Effective: 25 May 2018

Your privacy is important to Kiron Interactive. We developed this Privacy Policy to provide you with information on how we process your personal data when you create an account administered by Kiron Interactive, when you interact with our customer support, or when you visit Kiron Interactive websites or any other Kiron Interactive service

For use throughout this Policy, “Personal data” is information relating to an identified or identifiable natural person.

1. Categories of Personal Data Processed by Kiron Interactive
2. Categories of Recipients of Personal Data
3. Cookies and Similar Technologies
4. Children
5. Privacy Policy Updates
6. Retention of Personal Data
7. Data Controller and Data Protection Officer
8. Your Rights

1. Categories of Personal Data Processed by Kiron Interactive

   1. Personal data that is processed when you create a Kiron Interactive account:

      When you create a Kiron Interactive account, we ask you to provide your email address and name. You can choose to provide only your first name or a nickname instead of your full name if you wish.

      Purposes and Legal Grounds:

      (a) Kiron Interactive processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on Kiron Interactive’s legitimate interest in protecting the security of your account.

      (b) Kiron Interactive also processes your email address for the purpose of sending you important information about your Kiron Interactive account, such as updates, reports, important safety information or material changes to the website’s policies. The name you provide is associated with your account profile, and is displayed when you submit comments or other material on a Kiron Interactive website forum. The legal ground for processing your email address and name for these purposes is Kiron Interactive’s legitimate interest in providing you with important safety or other information about your Kiron Interactive account or material changes to policies, and in providing you an opportunity to engage with other users.

      (c) If you provide your opt-in consent to receiving marketing information from Kiron Interactive, Kiron Interactive will also process your email address for the purpose of sending you marketing information about Kiron Interactive products. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your Kiron Interactive account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from Kiron Interactive are based on the preferences you provide in your Kiron Interactive account, the locale indicated by your Internet Protocol (IP) address and any subscriptions included in your Kiron Interactive account. The legal ground for processing this data for this purpose is Kiron Interactive’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.

      (d) Kiron Interactive also processes your email address to associate it with your Kiron Interactive account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support and ensuring security of person.

   2. Personal data that is processed when you communicate with Kiron Interactive:

      When you interact with our customer support representatives via email, telephone, online or otherwise, we collect personal data, such as your name, mailing address, phone number, email address and contact preferences; and information about the Kiron Interactive website you are using. We also may create event logs that are useful in diagnosing product or performance-related issues, and capture information relating to the support or service issue. To improve customer service, and subject to applicable laws, we may also record and review conversations with customer support representatives, and analyse any feedback provided to us through voluntary customer surveys. Our customer support representatives may only use your account details with your explicit consent and only in order to sign in to your Kiron Interactive account, if appropriate, to help troubleshoot and resolve your issue.

      Purposes and Legal Grounds:

      We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is Kiron Interactive’s legitimate interests in providing quality product support. The legal ground for signing in to your Kiron Interactive account, if appropriate, to help troubleshoot and resolve your issue is consent, which you may withdraw.

   3. Personal data that is processed when you purchase a product on a Kiron Interactive website:

      If you purchase a product on a Kiron Interactive website, then Kiron Interactive will collect your name, mailing address and telephone number. We do not view or store your payment card information. A third party, Pay360, processes customer payment card information when Kiron Interactive customers use a payment card to make a purchase on a Kiron Interactive website. We recommend you carefully review Pay360’s Privacy Policy.

      Purposes and Legal Grounds:

      We collect your name, mailing address and telephone number so we can process your order and fulfil your purchase. The legal ground for processing your name, mailing address and telephone number for these purposes is performance of a contract. We also process your personal data as part of our fraud detection processes. The legal ground for processing your personal data for that purpose is our legitimate interest in protecting Kiron Interactive and our customers from attempts to engage in fraudulent transactions and underage gaming.

2. Categories of Recipients of Personal Data

   Service providers

   We use technical service providers which may operate the technical infrastructure that we need to provide the services, in particular providers which host, store, manage, and maintain the Kiron Interactive websites, its content and the data we process.

   We use technical service providers to help us communicate with you. Those services track the activities associated with these emails, such as whether they were opened, whether links in the emails were clicked on, and whether purchases were made following clicks on those links. Kiron Interactive uses this data to analyse the level of engagement with its emails.

   Other disclosures:

   We may disclose personal data about you to others in certain situations:

   (a) if we have your valid consent to do so
   (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation
   (c) to enforce any of our terms and conditions or policies
   (d) as necessary to pursue available legal remedies or defend legal claims.
   

   We may also transfer your personal data to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Kiron Interactive’s business or assets, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data to will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

   Transfers of Personal Data

   Kiron Interactive is a global business. To offer our products and services, we may need to transfer your personal data to other Kiron Interactive companies in other countries. When you create a Kiron Interactive account, add personal data in your account profile, or upload data to your Kiron Interactive account, your personal data will be collected and stored on Kiron Interactive (Pty Ltd’s servers in South Africa. Personal data regarding individuals is controlled by Kiron Interactive (Pty) Ltd. Payment related personal information is processed on its behalf by Kiron Interactive Limited in the United Kingdom.

   All Kiron Interactive companies are required to follow the privacy practices set forth in this Privacy Statement.

3. Cookies and Similar Technologies

   Websites:

   To help analyse how you and other visitors navigate Kiron Interactive websites, and to compile aggregate statistics about site usage and response rates, we collect certain information when you visit our site. This information could include IP address, geographic location of the device, browser type, browser language, date and time of your request, time(s) of your visit(s), page views and page elements (e.g., links) that you click.

   If you do not want information collected through the use of these technologies, there is a procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them. Please review your cookies settings in your relevant browser.

   If you reside in the European Union or other jurisdiction that requires us to obtain your consent to use cookies on our sites, then you will have an opportunity to manage your cookie preferences on the sites; except that certain cookies are required to enable core site functionality, and you cannot choose to disable those cookies.

   The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products and websites so we can enhance the user experience and functionality of our products and websites.

   Here are examples of third-party providers of analytics and similar services we currently use:

   Analytics Services:

   • Google: Google Analytics is used to track site statistics and user demographics, interests and behaviour on websites. We also use Google Search Console to help understand how our website visitors find our website and to improve our search engine optimization. Find out more information about how this analytics information may be used, how to control the use of your information, and how to opt-out of having your data used by Google Analytics.
   • SmartStats: Is similar to Google Analytics and is also used to track site statistics and user demographics, interests and behaviour on websites
   • MailChimp: MailChimp tracks the activities associated with emails, such as whether they were opened and whether links in the emails were clicked on. Kiron Interactive uses this data to analyse the level of engagement with its emails.

4. Children

   We do not accept personal data from children. We regularly perform checks to ensure that individuals under 18 not provide personal data to Kiron Interactive or perform any actions on our websites. If we learn that we have collected the personal data from a person under 18, we will take immediate steps to delete the information

5. Privacy Policy Updates

   We may update this Privacy Policy from time to time as we add new products, as we improve our current offerings and as technologies and laws change. Any changes will become effective upon our posting of the revised Privacy Policy.

   We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the Kiron Interactive websites that link to this Privacy Policy.

6. Retention of Personal Data

   We will retain your personal data as long as your Kiron Interactive account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.

7. Data Controller and Data Protection Officer

   If you reside in a country in the European Economic Area as well as any other country, then your personal data collected by Kiron Interactive is controlled by Kiron Interactive (Pty) Ltd, which is located at 26 Baker Street, Rosebank, Johannesburg, South Africa. Kiron Interactive’s Data Protection Officer is located at the same address and can also be reached by email at privacy@KironInteractive.com.

8. Your Rights

   If you reside in the European Union, you have the right under the General Data Protection Regulation to request from Kiron Interactive access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside of the European Union, you may have similar rights under your local laws.

   To request access to or rectification, portability or erasure of your personal data, or to delete your Kiron Interactive account, please contact Support. Note that rectification of your details can be performed via your account settings after logging in.

   If you wish to exercise your right to restriction of processing or your right to object to processing, contact Kiron Interactive’s Data Protection Officer at Kiron Interactive 26 Baker Street, Rosebank, Johannesburg, South Africa or by email at privacy@KironInteractive.com.