Last Updated: Sep 20, 2021
DESCRIPTION OF USERS
The Platform allows celebrities and influencers (“Talent”) to: (i) create a customized link (a “Keychain”) for placement on its web based social media, to allow Talent fans (“Fans”) to access a Keychain page populated with curated links to Talent’s content, newsletters, exclusive photos + videos, merchandise, contests, and SMS contact lists; (ii) livestream videos (“Livestream Videos”) that can be viewed by individuals who have signed up with the Platform and paid to view certain content (“Viewers”), and (iii) send personal videos in response to direct message requests from Viewers (“DM Videos,” and together with Livestream Videos, “Videos”) .
THE INFORMATION WE COLLECT AND HOW WE USE IT
In the course of operating the Services, Key collects or receives the following types of information.
Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Site, or the pages you’ve clicked on while on our Site). We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.
We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your visit. We use both first-and third-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.
● Session Cookies: We use session cookies to make it easier for you to navigate our Services. A session ID cookie expires when you close your browser.
● Persistent Cookies: A persistent cookie remains on your hard drive for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s “help” file. To the extent we provide a log-in portal or related feature on our Services, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to collect emails to build Custom Audiences and to track and target the interests of our visitors to personalize the experience on our Services.
In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use. In addition to facilitating the purposes described above, this is useful in understanding your engagement with other content related to our Services (e.g., email open rates, URL click-throughs).
If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. The management of cookies and collection of data from third party advertisers and remarketers can only be controlled through the settings feature on your device or following guidance provided by the advertiser or remarketer, as the case may be. However, if you decide not to accept cookies from us, certain aspects of the Services may not function properly or as intended.
Third-Party Analytics Providers
For Google Analytics, please visit: https://www.google.com/analytics
For Lotame, please visit: https://www.lotame.com/
We may, with your consent, automatically collect geolocation information from your device via your browser’s location services. This consent may be provided by you on the device level (e.g., you have consented to location services generally through your browser’s settings) or by accepting our request for geolocation access on the Services. Please consult your browser’s documentation regarding how to turn off location services. If you disable location services, you may not be able to use the full array of features and functionalities available through our Services.
In an ongoing effort to better understand our users and the Services, we might analyze your information in aggregate form to operate, maintain, manage, and improve one or all of them. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe the Services to current and prospective business partners and to other third parties for other lawful purposes.
Onward Transfer to Third Parties
• Like many businesses, we hire other companies to perform certain business-related services. The types of companies that may receive personal information and their functions are: hosting services, technical assistance, database management/back-up services, use analytics, advertising/remarketing, email marketing platforms, customer service, and payment processing. These other third-party companies will have access to personal information only as needed to enable them to provide such services.
• When a Viewer signs up to view a Livestream Video provided by Talent, or a Fan activates a Keychain or responds to Talent content on a Keychain page, we will share your email address with Talent for use in promotion and marketing communications and to communicate with you about their events and activities, you may opt out of such sharing by emailing us at firstname.lastname@example.org.
• Fans may opt out of future sharing of their contact information collected on our Website with Talent by engaging the opt-out link provided on our Website. Engagement of this link shall discontinue your receipt of marketing communications, including inclusion in the Custom Audience.
• In order to provide our Services and administer promotional programs, we may share your personal information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
• We may, from time to time, share and/or license personal information to other companies who may provide you information about the products and services they or their partners offer. However, to the extent required by law, you will be given the opportunity to opt out of such sharing.
• We may disclose personal information to our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control in order to support marketing, sale and delivery of any services.
Disclosure to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
OPT-OUT FOR DIRECT MARKETING; EMAIL MANAGEMENT
You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to email@example.com or by clicking on the “Unsubscribe” link located on the bottom of any Key marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional e-mails related to the Services. Opting out of marketing emails with Key will not remove you from a Talent’s email marketing list if you previously signed up to view the Talent’s Livestream Video, to receive Talent’s content through its Keychain page or otherwise. Please allow us a reasonable time to process your request.
HOW WE PROTECT YOUR INFORMATION
IMPORTANT NOTICE TO ALL NON-US RESIDENTS
Our servers are located in the US and elsewhere. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Services, you do so at your own risk.
CALIFORNIA PRIVACY RIGHTS
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Key via email at firstname.lastname@example.org.
DO NOT TRACK
Key does not respond to “Do Not Track” settings or other related mechanisms at this time.
LINKS TO EXTERNAL WEBSITES
HOW TO CONTACT US