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      PRIVACY POLICY

       

      Epoch, LLC DBA Kin Custom (“Kin Custom”) respects the privacy of our users and the importance of the information they entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to help you understand how we collect, store, process, transfer, share ad use data that identifies or is associated with you (“personal information”) and information regarding our use of cookies and similar technologies.

       

      This Policy applies to the Kin Custom Platform as defined in the Terms of Use. Prior to accessing or using the Kin Custom Platform please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as set forth in this Policy. Kin Custom is the data controller of the personal information held about you.

       

      THIS PRIVACY POLICY WAS LAST UPDATED ON: MAY 22, 2018.

       

      1.  INFORMATION WE MAY COLLECT

       

      We collect personal information about you in the following ways:

       

             • Information you voluntarily give us

             • Information that you may provide through the Services or otherwise communicate with use includes:

             • Your name, email address, telephone number and physical address when you register for an account.

             • Profile information, such as your username and password, display picture, interests, preferences and profile descriptions.

             • Content you post on the Kin Custom Platform such as text, images, Products (as defined in the Terms of Use), messages, comments or any other kind of content that you place in or on the Kin Custom

      Platform.

             • Feedback and correspondence, such as information you provide n your responses to surveys, report a problem on the Kin Custom Platform, receive customer support or otherwise correspond with us.

       

      If you choose to purchase or list for purchase items using the Kin Custom Site or using the Kin Custom Services, we or our third-party payment processors will collect your payment and/or payout information. Usage information, such as information about how you use the Kin Custom Platform.

       

      Additionally, we may also collect information from (i) our business partners and (ii) other third parties as we further describe in this Policy. We may combine the personal information that we receive from different sources. Please note that if you do not provide us personal information your use and enjoyment of the Kin Custom Platform may be hindered.

       

      2. INFORMATION WE MAY GET FROM OTHERS

       

      We do not purchase any data about you from other individuals or organizations. We may, however, combine publicly available information about you, such as information related to your personal interests and skill sets, with the personal information that you provide us through the Kin Custom Platform.

       

      3. INFORMATION AUTOMATICALLY COLLECTED

       

      Our server may automatically collect information about how you access and use the Kin Custom Platform as well as information regarding the device you use to access the Kin Custom Platform. Additionally, we may log information regarding your browser type, browser language, the URL of the last web page you visited before coming to our Site, pages you viewed, your preferences and settings (e.g., time zone), the ads you clicked on or viewed on our Site (if any), how long you stayed on the Kin Custom Platform and what services and features you used.

       

      4. ANONYMIZATION & AGGREGATION OF INFORMATION

       

      We may anonymize and aggregate any of the personal information we collect, including information about individuals that are your subscribers, website visitors or customers such that it does not directly identify you or them. We may use such information to test our IT systems, to conduct research, to analyze data, improve the Kin Custom Platform and develop new products or features. We may also share such anonymized information with other parties.

      We do not knowingly collect personal information from children under the age of 13. Should we ever do so, we will comply with the Children’s Online Privacy Protection Act.

       

      5. CHANGES TO PERSONAL INFORMATION

       

      It is important that all information that we collect and hold about you is current and accurate. If you believe that the information we have collected about you is inaccurate or there has been a change in your information during your relationship with us please update your profile accordingly, as per the provisions set forth in the Terms of Use or email us at info@kincustom.com

       

      6. INFORMATION COLLECTED BY COOKIES & OTHER TRACKING TECHNOLOGIES

       

      We may collect information using various technologies, including “cookies” and “pixel tags” (or otherwise referred to as web beacons or pixels). Cookies are small data files stored on your hard drive or in your device memory that assist us in improving the Kin Custom Platform along with your experience with us. Further, cookies will track a user’s usage of the Kin Custom Platform. Pixel tags are electronic images that may be used in the Kin Custom Platform or through email outreach to you, and track the usage of the Kin Custom Platform along with the effectiveness of our communication.

       

      7. PURPOSE BEHIND OUR USE OF COOKIES

       

      Authentication of User

       

             • The use of cookies allow us to recognize if you are logged into the Kin Custom Platform. Additionally, we are able to tailor the experience with the Kin Custom Platform to your interests. We may also employ third-party services that may use cookies to help you sign into their services from our Platform (i.e. Shopify, Wordpress, etc.).

       

      Security

       

             • The use of cookies assists us in detecting malicious activity and violations of our Terms of Use.

       

      Analytics and Research

       

             • The use of cookies assists us in analyzing how the Kin Custom Platform is being accessed and used by users. It further enables us to track the performance of the Kin Custom Platform in order to continue its improvement. We use third party analytics tools, such as Google Analytics, to collect and analyze certain user information and behavior as well as to assist with analyzing the performance of the Kin Custom Platform. These tools ma use cookies and store information on your device, such as time of visit, pages visited, time spent on each page of the Kin Custom Platform, links clicked and conversion information, IP address, browser, mobile network information and the type of operating system used to access and use the Kin Custom Platform.

       

      8. THIRD PARTY ADVERTISING

       

      We may work with advertisers to place ads before you which may be relevant to you based on the information collected about you. Such third party advertisers may use a cookie or other technologies, which may be placed by Kin Custom or by such third party on the Kin Custom Platform, or on a third party website or service. Placement of these technologies on your device may enable you to be identified across multiple websites or online service providers. We do not share information that identifies you with any advertiser.

       

      9. OPT OUT OF COOKIES

       

      The cookies we use are designed to provide you with the best experience when using the Kin Custom Platform. If you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that by refusing cookies you risk losing the ability to experience the Kin Custom Platform in its entirety as some functional components of the Kin Custom Platform rely on the use of such cookies.

       

      10. THIRD PARTY DATA COLLECTION

       

      As stated above, we may work with advertisers to serve you targeted advertisements based on your browsing history and other information we collect about you. We permit third party advertisers, social media companies and other third party services to collect information about your use of the Kin Custom Platform so that they may provide you with relevant ads on other websites, applications or services you may use or access as well as to provide advertising-related services such as reporting, analytics and market research.

       

      You may be permitted to opt-out of some of this advertising. To understand how you may be able to opt-out you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices.

       

      11. LINKS TO THIRD PARTY SITES

       

      The Kin Custom Platform may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we do not accept any responsibility or lability for their policies. Prior to submitting any information on these sites, please review the site’s privacy policy.

       

      How We May Use Information We Collect

       

      Information Collected When You Use or Access the Kin Custom Platform

       

             • Basic Information: Such as your full name, telephone number, email address and physical address.

             • How we use it: Communicate with you. Such communications may include marketing communications, alerts regarding your profile, sending notifications pertaining to payment owed or payout to you, and to provide you with news regarding updates to the Kin Custom Platform. To address your complaints, comments and questions regarding your use and access to the Kin Custom Platform please contact info@kincustom.com.

       

      Authentication and verification of user purposes.

       

             • Create and maintain customer accounts and User Marketplace’s and provide you with the features and functionalities available on and through the Kin Custom Platform.

       

      Legal Basis

       

             • Processing your basic information is necessary for our legitimate interests, namely in providing you with access to and use of the Kin Custom Platform as well as any and all services provided by and through the Kin Custom Platform to you. Additionally, it is necessary for our legitimate interest for marketing and communication purposes.

       

      Payment Information

       

             • Such as your credit card information, bank account information, account information, billing address and other information relevant to the payment or payout methods you provide us.

             • How we use it: We use your payment information in order to facilitate payment transactions for your use of the Kin Custom Platform, as well as to facilitate payout transactions to you for the sale of any items you sell through your User Marketplace (as defined in the Terms of Use).

       

      Additionally, we use this payment and payout information to prevent fraudulent behavior from occurring on, by or through your user account.

       

      Legal Basis

       

             • The processing of your payment and payout methods are necessary for the performance of our contract with you as set out in the Terms of Use to ensure proper payment is made to, when you sell items through your User Marketplace and from you when you purchase items either from another user’s User Marketplace or us. Additionally, processing is necessary for our legitimate interests in detecting and preventing fraudulent activity from occurring on the Kin Custom Platform and, more specifically, on, by or through your user account.

             • Contact, Correspondence and Commentary: When you contact us directly via email, telephone, mail, comments on our social media profiles, tag us in comments on other social media profiles, blogs or complete an online form or survey, we will record your comments and opinions.  

             • How we use it: We use and process this information to ensure that we can communicate with you in regard to your comments, concerns, questions and issues with regard to the Kin Custom Platform, along with your use of and access to it. Additionally, using and processing this information will allow us to tailor our marketing efforts to provide you with information regarding products and services we offer which may be of interest to you. Lastly, this information will assist us in communicating with you regarding updates, alerts and news relating to the Kin Custom Platform.

             • Legal Basis: The processing of this information is necessary for our legitimate interest in communicating with users and for marketing purposes.  

       

      12. INFORMATION SHARED WITH OTHERS

       

      Service Providers/Vendors: We will at times use third party vendors and service providers for the purposes of mailing or email services, tax, accounting and legal services, payment processing, fraud prevention, web hosting or analytics. Rest assured your information is never transferred to any of these third party vendors or service providers for the purpose of re-marketing to you.  

       

      Purchasers of Your Product: Your information may be shared with another user of the Kin Custom Platform when such user purchases a Product from your User Marketplace. This is done in order to ensure that communication between you and the purchasing user and the completion of the transaction for your Product is possible.

       

      Law Enforcement, Regulators and Other Parties for Legal Purposes: At times we may be required by law to share your information in order to comply with the law and the reasonable requests of law enforcement; enforce our Terms of Use; protect the security and integrity of the Kin Custom Platform; and/or exercise or protect the rights, property or personal safety of Kin Custom, our customers and others.  

       

      13. INFORMATION COLLECTED AUTOMATICALLY

       

      Info about how you access and use the Kin Custom Platform: This means the means in which you arrive to the Kin Custom Platform (i.e. which website did you come from prior to coming to the Kin Custom Platform), which websites you navigate to after you leave the Kin Custom Platform, the frequency of which you use and access the Kin Custom Platform, how long you use and access the Kin Custom Platform, whether you open, interact or respond to emails sent by us, whether you click any links provided in any email sent to you by us, whether you use multiple devices to access the Kin Custom Platform, and any other actions you may take when accessing the Kin Custom Platform.

       

             • How we use it: We use this information to present and provide to you access and use of the Kin Custom Platform, its services, products and other items on any/all device(s) you are using. Additionally, we will use this information to provide you with relative information, news, alerts and other communications relating to the Kin Custom Platform for marketing purposes. Lastly, we use this information to improve the Kin Custom Platform and any other platforms, services or products we may deploy in the future.

             • Legal Basis: The processing of this information is necessary for our legitimate interest, namely in order to improve the Kin Custom Platform and any and all other services and products we offer by and through the Kin Custom Platform. Additionally, it is necessary for our legitimate interest in order to monitor and resolve issues pertaining to user’s access and use of the Kin Custom Platform. Lastly, it is necessary for our legitimate interest for marketing purposes and to communicate effectively with users.

             • Information about your device: We also collect information relating to the type of device you are using to access the Kin Custom Platform. For example, we will collect information regarding the mobile device or smartphone, tablet, desktop, laptop or other electronic device that is used to access the Kin Custom Platform. Information obtained by us may include the type of device you are using, the browser you are using, operating systems on the device, your internet service provider or mobile network and your IP address.

             • How we use it: We use this information to provide you access to the Kin Custom Platform on the device you are using; provide you with the features and functionality available to you through the Kin Custom Platform for the device you are using; and to monitor and improve the Kin Custom Platform together with its services and products, and to assist us in developing new products and services in the future.

             • Legal Basis: The processing of this information is necessary for our legitimate interest, namely to provide the Kin Custom Platform to the user in a functional manner so as to permit the user to use the Kin Custom Platform for the purposes for which they intend. Additionally, this information is necessary for our legitimate interest in monitoring and resolving any issues regarding the Kin Custom Platform, to communicate with users, and to detect and prevent fraudulent activity on the Kin Custom Platform.

       

      14. INFORMATION SHARED WITH OTHERS

       

      Service Providers/Vendors: We will at times use third party vendors and service providers for the purposes of mailing or email services, tax, accounting and legal services, payment processing, fraud prevention, web hosting or analytics. Rest assured your information is never transferred to any of these third party vendors or service providers for the purpose of re-marketing to you.  

       

      Purchasers of Your Product: Your information may be shared with another user of the Kin Custom Platform when such user purchases a Product from your User Marketplace. This is done in order to ensure that communication between you and the purchasing user and the completion of the transaction for your Product is possible.

       

      Law Enforcement, Regulators and Other Parties for Legal Purposes: At times we may be required by law to share your information in order to comply with the law and the reasonable requests of law enforcement; enforce our Terms of Use; protect the security and integrity of the Kin Custom Platform; and/or exercise or protect the rights, property or personal safety of Kin Custom, our customers and others.  

       

      15. TRANSFER INFORMATION TO THE US & OTHER COUNTRIES

       

      Your information collected by us may be transferred and stored in countries outside of the jurisdiction you are located to where we and our third party service providers are located and have operations. If you are located within the European Union or the European Economic Area (EEA), you are hereby notified that your information may be processed inside or outside of the European Union and EEA including the United States. The transfer of your information is necessary for our capabilities to fulfill our duties and obligations as set out in our Terms of Use and in order to provide you with access to and use of the Kin Custom Platform, its services and products.

       

      16. SECURITY INFORMATION COLLECTED

       

      We take the safety, security and confidentiality of your information very seriously. We employ appropriate technical, electronic, administrative and organizational measures to protect your information against accidental or unlawful destruction, loss, alteration, damage, misuse, or unauthorized disclosure or access. All information we collect will be stored on secured servers. Additionally, all transactions entered into on the Kin Custom Platform will be protected by SSL encryption technology.

       

      As set out in our Terms of Use, you are responsible for maintaining your account’s security, including but not limited to your username and passwords.

       

      17. DATA RETENTION PERIOD

       

      We do not hold any data, whether voluntarily or automatically collected by us for any longer than is necessary for us to carry out and fulfill the purposes of collecting such information as set out in this Policy and in accordance with our legal obligations and legitimate interests.

       

      18. YOUR RIGHTS TO YOUR DATA

       

      This section applies exclusively to those users who are located within the European Union or the United Kingdom. In accordance with General Data Protection Regulation (GDPR) you are hereby  notified of the following rights you have in respect to your information that we hold:

       

             • Right of Access and Portability: You have the right to obtain access to and receive your information held and processed by us.

             • Right to Rectification: You have the right to obtain rectification of your information without undue delay when the information we have about you is inaccurate or incomplete.

             • Right to Erasure: You have the right to have your information removed or erased without undue delay under certain circumstances, such as when the information we have about you is no longer necessary in relation to the purposes for which it was collected and processed.

             • Right to Restriction: You have the right to restrict our processing of your information in certain circumstances, such as where you contest the accuracy of the information we have about you for a period of time that provides us the opportunity to verify the accuracy or lack thereof of your information.

             • Right to Object: You have the right to object, on grounds specific to your particular situation, to the processing of your information, as well as the right to object to the processing of your information for direct marketing purposes, to the extent it is related to such direct marketing.

       

      If you wish to exercise one of these rights, please contact us using the contact details provided at the end of the Policy.

       

      19. MISCELLANEOUS

       

      Scope of Policy

       

             • This Policy applies only to the Kin Custom Platform.

       

      Changes to Policy

       

             • We may change, modify, add or remove portions of this Policy and any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise.

       

      Notice to You

       

             • In the event we need to contact you, whether that be for legal, marketing or other purposes, we will select the best method to get in touch. Your receipt of such notices in any form we deem appropriate does not prevent you from opting out of particular communications as set out and explained in this Policy.

       

      How to Contact Us

       

      If you have any questions about this Policy, or our information practices, please contact us by email or postal mail below: EPOCH HOLDING GROUP 4341 Equity Dr. Columbus, OH 43228. If you feel that we are not abiding by this Privacy Policy, you should contact us immediately via email at info@kincustom.com.