Mkononi and its affiliates (Mkononi, “Organization”, “we”, “our” or “us”) are committed to
the privacy of our customers, website visitors, and users of our applications, products, and
services.
This privacy policy (“Privacy Policy”) discloses what information is gathered about users of our
website, applications, products and services, and successors thereof (collectively the
“Service(s)”),
however accessed, and how that information is used.
We have designed this Privacy Policy to identify how we collect, use, store and share your
Personal Information.
This Privacy Policy is provided in conjunction with our Terms of Use, found at https://mkononi.org/terms (the “Terms”), which governs
your access and use of the Services. By accepting the
Terms, you consent to our collection, storage, use and disclosure of your information as
described
in this Privacy Policy.
Privacy Policy
1. Scope of Privacy Policy
We obtain and process Personal Information in different capacities. When we collect or process Personal Information for our own purposes, meaning that we determine how and what Personal Information is processed, we are the data controller. This Privacy Policy applies to our collection, use, disclosure, and protection of Personal Information where we are the data controller.
2. What is Personal Information?
For purposes of this Privacy Policy, “Personal Information” means information that alone or in combination identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
3. Categories of Personal Information We Collect
We collect certain categories of Personal Information. The information we collect and process about you depends on how you use and interact with our Services. For example, the information collected will differ based on the content you choose to provide to our Services. A summary of the categories and a description of the types of data collected in each category are as follows:
Category
Identifiers
A real name, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers.
Customer Records
Name, telephone number, or email address and other similar information.
Biometric Information
Voice.
Internet Activity
Information on your interaction with our Services.
Geolocation Data
Imprecise location information, like the city, and area associated with your IP address or device.
Identifiers
A real name, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers.
Customer Records
Name, telephone number, or email address and other similar information.
Biometric Information
Voice.
Internet Activity
Information on your interaction with our Services.
Geolocation Data
Imprecise location information, like the city and area associated with your IP address or device.
4. Sources of Personal Information And The Purposes For Which We Collect And Use It
Mkononi obtains the categories of Personal Information listed above from the following categories
of sources:
- Directly from you. For example, from forms you complete, information you provide, or the content you submit. We ask that you refrain from providing Personal Information when interacting with our Services, unless otherwise necessary for support purposes.
- Indirectly from you. For example, from observing your actions on our Services or from information your computer or mobile device transmits when interacting with our Services.
- From third-party data sources. For example, if you have agreed to share
information with one of our third-party providers they may provide us with that
information.
The information we collect, use and disclose about you will vary depending on how you interact with Mkononi and the Services. Described below is a summary describing the purpose for which we collect this Personal Information from you.
Purpose for Collection and Use
Examples
Category of Data
Business Purposes
- To deliver, provide, monitor, and maintain the Services
- To provide customer service, such as troubleshooting problems with the Services
- To inform our business strategies
- To improve and develop the Services
- To perform analytics on the use of the Services and conduct research and development, such as administering surveys and understanding the demographics and user preferences of users of the Services
- Identifiers
- Customer Records
- Internet Activity
- Biometric Information
- Geolocation Data
Communication Purposes
- To respond to your requests or inquiries
- To send you updates
- To provide information about the Services
- Identifiers
- Customer Records
- Geolocation Data
Compliance and Legal Purposes
- To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, Mkononi, or third parties
- To prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and Services
- Identifiers
- Customer Records
- Geolocation Data
- Internet Activity
- Biometric Information
Business Purposes
- To deliver, provide, monitor, and maintain the Services
- To provide customer service, such as troubleshooting problems with the Services
- To inform our business strategies
- To improve and develop the Services
- To perform analytics on the use of the Services and conduct research and development, such as administering surveys and understanding the demographics and user preferences of users of the Services
- Identifiers
- Customer Records
- Internet Activity
- Biometric Information
- Geolocation Data
Communication Purposes
- To respond to your requests or inquiries
- To send you updates
- To provide information about the Services
- Identifiers
- Customer Records
- Geolocation Data
Compliance and Legal Purposes
- To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, Mkononi, or third parties
- To prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and Services
- Identifiers
- Customer Records
- Geolocation Data
- Internet Activity
- Biometric Information
5. Information We Collect From Third Party Sources
We receive information from our trusted partners, such as security partners to protect against fraud, abuse, and other security threats to our Services, or analytic partners, who provide us with information about our business and the Services to improve and develop the Services. We may also collect information from other sources, like information that is publicly available on the internet.
6. How Long Do We Keep Your Information
We retain Personal Information only as long as we have a legitimate business purpose to do so.
These purposes may include retaining Personal Information in order to:
- complete the purpose for which the Personal Information was collected;
- continue our ongoing business relationship with you; and
- resolve disputes, protect rights, maintain safety and security, and comply with legal,
regulatory, tax, accounting or reporting requirements.
This means, for example, that some data will be deleted or anonymized automatically after a set period of time.
IF YOU ARE AN UNREGISTERED USER OF OUR SERVICES ACCESSING SUCH SERVICES SOLELY VIA OUR WEBSITE, WE WILL NOT USE YOUR USER DATA, INCLUDING PERSONAL INFORMATION, TO TRAIN OUR LANGUAGE LEARNING MODELS WITHOUT YOUR CONSENT AND WE WILL AUTOMATICALLY DELETE YOUR USER DATA, INCLUDING PERSONAL INFORMATION, WITHIN THIRTY (30) DAYS UNLESS WE HAVE A LEGITIMATE BUSINESS PURPOSE TO RETAIN SUCH DATA.
7. Who We Share Your Information With
As further detailed herein, we may share your Personal Information when required by law, or with third parties that perform functions on our behalf or for whom we perform services. We may also share information to protect the interests of individuals or in connection with a sale of our business or a merger or acquisition. The information we collect, use and disclose about you will vary depending on how you interact with Mkononi and Services. Described below is a summary of who we may share your Personal Information with.
With Whom We Disclose Personal Information
Purpose for Disclosing
Category of Information
Employees and Professional Advisors
Business Purposes: delivering, monitoring, and maintaining the Services; providing
customer service; improving and developing the Services, including content,
functionality and customization of how Services are presented to you and other users;
performing analytics; conducting research and development; and if necessary, receiving
advice from our professional advisors, such as our attorneys, accountants, in their
capacity as advisors to us.
Communication Purposes: communicating with you, including to send you information
about our Services.
Compliance and Legal Purposes: complying with legal obligations and to protect
the rights, privacy, safety, or property of our users, Mkononi, or third parties;
preventing fraud, illegal activity, or misuses of our Services, and to protect the
security of our systems and Services; and if necessary, receiving advice from our
professional advisors, such as our attorneys, accountants, in their capacity as advisors
to us.
- Identifiers
- Customer Records
- Internet Activity
- Biometric Information
- Geolocation Data
Service Providers
Business Purposes: delivering, monitoring, and maintaining the Services, including
hosting the Services; providing customer service; improving and developing the Services;
performing analytics; and conducting research and development.
Compliance and Legal Purposes: complying with legal obligations and to protect
the rights, privacy, safety, or property of our users, Mkononi, or third parties;
preventing fraud, illegal activity, or misuses of our Services, and to protect the
security of our systems and Services.
- Identifiers
- Internet Activity
- Customer Records
- Biometric Information
- Geolocation Data
Government and Law Enforcement
Compliance and Legal Purposes: cooperating with law enforcement and other governmental agencies and disclosing Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, including to prevent fraud, illegal activity, or misuses of our Services; (ii) if we are advised to disclose Personal Information by our legal counsel; (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Mkononi or any other person or entity; or (iv) . We may also disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Identifiers
- Internet Activity
- Customer Records
- Biometric Information
- Geolocation Data
New Owners or Successors in Interest
Business Purposes: in the event of a change in ownership or control of our business, we may disclose your Personal Information in connection with a contemplated or completed strategic business transaction such as a merger, acquisition, sale of all or substantially all of our assets or stock to a subsequent owner or operator, a dissolution, bankruptcy, liquidation or other similar business transaction where Personal Information may be shared, sold or transferred to that third party, including during the due diligence process.
- Identifiers
- Internet Activity
- Customer Records
- Biometric Information
- Geolocation Data
Business Affiliates
Business Purposes: to facilitate business continuity and provision of the Services amongst the corporate structure.
- Identifiers
- Internet Activity
- Customer Records
- Biometric Information
- Geolocation Data
Employees and Professional Advisors
Business Purposes: delivering, monitoring, and maintaining the Services;
providing customer service; improving and developing the Services, including
content, functionality and customization of how Services are presented to you and
other users; performing analytics; conducting research and development; and if
necessary, receiving advice from our professional advisors, such as our attorneys,
accountants, in their capacity as advisors to us.
Communication Purposes: communicating with you, including to send you
information about our Services.
Compliance and Legal Purposes: complying with legal obligations and to
protect the rights, privacy, safety, or property of our users, Mkononi, or third
parties; preventing fraud, illegal activity, or misuses of our Services, and to
protect the security of our systems and Services; and if necessary, receiving advice
from our professional advisors, such as our attorneys, accountants, in their
capacity as advisors to us.
- Identifiers
- Customer Records
- Internet Activity
- Biometric Information
- Geolocation Data
Service Providers
Business Purposes: delivering, monitoring, and maintaining the Services,
including hosting the Services; providing customer service; improving and developing
the Services; performing analytics; and conducting research and development.
Compliance and Legal Purposes: complying with legal obligations and to
protect the rights, privacy, safety, or property of our users, Mkononi, or third
parties; preventing fraud, illegal activity, or misuses of our Services, and to
protect the security of our systems and Services.
- Identifiers
- Internet Activity
- Customer Records
- Biometric Information
- Geolocation Data
Government and Law Enforcement
Compliance and Legal Purposes: cooperating with law enforcement and other governmental agencies and disclosing Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, including to prevent fraud, illegal activity, or misuses of our Services; (ii) if we are advised to disclose Personal Information by our legal counsel; (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Mkononi or any other person or entity; or (iv) . We may also disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Identifiers
- Internet Activity
- Customer Records
- Biometric Information
- Geolocation Data
New Owners or Successors in Interest
Business Purposes: in the event of a change in ownership or control of our business, we may disclose your Personal Information in connection with a contemplated or completed strategic business transaction such as a merger, acquisition, sale of all or substantially all of our assets or stock to a subsequent owner or operator, a dissolution, bankruptcy, liquidation or other similar business transaction where Personal Information may be shared, sold or transferred to that third party, including during the due diligence process.
- Identifiers
- Internet Activity
- Customer Records
- Biometric Information
- Geolocation Data
Business Affiliates
Business Purposes: to facilitate business continuity and provision of the Services amongst the corporate structure.
- Identifiers
- Internet Activity
- Customer Records
- Biometric Information
- Geolocation Data
8. Site Analytics, Cookies And Other Tracking Technologies
We may use cookies, beacons, tags, pixels, SDKs, session replay and other tracking technologies
on our Services (“Cookies”) to operate the Services, to gather analytical data about use of the
Services, and to further your use and enjoyment of the Services. Information collected may
include Personal Information, including IP addresses, digital identifiers, information about
your web browsing and app usage and how you interact with our Services for a variety of
purposes, such as personalization, analytics about how you engage with the Services, supporting
the operation, maintenance, and improvement of our Services, and other legitimate business
purposes.
Further information about Cookies, including how to see what cookies have been set on your
computer or mobile device and how to manage and delete them, visit http://www.allaboutcookies.org.
Google Analytics
We use “Google Analytics” to collect information about use of the Services across
devices to support operation, maintenance, and improvement of our Services. You can learn about
Google's practices by going to https://www.google.com/policies/privacy/partners/.
You can opt out of Google Analytics without affecting how you visit the Services. For more
information on opting out of being tracked by Google Analytics, visit this Google page.
Statements regarding our practices do not apply to the methods for collecting information used
by these third parties or the use of the information that such third parties collect. We do
however work with third parties to make efforts to have you provided with information on their
practices and any available opportunity to exercise choice. We make no representations regarding
the policies or practices of third parties.
9. Your Consumer Privacy Choices
- Updating your Personal Information. If your Personal Information changes, or if you no longer desire our Services, you may request to correct, update, amend, or delete/remove it by emailing us at support@mkononi.org. We will respond to your request within a reasonable timeframe.
- Disabling Cookies. Most browsers automatically accept Cookies. You can disable this function by changing your browser settings but disabling Cookies may impact your use and enjoyment of the Services. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Services. You can manually delete persistent Cookies, or Cookies that track your activity across websites, through your browser settings.
- Opt-Out of Email Marketing. If for any reason you would no longer like to receive email marketing messages from us, you may Unsubscribe by following the instructions contained within our promotional emails. Please allow up to ten (10) days for us to process your request. Please note, if you opt not to receive marketing emails from us, you may still receive “transactional” email messages regarding your use of the Services. To opt-out of receiving our direct mail, you may send us an email at support@mkononi.org
- Do Not Track. Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have the user’s online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about that browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, the Services may not respond to DNT signals.
10. Leaving Our Website And/Or Linking To Third Parties
When you leave our Services and go to another linked website, we are not responsible for the content or availability of the linked website. Please be advised that we do not represent either the third party or you, if you enter into a transaction on the third-party site. Further, the privacy and security policies of the linked site may differ from ours. We do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
11. Information Security
We take the security of your Personal Information seriously. We use reasonable technical, administrative, and physical safeguards to maintain the security and privacy of Personal Information we collect and use. When disclosing Personal Information, you should remain mindful that there is always risk in sending Personal Information using the internet.
12. De-Identified/Aggregated Data
We may aggregate or de-identify Personal Information we collect through our Services and when operating our business so that it no longer identifies you. For example, we may aggregate Personal Information to calculate the percentage of users in a particular location. Once information or data has been de-identified and/or aggregated, such information is no longer Personal Information. This means we may share it with third parties and may use this de-identified / aggregated data for our legitimate business purposes, such as for the purposes described above, to analyze the way our Services are being used, to improve and add features to them, and to conduct research. We will maintain and use de-identified information in de-identified form and not attempt to reidentify the information, unless required by law.
13. International Users
Our Services are operated in the United States and intended for users located in the United States. Like almost every website, our website can be accessed by an international audience. If you are located outside of the United States, please be aware that information we collect, including personal information, will be transferred to, processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. In addition, such data may be stored on servers located outside your resident jurisdiction and in jurisdictions which may have less stringent privacy practices than your own.
14. Children's Privacy
We do not direct or target our Services to children under the age of 13. If we learn that we have collected the Personal Information of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Information to us, please contact us at support@mkononi.org. We will make reasonable efforts to remove such information from our databases.
15. Notification of Changes
We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. If we make any material changes, we will notify you by email (to the extent we have your email) or by means of a notice on the top of this Policy or the top of the website or within the Services.
16. Contact Information
If you have any questions about the Privacy Policy or how we process Personal Information, please contact us at: info@mkononi.org.
We will periodically review and update this Privacy Policy and reserve the right to change or update it.