our sites easier,

o   and for online marketing activities.

·       We also include pixels in our email messages or newsletters to determine:

o   whether you open them,

o   and click on their links.

·       This helps us:

o   understand whether you are an active user,

o   measure the effectiveness of our marketing efforts,

o   derive insights and analysis,

o   personalize the content of our communication,

o   and guide our marketing decisions and strategy.

Our Do Not Track Policy

·       Some browsers have “do not track” features that allow you to tell a website not to track you.

·       These features are not all uniform.

·       Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as the Global Privacy Control (GPC).

·       You may need to use a specific browser or an extension that supports these tools and universal signals.

·       When detected, we will process such a signal as a request to:

o   opt out of tracking PI, and

o   opt out of “sale” or “sharing” of your data, as explained in the “Your Privacy Choices” section below.

·       You can also opt-out of such tracking directly on our Platform by following the steps noted in the Interest-Based Advertising section above.

·       If you have questions, please contact us via one of the methods listed in the “How to Contact Us” section at the end of this Policy.

🔐 YOUR PRIVACY CHOICES

📩 Promotional Emails and Text Message Communications

·       At any time, you can opt out of receiving our promotional email or text message communications.

·       If you opt-out you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries.

·       You can opt-out of our promotional emails or text messages by following the instructions included within each of those communications.

·       You can also opt-out of these promotional messages by contacting us:

o   Send us an email at hello@kefey.co

📱 Mobile Application and Location Based Services

·       You may control our collection and use of location-based information through our mobile applications by adjusting the settings on your mobile device.

·       If you withdraw permission for mobile applications to access precise location data, we may continue to approximate your location based on information like your IP address.

·       You may completely opt out of all location-based information collection by us if you uninstall all of our mobile apps from your devices.

🎯 How to Exercise Choice for Interest-Based Advertising

Advertising Industry Opt-Outs

·       To exercise choice with respect to interest-based advertising, you can use the opt-out mechanisms provided by the Digital Advertising Alliance by visiting:

o   https://youradchoices.com/token (for device identifier-specific opt outs)

o   https://optout.aboutads.info/?c=2&lang=EN (for desktop or mobile browser advertising)

o   https://youradchoices.com/appchoices (for in-app advertising)

·       You can also use the Network Advertising Initiative’s (NAI) tool that allows consumers to opt out of certain interest-based advertising delivered by NAI members’ ad networks:

o   http://www.networkadvertising.org/choices/

·       To opt-out of Unified ID 2.0 globally visit:

o   https://www.transparentadvertising.com/

⚠️ Important Notes

·       Even if you opt-out of certain kinds of interest-based ads, you may continue to receive other ads.

·       Opting out of one or more DAA or NAI members only means that those selected members should no longer under the DAA / NAI rules deliver certain targeted ads to you.

·       This will affect services provided by the applicable DAA / NAI members but does not mean you will no longer receive any targeted content and/or ads from non-participating parties.

·       If your browsers are configured to reject cookies when you visit the opt-out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser-based method of access, your DAA / NAI browser-based opt-out may not, or may no longer, be effective.

·       Mobile device opt-outs will not affect browser-based interest-based ads even on the same device, and you must opt-out separately for each device.

·       We are not responsible for the effectiveness of, or compliance with, any third party opt-out options or programs or the accuracy of their statements regarding their programs.

🍪 Prevent or Reduce Interest-Based Ads

·       You can also prevent or reduce getting interest-based ads on websites by declining cookies in your browser(s).

·       On mobile devices by declining the “access to data” requests that apps usually present when you install them.

·       Or by adjusting the ad tracking settings on your device.

📌 Contextual Ads

·       You will still see “contextual” ads even if you opt out of interest-based ads.

·       Even if we stop sending you interest-based ads, you will still get ads from our brands on your computer or mobile devices.

·       These ads, however, are based on the context of the sites you visit and are called contextual ads.

·       Unlike interest-based ads which are based on pages you visit on your mobile phone or computer viewing activities over time and across unrelated services, contextual ads are ads shown to you based on the context of the specific site you are visiting.

·       You should also know that we may still collect information from your computer or devices and use it for other purposes like evaluating how our websites work, for consumer research, or detecting fraud, pursuant to applicable laws.

🍪 How You Can Control Cookies

·       Your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies.

·       To control flash cookies, which we may use on certain websites from time to time, you can visit:

o   Flash Player Settings Manager

o   ⚠️ Because flash cookies cannot be controlled through your browser settings.

·       If you block cookies, certain features on our Platform may not work.

·       Depending on your mobile device and operating system:

o   you may not be able to delete or block all cookies,

o   and you may not be able to block non-cookie technologies (such as flash cookies).

·       These browser settings that block cookies may have no effect on such techniques.

·       In addition, options you select relating to cookies and other tracking technologies are browser and device specific.

·       You must exercise these choices on each browser and device you use.

🍪 Opt-Out Cookies

·       When you opt out of interest-based advertising, an opt-out cookie is sent to your browser that indicates you no longer want to receive interest-based ads.

·       Your opt-out cookie will be deleted if you decide to delete all cookies on your browser.

·       You will need to opt out again on each browser when you clear or delete cookies if you do not want to receive interest-based advertising.

🛡️ Privacy Rights

·       We offer certain privacy rights as stated below, subject to certain limitations at law.

Privacy Right	Description
Right to Know	The right to request the following information relating to the personal information we have collected about you and disclosed about you: • The categories of personal information we have collected about you; • The categories of sources from which the personal information was collected; • The business or commercial purposes for collecting, selling, or sharing the personal information; • The categories of third parties with whom the business shares personal information; • The categories of personal information sold, and for each category identified, the categories of third parties to whom it sold that particular category of personal information; and • The categories of personal information that the business disclosed for a business purpose, and for each category identified, the categories of third parties to whom it disclosed that particular category of personal information.
Right to Access (Right to Know Specific Pieces of Information) / Portability	The right to access and obtain a copy of the specific pieces of personal information we have collected about you in a structured, machine-readable format that may be transmitted to another entity without hindrance, to the extent technically feasible.
Right to Correct	The right to request that we correct your inaccurate personal information maintained by us.
Right to Request Deletion	The right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions.
Right to Opt Out of Data Sales or Sharing, Profiling (Right to Opt-Out of Targeted Advertising or Profiling)	The right to direct us not to sell or share personal information we have collected about you to third parties, including for ad targeting/cross-contextual behavioral advertising. DO NOT SELL OR SHARE MY PERSONAL INFORMATION
Right to Limit Use of Sensitive Personal Information	The right to direct us to limit our use of sensitive personal information to certain purposes and/or revoke a previously given consent to our use of sensitive personal information about you. LIMIT USE OF MY SENSITIVE PERSONAL INFORMATION
California’s “Shine the Light” Law	California’s “Shine the Light” law (Civil Code § 1798.83) also permits California residents that have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures. To exercise this right, please visit the webform at: DO NOT SELL OR SHARE MY PERSONAL INFORMATION and follow the instructions for Right to Opt Out of Data Sales or Sharing, Profiling (Right to Opt-Out of Targeted Advertising or Profiling).

 

🔹 HOW TO EXERCISE YOUR PRIVACY CHOICES – KEFEY

·       To Exercise Your Rights to Know, Access, Correct, and/or Delete

o   Please send us an email to: hello@kefey.co

o   We may need to verify your identity before processing most requests, which may require us to obtain additional personal information from you.

o   In order to verify your identity, we will generally require either:

§  the successful authentication of your account, or

§  the matching of sufficient information you provide us to the information we maintain about you in our systems.

o   Please provide your name, email address, and mailing address in the original request, as well as an explanation of the rights you wish to exercise.

o   We will only use the personal information provided in connection with a Privacy Rights Request to review and comply with the request.

o   If you do not provide this information, we may not be able to verify or complete your request in all circumstances.

·       Submitting a Request on Behalf of Another Individual

o   If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf.

o   Please see the “Authorized Agents” section below for more information.

·       Right of Kefey to Decline Requests

o   In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.

·       To Exercise Your Right to Limit Use of Your Sensitive Personal Information

o   To exercise your Right to Limit Use of Sensitive Personal Information, please submit a request by clicking the button below: LIMIT USE OF MY SENSITIVE PERSONAL INFORMATION.

o   We may ask you to provide additional personal information (including your name, email address, and mailing address) so that we can properly identify you in our dataset to facilitate the opt-out request.

o   If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

o   Once you make a limit request, you may change your mind and permit other uses of your sensitive personal information at any time by contacting us at hello@kefey.co

·       To Exercise Your Right to Opt Out of Personal Information Sales or Sharing (Profiling or Targeted Advertising)

o   As is common practice among companies that operate online, Kefey permits third party advertising networks, social media companies, and other third-party businesses to collect personal information directly from your browser or device through cookies or similar online tracking technologies when you visit or interact with our websites, use our apps, or otherwise engage with us.

o   For example, these third parties may collect:

§  Internet/Network information (such as a cookie or device ID, browsing history, and website usage),

§  Geolocation data,

§  Commercial information,

§  Inferences or consumer profiles generated from your browsing history and interactions with our service as well as other sites and services.

o   These third parties use this information for purposes such as:

§  serving ads that are more relevant,

§  ad campaign measurement and analytics,

§  fraud detection and reporting,

§  and they may sell or share that information to other businesses for advertising and other purposes.

·       Two Separate Instructions for Opt Out:

o   There are two separate sets of instructions for exercising your Right to Opt Out:

1.     For Tracking Technology personal information (Tracking PI) – such as cookie ID, IP address, online IDs, or electronic activity information.

2.     For Non-tracking PI – such as information we previously collected directly from you (e.g., your email address).

·       How to Opt Out of Non-tracking PI

o   To exercise your Right to Opt Out of non-tracking PI, please submit a request by clicking the button below: DO NOT SELL OR SHARE MY PERSONAL INFORMATION.

o   We may ask you to provide additional personal information (including your name, email address, and mailing address) so that we can properly identify you in our dataset to facilitate the opt-out request.

o   If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

o   Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at hello@kefey.co

·       How to Opt Out of Tracking PI

o   To exercise your Right to Opt Out of tracking PI, visit the bottom of a Kefey brand homepage that links to this Policy and click on: “AdChoices – Do Not Sell or Share”.

o   You will be taken to our cookie management tool with instructions for using the toggle to enable certain cookie preferences on your device.

o   Important Notes:

§  Some advertising opt-outs may not be effective unless your browser is set to accept cookies.

§  Options you select relating to interest-based advertising are browser and device specific.

§  If you use a different device, change browsers, or visit a different Kefey brand website, or delete the opt-out cookies, you may need to perform the opt-out task again.

§  Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as the Global Privacy Control (GPC).

§  When detected, we will process such a signal as a Right to Opt Out of Tracking PI request.

·       Personal Information of Minors Under Age 18

o   Kefey does not “sell” or “share” for targeted or cross-context behavioral advertising the personal information of consumers we know to be less than 18 years of age unless we receive affirmative authorization as permitted or required by applicable law.

o   Our Platform is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under 13.

o   The minor, parent, or guardian who has opted into personal information sales or sharing may opt out of future sales at any time by using our form at DO NOT SELL OR SHARE MY PERSONAL INFORMATION.

·       Authorized Agents

o   In certain circumstances, you are permitted to use an authorized agent to submit privacy rights requests on your behalf.

o   We may verify the authorized agent’s authority to act on your behalf as follows:

§  For requests to opt-out of personal information “sales” or “sharing,” we may ask you to provide a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

§  For all other requests, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Policy, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

·       Right to Know Specific Third Parties

o   In certain circumstances, you may have a right to request information about specific third parties with whom we share personal information.

o   You may make this request by contacting us at hello@kefey.co

·       Right to Revoke Consent

o   Where we are processing your personal information based on your consent, you have the right to revoke such consent.

o   You may make this request by contacting us at hello@kefey.co

·       Right to Appeal

o   In certain circumstances, we may decline a request to exercise the rights described above.

o   If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request.

o   You may appeal a denied request by contacting us at hello@kefey.co

·       Nondiscrimination

o   Kefey does not discriminate against you for requesting any of the rights noted above.

o   We are permitted to deny or limit your request in accordance with applicable laws.

🔹 PRIVACY RIGHTS METRICS – KEFEY

·       Privacy Rights Metrics

o   Click here to see request metrics.

🔹 FINANCIAL INCENTIVES – KEFEY

·       From time to time, Kefey may offer you certain financial incentives permitted by law (such as coupons, samples, and loyalty programs) in exchange for the collection, retention, or use of certain personal information about you.

·       Each financial incentive related to the collection and use of personal information is based upon Kefey’s reasonable, good-faith determination of the estimated value of such information to our business.

·       When necessary, Kefey will provide information about the specific terms of the financial incentive, such as:

o   the type of personal information required to be disclosed, retained, or sold in exchange for the benefit you may receive, and

o   instructions on how to opt in or opt out, on the webpage or form where the financial incentive is made available.

🔹 SECURITY – KEFEY

·       The Internet is not 100% secure.

·       Kefey cannot guarantee the security of the personal information you provide to us via our Platform.

·       Kefey has taken steps designed to reduce the risk that the personal information you provide will be lost, misused, or subject to unauthorized access, disclosure, alteration, or destruction.

·       Please use caution when using the Internet.

·       It is your responsibility to protect your username and password used on our Platform.

🔹 STORAGE OF INFORMATION – KEFEY

·       Our Platform is directed only to U.S. consumers for products and services of Kefey group of companies and brands in the United States and only intended for use in the U.S.

·       Our Platform is not directed to consumers outside of the U.S.

·       Personal information we maintain may be stored in or outside of the United States.

·       If you live outside of the United States, you understand and agree that Kefey may transfer your personal information to the United States.

·       Our Platform is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.

🔹 RETENTION OF PERSONAL INFORMATION – KEFEY

·       The period for which Kefey retains your personal information varies, depending on:

o   the type of personal information, and

o   the purpose for which it was collected.

·       The duration is limited to the time necessary to fulfill the purposes for which the information was collected, in light of:

o   any restrictions or deletions you might request, and

o   Kefey’s need to address legal obligations or rights.

🔹 LINKS TO THIRD-PARTY SERVICES – KEFEY

·       Our Platform may contain links to other third-party sites, plug-ins, applications, or other online services.

·       If you click on a link to a third-party site or other online service, you will be taken to a site or service Kefey does not control and that is not governed by this Policy.

·       Kefey is not responsible for the privacy practices used by third-party sites and other online services.

·       Kefey suggests that you read the privacy policies of those sites and other online services carefully.

🔹 HOW TO CONTACT US – KEFEY

·       If you have any questions, comments, or concerns with respect to Kefey’s privacy practices or this Policy, or wish to update your information, please feel free to contact us at:

o   hello@kefey.co

🔹 CHANGES IN POLICY – KEFEY

·       From time to time, Kefey may change this Policy.

·       Kefey will notify you of any material changes to this Policy as required by law.

·       Kefey will also post an updated copy of this Policy on our Platform.

·       Please check our Platform periodically for updates.