Last Updated: 12/15/2024
 
1. Introduction

This “Privacy Policy” governs your use of the Kina Rewards Inc (“Kina” or “Company” or “we” or “us”) websites and all features, tools, content, downloads, and other services (“Services”) that we make available through those websites (collectively, referred to herein as the “Platform”).

If we notify you of a different privacy policy for a different service, this Privacy Policy will not apply. This Privacy Policy also does not apply to information collected by us offline or collected by any third party, including through any application or content (including advertising) that may link to or be accessible from our websites. By using our Platform you consent to our Privacy Policy and our collection, use, and sharing of your information and data, and other activities, as described below. If you disagree to be bound by those terms, you are not authorized to access or use the Platform, and you must promptly exit the Platform. If we make any changes to our Privacy Policy, we will post the revised Privacy Policy and update the "Last updated" date of the Privacy Policy.

Our Platform and Services are not intended for children under the age of 18.  If you are under the age of 18, please do not access our Platform. If we learn that we have inadvertently collected personal information from someone under the age of 13, we will promptly delete that information. If you believe we have collected personal information from someone under the age of 13, please contact us using the contact information at the end of this privacy policy.

1.2 Information covered by this Privacy Policy.  For purposes of this Privacy Policy, our use of the term “information” means any and all information we receive from or about you.  Information is divided into two distinct categories: 

• “Non-Personal Information” means Information that does not personally identify a person. 
• “Personal Information” means information related to a natural person that can be used to directly or indirectly identify the person, such as names, addresses, e-mail addresses, and phone numbers, as well as other non-public information that is associated with the foregoing.

• to administer the Site, manage accounts and provide the Services; 
• to monitor, analyze, improve and develop content, advertising and the Site and Services, and to create new features of the Services; 
• to provide a more customized experience on the Site, Services and/or our partners’ or affiliates’ websites; 
• to verify identity and determine appropriate services; 
• to understand our users better; 
• to validate user information provided to us for fraud and risk detection purposes; 
• to determine eligibility for the Services; 
• for internal purposes such as auditing, data analysis, and research; 
• to prevent, identify and address fraudulent or other illegal activity and security issues; 
• to (i) solicit feedback, (ii) respond to your comments, requests or inquiries, (iii) provide customer service and support, or (iv) otherwise contact you in connection with the Site or Services; 
• to generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports; 
• for our marketing purposes, such as (i) informing you of our or our partners’ or affiliates’ products, services, features or offerings that may be of interest to you, (ii) providing you with newsletters, articles, reports, updates and announcements, as well as information about upcoming events, (iii) contacting Referred Leads and suggesting Contacts for you to refer to Kina, (iv) improving and tailoring our advertising and communications, (v) analyzing our marketing efforts, and (vi) determining your eligibility for certain marketing programs, events and offers. If you prefer to be removed from our mailing list, you can opt-out at any time by updating your preferences in your account or contacting us at hello@kinarewards.com; 
• to operate our business, which includes, without limitation, using your information (i) to process payments, (ii) to send important notices, such as communications regarding the Site and Services, and changes to our terms and policies; (iii) to manage and enforce contracts with you or with third parties, (iv) to manage our corporate governance, compliance and auditing practices, and (v) for recruitment purposes, if you submit an application for employment with Kinavia the Site; 
• to administer any sweepstakes, contests, or similar promotions you may enter; 
• in the case of non-personal information (which includes, without limitation, zip code, area code, unique device identifier, referrer URL, location, and the time zone), we may collect, use, transfer, and disclose non-personal information for any purpose; 
• to (i) comply with laws, rules and regulations, including any disclosure or reporting obligations, (ii) resolve disputes with users or third parties, (iii) respond to claims and legal process (including but not limited to subpoenas and court orders) as we deem necessary or appropriate, (iv) protect our property rights or those of third parties, (v) protect the safety of the public or any person, and (vi) prevent or stop any activity which we may consider to be (or to pose a risk of being) illegal, unethical or legally actionable; and 
• for any other purpose for which you expressly authorize us to use your information. 

• government agencies and taxing authorities, as required to provide the Services, including but not limited to the Internal Revenue Service and state and local tax agencies; 
• banking and financial institutions; 
• certain parties as necessary to respond in good faith to legal process (including but not limited to subpoenas and court orders); 
• legal and financial advisors and auditors; 
• third-party agents, partners and service providers, who (i) are only permitted to use your information as we allow (which may include contacting you on our behalf), and (ii) are required under law or contract to keep your personal information confidential; and 
• the following third parties under the circumstances described below: 
• we may share business information with credit bureaus, and we may share information with certain companies, banks and organizations for the purposes of fraud prevention and determining eligibility for the Services; 
• if you participate in our referral programs and/or share your Contacts with us and invite them to join Kina, the referral emails sent to your Contacts and Referred Leads will include your name and the fact that you are a Kinauser; 
• if there is a sale of all or a portion of the Kina business (including, without limitation, a merger, stock acquisition, sale of assets or reorganization), or in the event that Kina liquidates or dissolves, we may sell, transfer or otherwise share some or all of our assets, which could include your information, to the acquirer; 
• from time to time, we may share reports with the public that contain anonymized, aggregate, de-identified information and statistics; 
• we may share your information with certain other third parties with whom you expressly authorize us to share your information; and 
• we may disclose information about you if we determine that for purposes of national security, law enforcement or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.