Privacy Notice

This Privacy Notice is intended to inform you how we at KMEW Co., Ltd. use any information we collect about you (which we call "Personal Data” as defined below) in accordance with the Data Protection Directive of the European Union until 24 May 2018 and the General Data Protection Regulation (GDPR) thereafter, and to advise you of your rights and our obligations relating to the processing of your Personal Data.

This Privacy Notice applies to the use of our services, products and websites (collectively, our "Services”) and applies to your use of our Services you access via a computer, mobile phone, tablet, TV or other device.

1. Who are we?

  • KMEW Co., Ltd. ("KMEW,” "we,” "us,” or "our”) is, in the capacity of controller, responsible for processing Personal Data.
  • Please find a list of our branches at:

    KMEW USA Inc.
    15359 NE 90th Street, Redmond, WA 98052

    Savvinskaya naberejnaya 15, 119435 MOSCOW

2. What is Personal Data?

For the purpose of this Privacy Notice, "Personal Data” is defined as any and all information that relates to an identified or identifiable individual (such as you). Examples of Personal Data are your name, address, phone number, photographs, the products purchased by you, and online identifiers (e.g. cookies and IP address), among others. Personal Data also includes information which does not identify you by itself but which we are able to link to you.

3. What are the purposes for processing Personal Data and the legal basis on which we process Personal Data?

We collect information about your use of our Services and your use of online applications. We are not permitted to process your Personal Data without valid legal grounds. Specifically, we process your Personal Data only where:

  • Processing is necessary for the performance of contractual obligations to you or for taking pre-contractual steps upon your request;
  • Processing is necessary for legitimate interests of KMEW or third parties, and examples of "legitimate interests” are:

    » To benefit from cost-efficient Services (e.g. we may opt to use a certain specific platform offered by suppliers);

    » To protect the security of IT systems, architecture and networks; and

    » To fulfil our corporate responsibility and responsibility vis-à-vis society, and to achieve related goals;

  • Your explicit prior consent has been obtained;
  • Processing is necessary for our compliance with laws and regulations; or,
  • Processing is necessary for the protection of your vital interests and the interests of other natural persons.

The purposes of our processing of your Personal Data, and legal basis we rely on therefore, are shown below:

Item Purpose Legal Basis
Create an account/login on websites, applications To enable you to create a profile on our websites and applications and to login to such websites and applications Legitimate interests
Performance of contractual obligations
Provision of our Services To provide specific functionality that you or our Services may require so that we can fulfil our contractual obligations to you (e.g. product warranties) Performance of contractual obligations
Response to inquiries from website users To improve the quality of our Services and products and to conduct marketing activities Legitimate interests
Analytical purpose for service improvements To evaluate and analyze markets, customers, products, and other Services for improvements of existing KMEW products and Services and development of new products and Services Legitimate interests
Creation of statistical information To create anonymous aggregated statistics about the use of our Services. Such anonymized data may be shared with third parties Legitimate interests
Profiling To predict your interests based on which direct marketing is provided to you Legitimate interests
Customer support service To provide customer support service for our Services or to respond to your inquiries and support-related requests (responding to dissatisfied customers, etc.) Legitimate interests
Training For staff training and quality assurance especially in relation to our customer support personnel Legitimate interests
  • To protect our customers (e.g. preventing spam mails and other attempts to defraud users of our Services)
  • To operate and maintain the security for our Services (e.g. preventing or blocking attacks on our systems and networks)
  • To protect our rights or property, including enforcing terms and contracts that govern the use of our Services
Legitimate interests
Performance of contractual obligations
Corporate transactions To manage our corporate transactions such as reorganizations, mergers, transfers, sales, joint ventures, assignments and other dispositions of all or any portion of KMEW’s business, assets or shares including, without limitation, in connection with any bankruptcy or similar proceeding Legitimate interests
Updates To exchange information with you about your account, profile or transactions with us, to deliver important information about your products, applications and other Services, to send notices about important changes to our Privacy Notice and to communicate with you Legitimate interests
Integration of Personal Data To combine pieces of Personal Data KMEW collects for the provision of, for example, better support services and for the delivery of more personalized content, to name a few Legitimate interests
Survey To seek opinions and comments from you on our Services and to conduct other surveys Consent
Dissemination and newsletters To provide customized content, to issue recommendations based on your past activities related to our Services and ads (directly or through our partners such as social media networks) and to provide means of communication such as newsletters, postal mail, phone, e-mail and/or other electronic means of communication Consent
Publication of customer comments and content uploading KMEW may link to or publicly post (including in our advertisements) your product review, comment and content you upload to our websites, applications or community forums or you state in your voluntary survey response. Consent

4. Categories and sources of data that are not directly obtained from you but subject to our processing

Where required for contractual relationships with you and for your activities, we may lawfully collect Personal Data from our networks, other companies (insurance companies and financial institutions, etc. ) and other third parties and, where necessary, from publicly accessible sources (e.g. commercial registry and related documents, resident registry, media organizations, Internet and other media), and we may process the Personal Data we lawfully collect, receive or acquire in accordance with applicable laws. The following categories of Personal Data are of relevance to this:

  • Personal Data (name, date of birth, country of origin, nationality, marital status, vocation/trade and similar data, address, phone number, e-mail address, etc.)

5. How long can we retain your Personal Data?

We will process and store your Personal Data while a business relationship (including any pre-contractual relationship and contract execution) between you and us is in force. We are subject to a variety of storage and documentation obligations that arise out of applicable laws, but unless stipulated otherwise by applicable laws, we will keep your Personal Data as defined in this Privacy Notice for a maximum period of 10 years after the termination of a contractual or pre-contractual relationship.

When we are no longer required to fulfil contractual or legal obligations, we will erase relevant Personal Data periodically, except where further processing is necessary to achieve the purposes of compelling and legitimate interests and the purposes of use outlined in this Privacy Notice. Legitimate interests are deemed to exist in cases where data cannot be erased as a result of the selection of a specific method of data storage and where the cost of erasing is unreasonably high and appropriate technical and organizational measures in place exclude processing for other purposes.

6. To which parties and to which countries do we disclose your Personal Data?

6.1 Third-party recipients of Personal Data

KMEW may disclose your Personal Data to the following companies:

  • KMEW’s affiliates
    We may disclose your Personal Data to our affiliates in order to provide the Services you need or other Services and assistance.
  • Selected partners
    KMEW may share your Personal Data with our business partners including wireless carriers. These partners may use your Personal Data to provide the Services you require (e.g. video content etc.), to predict your interests and to provide promotional, advertising and other materials.
  • Service providers
    KMEW engages third party service providers, which administer certain activities and services on our behalf, including fulfilling and delivering your purchases, processing credit card payments, transmitting postal mail and e-mails, sending text messages (SMS, etc.), providing advertising, analysing Service usage, tracking the effectiveness of marketing campaigns, connecting users to social networks and providing customer support service, among others. We share your Personal Data with such third-party service providers only for the purpose of enabling them to execute the Services on our behalf, and they act only in accordance with our instructions. An example of third-party service providers KMEW engages is listed below:
    • Analytics service provider:We engage an analytics service provider to improve our Services and help us understand usage patterns of our products and other Services. Currently, we engage Google Analytics.
  • Third parties when required by law or to protect our Services
    KMEW will disclose your Personal Data to comply with applicable laws of the EU or an EU member country or to respond to a valid legal process, including from law enforcement and other governmental agencies.
  • Other parties related to KMEW’s corporate transactions
    KMEW may disclose your Personal Data to third parties (or other affiliates of KMEW) as part of the reorganization, merger, transfer, sale, joint venture, assignment and other disposition of all or any portion of KMEW’s business, assets or shares, including, without limitation, in connection with bankruptcy or similar proceedings.

6.2 International transfer of Personal Data

The Personal Data we collect from you may be stored and processed in your region, or transferred to, stored or processed outside the European Economic Area ("EEA”), including but not limited to Japan and Russia or in any other countries which do not have an adequate level of data protection as prescribed by the European Commission, and where KMEW, its affiliates, subsidiaries or service providers maintain facilities.

Should we transfer Personal Data to a non-EEA region, we will ensure that appropriate protection measures, including transfer agreements (EU standard contractual clauses) are in place to ensure an appropriate level of protection will be accorded to your Personal Data. You may request additional information on this and obtain a copy of relevant protection measures from the contact indicated in Section 8 below.

7. What do we do to keep your Personal Data secure?

Appropriate technical and organizational measures are in place for the protection of Personal Data we collect in connection with our Services. The protection measures take the following factors into account:

  • Technological standards;
  • Implementation costs;
  • Nature of the data; and
  • Risks of processing

The objective of these measures is to protect against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access, and other unlawful forms of processing.

Please note that although we take appropriate measures to safeguard your Personal Data, no website, product, online application, data transmission, computer system or wireless connection is completely secure and hence we cannot guarantee the security of your Personal Data.

8. What are your rights as a customer and how can you exercise your rights?

8.1 Your rights

KMEW will collect, store and process your Personal Data in accordance with your rights under applicable data protection laws.

Your rights under the GDPR include the right to access a copy of your Personal Data, the right to request corrections of inaccurate information about yourself or request updates of your Personal Data, and the right to object to the processing of your Personal Data under the conditions set forth by the GDPR.

You also have the right to request the erasure of your Personal Data. Even if you have agreed to the processing of your Personal Data, you have the right to withdraw your consent at any time (note that such withdrawal will not affect the lawfulness of the processing prior to your withdrawal). Furthermore, you have the right to transfer data in certain cases. This is the right to request the return of your Personal Data you have provided to us in a structured, commonly-used, machine-readable format and to request the transfer of such Personal Data to a third party without hindrance from us and subject to your own confidentiality obligations.

8.2 Exercising your rights

If you wish to exercise your rights stated above, please contact us by using any of the methods shown below. You need to submit to us a document that serves as proof of your identify when exercising your right.

We will respond to your complaint within a month of our receipt, except where a longer period is permitted under applicable privacy protection laws.

8.3 Complaints

If you are not satisfied with the way we process your Personal Data, you may file a complaint with the competent data protection authority in addition to exercising your rights explained above.

9. Third-party links and products on our Services

Our websites, applications and products may contain links to other third-party websites that are not operated by us, and our websites may contain applications that you can download from third parties. Since such linked sites and applications are not under our control, we are not responsible for the privacy practices or content of such sites and applications. If you opt to use a third-party website or application, any Personal Data collected by the third-party website or application will be subject to the privacy protection policy of that third party. We strongly recommend that you carefully review and understand the privacy protection policy of any third party to which you provide your Personal Data.

10. Cookies

  • What are cookies?

    We, like other third parties providing content, advertising or other functionality on our Services, may use cookies and other technologies in certain areas of our Services. Cookies are small text files put on your device when it accesses our websites. The text files can be read by a web server which puts the cookie on your hard drive. We may use cookies to store preferences and settings, to assist your signing in, to deliver targeted ads, and to analyze your browsing experiences on our sites.

    Please note that you may change your browser setting so that you will be notified when cookies are sent out to it. If you do not wish to receive cookies, you may refuse all cookies by activating the relevant setting on your browser. However, please be warned that if you choose to refuse all cookies, some features of our Services may become inaccessible by your browser or may not work properly. Finally, you may also delete the cookies that have already been sent.

  • Details about cookies

    Please read our cookie policy for more information about cookies, how we and third parties use them and how to disable cookies.

11. Children’s Personal Data

  • Who is a "child”?
    Anyone under the age of 16, or under such age as may be specified by applicable data protection laws, is considered by us as a child.
  • Do we collect Personal Data of children?
    We do not knowingly collect or attempt to collect Personal Data from a child or about a child without obtaining the consent of his or her guardian or statutory agent. If we collect Personal Data from a child, we will use reasonable efforts to verify that the consent or approval of the guardian or statutory agent has been obtained.
  • Our responses upon the receipt of Personal Data about children
    If we become aware that the Personal Data provided to us relates to a child without the consent of his or her guardian or statutory agent in respect thereto, we will make reasonable efforts to:
    • Delete that Personal Data as soon as possible; and,
    • Ensure that that Personal Data is not used for any purpose or disclosed to third parties if we cannot delete the Personal Data.
  • Inquiries from guardians or statutory agents
    If you are the guardian or statutory agent wishing to inquire about our practice of processing Personal Data about children, please contact the party given in Section 8 below.

12. Changes to the Privacy Notice

We reserve the right to change this Privacy Notice from time to time. The "Date last updated” at the bottom of this page indicates the date of the most recent update, and changes will become effective upon our posting of the revised Privacy Notice.

Where required by applicable laws, we will seek your consent in respect of changes. We will give this notice by e-mail or by posting notice of changes on our websites or through relevant Services.

Last updated on: [October] 2018

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