Effective date: Sep. 19, 2023
KAWO respects your right to privacy. This privacy policy (“Privacy Policy”) explains who we are, how we collect, share and use information about you and how you can exercise your privacy rights.
Our Privacy Policy applies to all users of KAWO websites and services, including but not limited to www.kawo.com, app.kawo.com and engage.kawo.com (depending on your use, the “Site” and/or the “Service”). For further information on the terms which govern your use of the respective Service, please see https://kawo.com/en/terms-of-service or any service order you may have signed with us.
This Privacy Policy will help you to understand the following key issues in relation with your personal information:
1. What Does KAWO Do?
2. Information Collected
3. Use of Information
4. Categories of Third Parties With Whom We May Share Your Information
5. Data Retention
6. Sensitive Personal Information/IP address Information
7. Legal Basis for Processing Personal Data
8. Cookies, Similar Tracking Technology, and Analytics
9. Social Media and Technology Integrations
10. Your Data Protection Rights
11. Security & User ID/Password
12. CAN-SPAM Compliance Notice (U.S. users only)
13. International Transfers
14. Contacting Us, Complaints and Dispute Resolution
15. Children
16. Updates to this Privacy Policy
17. How to Contact Us
1. What Does KAWO Do?
If you have any questions or concerns about our use of your information, then please contact us using the contact details provided in the “How to Contact Us” section of this Privacy Policy.
KAWO is a provider of software for social media management, social advocacy and social analytics headquartered in China. For more information about KAWO, please see the “About KAWO” section of our Site at https://kawo.com/en/about
2. Information Collected
We collect information about visitors to our Site, our customers and their users of the Service and users of our customers’ social media pages / properties.
Such information is collected from the following sources:
1) Information We Collect Directly from You:
The type of information that we collect directly from you varies based on your interaction with our Site and our Service. For example, we collect information directly from you when you register an account with us, liaise with us on a customer service issue , apply for a job, and complete an application or other forms on the Site and/or Service. We also collect information that you send us via any medium, including, but not limited to email address and phone number. In addition, we collect information about you from your social media interactions on third party social media properties, such as your social media handle, username, profile, postings, and messages you exchange with our customers.
2) Information We Receive from Customers:
We receive information from customers in order to provide our Service. Such information may include a user’s social media handle, username, profile picture, biography, follower counts, website URL, first and last name (if provided by user), and messages or communications with our customers. We collect information from individuals employed by our customers such as their contact information in order to provide our Service.
3) Information Collected Automatically
When you visit our Site or use our Service, we may collect certain information automatically from your device. This information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), third-party webpages accessed via the Service, and other technical information. We may also collect information about how your device has interacted with our Site (including the pages accessed and links clicked) or Service (including content accessed).
Collecting this information enables us to better understand the visitors who come to our Site or use our Service, where they come from, and what content and functionality is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Site and/or Service to our visitors and users.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies, similar tracking technology, and analytics” below.
4) Information from Other Sources
We also collect information from other sources, including without limitation: :
• Data brokers or resellers from which we purchase data to verify and supplement the data we collect.
• Social networks when you engage with our content, reference our Site or Service, or grant us permission to access information from the social networks.
• Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
5) Information that is not applicable with this Privacy Policy
• Keyword information you type in when you use searching service on the Site.
• The information contained in the content you post through the Site.
• Any information that is in violation of applicable laws and regulations or this Privacy Policy.
3. Use of Information
KAWO processes information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include the following:
• Operate and improve the Site and Service;
• Provide users or customers with the Service and other products and services that a user or customer may request or that a user or customer has expressed interest in;
• Facilitate subscription processing, reviews and analysis;
• Evaluate user interest and needs in order to improve the Service and make available other offers, products or services;
• Record calls with customers for quality, training and Service improvement purposes (upon receipt of consent where required by applicable law);
• Evaluate the types of offers, products or services we make available to users or customers and potential users or customers;
• Monitor use of the Service, including for troubleshooting and product improvement purposes;
• Provide customer support;
• Communicate and provide additional information that may be of interest to users through email or other means, such as special offers, announcements, and marketing materials;
• Conduct online research surveys regarding the Site and/or Service;
• Combine datasets to create aggregated data for internal evaluation and analysis;
• Send you reminders, technical notices, updates, product announcements, security alerts and support and administrative messages, service bulletins, or marketing;
• Provide advertisements to you through email messages;
• Manage our everyday business needs such as Site and/or Service administration, forum management, fulfillment, analytics, fraud prevention, enforcement of our corporate reporting obligations, legal terms and any other contractual agreement relating to our Service or to comply with the law; and
• Fulfill any other business or commercial purposes at your direction or with your notice and/or consent.
Notwithstanding the above, we may use and share information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see “Your Data Protection Rights” below.
4. Categories of Third Parties With Whom We May Share Your Information
4.1 We share information we collect in accordance with the practices described in this Privacy Policy. The following are the categories of recipients:
• to our affiliates, service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site or Service), or who otherwise process information for purposes that are described in this Privacy Policy or for which we provide you notice when we collect your information. We share information with our affiliates for business and commercial purposes. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• to our customers (including information pertaining to customer end-users as well as internal personnel) in order to effectively provide our social media management and social analytics services and to manage the customer relationship. For example, we share information with our customers in order to facilitate the processing of their orders, maintain and administer their online accounts, respond to their questions and comments, comply with their requests, market and advertise to them and otherwise comply with our contractual obligations and with applicable law;
• to local information technology resellers in certain countries where permitted by applicable law. We may provide contact information of customers / potential customers to such reseller to market our Service.
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or court order or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to a potential buyer (and its agents, investors, and/or advisors) in connection with any proposed or actual purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your information only for the purposes disclosed in this Privacy Policy;
• to vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Cookies, similar tracking technology, and analytics” section below;
• to any other person with notice to you and your consent to the disclosure;
• when you voluntarily enter a sweepstakes, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials;
• when you make information public through the Site or Service, such as information in your profile or that you post or comment on public boards, including through Disqus and social media, your information is publicly viewable. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Data Protection Rights” section below; and
• when you request or direct us to share information, such as when you choose to share information with a social network or other third party platform about your activities on the Service, which may require you to accept such third party’s terms of use or privacy policy.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
4.2 Security Review
We may conduct certain security review of the content you intend to publish through KAWO by transmitting your content to Tencent Security Product. However, despite the fact that KAWO may have conducted such security review, KAWO does not make any warranty with regard to the security of the content you intend to publish. You still need to consider the security of such content. If there is any issue in relation with the content you publish (i.e. in violation of any laws or regulations), you shall take any and all legal responsibilities and consequences.
5. Data Retention
We retain information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it in accordance with our data retention policy, or, in the limited circumstances where this is not possible (for example, because your information has been stored in backup archives), then we will securely store your information and isolate it from any further processing until deletion is possible.
6. Sensitive Personal Information/IP Address Information
6.1 The terms that govern your use of the Service prohibit you from providing KAWO with sensitive personal information as that term is defined under applicable law.
6.2 When you publish content through KAWO, the IP address automatically generated will be the location of KAWO’s server, which may be inconsistent with the actual location information when you publish such content. Therefore, KAWO has provided certain optional server location information (including Beijing, Shanghai, Guangzhou, Shenzhen, which may be continuously updated in the future). You may choose such IP address based on your actual location when you publish the content. Nevertheless, we’d suggest you choosing the actual (or the closest) server location information of your location to avoid any misleading or potential issues. If you choose otherwise, you shall bear any and all legal responsibilities in relation with any dispute or legal risk .
7. Legal Basis for Processing Personal Data
If you are a visitor or user from the European Economic Area or the UK, our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).
Similarly, if we collect and use your personal data in reliance of our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How to Contact Us” heading below.
8. Cookies, Similar Tracking Technology, and Analytics
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.
We also use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to a technology service or incorporating a pixel from a technology service into our own Service, and the technology service matching common factors between our data and their data. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
To opt out of us using your data for Matched Ads, please contact us at [email protected] with the following information:
– Your first name
– Your last name
– Your email address
– Your phone number
– Your Full Address
– The details of your request
You can also set your browser to send a Global Privacy Control signal that communicates to us that you would like to opt-out of Matched Ads. Please note that opting out of Matched Ads does not mean that you will stop seeing ads. You will still see ads related to the Services, but you will stop receiving ads that are personalized to you.
As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
9. Social Media and Technology Integrations
We offer parts of our Service through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate technologies operated or controlled by separate entities into parts of our Site and Service. Some examples include:
a. Links. Our Site and Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
b. Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Site or Service that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
c. Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on the Site or Service) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with KAWO in a tweet or post), we may use your reference on or in connection with our Site or Service.
Please note that when you interact with other entities, including when you leave our Site or Service, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies, terms, and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in China. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
10. Your Data Protection Rights
You have the following data protection rights:
a) If you wish to access, correct, update or request deletion of your information, you can do so at any time by contacting us using the contact details provided under the “How to Contact Us” heading below. Note that if you submit a request to delete your information, this may prohibit you from using the Site and/or Service. If you have authorized us to access your data via the YouTube API Services, then in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, located at https://security.google.com/settings/security/permissions.
b) In addition, if you are a resident of the European Economic Area or the United Kingdom, you can object to processing of your personal data, ask us to restrict processing of your personal data, or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to Contact Us” heading below. Note that if you submit such a request, this may prohibit you from using the Site and/or Service.
c) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to Contact Us” heading below. Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
d) Similarly, if we have collected and processed your information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
e) You have the right to complain to a data protection authority about our collection and use of your information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Where we process your information solely on behalf of a customer, we may be legally required to forward your request directly to our customer and/or social media business partners for their review / handling.
11. ID/Password
Our Site and/or Service implements and maintains various reasonable and appropriate administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. These security safeguards include, but are not limited to, network and host security controls (e.g., firewalls, intrusion detection systems, etc.), data encryption (both at rest and during transmission), and operating procedures that are designed to protect your information. You should protect your user ID and password and NOT share it with anyone. Additionally, we recommend enabling two-step verification where available. If you believe your user ID and password have been compromised or you have trouble changing your user ID/password on the Site or Service, please contact our technical support department ([email protected]). Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
12. CAN-SPAM Compliance Notice (U.S. users only)
We may send periodic promotional or informational emails to you. You may opt-out of promotional communications by following the unsubscribe or opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Service you have requested or received from us.
13. International Transfers
Your information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
However, we have taken appropriate safeguards to ensure that your information will remain protected in accordance with this Privacy Policy.
14. Contacting Us, Complaints and Dispute Resolution
In compliance with the Privacy Shield Principles, KAWO commits to resolving complaints about your privacy and our collection or use of your information. We will work to resolve your issue and will respond within 45 days of receipt.
KAWO commits to cooperate with Chinese data protection authorities and comply with the advice given by such authorities with respect to human resources data transferred from the People’s Republic of China in the context of any employment relationship.
15. Children
This Service is intended for a general audience and is not directed at children under fourteen (14) years of age.
We do not knowingly request personal information from anyone under the age of 14 without requiring parental consent. Any person who provides their personal information to us through our Site or Service represents that they are at least 14 years of age. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, please contact us at [email protected]. We will remove the data to the extent required by applicable laws.
We do not knowingly “sell” or “share,” the personal information of minors under 14 years old.
If you are under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at the email address set out in the “How to Contact Us” section and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
16. Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. Please check on regular basis. When we make substantial change to our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.
You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.
17. How to Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us at [email protected].
If you have a privacy concern or complaint, please contact us at [email protected]. When you contact us, please indicate in which country you reside.
