Privacy Policy
Through this privacy policy, data subjects are informed about the various processing operations carried out by BIENBONITA, LLC through this website and app, under the kiinos brand, from the United States of America that affect their personal data in accordance with the provisions of: a. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR); b. California Consumer Privacy Act (CCPA); c. Florida Privacy Protection Act (FIPA); d. HB 969; Delaware Digital Privacy Protection Act (DOPPA); e. and in the respective implementing national data protection regulations applicable depending on where the kiinos Service is used.
Personal Data is defined as any reference to data, personal information or simply information, including information by which a person can be identified.
IDENTIFICATION AND CONTACT DETAILS OF THE DATA CONTROLLER
COMPANY NAME: BIENBONITA, LLC.,
TAX ADDRESS: 1401 Brickell Avenue Ste. 330 Miami Florida 33131 USA
DUNS NUMBER: 118966914.
CONTACT: info@kiinos.com
DATA PROTECTION DIRECTOR: The KIINOS Data Protection Officer (DPO) in the United States of America: DPD-USA@kiinos.com .
DATA PROTECTION DELEGATE IN THE EUROPEAN UNION: Seven Degrees Global Partners S.L. DPD-UE@kiinos.com
Kiinos is a subscription service offered by BIENBONITA, LLC. This privacy policy applies to all products and services offered by the TREATMENT CONTROLLER through this website.
PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA
WEBSITE VISITORS
Your data will be processed on our website for the purposes indicated below:
Attention to requests, comments and incidents.
Understand the behavior of the surfer within the web to detect possible computer attacks.
Comply with our legal obligations.
Protect and exercise our rights.
Respond to claims of any kind.
Where appropriate, request for links or e-mails that lead the user to Kiinos pages.
Where appropriate, sending commercial communications relating to the services that make up our business.
Sending news or newsletters related to our activity.
USERS OF OUR SERVICES (KIINOS ACCOUNT CREATOR)
We will process your personal data to:
Collect information about your use and interaction with our services.
When the user subscribes to receive our services, collection of contact data.
When the user registers by creating an account on www.kiinos.com, collection of contact details (username, password and email address).
Collect information from Recipients when they respond to surveys, requests or questionnaires through BIENBONITA, LLC. technology.
When the user makes a payment to BIENBONITA LLC, to the payment method you choose from the options available on the website. We consider the billing address to be the location of the account holder.
The provision of the services you have contracted with us.
Respond to requests, complaints and incidents.
Attention to requests, comments and incidents.
Understand the behavior of the surfer within the web to detect possible computer attacks.
Comply with our legal obligations.
To protect and exercise our rights.
Respond to claims of any kind.
Where appropriate, sending commercial communications relating to goods or services that make up our business.
Sending news or newsletters related to our activity.
TARGET
In the event that you access a digital link to the Kiinos application, either by clicking on a hyperlink or reading a QR code, generated with the Kiinos Service; and respond to a survey, form, questionnaire or any other form of communication, within the Kiinos Application, technology of BIENBONITA LLC, your data may be processed for the purposes indicated below:
Management of the service offered to our customers.
Collect information from surveys, forms, questionnaires, forms or other types of communication, for the purpose of managing, measuring or tabulating the responses. *
Attention to requests, comments and incidents.
Comply with our legal obligations.
Protect and exercise our rights.
Respond to claims of any kind.
Where appropriate, sending commercial communications relating to goods or services that make up our business.
Sending news or newsletters related to our activity.
* This treatment is of an exceptional nature. The information obtained from the surveys is controlled and managed by the user of the Kiinos service (the Creator), who prepares, sends and implements the survey. BIENBONITA, LLC only processes these responses on behalf of the Creator. In this case, the Kiinos system is limited to analyzing the data and tabulating the responses by generating survey reports, forms, questionnaires, or other types of communication. This task is performed by automated processes that generate statistical information.
INFORMATION FROM THIRD PARTIES
We may obtain personal information from third parties, both to manage the service we provide to our customers and to ensure that the service is accessible and efficiently managed.
LEGAL BASIS FOR PROCESSING
VISITORS TO THE WEBSITE
Consent of the user (Refusal implies the impossibility of treatment).
Fulfillment of the legal obligations applicable to us (the data subject may not refuse the processing of personal data in this case).
Legitimate interest to protect our image, business and track record by preventing attacks on our website (the data subject may not refuse the processing of personal data in this case, although he/she may exercise the rights recognized in this policy).
USERS OF OUR SERVICES
Consent of the user (Refusal implies the impossibility of treatment).
Execution of a contract to which it is a party or application of pre-contractual measures (refusal implies the impossibility of processing).
Fulfillment of the legal obligations applicable to us (the data subject may not refuse the processing of personal data in this case).
Legitimate interest to protect our image, business and track record by preventing attacks on our website (the data subject may not refuse the processing of personal data in this case, although he/she may exercise the rights recognized in this policy).
TARGET
Fulfillment of the legal obligations applicable to us (the data subject may not refuse the processing of personal data in this case).
Legitimate interest to manage the service offered, as well as to protect our image, business and track record by preventing attacks on our website (the data subject may not refuse the processing of personal data in this case, although he/she may exercise those recognized in this policy).
TIME LIMITS OR CRITERIA FOR DATA RETENTION
The rule is that as long as your account is active, we will not delete personal data; it will be retained for as long as necessary or, where appropriate, as required by law, to fulfill the purposes for which it was originally collected.
We will delete your personal data and the rest of your Content, at the end of your Subscription, in accordance with our data retention policy.
We will delete the Responses received in your Kiinos Service account, after 30 days from the expiration of the last Package Plan contracted.
Review your account data retention practices.
AUTOMATED DECISIONS AND PROFILING
BIENBONITA, LLC does not make automated decisions or create profiles.
TARGET AUDIENCE
For the duration of the processing of your personal data, BIENBONITA, LLC may disclose your data to the competent public authorities or bodies, where the controller is under a legal obligation to provide the personal data.
INTERNATIONAL TRANSFERS OF DATA
All data will be processed in the United States of America;
We ensure that the data repository provides the appropriate level of protection; standard to all our agreements with customers and use standard contractual clauses for the transfer of data as approved by the European Commission. These clauses can be accessed at the following link:
https://eur-lex.europa.eu/legal-content/ES/TXT/PDF/?uri=CELEX:32021D0914&qid=1623249029503&from=ES
RIGHTS
You, as a data subject, may exercise your rights of access, rectification and deletion, as well as request that the processing of your personal data be restricted, object to the processing, request the portability of your personal data (where technically possible) or withdraw the consent given, and if applicable, where appropriate, not to be subject to a decision based solely on automated processing, including profiling. These rights may be exercised at any time and free of charge.
To do so, please send your request to info@kiinos.com. In case of doubts about your identity, we will ask you for a photocopy of your identity document.
In any case, you may file a complaint with the competent Data Protection Supervisory Authority.
In case you have given your consent to receive commercial information about our services, and if at any time you do not wish to receive more information about them, you can unsubscribe in the same application of Kiinos Service or by sending an email to the address info@kiinos.com indicating that you want to unsubscribe from receiving such information.
VERACITY OF THE DATA
The interested party guarantees that the data provided are true, accurate, complete and up to date; undertaking to inform of any change with respect to the data provided, through the channels provided for this purpose and indicated in point one of this policy. You will be responsible for any damage or harm, both direct and indirect, that may be caused as a result of non-compliance with this obligation.
In the event that the User provides data of third parties, declares that it has the consent of the parties concerned and undertakes to transfer the information contained in this clause, exempting Bienbonita, LLC from any liability for failure to comply with this obligation.
SOCIAL NETWORKS
Social Networks are part of the daily life of many Internet users, and for them the Entity has created different profiles in some of them.
All visitors to our website have the opportunity to join our social networks or groups.
However, you should keep in mind that, unless we request your data directly (for example, through marketing actions, contests, promotions, or any other valid way), your data will belong to the corresponding Social Network, so we recommend that you carefully read their terms of use and privacy policies, as well as, be sure to configure your preferences regarding the processing of data.
MINORS
The services of this site are intended for persons over 18 years of age. The RESPONSIBLE does not collect personal data from minors and does not allow them to register. Minors under 18 years of age are not authorized to send us their personal data, in case they contravene our indication, we may delete them without prior notice.
MODIFICATIONS/UPDATE
This privacy policy may be modified/updated according to the legal requirements established or with the purpose of adapting this policy to the instructions issued by the entities in charge of data protection in the countries where this application is used, or because we make changes to our website.
For this reason, we encourage users to periodically review our privacy policy.
If you have any questions about this policy, you can contact us at the following e-mail address info@kiinos.com.
SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA
This Notice describes the rights of California residents under the California Consumer Privacy Act (CCPA) of 2018. While we have established the categories below as required by the CCPA.
This Notice consists of the following sections:
Your rights under the CCPA
Categories of personal information we collect and sources
Categories of third parties with whom we share personal information
Categories of personal information we use for business or marketing purposes
Your choices for advertising cookies
1. Your rights under the CCPA
Subject to certain restrictions, California residents have the right to request that we tell them what personal information we collect about them, to have any personal information we collect or maintain about them deleted, and to opt out of any sale of personal information about them. As a California resident, you also have the right to designate a representative to exercise these rights on your behalf. This section describes how you may exercise these rights, including the methods we use to verify your identity. If you would like more information about your legal rights under applicable law or wish to exercise any of these rights, you may write to us at DPD-USA@kiinos.com .
Right to request access to your personal information
You have the right to request a copy of your information at: info@kiinos.com Under the CCPA, you may also request that we tell you what categories of personal information we collect, use, and the specific personal information we have collected about you during the past 12 months. However, as permitted by the CCPA, we may withhold certain information if disclosure would pose an unreasonable risk to you or your personal information, such as financial information or account passwords.
Right to request deletion of your personal information
You have the right to request that we delete personal information info@kiinos.com that you have provided to us or that we have collected about you. However, we may retain personal information as authorized by applicable law, such as for personal information required or necessary to provide our services; to provide protection against fraudulent activities; to identify and correct errors; to exercise free speech or other rights, in response to a request by authorities pursuant to legal process; for scientific or historical research purposes; for internal business purposes reasonably resulting from your relationship with us; or to comply with legal obligations. In order to provide our services, we need certain types of information. If you ask us to delete such information, you may no longer be able to access or use our services.
How to exercise your access and removal rights
You may exercise your rights of access and deletion by sending an email to DPD-USA@kiinos.com For security purposes, we may ask you for additional information to verify your identity when you request to exercise your access and removal rights.
If you have an online account with us, logging into your account will serve to verify your identity and application. If we have reason to suspect that the security of your account has been compromised, we will request additional information about you to match our existing records to verify your identity, depending on the nature of the request and the confidentiality of the information sought.
Once you submit a request (1) to access categories of personal information we hold about you or (2) to obtain a copy of specific personal information we hold about you, we will ask you to verify your identity by logging in to your account with your user name and password. There, we will provide you with your information in a password-protected format.
To request that we delete the personal information we collect about you, you will need to authenticate yourself by logging in to your account with your username and password that we have on record and deleting your account. Once you notify us that you have done so, we will initiate the process to delete your information.
If you wish to exercise any of these rights and do not have an account, please contact us at info@kiinos.com and we will request additional information to verify your identity where possible.
The right not to be discriminated against for exercising your rights under the CCPA
The CCPA prohibits us from discriminating against you for exercising the CCPA rights described in this section. Such discrimination may include charging you different prices for our services, providing you with a different level or quality of services or suggesting that this will occur, or refusing to provide services to you if you exercise your rights under the CCPA. We will not discriminate against you for exercising your rights under the CCPA.
2. Categories of personal information we collect and sources
Depending on how you interact with us, Bienbonita, LLC. may collect the following categories of information, which are summarized below. If you reside in California and interact with our site as a Recipient, all of your response data is the property of the person who sent you the survey/form/application/questionnaire (the Originator) and we encourage you to contact them to inform them of your practices under the CCPA. This Notice does not apply to personal information we collect from our employees or job applicants in their capacity as employees or job applicants. It also does not apply to personal information we collect from our employees, owners, directors, officers or contractors of businesses in the course of providing or receiving business-related services.
All categories of personal information collected about you (as detailed below) come from the following categories of sources:
You, including through the use of our services
Automatically collected from you
Our affiliated companies
Third parties, such as when you give permission to social networks to share your information with us or when you have made your personal information public online
We collect the following categories of personal information:
Personal data that identifies you (e.g. name, address and e-mail address)
Commercial information (e.g., transaction data)
Financial data (e.g. billing information)
Internet or other network or device activity (e.g., browsing history or application usage)
Location information (e.g., inferred from your IP address)
Professional or employment data (e.g., your employer's name)
Classifications protected by law (e.g., sex and marital status)
Other information that identifies you or can be reasonably associated with you
3. Categories of third parties with whom we share personal information
We share the categories of personal information we collect about you (as detailed above) with the following categories of third parties:
Our subsidiaries
Our information providers (e.g., analytical services)
Third parties (e.g., our service providers and integration partners)
Your organization, through the creation of an account, in the case of personal data that identifies you (e.g. name, address and e-mail address).
4. Categories of personal information we use for business or marketing purposes
We use all categories of personal information collected about you (as detailed above) for the following purposes:
To provide our services (e.g., account servicing and maintenance, customer service, marketing and advertising, analytics, and communications about our services)
For operational purposes, both for our company and for our suppliers and integration partners.
To improve existing services and create new services (e.g., through research aimed at creating new products or functions).
To detect incidents and fraudulent or illicit activities, take protective measures and follow up actions against those who commit such incidents or activities.
To detect and report errors, and to carry out activities aimed at maintaining the quality or security of our services.
To monitor consumer interactions on our site (e.g., to evaluate reaction to our advertisements)
Short-term transitory use; for example, for the personalization of the content that we or our suppliers display on the services
Other uses that further our commercial or economic interests, such as third-party advertising and communications we send you about relevant offers from our external partners
Other uses that we inform you about
5. Your choices for advertising cookies
The CCPA requires companies that "sell" personal information, as the term "sale" is defined in the CCPA, to provide California residents with the right to opt out of such sales. The California Privacy Rights Act (CPRA) amends the CCPA to broadly define "sale" in a way that includes allowing third parties to receive certain information such as cookie identifiers, IP addresses or browsing behavior to add to a profile about your device, your browser or your person. Such profiles may enable the offering of interest-based advertising by such third parties within their platform or on other sites. Depending on how you use the Services, we may share the following categories of information for such interest-based advertising, which may be considered a "sale" as defined by the CPRA: (1) device information and identifiers, such as IP address and unique advertising identifiers and cookies; and (2) connection and usage information, such as browsing history or application usage. You may opt out of receiving such advertising cookies within our cookie banner.