Last Update as of: October 20, 2021

Keemoji Privacy Policy

Effective as of: August 25th, 2021

Welcome!

Keemoji (“Keemoji”, “we”, “us”, or “our”) believe in creating immersive mobile-first environments where people can connect with the teams, entertainers, and creators they love. Keemoji cares about the security and privacy of the personal data that is entrusted to us.

Keemoji a business brand of

Mocha Holdings LLC
43 W 29th Street
New York, NY 10001
USA

Our EU representative under the GDPR is Mocha Operations (Ireland) Limited. In regards to the processing of your data, Mocha Holdings LLC will act as its Controller.

For all data privacy matters, please contact our Data Protection Officer (DPO) at dpo@mocha.global

1. Overview

Data that directly identifies you is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you is personal data. Aggregated data is considered non-personal data for the purposes of this Privacy Policy.

This policy describes the Personal Data that we collect, how we use and share it, your rights and choices, and how you can contact us about our privacy practices.

Keemoji only collects Personal Data obtained directly from you. “You” may be a visitor to one of our Sites or a user of one of the applications developed by us.

2. Personal Data Collected

At Keemoji, we believe that you can have great products and great privacy. This means we provide different categories of data access. Since our software is capable of collecting personal data on-device only, more sensitive and private information will be accessed exclusively by your device, while information we need for marketing efforts and delivering our services will be collected, stored and shared with third-parties. The personal data Keemoji processes is collected automatically on our Sites/Apps and through marketing of our products.

1. Website

We collect personal data when you visit our website. This kind of data is shared with our partners in order to improve user experience and for marketing purposes.

  • Device information. IP address.
  • Location information. Geographical location derived from IP address.
  • Cookies. First-party cookies.

2. Applications

1. We collect personal data when you use the applications developed by us. This kind of data is shared with our partners in order to improve user experience and for marketing purposes.

  • Device information. Unique identifiers for mobile devices
  • Usage data. Browser type. Number of users and sessions. Session duration. Operating system and version. System language. Device model. Device motion parameters and carrier. Memory. Wi-fi status. Timestamp and timezone. First launch. App opens. App updates. Clicks on ads. Ad impressions viewed. Audiences and segments to which an ad campaign is attributed. The type of ads and the webpage or Application from which such ads were displayed. The webpages visited by the user. The URL from the referring website. Download and installation of Applications. Engagement time. Add to cart. In-app purchases. Advertising ID.
  • Location information. Based on IP address.

2. When using our applications your device may also request access to the following features:

  • Keyboard. Logs of what you typed on the keyboard.
  • Contact list. The contact list on the device (contact suggestions).
    Our software uses this particular information to deliver personalized ads, as well as to invite other users to download the app. This feature is performed within the device itself, and Keemoji does not have access to this information whatsoever. Everything you type and your contact list are 100% private.

We will not collect additional categories of personal data without notifying you.

3. How We Use Personal Data

Keemoji uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance. Keemoji may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interest or those of other persons, or comply with the law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. If you have questions about the legal basis, you can contact the Data Protection Officer at dpo@mocha.global.

  • Device Identifiers. Keemoji collects this information to optimize our services and to help with troubleshooting. Device identifiers can also be used for attribution.
  • Usage data. Keemoji collects this information to power our services and to inform our business operations.
    Location data. Keemoji collects this information to provide you with the most relevant features based on your general location. We only use location information at the city level.
  • Cookies. Keemoji collects this information to power the website and to give you the best experience.

Keemoji does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review.

4. How We Disclose Personal Data

Keemoji does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

  1. Keemoji:
    We share Personal Data with other Keemoji-affiliated entities in order to provide our services and for our administration purposes.
  2. Service providers:
    We share Personal Data with certain of our service providers subject to contract terms that limit their use of Personal Data. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, marketing service, 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 or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.
  3. 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, but subject to the terms of this Privacy Policy.
  4. Compliance and harm prevention:
    We share Personal Data as we believe necessary: (i) to comply with applicable law; (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.

5. Your Rights

You may have choices regarding our collection, use, and disclosure of your Personal Data.

  • 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;
  • The right to request that Keemoji rectifies or updates your Personal Data that is inaccurate, incomplete, or outdated;
  • The right to request that Keemoji erase your Personal Data in certain circumstances provided by law;
  • 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);
  • 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.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches the email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

6. Security And Retention

We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical, and administrative measures designed to protect Personal Data covered by this Privacy Policy against unauthorized access, destruction, loss, alteration, or misuse. Your Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (e.g., you feel that the security of your account has been compromised), please contact us immediately.

We retain your Personal Data as long as we are providing the Services to you or our Users (as applicable). Nevertheless, we keep your Personal Data in order to comply with our legal and regulatory obligations. We may also keep it to assist with our fraud monitoring, detection, and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations. In all cases where we keep data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

7. International Data Transfers

Keemoji products and offerings connect you to the world. Personal Data may be stored and processed in any country where we do business or our service providers do business. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. Officials (such as law enforcement or security authorities) in those other countries may be entitled to access your Personal Data.

We comply with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be.

Keemoji’s international transfer of personal data collected in the European Economic Area, the United Kingdom, and Switzerland is governed by Standard Contractual Clauses.

8. Use By Minors

Keemoji has services that are kid-friendly and for teens.

Sometimes we might ask for parents’ or guardians’ contact details, so that we can contact them. Other times we may contact your parent or guardian directly:

  • so we can send you notifications
  • so we can show you more things we think you will like

9. Updates To This Privacy Policy And Notification

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices, or relevant laws. The “Effective as of” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services.

We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website.

If applicable law requires that we obtain your consent or provide notice in a specified manner prior to making any changes to this Privacy Policy applicable to you, we will provide such required notice and will obtain your required consent.

10. Contact Us

If you have any questions or complaints about this Privacy Policy, please contact us at dpo@mocha.global