Kai initiative Group Ltd
Effective: April, 23, 2020
At Kai initiative Group Ltd, our mission is to unite together for sustainable socioeconomic development by creating and sharing opportunities, technology, knowledge, investment, capital and resources between developed countries and developing/underdeveloped countries. Together we can serve the people and planet through Venture Development, entrepreneurship, innovation and social and environmental action.
Who We Are
We are Kai initiative Group Ltd, trading referred to herein as “KAii” “we,” “us,” or “our”). We provide Internet, mobile app-based services and venture development.
Information About Your Personal Data
“Personal Data” is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, phone number, precise location, device IDs, certain cookie and network identifiers, and “Purchase and Preference Data.”
How We Collect and Use Personal Data
We collect your Personal Data in a number of ways and for various purposes, including:
We may collect your Personal Data when you engage with our online communities. This includes when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields, blogs, message boards, events, and other community forums sponsored by or affiliated with Evocco. Please note that our community forums are public, so we recommend that you exercise care in deciding what information and content you wish to disclose.
We may allow you to register and pay for third-party products and services or otherwise interact with another website, mobile application, or Internet location (collectively “Third Party Sites”) through our Services, and we may collect Personal Data that you share with Third Party Sites through our Services. When we do so, we will inform you of the further details of how we use your Personal Data.
We may obtain certain data about you from third party sources to help us provide and improve the Services and for marketing and advertising. We may combine your Personal Data with data we obtain from our Services, other users, or third parties to enhance your experience and improve the Services, such as providing you with a single point of sign on for our Services and/or building an account dashboard letting you understand how to access and control all the Services you use from a single page.
We may collect certain Personal Data using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising.
For certain KAii partner stores and outlets, we may use video cameras and WiFi sensors and cameras for in-store analytics. Specifically, these technologies are used to determine the number of unique visitors, in-store traffic patterns, and shelf interest. Video image data is not permanently stored. Although we may use a third party vendor to perform these services, in-store image and WiFi data are not shared with any other third parties for their own purposes and are not used to personally identify you except for fraud and loss prevention and to prevent or investigate instances of suspected wrongdoing or potential criminal activity as permitted by law.
We aggregate and centralize Personal Data and Purchase and Preference Data for purposes of analytics, innovation, and to provide enhanced services to our customers and end-users.
Some of our services consist of social sharing and communication with others. We use your Personal Data to enable sharing as described in the service, including to enable you to find and link to friends on other KAii platforms.
We use Purchase and Preference data you provide to us to assess the climate impact of your food purchases. We use this data to provide instructional videos and instructional feedback. With your permission, we access your contacts and calendar to enable you to share content or achievements, including videos, with friends or other members, and to invite friends to use the Services.
Where you have provided consent to process your precise Location Data, we may use such data to provide you with Services, offers or advertising that are relevant to your location.
How We Disclose Personal Data
With companies or ventures that are owned or controlled by KAii, and internally within Evocco, in order to provide and improve Services, for marketing purposes, and for advertising.
With business partners, marketing partners, and vendors to provide, improve, and personalize the Services.
With social network providers when we use social network widgets, buttons, or plug-ins in our Services.
With other users in the context of specific Services that are social in nature. In these cases, we disclose social data and certain Purchase and Preference Data by default because the service being provided is one of social interaction. Additionally, any information you post or disclose in our community forums (for example, Facebook, WeChat, YouTube, Twitter, or other sponsored pages on the KAii Blog) is public.
With advertising and marketing partners for advertising and marketing purposes on KAii’s behalf and on behalf of third parties, including Facebook, Baidu, and WeChat.
In addition, with your consent, we may share your precise Location Data with Third Parties for on and off platform personalization and curated marketing and advertising purposes.
With certain companies for purposes of analytics and improvement of the Services.
With companies involved in interest-based advertising, including web, mobile app and other advertising. This advertising consists of KAii and third party ads that are personalized and displayed on our sites and apps and through other channels.
With prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
To perform our contractual obligations to you, including account registration, fulfilling orders or purchases you have made (including processing of payment), contacting you in relation to any issues with your order, in relation to the provision of the Services, including when you use or interact with a wearable or other connected device and in relation to location-based Services (including to provide you geographically relevant Services), to connect you with friends across platforms, when you take fitness tests or assessments, share content or achievements, or invite friends, when you ask us to customize apparel, products, or Services, where we need to provide your Personal Data to companies or ventures that are owned or controlled by KAii and to our service providers, where we need to collect Personal Data from third party sources and when you access third party products and services, where we collect data from third parties or publicly-available sources, or to aggregate and centralize data for the performance of the Services
To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.
To operate our business and provide the Services, other than in performing our contractual obligations to you for Evocco’s “legitimate interests” for the purposes of applicable law – except where overridden by the interests or fundamental rights and freedoms that require protection of Personal Data.
Communication. To communicate with you regarding the Services, including to provide you important notices regarding changes to our Terms and also to address your requests, inquiries, and complaints. We may send strictly necessary communications, including emails, even if you have opted out of receiving other KAii emails or communications. These types of communications do not require consent. We also process your Personal Data for our legitimate interests when you communicate with us, including when you sign up for promotional materials and we have not asked you for your consent in that regard.
To respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.
We process your non-sensitive Personal Data to provide you with promotional messages and personalized marketing, including: when you communicate with us or sign up for promotional materials; when you participate in special activities, offers, or programs; when you engage with our online communities or advertising; to provide you geographically relevant Services, offers, or advertising; when we aggregate and centralize data; and when we share Personal Data with companies or ventures that are owned or controlled by KAii and with our service providers and vendors.
To send you surveys in connection with our Services, unless commercial in nature. In those cases, a survey request may be sent to you if you have given us your consent to receive marketing from us.
To assist in the investigation of suspected illegal or wrongful activity, including in-store tracking and sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and defend our rights and property, or the rights or safety of third parties.
To develop, provide, enhance, and improve our Services and your experience, including to enable you to use the full range of our Services (e.g., processing of non-sensitive Personal Data related to your use or interaction with a wearable or other connected device; in-store tracking; when you access third party products and services; when we collect, use, or otherwise leverage cookies, device IDs, Location Data, data from the environment, and other tracking technologies; when you connect with us through social media; when we collect data from third parties or publicly-available sources; when we aggregate and centralize data; and when we share Personal Data with companies or ventures that are owned or controlled by KAii and with our service providers and vendors). For internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
To support a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.
Consent as a Basis for Processing
In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Personal Data through our Services or a form (including enrolling in Promotions); or (ii) registering or creating an account with us. Due to different countries’ laws governing consent for the collection and use of Personal Data, the requirements for consent will differ across regions. We may request your consent for a number of activities including:
We may ask for your consent to contact you by telephone, SMS/text message, WeChat, and/or email about other offers, products, Promotions, events, or services that we think may be of interest to you and for other marketing purposes.
We may also ask for your consent to share your Personal Data with certain Third Party business partners in order to offer certain goods, services, or programs. To withdraw consent, please go to the preferences of the specific third party service or app.
We may ask for your consent to provide Personal Data to allow third parties to contact you regarding their products, services, Promotions, or offers. Typically this is in conjunction with a sweepstakes or challenge (your consent for third party marketing is generally not a pre-requisite to participation. To withdraw consent, please go to the preferences of the specific third party
When you use our mobile apps we may ask for your consent to collect these (this consent may be captured at the operating system level). To change your consent status for this data please go to the preferences of the specific service or app. If you choose not to provide this information, certain Services features may be unavailable or not function properly.
We may request your consent to process sensitive Personal Data. Certain Websites or Mobile Apps may require this data to provide the Services, including when you use or interact with a wearable or other connected device, and when you take fitness tests or assessments. If you choose not to provide sensitive Personal Data (for example, specific kinds of Purchase and Preference Data), certain features or Services may be unavailable or not function properly.
We may request your consent to collect your precise Location Data. Our Services may require this data to provide the Services. If you choose not to provide this information, certain Services features may be unavailable or not function properly. Location Data may be used to display your live location and movement and may also recognize when you have entered a partner KAii store to provide you with tailored information, advertising about products and services.
In addition, we may request your consent to share your precise Location Data with Third Parties for on and off platform personalization and curated marketing and advertising purposes.
We may request your consent to use your Personal Data for Research purposes. We may also request your consent to contact you to determine your interest to participate in certain Research initiatives and to share identifying results. For market research, we may ask questions on behalf of business partners and share your response with business partners.
We transfer data to the Republic of Ireland and to other countries for processing. We may request your consent for this transfer or the transfer, in other cases, may be justified by a legal basis other than consent.
We may use some automated processing to provide our Services and to make recommendations in the context of specific services. This processing is strictly necessary for providing certain Services (and, in some cases, is the service itself) and is not covered by consent. Other automated processing is not significant either due to the nature of the data or the decisions being made or recommended, and so consent is not required. However, for automated processing that is significant and related to sensitive Personal Data, prior to sharing or using such data, we will first seek your consent.
For the subset of automated processing included in ad profiling for ad targeting, you can change your consent status (for website services) by turning advertising cookies off as outlined in in our Cookie and Device ID Use section. For mobile apps, you can change your consent status by activating your Limit Ad Tracking or equivalent setting as described in our Cookie and Device ID Use section.
Some of our services consist of social sharing and communication with others. If you sign up for these services, we may ask for your consent to use your information to enable sharing as described in the service.
We may also ask for your consent when you connect with us through Social Media.
We may ask you for permission to use your Personal Data and Purchase and Preference Data for special offers, events, sweepstakes, and other Promotions. We may use the Personal Data we collect during Promotions, to administer the Promotion, verify identity and age, and to communicate with you about the Promotion.
Social Sharing Settings
Within our Services there are two sharing settings: Private, Share with Friends. You are able to control what Personal Data you share and with whom you share it. We encourage you to adjust the sharing settings to best meet your objectives and sharing comfort level. In the interest of safeguarding your Personal Data, we have outlined some initial default sharing settings.
We disclose various types of information for purposes of interest-based advertising, including for third party, interest-based advertising. This processing includes the use of Personal Data to create de-identified audience segments. These audience segments are then made available for interest-based advertising, including for third party advertising, on KAii online properties. The audience segments are based on website visits, app usage data, Purchase and Preference Data, online and offline purchasing behaviours, interaction with our ads or marketing emails, similar types of information, and in some cases, data from third parties. The segments, prior to being used, are de-identified so that they will not identify you personally.
For all of the interest-based advertising described above, including segments, you have the choice to not have your data used to target and serve you interest-based advertising-including third party advertising-regardless of where such ads might be served. These opt-outs require that strictly necessary cookies are not blocked by the settings in your web browser. We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance in the US, the Canadian Digital Advertising Alliance in Canada, and the European Digital Advertising Alliance in the EU. If you live in the United States, Canada, or the European Union, you can visit Ad Choices(US), Your Ad Choices (Canada), or Your Online Choices (EU) to find a convenient place to opt-out of interest-based advertising with participating entities for each region. These websites also provide detailed information about how interest-based advertising works. Opting out does not mean that you will no longer receive advertising from us, or when you use the Internet. It just means that the data collected from our website will not be used for interest-based advertising and that the advertising you see displayed on websites will not be customized to your interests.
Managing Preferences and Withdrawing Consent
You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection, interest-based advertising, your communication settings, and app preferences. Depending on the Service, collection and use of Personal Data may be required for the Services to work.
We provide you several ways to manage your preferences:
Cookies serve a wide variety of purposes. Cookies are pieces of data stored in your web browser that are transmitted to websites to remember your browser over time and distinguish it from other users. Cookies are used to remember your shopping cart and personalize your web experience and for security, analytics, marketing, and interest-based advertising. Our cookies are placed and read by our web servers, while other cookies are placed and read by other companies’ web servers. Information on specific cookies is found on our website via the AdChoices link. You can block and control cookies using the information noted in this section. If you block all cookies, certain functionality on our website will not work.
[ IN ] Required Cookies. These strictly necessary cookies are used for core functionality, and recognize when you are signed in, remember things such as shopping carts and text entered, are necessary for security, and enforce your privacy preferences. Without these cookies, some functionality on our websites will fail. You can block these cookies in your browser preferences.
[ IN / OUT ] Functional Cookies. These cookies help to improve the sites by allowing us to understand how the site is used and how the site performs. These cookies include analytics and measurement.
[ IN / OUT ] Advertising Cookies. These cookies help us and other parties personalize ads that are shown to you on our sites and Services, as well as on other sites. If enabled, these cookies will allow third parties engaged in interest-based advertising on our site to recognize your browser software on other sites too.
IP Address Use
You can choose not to have IP address used for purposes of advertising or analytics by using the cookie controls for “Advertising Cookies,” and “Performance/Analytics,” above.
Pixels are extremely small image files that, when loaded by your web browser, cause the browser to make a network request to the party corresponding to the pixel. If that party’s cookies are currently stored in your browser, those cookies will be transmitted with the request. Beacons can be used on web pages for advertising or to confirm the opening of a marketing email. When used in conjunction with cookies for interest-based-advertising, the cookie controls above can be used to control the purpose for which they are used.
HTML5 Local Storage in the browser is different from cookies, but can be used for the same purpose (to pair a tracking ID to a particular web server with your web browser so that the web server can identify your web browser over time). You can control the purpose for which HTML5 Local Storage is used by using the cookie controls outlined above.
Flash cookies are “local shared objects” used by Flash player to store data, similar to cookies. Although Flash content is declining in use, we may still use Flash on our sites. If you have Flash installed, and wish to delete, block, or manage Flash cookies, please use the Flash settings panel made available by Adobe.
Social Network Interaction and Widgets
Social network widgets, buttons, and plug-ins on our websites passively transmit data regarding a social network’s members to that social network, even when a button is not clicked. These technologies may allow a social network (such as Facebook, Twitter or YouTube) to personally identify its members and to know the web pages its members have visited. This is true wherever social network buttons are embedded, regardless of whether a button is “clicked” or “pressed.” If you belong to a social network or use these categories of web services, you should review the privacy policies of those services to understand the nature of the data that they collect and what, if any, options the service offers to control how data is collected and used. If you disable advertising cookies, the passive tracking associated with these buttons will be blocked on our sites.
Our mobile apps and our Services may transmit Device IDs, Location Data, and data from sensors to us and our partners, including our advertising partners.
Device IDs include IDs associated with your mobile device carrier such as IMEI, MEID, IMSI; platform-specific IDs such as Android ID, Google AID, and Apple’s IDFA; and IDs that are part of your device hardware, such as WiFi MAC address, and serial number. Exactly which Device IDs are transmitted can depend on your mobile device platform and the version of your operating system.
Location Data. Our apps and Services transmit precise Location Data. Location Data may be obtained from GPS services, cell tower triangulation, or known location of nearby WiFi access points.
Sensor and In-Range Device Data. Our apps and Services may also collect Device IDs and network addresses (including IP addresses, MAC addresses, and SSIDs) from other, in-range or networked devices and WiFi Access Points. Our apps and Services may also collect information about altitude, air pressure, change in position.
How We Use Mobile Device Data. We may use Device IDs, coarse location and Location Data, and data from sensors, including the local network, (together with app usage data and Purchase and Preference Data) for strictly necessary purposes; improving our apps and analytics; personalization and preferences; and cross-app, cross-device, interest-based advertising.
Withdraw Your Consent for Use of Your Mobile Device IDs and Location Data for Analytics and Advertising
Activating the “Limit Ad Tracking,” “Opt out of Ads Personalization,” or equivalent setting from your mobile device will transmit a signal to us and any third parties that we use (the signal will apply to all of our mobile apps running on that device). When that signal is received by KAii or third parties, it communicates your choice to not have device IDs or Location Data used for purposes of advertising or analytics. We honor the signal and require that our third party advertising and analytics partners do the same.
To the extent our mobile apps personalize functionality for you, you can change these settings within the app, or reset to defaults by deleting and reinstalling the app.
You can also turn off the transmission of precise Location Data by turning off those services using your mobile device’s built-in settings. Turning off location may cause some of our Services not to work.
Consent for Email Communication: After signing up for email communications, you can choose to unsubscribe using the unsubscribe link in any commercial email we send. If you use more than one Service, then unsubscribing from the emails relating to that Service will not stop you from receiving emails from other Services. Please note that if you unsubscribe from “all emails” this means “all emails other than strictly necessary emails.” You will still receive email communications from us if they are strictly necessary to provide the KAii service or to confirm or validate a transaction, recover accounts, etc.
Mobile Push Notifications: You can manage the type of push notifications you receive from KAii by modifying the settings within the KAii Service. You may also set your mobile device settings to not allow push notifications from us.
Transfers of Your Personal Data to Other Countries
The Personal Data KAii processes, and all associated Services and systems, including registration, is housed on servers in the Republic of Ireland. If you are located outside of the Republic of Ireland, please be aware that Personal Data we collect will be processed and stored in the Republic of Ireland (the data protection and privacy laws in the Republic of Ireland may offer a lower level of protections than in your country/region).
We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Where permissible, we will also delete your Personal Data upon your request. Information on how to make a deletion request can be requested at .
If you have questions about our data retention practices, please contact us at firstname.lastname@example.org .
We do not knowingly collect Personal Data online from children under 13 (note that the minimum age may vary based on country/region, and on local law). If you become aware that a child has provided us with Personal Data without parental consent, please contact us at email@example.com. If we become aware that a child under 13 has provided us with Personal Data without parental consent, we will take steps to remove the data and cancel the child’s account.
How to Contact Us
If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us through firstname.lastname@example.org .