1. This policy is effective from Jan 1st, 2020.
2.1 KNiTO is owned by Notion Wave Inc who is a Canadian company (hereinafter “KNiTO”, “we”, “or”, “us”), providing an online platform named KNiTO that enables registered users (hereinafter “User”, “Publisher”, or “you”) to upload and publish their content, in particular ePUB3 books and other content, hereinafter the “Platform”).
2.2 Our address headquarter is located at: 53 Wellington Street East, Aurora, ON, L4G 1H6, Canada. The company is duly incorporated under the laws of the province of Ontario.
3. Data controller
3.1 KNiTO is the data controller for the personal data collected from Users domiciled within the EU when using the Platform.
3.2 We will process your personal data in compliance with European General Data Protection Regulation. (“GDPR”)
4. Purpose and legal basis**
4.1 We process your personal data in order for us to manage our user relationship with you, including managing your account and provide you with access to use the Platform, we collect and use information about you. The processing of your personal data is performed on the legal basis of:
- fulfilment of our contractual obligations when delivering the Platform to you.
4.2 We process your personal data to facilitate any sale of content via the Platform on the legal basis of:
- fulfilment of our contractual obligations to facilitate your purchase of content.
4.3 We also process your personal data to deliver and improve the Platform, to let you know about our policies and Terms of -Service, to manage our business, to improve our offerings, develop new features and updates, develop personalization services and other types of service, including but not limited to develop and implement algorithms and machine learning. This processing is on the basis of:
- Our legitimate interest to improve our platform and services.
4.4 We also use your personal data to display to you personalized marketing message on our Platform, to inform you about new features and updates on the Platform. The processing of personal data is performed based on:
- your freely given consent to receive marketing by e-mail and push notifications provided when signing up to the Platform or at a later stage, You may withdraw your consent at any time by contacting us by email at email@example.com.
If you withdraw your consent to receive personalized marketing message on the platform, will we still display marketing message to you on the Platform, but they will be of a generic nature and therefore less relevant to you.
Please be aware that the content on the Platform may contain advertisement, product placement and other marketing material, that is placed within the content as part of the content. This marketing is outside of our control and will not be affected by your withdrawal of your consent to receive marketing by e-mail.
5. Categories of personal data
5.1 We mainly collect the personal data that you submit to us, including your contact information and purchase history. But we also collect information in several ways from different parts of the Platform, as further detailed below, including but not limited to the way you use the Platform and if applied tracking information about your whereabouts on the Internet and technical information about your devices and location.
5.2 Please visit Clause 8 to read more about your right to access and deletion of your personal data.
5.3 When signing up
5.3.1 When registering via our online Platform, you provide us with certain information, including email, password, username, name, country of origin, preferred language. When registering and signing in via third-party application login (such as Facebook), you authorize us to access certain account information from that third-party application, such as basic profile information; name, profile picture, e-mail address (optional), current city (optional). Some of this information will never be made public, such as password. Other information can be either hidden by default (email address, country of origin) or public by default (name and profile picture if third party application sign up). Geolocation will not be disclosed, but you have the possibility to add a geotag when reviewing wines as a public user. You can manage the visibility of this information under Profile Settings.
5.4 Please note that your username will be public at all times.
5.5 When using the Platform
5.5.1 We register the information you provide us with, when using the Platform, including what content you view and read, your content orders, your traffic on the Platform and your communication with us.
5.5.2 The Users are encouraged not to reveal personal data concerning themselves or a third party on the platform, in particular special categories of data (such as information about a person’s health, addictions or allergies) when commenting on the content or making reviews, nor when uploading to the Platform.
22.214.171.124 Should a User make such information about them or others public, the User is responsible for ensuring it has a legal ground for disclosing the information.
6. Transfer of data to third countries including United States and Canada
6.1 As KNiTO is located in Canada all collected data is transferred to the Canada for processing.
6.2 We undertake the transfer to the Canada on the legal basis of fulfilling our contractual obligation towards you. The transfer of your personal data is necessary for us to perform our contractual obligations to you as a User under the Terms of Service and to deliver the services we have agreed with you as a User to provide.
6.3 We and our suppliers have, as required by the General Data Protection Regulation, implemented appropriate technical and organizational measures to keep your personal data safe. Please contact us at firstname.lastname@example.org if you would like to learn more about how we keep your personal data safe.
6.4 If you are not a User, we rely on your consent for transferring your personal information outside the EEA. Please see Clause 10 in respect of your right to withdraw consent.
7. Sharing of data
7.1 Personal data about our Users is an essential part of our business. We only share your personal data as described below apart from when we share it with a third-party vendor (including card processing and payment service providers), from whom you have purchased content.
7.2 We may share personal data regarding you if we are obligated to do so by law, to enforce our terms of service, to protect us against loss or damage. This may include exchanging information with the police, courts or law enforcement organisations.
7.3 If we sell our business or our company assets are acquired by a third party personal data held by us about our users may be one of the transferred assets.
8. Your rights as a user
8.1 As provided by the GDPR, you have the right to:
- Access personal data regarding you.
You can always access your account to review the personal data we have collected about you. You may delete and amend the data collected.
You also have the right to obtain a copy of the personal data free of charge. However, we may charge a fee corresponding to administrative costs if further copies of the information are requested, or if the request is unfounded or excessive.
Ask for rectification of incorrect or inaccurate data concerning you, or to have incomplete personal data completed. You can use your access to your account to update your personal data.
Ask for erasure of personal data regarding you (under certain circumstances).
Ask for the restriction of the processing of your data (under certain circumstances).
Object to the processing of your data for marketing purposes by withdrawing your personal consent.
You can at any time withdraw your consent by deleting your profile .
You have the right of portability of the personal data you have submitted to us. We will deliver your personal data in a structured, commonly used and machine-readable format
When we receive a request to access, rectify, erase or port data, we may ask you for additional information in order to confirm your identity and ensure data security. You can send a request using the KNiTO Support.
9. Data retention and account deletion
9.1 We store your personal data for as long as your account is active.
9.2 We may also store some of your personal data to comply with our legal obligations.
9.3 You may add or update certain information to your account. When you update information, however, we often maintain a copy of the unrevised information in systems back-ups for a period of time until our backup is updated with the latest version.
9.4 You may request deactivation of your account by following the instructions at the Platform. If you deactivate your account, we do not delete your information but hold it for you until such time as you either activate your account again or delete it.
9.5 When you delete your account, we delete the data attached to your account including your username. The username will be deleted from all reviews, and the reviews will be anonymized for future viewing.
9.6 Please note that some information may remain in our records after your account has been deleted, and that we may only be able to delete this information later when updating our backups.
10.1 User accounts including personal data are protected by a password for your privacy and security. You should ensure no unauthorized access to your account and personal data by choosing and protecting your password appropriately, and by signing off when finishing accessing your account. When signing in via third-party application provider your password is solely managed by such third-party.
10.2 We do our best to ensure that user accounts are kept private. However, various instances such as unauthorized entry/use, hardware or software failure, and other factors, may compromise the security of the personal data.
11. Children’s privacy
11.1 The Platform is intended for use by people above the age of sixteen or the legal age for granting consent to an information service provider on the Internet in the jurisdiction in which you reside. If we receive notice or reasonably believe that someone under the appropriate age has provided us with personal information, we will promptly delete the account and all personal information that has been provided to us.
11.2 We may use a registration of age as a tool to try and prevent users under the legal age in the jurisdiction where the user resides to read content not rated for minors.
13. Questions or concerns