Privacy Policy
Introduction
This Privacy Policy elucidates our practices concerning the collection and utilisation of your information, emphasising our commitment to safeguarding your privacy through stringent standards, audits, policy adherence, compliance, and governance.
Definitions
Throughout this Privacy Policy, the terms "using" and "processing" encompass various actions involving information, such as employing cookies, subjecting data to analysis, and handling it in any manner, including collection, storage, evaluation, modification, and disclosure within our organisation. "You" or "your" pertains to individuals engaging with this website or Koko Tales app, its features, services, or interacting with us directly via any medium. This policy pertains to information acquired by Koko Tales (referred to as "Koko Tales," "we," "us," or "our") through your utilisation of the Koko Tales platform, its features, services, and information accessible via the Koko Tales app.
Scope
This Privacy Policy does not govern all data processes by Koko Tales. For enterprise clients, we provide detailed insights into data management, controls, governance, and policies. Additionally, we offer Data Processing Agreements (DPAs) and internal employment policies governing responsibilities and procedures. Regardless of the scenario, transparency regarding customer, employee, and data management remains our paramount concern.
Personal Data
Koko Tales collects information about individuals primarily through the following methods:
- Purchasing a service.
- Registering as a user on the Koko Tales app.
- Visiting this website or contacting us directly.
- Contacting support, either before or after becoming a user.
Data Collected
Customers with a Koko Tales account and those interacting with Koko Tales for customer service purposes are considered end users. We process "End User Data," which includes information about Koko Tales customers' end users, such as their first name, last name, and email address.
Personal Information
Personal information identifies or could be used in conjunction with other data to identify individuals. Examples include name, email address, and billing information.
Non-Personal Information
Non-personal information cannot be used alone or combined with other data to identify or contact individuals. This includes device id (FCM tokens).
Registering
Customers must register an account to access the Koko Tales app fully. Account creation necessitates providing personal and non-personal information. Additionally, personal information may be obtained through email inquiries.
3rd-party Information
Koko Tales collects End User Data essential for providing services. In business operations, Koko Tales utilises the GDPR-compliant platform Firebase for managing authentication and users. Through Firebase authentication, Koko Tales utilises Single Sign-on (SSO) for seamless authentication via Google and other federated providers. Federation involves importing user information, such as email, first and last names, and public avatars, which is then used for connecting payment services like Apple Pay and Google Pay.
In general, we use the information collected to provide you with a great overall experience and for internal operations such as operating and improving the Koko Tales platform, to contact you for customer service and billing purposes. We also use your information to send welcome emails, transcription notification and story sharing alerts, when you are invited to Koko Tales, or when you sign up for a demo. We also use your information to send other email communication related to the Koko Tales app. We always give you the option to unsubscribe in any email we send you.
If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personal information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. We also use the information collected to send announcements and updates regarding changes to our Terms of Service, Privacy Policy or when making pricing changes. You will not be able to unsubscribe from these announcements and updates as they contain important information relevant to your use of the Koko Tales app and our services.
We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Koko Tales services. We may link some of this information to personal information for internal purposes or to improve your experience with the Koko Tales app, in these cases we will obtain your consent.
Use of End User information
We use End User Data to identify you and to provide you with customer service on behalf of a Koko Tales customer. We will disclose End User Data to the relevant Koko Tales customer so that they are better able to assist you.
Outside Contractors and Third-Party Processors
We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to the Koko Tales app, such as hosting, credit card processing and fraud screening, and mailing list hosting. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Koko Tales app or help desk services, including your personal information. We require that these Outside Contractors agree to (1) protect the privacy of your personal information consistent with this Privacy Policy, or the Data Protection Amendment and (2) not use or disclose your personal information for any purpose other than providing us with the products or services for which we contracted or as required by law.
Laws and Legal Rights
We may disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personal information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Koko Tales Terms of Service, to detect fraud, or to protect the safety and/or security of our users, the Koko Tales app, or the general public. Koko Tales is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
We also may be required to disclose an individuals personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU Standard Contractual Clauses, Koko Tales is potentially liable.
Sale of Business
We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Koko Tales or any of its Corporate Affiliates (as defined herein), or that portion of Koko Tales or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganisation or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.
Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Privacy Policy, “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Koko Tales, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.
International transfer of information
Koko Tales is incorporated in United Kingdom. User information is stored in regions related to the user’s location respectively. Information collected via our app, through direct interactions with you, or via our platform and services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and hosting of such information.
Security
We take precautions to protect the security of your information. We employ electronic, and managerial procedures to help safeguard, prevent unauthorised access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standards used to measure our compliance with that duty. Koko Tales maintains ongoing Cyber Security Essentials compliance standards and auditing. Any payment information adheres to stringent industry standards (PCI-1) for storing, processing and transmitting credit card information online.
Collection, disclosure and distribution of information
Except as otherwise described in this Privacy Policy or in the Data Processing Agreements, as applicable, we will only use personal information for the purposes described above or as otherwise disclosed at the time we request such information from you. You may also change your preference and “opt out” of receiving certain marketing communications from us by clicking the unsubscribe link included on the bottom of all such communications, or by contacting us via email ([email protected]).
Updating or correcting information
Customers have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by cancelling your account. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable. If you are an end user and wish to update, delete, or receive any information we have about you, you may do so by contacting the organisation of which you are a customer.
Notifications of changes to this Privacy Policy
We may revise this Privacy Policy from time to time without notice. We encourage you to check this page periodically for any changes. Your continued use of our services and the Koko Tales app following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.
Questions
If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact us via email ([email protected]).
Applicable Law
This Privacy Policy is governed by the laws of Great Britain, without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy except for those individuals who may have rights to make claims under the EU Standard Contractual Clauses.
By using the Koko Tales app or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our app, or use our services. Continued use of the app, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personal information will mean that you accept those changes.