Last updated: December 11, 2024
Our Platforms (“Platforms” means the website(s), including but not limited to https://kaminari.click/ and related websites and/or subdomains (the “Site”) and any related documentation, services; any images, logos, photographs and video content, software, designs, graphics, photos, illustrations, animations, videos, scripts, texts, music, sounds, voiceover, interactive features, and all other materials and content accessible within the Site that are incorporated into and form part of our Site and etc. (“Site Content”)) are owned, managed and operated by the Company.
Company shall mean:
KADAM CY LTD, created and operating under the laws of the Republic of Cyprus, registered number ΗΕ 424427, address: Nikos Pattichis, 113, floor 2, 3070, Limassol, Cyprus (hereinafter - “We”, “Company”, “KADAM CY LTD”, “Kaminari Click”).
We can be contacted by writing to:
KADAM CY LTD, Nikos Pattichis, 113, floor 2, 3070, Limassol, Cyprus or via support@kaminari.click
We are dedicated to providing cutting-edge antifraud solutions to safeguard your online presence. At Kaminari Click, our mission is to ensure comprehensive protection against unwanted traffic, bot activity, and fraudulent clicks. By leveraging advanced technology, we help businesses maintain clean, reliable data, enhance user trust, and maximize the efficiency of their digital campaigns in an ever-evolving online ecosystem.
We believe in the remarkable potential of technology to drive positive change and are committed to the highest standards of privacy and security. As trusted keepers of your personal data, we prioritize transparency and accountability in our data practices, ensuring that you have full knowledge of your data while benefiting from our Platforms.
When you use Platforms, we may collect, store and process some data, including personal data. This privacy policy (“Privacy Policy”) sets out the main principles on which the data collected from you, or that you provide to us, will be processed by us. This Privacy Policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them. In accordance with data protection legislation (GDPR, UK GDPR, CCPA and etc.), we act as the controller of your personal data. In some cases, we may act as the processor of personal data, as indicated in this policy below.
We encourage you to review our Privacy Policy in its entirety to gain insight into our data handling practices. We have meticulously crafted this policy to be clear and accessible, but if you have any questions or concerns, please don't hesitate to contact us via support@kaminari.click or dpo@kaminari.click or the address below for further information:
KADAM CY LTD Nikos Pattichis, 113, floor 2, 3070, Limassol, Cyprus.
IF YOU DO NOT ACCEPT THE TERMS OF THE PRIVACY POLICY, PLEASE DO NOT USE OUR PLATFORMS.
As you engage with our Platforms, we gather data concerning a recognized or identifiable living individual (“personal data”) through the following means:
Data Directly Provided by You: this encompasses any information you manually input or furnish to us while utilizing our Platforms. For instance, this might include details like your name, email address, phone number, photo, geolocation data, place names and addresses, added by you or any other information you decide to disclose during registration or account setup.
Data Automatically Collected by Us: when you access our Platforms, we automatically procure certain details regarding your engagement and activities within the Platforms. This may entail specifics about your device, such as its model, operating system, unique identifiers, IP address, and data related to your actions within the Platforms.
Data Acquired via Cookies: to understand your interactions with our Platforms better, we utilize cookies and similar technologies. Cookies enable us to retain particular details about you, such as your preferences or previous interactions, thereby enhancing your experience on our Platforms and delivering tailored content. You can find more in our Cookie Policy.
Data processing is crucial to enable your usage of our Platforms. Whenever you use our Platforms, some personal and non-personal data is collected, stored, and analyzed using internal and third-party tools.
Below are several additional purposes for which we process your data:
Depending on which features of the Platforms you use, we will process your personal data based on one or more of the following legal bases (we have provided you with some examples):
| TYPES OF LEGAL BASIS WE USE | DESCRIPTION |
|---|---|
| Legitimate interest | We process your usage data on this legal basis to technically improve the Platforms based on our legitimate interest as a Company to continuously improve the Platforms and deliver an improved service to you. |
| Сontract | We process your usage data on this legal basis to fulfill the contractual duty of granting you access to use our Platforms. |
| Legal obligation | We process your usage data on this legal basis to comply with pertinent laws and regulations. This implies that we may handle personal data as mandated by law, ensuring adherence to applicable legal mandates. |
| Consent | We process your usage data on this legal basis to promote Platforms and optimize our advertising efforts to effectively tell more people about Platforms. |
We are committed to being clear and transparent so that you can really understand what we do with your data. Below, we explain the purposes for which we process your personal data and the legal basis supporting this. We also give you some basic examples:
| LEGAL BASIS | PURPOSE OF PROCESSING | EXAMPLE |
|---|---|---|
| Legitimate interest | Responding to your requests. | We may process your name and email, e.g., to properly respond to your request. |
| Сontract | Processing transactions and sending you related information, including confirmations and reminders for account management and other administrative purposes. | We may send you reminders regarding payments, or we may email you containing your invoice, if applicable, using your device data. |
| Consent | Making offerings to you. | We may offer you some discounts. |
For the processing of physical data and special categories of personal data, including sensitive information like health data, explicit consent from the user serves as the legal basis. This consent is essential for enabling users to utilize the Platforms provided by us.
When you make purchases directly through our Site, you authorize an applicable payment system and/or provider to collect this payment information. We do not collect or process your payment data (such as credit card number, expiration date, etc.) for purchases made through our Platforms. We strongly recommend reviewing the Privacy Policy of the payment system you use for making payments, such as (for example) the privacy policy of Stripe: https://stripe.com/en-pl/privacy.
We retain your personal data for as long as your account is active or for as long as it is necessary for the purposes of its collection and processing (e.g., for resolving disputes, for safety and security reasons, or for complying with our legal obligations). However, the period for which we may retain your personal data cannot exceed 6 (six) months from the date of account deletion.
We may need to share your personal data with certain third parties as follows:
Third-party service providers:
This may include providers of certain systems and services that we use to host, administer, and maintain our Platforms, including the servers used to host our Platforms, email service providers, payment processors, fraud prevention vendors, analytics, customer service providers and other service providers.
Third-party service providers for marketing purposes:
If you consent to any marketing from us, certain personal data may be shared with third-party service providers we use to help us carry out marketing including, e.g., third-party marketing automation platforms.
Compliance with Laws:
We may disclose your personal data to a third party if:
Aggregated or Anonymized Data:
We may also share aggregated or anonymized information with third parties that do not directly identify you.
Group companies:
Your personal data may be shared among affiliates and subsidiaries. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction, such as a merger or sale of assets.
| Processor’s name | Processor’s privacy policy | Purpose |
|---|---|---|
| Clarity | https://www.microsoft.com/en-us/privacy/privacystatement | Track user interactions and engagement within the App. Collect user behavior data, event tracking, and App usage statistics to analyze user behavior, measure app performance, and improve user experience. |
| Google analytics | https://policies.google.com/privacy | Track activity on our Site (and on each page separately): page reach, unique users and repeat visits, we learn information about our audience, we track conversions (including from Google advertising). |
| Google tag | >https://policies.google.com/privacy | Launch and track Google ads. |
The personal data we maintain will primarily be stored and processed within the EU. We will do our best to keep this personal data secure. All information we hold is stored on our secure servers (which we own or license from appropriate third parties). We use industry-standard procedures and security standards to prevent unauthorized access to our servers.
However, there may arise situations where we need to collaborate with trusted third parties located outside the EU to deliver services to you (for instance, when utilizing servers in the US). We choose our processors very carefully. We do not work with processors based in countries where we are concerned about the rule of law with respect to privacy.
We have entered into Standard Contractual Clauses with all non-EEA third parties whose data processing tools we use (data processors) if there is no adequacy decision by the EU Commission for their particular country. We adhere to the principles of minimization and anonymization, where feasible, to ensure compliance with the GDPR and other relevant data privacy laws when transferring personal data, if necessary.
By providing your personal data, you explicitly consent to its transfer, storage, or processing outside the EU. We will take all reasonable steps to ensure that this information is handled securely and in accordance with this Privacy Policy.
Ensuring the security of your data is a top priority for us. We employ robust technical and organizational measures to safeguard the personal information entrusted to us.
Your personal data is safeguarded by the password you create when registering on our Platforms. It's essential to choose a strong password and keep it confidential to prevent unauthorized access. Additionally, refrain from sharing your password and ensure the security of your computer or mobile device.
We have instituted reasonable administrative, technical, and physical security measures to protect your personal data from unauthorized access, alteration, or destruction. For instance:
In the event of a personal data breach as defined in Article 4.12 of the GDPR, we will promptly notify you. This notification will include relevant details, measures taken, and an assessment of associated risks, as required by applicable law and our Privacy Policy. We are committed to addressing breaches promptly and transparently, taking necessary actions such as logging affected users out, initiating password resets, and other appropriate measures to mitigate the breach.
To report a personal data breach or seek assistance, please contact us at support@kaminari.click or dpo@kaminari.click. We will address your concerns accordingly.
We aim to ensure that you are fully informed about all your data protection rights and the methods available to exercise them. Please note that these rights may vary depending on your location:
To exercise your rights, please contact us via support@kaminari.click or write to us at the address specified hereinabove.
If you submit a request, we typically aim to fulfill it within one month. If additional time is needed to assist you in exercising your rights, we will inform you accordingly. We reserve the right to reject manifestly unfounded or excessive requests.
During the process of exercising your data protection rights, we may ask you to confirm your identity. This verification step ensures that you are entitled to access certain information and that the rights of third parties are not infringed upon. If we are unable to verify your request, we will be unable to fulfill it.
If you are at least 18 years old, you are eligible to provide explicit consent for the processing of your data. Alternatively, if you are under the required age, you can’t use our services.
In the event that we learn that we have inadvertently gathered personal data from children, we will take reasonable measures to promptly erase such information from our records.
If you are a parent and learn that your child is using our Platforms without your permission, or if you have a specific question about data privacy, do not hesitate to get in touch with us via support@kaminari.click.
If we become aware that information has been collected from persons under the age of 18, we reserve the right to promptly delete the account and erase all associated information, including health and sensitive data, from our servers.
If you wish to access, correct, or update your personal data, you can do so at any time by contacting us via support@kaminari.click.
If you would like us to delete your information, please write an email to our support team on the following email: support@kaminari.click.
If you proceed with the deletion of your account, you will no longer have access to the account.
Please note that if you ask us to delete your account, all your statistics and other items will be lost and we may not be able to restore them in the future.
DATA PROTECTION OFFICER
You can reach the Company’s Data Protection officer via email: dpo@kaminari.click.
We reserve the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and data use practices, the features of our Platforms, or advances in technology.
Please check this page periodically for changes and refer to the “last updated” date at the top of the page to know if it has been revised since your last visit. If we make any changes to this Privacy Policy that we consider to be material to your consent, we will notify you of them.