Privacy Policy of KeeMoji by KeeMoji. Privacy Policy

Summary of Privacy Policy Updates

This Privacy Policy is being updated to reflect requests and co-marketing planning with collegiate institutions to support the following goals:

Support and measure the success of future mobile marketing campaign to increase keyboard downloads, keyboard engagement and measure the ROI on the marketing expenditures,

Integration with industry leading Mobile Marketing Partners, Google Analytics (Firebase) and AppsFlyer,

Prepare and enable future opt-in information provided by the end-user to better focus college content related to the user’s interest,

All updates are fully compliant with both the General Data Protection Regulation 2018 (GDPR) and the California Consumer Privacy Act of 2018 (CCPA). College Keyboards are compliant with both these regulations regardless of the end-user’s physical address.

Effective as of: August 25th, 2021. 

Privacy Policy of Keemoji Platform by Mocha Global. Privacy Policy. 

This application collects some Personal Data from its Users. 

For clarity, Personal Data is considered as anonymized if it does not relate to an identified or identifiable a natural person or if it has been rendered anonymous in such a manner that the person / data subject is not or no longer identifiable. PII includes any information that can be used to identify a person. 

All updates are fully compliant with both the General Data Protection Regulation 2018 (GDPR) and the California Consumer Privacy Act of 2018 (CCPA). College Keyboards are compliant with both these regulations regardless of the end-user’s physical address.

OWNER AND DATA CONTROLLER: 

Keemoji Platform, a business brand of Mocha Holdings LLC 43 West 29th Street, 4th Floor New York, NY 10001, USA. 

CONTACT: dpo@mocha.global

Introduction

Keemoji Platform (“Keemoji”, “We”, “us”, or “our”) is a privacy first mobile device technology development company which specializes in offering and users (“Users”) 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 compromise to 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, with your knowledge and consent. Consent is given when you download the software and begin to use the Services. 

College Keyboards are officially licensed and published by 2Thumbz, Inc. All college content is copyrighted and owned by the respective university. 

College Keyboards are developed by an exclusive 2Thumbz and Keemoji contractual partnership. All respective data collection, usage, and sharing can be reviewed below as it relates to the success of the application and the partnership between 2Thumbz, Inc, the specific university and Keemoji. For customer support related to the College Keyboards, 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.

The Keemoji Platform may link to external sites and services that are not operated by us. Please be aware that we have no control over the content and practices of these sites and cannot accept responsibility or liability for their respective privacy policies. 

Your continued use of the Keemoji Platform will be regarded as acceptance of our practices around privacy and personal information. If you have any questions about personal information, please contact us at: dpo@mocha.global.  

Keemoji Platform recognizes that Users are mindful about 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 College Keyboard applications

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. 

Overview

Keemoji only utilizes 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. 

Personal Data Collected

At Keemoji, we believe that great products and great privacy can coexist. We know how important our users’ privacy is, which is why our apps work locally on your device instead of utilizing servers. For example, we never collect, store, or share keystrokes or contact lists off of your device. There is certain information we require for marketing efforts and product improvement such as a mobile advertising ID that will be collected and shared with third parties. The data Keemoji processes is collected automatically on our applications and through the marketing of our products. 

  1. Website
    Similar to nearly all websites available to the public, we collect an IP address, geographical location derived from the IP address, and we may collect first-party cookies depending on the browser used to visit our website. This kind of data is used to provide a customized user experience.

  2. Applications
    1. We utilize personal data when you use the applications developed by us. This kind of data is shared with our carefully selected partners in order to improve the user experience for media attribution purposes.

      Device Information: Advertising identifiers for mobile devices. 
      Usage App Data: Browser type, Number of users and sessions, session duration, operating system and version, system language, device model, device motion parameters, mobile carrier, memory, Wi-Fi status, timestamp and time zone, first launch, app opens and updates, ad engagement, download and installation confirmation, advertising ID. 
      Location Information: based on IP address.
       
    2. 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 first or third-party servers.  

      Keyboard: Usage and data logs
      Contact List: for contact suggestions

      Our software uses this particular information to deliver personalized ad experiences. This feature is performed within the device itself and Keemoji or our staff do not have access to this information. Everything you type and your contact list are 100% private. We will never collect additional categories of data without notification and your consent. 

Push Notifications

We use push notifications for carefully considered business purposes which has to benefit Users, and which include some or all of the following: 

  • To provide upgrades to the Keemoji Platform application. 
  • To communicate with you. 
  • To provide you with offers and promotions about services and products of Keemoji Platform or of other parties that may be of interest to you. 
  • To enhance your experience. 
  • To notify you of service-related issues. 

Push notifications are preset as opt-in in the consent upon application download and use of the Services. 

How We Use Personal Data 

Keemoji does not use your personal data, except in valid GDPR and CCPA compliant circumstances. Keemoji will rely on your consent to protect your vital interest or those of other persons, or to comply with a legal order. If you have questions about the legal basis, you can contact the Data Protection Office at dpo@mocha.global.

  • Device Identifiers: Keemoji collects this information to optimize our current services and to help with troubleshooting. Device identifiers can also be used for media 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 personalized experience. 

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

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 some personal data with other 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 regards to advertising engagement.

    Service providers:

    We share Personal Data with certain of our service providers such as Google Analytics, 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 and will always 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 located in the European Union and the United States of America
     
  2. 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.
     
  3. Compliance and harm prevention:

    We share Personal Data as we believe necessary: (i) to comply with applicable law 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.

Legal basis for processing (For EEA Users): 

If you are an individual in the European Economic Area (EEA), we are under legal obligation with the collection and processing of certain information under applicable EU laws. The legal bases depend on the Services you use and how you use them. Keemoji Platform does not seek, hold, or retain PII and accordingly for the most part the EEA regulations are not directly applicable. In the event that our policy changes or we become legally obligated to retain such PII, it would because: 

  • We need it to provide you with additional Services that you have opt-in for and that such services you will have been given notification that due to such service, the Keemoji Platform Privacy Policy will have been amended to include PII (Personal Identifiable Information). This PII will only be used to operate the additional services (where applicable), to provide customer support and personalized features and to protect the safety and security of the additional Services. 
  • You give us consent to do so for a specific purpose; or 
  • We need to process your data to comply with a legal obligation. 

If in the even that you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. When we are using your information because we have the legitimate interest to do so, you have the right to object to that use. 

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 may 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. 

If you do not agree with any part or the entirety of our Privacy Policy, please uninstall the application and discontinue use of the Keemoji services. Continued use of the application will represent your acceptance of our Privacy Policy in its entirety. 

Our Commitment to Data Security

Keemoji Platform uses commercially reasonable, physical, managerial, and technical safe guards to preserve the integrity and security of our technology and (where applicable) personal information. We cannot, however, ensure or warrant the security of any information you transmit using the Keemoji Platform and you do so at your own risk. Using unsecured Wi-Fi or other unprotected networks using any form of communication including the Keemoji Platform is never recommended. Keemoji Platform makes 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 safe guards. If Keemoji Platform learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Keemoji Platform may post a notice on Keemoji Platform Site or through other forms of communication including push if a security breach occurs. 

Accuracy, Security, and Retention of Your Personal Information 

Keemoji Platform uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of any passwords and login credentials. 

Questions Regarding This Privacy Policy 

If you have questions regarding this Privacy Policy, please contact us at dpo@mocha.global. Please include “Privacy” in the subject line of your inquiry. If you have complaints about Keemoji Platform’s processing of your personal information, you may have the right to contact the applicable supervisory authority. 

GDPR (EU) 2016/679

The General Data Protection Regulation (2018) (GDPR) is now in force and gives individuals within the UK and the European Union enhanced rights over the use of their data. 

Under the GDPR we can only hold and process your personal data on one or more of the grounds authorized by the GDPR. In this Privacy Policy, we advise you of the basis on which we hold and process your personal data and of your rights under the GDPR. 

Your California Privacy Rights 

This part of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by Mocha Global and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we” “us” “our”). 

The provisions contained in this section apply to all users who are consumers residing in the state of California, United States of America according to “The California Consumer Privacy Act of 2018.” (Users are referred to below, simply as “you”, “your”, “yours”) and for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term “personal information” as it is defined in The California Consumer Privacy Act (CCPA). 

You may also make such a request by writing to us at: 

Keemoji Platform Attn: Data Protection Office 

43 West 29th Street, 4th Floor New York, NY 10001

Modifications to This Privacy Policy

Keemoji Platform 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. 

Changes and updates to this Privacy Policy

This Privacy Policy may be revised periodically, and this will be reflected by the “effective date” below. Please revisit this page to stay aware of any changes. Your continued use of the Keemoji Platform constitutes your agreement to this Privacy Policy and any amendments. 

This updated Privacy Policy dated August 2021 is in review by 2Thumbz, Inc.

Date Last Modified: 

This Privacy Notice was last modified August 2021, v4