Introduction

Keemoji Platform (“Keemoji”, “We”, “us”, or “our”) is a privacy-first mobile device technology development company that specializes in offering end users (“Users” or “You”) the best-in-class experience in an internet keyboard application. We believe in creating immersive mobile-first environments where people can connect with the teams, entertainers, and creators they love. This is facilitated through a combination of technology solutions that have user privacy at its core without compromising the user experience. Keemoji cares about the security and privacy of the personal data that is entrusted to us. We believe the user should not have to compromise privacy for functionality.

 It is Keemoji Platform’s policy to respect your privacy while you use our platform (“the Keemoji Platform”), which we own and operate. Any information that we do receive is by fair and lawful means.

Keemoji Platform recognizes that Users are mindful of their privacy. Keemoji Platform provides this Privacy Policy to help you make an informed decision about whether to use or continue to use the Keemoji Platform. If you do not agree to our practices, please do not use Keemoji Platform and our Keyboard applications. Your continued use of the Keemoji Platform will be regarded as acceptance of our privacy and personal information practices.

We offer Keemoji Platform software for both iOS and Android applications and we refer to all these products, including future updates and upgrades as “services” in this policy.

A Special Notice About Children

 Children (under the age of 16) are not eligible to use the Platform unsupervised, and we ask that children do not submit any personal information to us. If you are under the age of 16, you may only use this Platform in conjunction with, and under the supervision of your parents or guardians.

Users Under 13 Years of Age

 Children under the age of 13 are not eligible to use the Platform at all.  Only parents or legal guardians can submit personal information to us about a child.

By visiting our Site and/or using our Services, or by including children under the age of 13 years old in our provided services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.

If we learn we have collected Personal Information from a User under the age of 13 without parental consent, we will delete that information as quickly as possible.

Owner and Data Controller

Keemoji Platform, a business brand of Mocha Holdings LLC 43 West 29th Street, 4th Floor New York, NY 10001, USA. In regard to the processing of your data, Mocha Holdings LLC acts as the controller.

How to Contact Us

For customer support, please email support@mocha.global.

For all data privacy matters, please contact our Data Protection Office (DPO) at dpo@mocha.global. Our EU representative under the GDPR is Mocha Operations (Ireland) Limited. In regard to the processing of your data, Mocha Holdings LLC acts as the controller.

How We Collect Your Information

We may collect browsing data automatically when you use our services.

Which Information We Collect About You

We may collect the following information from you:

a) Device Information: Advertising identifiers for Android mobile devices, IP Address. When using our applications your device may also request access to the following features, but the data will never leave your device. This means the data below is never collected or stored on any servers.

b) Contact List: For contact suggestions related to call management while using the keyboard.

c) App Usage Data: Usage Data such as browser type, session duration, operating system, system language, device model, device motion parameters, first launch, app opens and updates, download, and installation confirmation.

How We Use Your Data

a) Device Identifiers: Keemoji collects this information to optimize our current services and to help with troubleshooting. (legitimate interest) Device identifiers can also be used for media attribution. (legitimate interest)

b) Usage Data: Keemoji collects this information to power our services and to inform our business operations. (legitimate interest) 

c) Contact List: This feature is performed within the device itself and Keemoji or our staff do not have access to this information. (consent)

d) Suggestions: We may suggest to you certain links that you may choose to access (consent through course of action). Clicking on the links is your own choice and you will be taken to sites not controlled by Us.

e) Push Notifications. We may send you push notifications related to upgrades to the Keemoji app, to communicate with you or to notify you about service-related issues (legitimate interest). Push notifications can be turned at any time off from your phone`s menu.

Keemoji does not use algorithms or profiling to make any decision that would significantly affect you.

How We Disclose Personal Data

We may disclose personal data to third parties in the following circumstances:

a) Our entities within the Mocha Global group of companies.

b) Keemoji-Affiliated Entities: In order to provide our services and for our marketing attribution purposes. Media attribution is the practice of establishing which media channels are the most efficient with regard to advertising engagement.

c) Service Providers: We share Personal Data with some of our service providers such as Google Firebase, subject to contract terms that limit their use of Personal Data. We may have service providers that provide services on our behalf, such as media attribution, identity verification services, website hosting, data analysis, marketing services, information technology, and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only to perform services on our behalf and will always comply with legal requirements. We require such service providers to contractually commit to protecting the security and confidentiality of Personal Data they process on our behalf. Our service providers are located in the European Union and the United States of America.

d) Corporate Transactions: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, subject to the terms of this Privacy Policy.

e) Compliance and Harm Prevention: We share Personal Data as we believe necessary: (i) to comply with applicable laws such as GDPR, CCPA, and others; (ii) to enforce our contractual rights; (iii) to protect the Services, rights, privacy, safety, and property of Keemoji, you, or others; and (iv) to respond to a request from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

Some of the service providers mentioned above may be located abroad and, in this case, we adopt additional safeguards to guarantee an adequate level of protection for your personal data.

Transfer of Your Information

We from Keemoji will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

In accordance with the GDPR, when we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that we use specific controls approved by the European Commission which give personal data the same protection it has in Europe.

How We Protect Your Information

To ensure that your personal information is secure, we communicate our privacy and security guidelines to all Keemoji employees and business partners and strictly follow precautionary measures regarding privacy within the company.

We strive to protect your personal information through physical, technical, and organizational measures aimed at reducing the risks of loss, misuse, unauthorized access, disclosure, and improper alteration of this data.

 We make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical technical or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on our Site or through other forms of communication.

How Long We Retain Your Information

We have determined retention periods based on the purpose of the processing and the rules set forth within the GDPR as well as the legal and business requirements. For example, the GDPR requires us to remove data when it has served its purpose and is no longer of use. We review the personal data we collect regularly to ensure that the personal data we have is up-to-date and is not retained longer than needed or required by the regulation.

If you wish to have more detailed information about our retention times, please contact us at dpo@mocha.global.

California Privacy Rights

This section applies only to California consumers. The  California Consumer Privacy Act (CCPA) is a data protection law that ensures you have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.

• Right of Access: you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months. 

• Right of Deletion: you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.

• Right to Non-Discrimination: You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.

You also have the right to opt-out of the sale of personal information. In the preceding 12 months, we have not disclosed your personal information to any third party in a manner that would be considered a sale under the CCPA.

For more details on the personal information collected in the preceding 12 months, see our sections above How We Collect Your Information and Which Information We Collect About You. We collect this information for business and commercial purposes as described above in How We Use Your Data section. Information about which categories of third parties we share this information with is described above in How We Disclose Personal Data.

a) California consumers can make a request related to the above-noted rights by emailing us at dpo@mocha.global.

Your Rights Under the GDPR (If You Are a Data Subject in the EU)

Under the law, you are granted six fundamental rights when data about you is being processed. We will ensure to reach out without undue delay (no more than 30 days) when you submit a request related to exercising your data subject rights. Although uncommon, when applicable for official or legal reasons we may be unable to address the specific request you make related to your rights.

Also, if a request is manifestly unfounded or excessive, in particular, because of their repetitive character, we may either:

• charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or

• refuse to act on the request.

In this scenario will we inform you of the reasons we believe your request is manifestly unfounded or excessive character of the request.

As a data subject, you have the right to:

a) The right to request confirmation of whether Keemoji processes Personal Data relating to you, and if so, to request a copy of that Personal Data;

b) The right to request that Keemoji rectifies or updates your Personal Data that is inaccurate, incomplete, or outdated;

c) The right to request that Keemoji erase your Personal Data in certain circumstances provided by law;

d) The right to request that Keemoji restrict the use of your Personal Data in certain circumstances, such as while Keemoji considers another request that you have submitted (including a request that we make an update to your Personal Data);

e) The right to request that we export your Personal Data that we hold to another company, where technically feasible;

Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or:

• In some cases, you may also have the right to object to the processing of your Personal Data.

• To exercise your data protection rights please contact our DPO at dpo@mocha.global.

We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.

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Under certain circumstances such as when you visit the websites of our partners, you may witness advertisements coming from us or from our demand partners.

Modifications to This Privacy Policy

Keemoji reserves the right to change this Privacy Policy at any time by posting revisions on this web page. Such changes will be effective upon posting and the current version published on our website shall apply.

Please revisit this page to stay aware of any changes. If the Privacy Policy is part of an agreement with you, we will notify you by e-mail or other appropriate means in case of an amendment.