Privacy Policy

Keys 2 Empower & Grow (the “Company”) respects your privacy. This Agreement sets forth the privacy policy for the mobile application, website, and all subdomains (collectively, the “Site”), owned and operated by the Company. By using the Site, you consent to the collection and use of information in accordance with this Policy.

Collection of Information

We may collect and process the following information about you:

• Information you provide. This may include identifying information, such as your name, address, email address, and telephone number. If you transact business with us, you may provide financial information. You may also provide us with photos, a personal description, and information about you and your preferences.
• Location information via your mobile device.
• If you contact us with a customer service or other inquiry, you provide us with the content of that communication.
• Information (such as your name, email and postal address, telephone number, sex, and country of residence) that you provide by completing forms, including if you register as a user of the Site, subscribe to our newsletter or make a purchase or inquiry.
• Your login and password details are in connection with the account sign-in process.
• Details of any requests or transactions made by you through the Site.
• Communications you send to us, for example, to report a problem or to submit queries, concerns, or comments regarding the Site or its content.
• Information that you post in the form of comments or contributions to discussions.
• Information is collected automatically from your browser or device when you use our Site. This information could include your IP address, device ID and type, your browser type and language, the operating system used by your device, access times, your mobile device’s geographic location while our application is actively running, and the referring website address.
• Cookies and Use of Cookie Data. When you visit our Site, we may assign your device one or more cookies to facilitate access to our Site and to personalize your experience. Through the use of a cookie, we also may automatically collect information about your activity on our Site, such as the pages you visit, the time and date of your visits, and the links you click. We (or third parties authorized by us) may use certain data collected on our Site to show you advertisements on other sites or applications. You can learn more about cookies by visiting www.allaboutcookies.org. By blocking or deleting cookies, you may not be able to take advantage of all aspects of the Site.
• Pixel tags. The Company may embed pixel tags (also called web beacons or clear GIFs) on web pages, ads, and emails. Pixel tags help to measure the popularity of the Company’s features and services.
• Mobile Device IDs: If you’re using our app, we use mobile device IDs (the unique identifier assigned to a device by the manufacturer), or Advertising IDs, instead of cookies, to recognize you. Unlike cookies, device IDs cannot be deleted, but Advertising IDs can be reset in “Settings” on an iPhone. Ad companies also use device IDs or Advertising IDs to track your use of the Site, track the number of ads displayed, measure ad performance, and display ads that are more relevant to you. Analytics companies use device IDs to track information about app usage.
• Information collected by third parties for advertising purposes. We may allow service providers, advertising companies and ad networks, and other third parties to display advertisements on our Site. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements. We do not provide any personal information to third parties that is not anonymized. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org). Opting out will not decrease the number of advertisements you see.

Uses of Your Personal Information

We will use the personal information you provide to:

• identify you when you sign in to your account;
• enable us to provide you with the services;
• send you information we think you may find useful or that you have requested from us;
• administer your account with us;
• enable us to contact you regarding any question you pose through the Site;
• analyze the use of the Site and the people visiting to improve our content and Site;
• communicate with you by email, postal mail, telephone, and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
• develop, display, and track content and advertising tailored to your interests on our Site and other sites, including providing our advertisements to you when you visit other sites; and
• use for other purposes that we may disclose to you when we request your information.

Sharing of Your Personal Information

• Personal information. We do not share your personal information with others except as indicated in this Privacy Policy or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with third parties that perform certain services on behalf of the Company. These services may include providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, member screenings, supporting our Site functionality, and supporting contests, sweepstakes, surveys, and other features that may be offered through our Site. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
• Legal Disclosures. We may disclose your information, including personal information in response to a subpoena or similar demand, a court order, or a request for cooperation from a law enforcement or other government agency, to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. We may also disclose your information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing, to protect and defend the rights, property, or safety of our company, our users, our employees, or others, to comply with applicable law or cooperate with law enforcement and/or to enforce our policies. If we sell the Company, merge with another company, or file for bankruptcy, we may also disclose your information.
• Aggregated and/or non-personal information. We may use and share non-personal information we collect under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising on our Site and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in non-human readable form, with third parties, including advisors, advertisers, and investors, to conduct general business analysis or other business purposes. To opt out of cookies that may be set by third-party data or advertising partners, please go to http://www.aboutads.info/choices.
• On request, we will give you a copy of all the personal information about you that we hold. This information is subject to a fee not exceeding the prescribed fee permitted by law.

Closing Your Account

If you close your account, the Company will retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our policies, take actions we deem necessary to protect the integrity of our Site or our users or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

Protection of Your Information

Although we take your security seriously and take measures to protect your information from unauthorized access, no system can be completely secure. Therefore, we do not promise, and you should not expect, that your personal information, chats, or other communications will always remain secure. You should always exercise caution with the disclosure and sharing of your personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

Third-Party Services

If you click on an advertisement or link within the Service, you do so with the understanding that third-party advertising sites or other links of any kind are not operated under our control and that we are not responsible for any information collected by third parties. It is recommended that you review the terms of service and privacy policy for any sites you are visiting.

Children’s Privacy

We recognize the need to provide further privacy protections with respect to the personal information we may collect from children on our sites and applications. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:

• Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information.
• In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children.
• Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and
• Giving parents access or the ability to request access to the personal information we have collected from their children and the ability to request that the personal information be changed or deleted.

For additional information about our practices regarding children’s personal information please read our Children’s Privacy Policy.

Foreign Use

If you are visiting our Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where our servers and our central database are operated. By using our services, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the website.

Changes to this Privacy Policy

We will occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy. We recommend that you check our Site from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

Email

We want to communicate with you only if you want to hear from us. We try to keep emails to a minimum and give you the ability to opt-out when we can. We will send you emails relating to your personal transactions, and we may send you service-related announcements on occasion. This section is regarding e-mail directly from the Company – we will not disclose your email to other users or third parties.

Children’s Privacy Policy

Keys 2 Empower & Grow (the “Company” or “we”) is committed to protecting the privacy of children who use our sites and applications. This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices in the United States regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.

Information We Collect From Children, How We Use It, and How and When We Communicate with Parents

Registration

Children can register with our site to view and engage with the learning modules. During the registration, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name and gender, the child’s member or account and username, and password. We may also ask for birth dates from children to validate their ages. We strongly advise children never to provide any personal information in their usernames.

Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. We will not use parent emails provided for parental purposes to market to the parent unless the parent has expressly opted into email marketing or has separately participated in an activity that allows for such email contact.

Persistent Identifiers

When children interact with us, certain information may automatically be collected, both to make our sites and applications more interesting and useful to children and for various purposes related to our business. Examples include the type of computer operating system, the child’s IP address or mobile identifier, the web browser, the frequency with which the child visits various parts of our sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers. This information may be collected by the Company or by a third party.

This data is principally used for internal purposes only in order to provide children with access to features and activities on our sites and applications, customize content and improve our sites and applications, or conduct research and analysis to address the performance of our sites and applications. In the event we collect (or allow others to collect) such information from children on our sites for other purposes, we will notify parents and obtain consent before such collection.

When Information Collected From Children is Available to Others

We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us. We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take protections against liability.

Parental Choices and Controls

At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of the account.

Contact Information

If you have any questions about this Privacy Policy, please contact us by email or postal mail as follows:

Global Tendo La Upendo, Inc.
8700 Stonebrook Pkwy #231
Frisco, Texas 75034
info@keys2empower.org