Privacy PolicyEffective Date: April 11th, 2024
Introduction
KillB and its subsidiaries and affiliated companies (“KillB”, “we”, “our”, “us”) understand and respect our users’ need for privacy. This Privacy Policy (“Privacy Policy”) explains how KillB collects, uses, and shares information we collect about you when you use our Website (www.killb.com), mobile applications, browser extension, payment processing services, application programming interfaces, and other online products and services that link to this privacy notice (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us or our Services.
We may change this privacy notice from time to time. If we make changes, we will notify you by revising the date at the top of this notice and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this privacy notice regularly to stay informed about our information handling practices and the choices available to you.
How We Collect Your Information
Information We Collect From Our Website
Information You Provide to Us
We collect the information you provide directly to us. For example, you can provide information directly to us when you create a KillB account, use our Services to send and receive money or cryptocurrency or to buy and sell cryptocurrency, request access to or use certain features, request customer support, or otherwise communicate with us. The types of information we may collect about you include your name and contact information (such as email address, postal address, and phone number), date of birth, username, profile image, photograph, payment and transaction hashes (including blockchain addresses), identity information you submit (such as government-issued identification numbers, photos of government-issued documents, and proof of address), passcode, payment and financial account information (including payment method information and bank account and routing numbers), transaction information (including information about other parties to the transaction), and any other information you choose to provide.To open a business account with KillB, we may require you to provide additional information about you and the beneficial owners of the business. The types of additional information we may collect for business accounts include business name, physical address, mailing address, proof of address, tax ID, name of beneficial owner(s), proof of legal formation (for example, a Certificate of Incorporation), bank statement, bank account information, and name and contact information of employees authorized to act on behalf of the business.Information We Collect Automatically When You Interact with Us
When you use or interact with our Services, we may automatically collect certain information, including:
- Transactional Information
When you transfer, purchase, or sell cryptocurrency or make or receive a payment, we collect information about the transaction, such as the transaction amount, the date of the transaction, the transaction origination and destination (including any address information), and, in some cases, the identity and contact information of the other party to your transaction.
- Device Information
We collect information about your device when you interact with our Services, including the hardware model, operating system version, mobile network, IP address, device identifier, browser type, and app version.
- Location Information
We infer your approximate geographic location (e.g. country or city-level location) based on your IP address.
- Information Collected by Cookies and Similar Tracking Technologies
We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us provide and improve our Services and your experience, such as by allowing us to see which areas and features of our Services are popular, store preferences, and help protect our systems and users. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.
- Do Not Track
Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.
Information We Collect from Other Sources
We collect information about you (and the other party to a transaction) from third-party sources. For example, we may collect this information from identity verification and know-your-customer service providers, financial services providers, and financial institutions, including information such as name, username, phone number, postal address, transaction confirmations, age, government-issued identification numbers (such as Social Security number), and financial account information (including account balances and transaction history). In addition, we receive information about you and your use and interactions with our Services, our marketing campaigns, and other third-party websites and services from third-party partners, such as advertising partners who provide us with information about your interest in and engagement with our Services and online advertisements. We may also receive information about you from other users, such as when they engage in transactions with you through our Services or invite you to use our Services. This information may include transaction descriptions that relate to you or your name or username.
Information We Derive
Finally, we may also derive information or draw inferences about you based on the information we collect. For example, as noted above, we may make inferences about your location based on your IP address, we may infer that certain products or services may be of interest to you based on your transaction history, and we may draw inferences about potential fraudulent activity.
How We Use Your Information
We use the information we collect to provide, maintain, and improve our Services, including processing transactions, identifying and repairing errors in our Services, and analyzing usage over time. We or our service providers also use the information we collect to:
- Authenticate and help verify your identity;
- Send you transactional or other account-related information, including confirmations, receipts, customer experience surveys, security alerts, transaction updates, and other customer support and administrative messages;
-To notify you about changes to our Services;
- Send you marketing communications that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
- To measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
- Detect, investigate, and help prevent security incidents and other malicious, fraudulent, or illegal activity and help protect the rights and property of KillB and others. Some of this preventative action may prevent you from registering for an account, setting deposit or withdrawal limits, or rejecting requested transactions on an automated basis. If you have questions about the validity of any automated rejection or limitation, please contact us;
- To carry out our obligations and enforce the terms of our Services;
- De-identify, anonymize, or aggregate your information;
- Comply with our legal and financial obligations; and
- Carry out any other purpose described to you at the time the information was collected.
How We Share Your Information
We may share your personal information as follows:
- With companies, professional advisors, and contractors that access your information to perform services for us, such as companies that assist us with web hosting, data storage, identity verification, fraud prevention, payment processing, tax reporting, financial services, customer service and support, legal and consulting services, customer communications, analytics, and marketing and advertising;
- Depending on your location, we, or our financial institution partners may provide your personal information to vendors to help verify your identity and prevent fraud, including by determining whether a selfie you take matches the photo in your government-issued identity document.
- With financial institutions that we partner with we receive and process payments and transactions you have authorized via the Services. Our financial institution partners may vary depending on your geographic location. Please review our Terms of Service for additional information regarding our financial institution partners’ services;
- With business partners that provide products or services, you request or that jointly offer products and services with us;
- With other parties to transactions, including other people you are sending payments to or receive payment from, merchants when you use the Services to pay for goods and services, and their service providers;
- With advertisers and advertising networks to facilitate more relevant and targeted advertising;
- If we believe that disclosure is in accordance with, or required by any applicable law or legal process. For example, we may disclose information about users or transactions in connection with tax filings, regulatory requests, court orders, or law enforcement requests;
- If we believe that your actions are inconsistent with our user agreements or policies, that you have violated the law, or that it is necessary to protect the rights, property, and safety of KillB, our users, the public, or others;
- In connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
- Between and among KillB and its affiliates for use in connection with the purposes outlined above; and
- With your consent or at your direction.
We may also share aggregated or de-identified information that cannot reasonably be used to identify you.
Analytics
We allow others to provide analytics services in connection with our Services. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and across other websites and online services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, and links clicked. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.Location of Processing
KillB’s headquarters are in the Cayman Islands, and it has offices around the world. In providing its services, KillB may process your personal information on servers outside the country where you live, including in countries that do not have the same data protection laws as your country. Although the data protection laws of various countries may differ from those in your own country, we take appropriate steps to ensure that your personal information is processed as described in this Privacy Policy and under the law.If you are located in the European Union (“EU”), the United Kingdom (“UK”), or Switzerland, please see the “Transfer of Personal Information to Other Countries” section in Appendix B for more information.
How We Protect Your Information
We are committed to protecting your information. We maintain appropriate administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.
How Long We Retain Your Information
We will retain your personal information on file for as long as necessary for our legitimate business purposes. Please note that in certain cases, legal or regulatory obligations require us to retain specific records for a longer period.
Children's Information
To open a KillB Account and use the Services, you must be 18 years of age or older. We do not knowingly collect or solicit any information from any person under the age of 18 on our Services. If we have inadvertently collected personal information from anyone under the age of 13, we will make reasonable efforts to delete the information. If you believe that we may have collected any such information, please contact us at [email protected].
Your Rights
You have the right to request a copy of your information, to object to our use of your personal information (including for marketing purposes), where applicable, to correct your personal information, to request the deletion or restriction of your personal information, or to request your personal information in a structured, electronic format.Please note that we may retain certain information as required by law or for legitimate business purposes. If you would like to exercise any of these rights, please contact [email protected].Depending on where you are located, you may have certain rights in connection with the personal information that we obtain. These rights vary depending on your jurisdiction. To learn more about your rights, see:
- Appendix A for CCPA rights if you are a California resident.
- Appendix B for GDPR rights if you are located in the EU, UK, or Switzerland. Third-Party Services, Applications, and Websites
Certain third-party services, websites, or applications you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Policy. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application prior to use.
Changes To This Privacy Policy
We periodically review and update this Privacy Policy to describe new services or changes to our practices. You can determine when this Privacy Policy was last revised by referring to the “Updated” date at the top of this document. We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our privacy practices and the ways that you can help protect your privacy.If we make significant changes to this Privacy Policy, we may provide additional notice through a prominent notice on the Website or via the email address associated with your account.
Contacting Us
To submit questions regarding this Privacy Policy, you can contact KillB by emailing us at [email protected] or
[email protected]
Appendix A: California Consumer Privacy Act Addendum
Additional provisions are applicable to processing the personal information of California residents.
Scope and Applicability
This Appendix A to the Privacy Policy (“Appendix A”) applies to California residents and outlines individuals’ rights and choices with respect to the processing of their personal information under the California Consumer Privacy Act (“CCPA”). This Appendix A controls to the extent it conflicts with any provision in the main body of the Privacy Policy.
Data Collection, Use, and Sharing
The CCPA requires that we inform individuals whether we collect any categories of personal information as classified under the CCPA and whether we share this information with selected recipients for specific purposes.
Categories of Information
We collect the following categories of information as classified under CCPA:
- Personal identifiers - We collect names, IP addresses, email addresses, and usernames.
- Commercial information - We collect payment information such as sender/beneficiary account names and numbers; descriptions of transactions; payment amounts and instructions; and sender/beneficiary addresses and phone numbers. We also collect information about the products requested and records of services purchased.
- Internet or other network activity information - We collect IP address, device information, clickstream data, and dates and times of visits to our Site.
- Geolocation - We collect geolocation information directly from users and Website visitors and, on a less granular level, automatically on the KillB platform through the use of cookies and related technologies.
Please see the “How We Collect Your Information” section in our Privacy Policy to see the full description of the information that we collect.
Publicly Available Information: Personal information does not include publicly available information. For purposes of this paragraph, “publicly available” means information that is lawfully made available from federal, state, or local government records.
Sharing Information
We share the information collected with third-party service providers such as suppliers, vendors, and business partners (e.g., advertising partners, and consultants) to operate our business and provide the RippleNet Service. We do not sell personal information.
Using Information
We collect and use personal information to:
- Interact with the users;
- Facilitate transactions;
- Provide the Service;
- Conduct internal research and development;
- Improve the quality and safety of our products and services; AND
- Detect security incidents and prevent fraud.
Please see the “How We Use Your Information” section in the Privacy Policy for a full description of how we use personal information.
Your CCPA Rights
The CCPA grants California consumers certain rights in connection with the personal information we collect, as described below.
- Right to Know: You have the right to know the categories and specific pieces of your personal information we have collected in the previous 12 months.
- Right to Deletion: You have the right to request that we delete any of the personal information we have collected.
- Right to Request Information: You have the right to request information about the collection, sale, and disclosure of your personal information from the previous 12 months.
- Right to Opt-out of the Sale of Information: You have the right to opt-out of the sale of personal information we have collected about you.
- Right to Non-Discrimination: You have the right to not receive discriminatory treatment for exercising any of your CCPA rights. We do not treat individuals differently for exercising any of the rights described above.
Exercising Your Rights
If you wish to exercise any of the above rights, see the “Contact Us” section in Appendix A. You may also authorize an individual to submit a verifiable consumer request relating to your personal information.We verify your request using your email address. Government identification may be required. We cannot respond to your request if we cannot verify your identity and/or authority to make the request on behalf of another and confirm the personal information related to you.If you wish to use an authorized agent to submit a request to opt out on your behalf, you must provide the authorized agent written permission signed by you, the consumer. We may deny a request from an authorized agent if the agent cannot provide Ripple with your signed permission demonstrating that the agent is authorized to act on your behalf.We fulfill requests within 45 days of receiving your request. Please note that your request may be limited in certain cases, for example, if complying with your request would conflict with:
- Federal, state, or local law;
- Regulatory inquiries;
- Subpoenas; or
- Exercising or defending legal claims.
Contact Us
To submit questions about Appendix A or to update or request changes to your personal information, please contact us at:
[email protected] or
[email protected]
Appendix B: General Data Protection Regulation Addendum
Additional provisions are applicable to the processing of personal information of individuals based in the European Union (“EU”), the United Kingdom (“UK”), or Switzerland.
Scope and Applicability
This Appendix B to the Privacy Policy (“Appendix B”) applies to individuals based in the EU, UK, and Switzerland, and outlines their rights and choices regarding the processing of their personal information under the General Data Protection Regulation or related regulations (collectively, the “GDPR”). Capitalized terms not defined in this Appendix B are defined in the Privacy Policy above.
Data Collection, Use, and Sharing
KillB acts as a data controller for personal information that we collect about individuals while using the Service as described in the Privacy Policy.We collect and process personal information about you only where we have a legal basis for doing so under applicable data protection laws. Our legal bases include processing personal information under:
- Your consent: Where appropriate or legally required, we collect and use information about you subject to your consent.
- Performance of a contract: We collect and use information about you to contract with you or to perform a contract that you have with us.
- Legitimate interests: We collect and use information about you for our legitimate interests to improve the Services, deliver content, optimize your experience, and market the Services.
- Compliance with laws: We may also collect and use information about you:
- As required by law, such as to comply with a subpoena or similar legal process;
- When we believe in good faith that disclosure is necessary to protect our rights or property, protect our health and safety or the health and safety of others, investigate fraud, respond to a government request; or
- If we participate in a merger, acquisition, or sale of all or a portion of its assets.
Transfer of Personal Information to Other Countries
We transfer your personal information to countries outside the EU, UK, or Switzerland, including, but not limited to the United States.If we transfer your personal information out of the EU, UK, or Switzerland and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so. Such safeguards may include applying the European Commission-approved standard contractual data protection clauses or other appropriate legal mechanisms.
Data Subject Rights
You have certain rights related to your personal information when you use the Services. Some of these rights only apply in certain circumstances, as set out below. We also describe how to exercise these rights in the “Exercising your Rights” section of Appendix B.The GDPR provides data subjects with the following rights:
- Right of Access: Data subjects have the right to request access and receive certain information about how we use their personal information and who we share it with.
- Right to Rectification: Data subjects have the right to request correction of personal information we hold about them where it is inaccurate or incomplete.
- Right to Data Portability: Data subjects have the right to request a copy of data we hold about them in a structured, machine-readable format, and to ask us to share this information with another entity.
- Right to Erasure: Data subjects have the right to request deletion of the personal information we hold about them:
- Where one believes that it is no longer necessary for us to hold their personal information;
- Where we are processing personal information based on legitimate interests and a data subject objects to such processing, and we cannot demonstrate an overriding legitimate ground for the processing;
- Where a data subject has provided their personal information to us with consent, and they wish to withdraw their consent and there is no other ground under which we can process their personal information; or
- Where a data subject believes their personal information is being unlawfully processed by us.
- Right to Restriction of Processing: Data subjects have the right to ask us to restrict (stop any active) processing of their personal information:
- Where they believe their personal information is inaccurate and while we verify accuracy;
- Where we want to erase their personal information as the processing is unlawful, but they want us to continue to store it;
- Where we no longer need their personal information for our processing, but they require us to retain the data for the establishment, exercise, or defense of legal claims; or
- Where they have objected to us processing their personal information based on our legitimate interests and we are considering their objection.
- Right to Object: Data subjects can object to our processing of their personal information based on our legitimate interests. We will no longer process their personal information unless we can demonstrate an overriding legitimate purpose.
- Objection to Marketing, Automated Decision-Making, and Profiling: Data subjects have the right to object to our processing of personal information for marketing communications, automated decision-making, and profiling. We will stop processing the data for that purpose.
- Withdrawal of Consent: Where a data subject has provided consent for us to process their personal information, they can withdraw their consent by emailing [email protected]
Please note that before we respond to requests for information, we will require identity verification or the identity of any data subject for whom one is requesting information. Our verification methods may include requesting that the data subject logs into their KillB account, confirm their contact information or email address, and/or provide documents for identity verification.KillB commits to resolving complaints about our collection or use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our privacy policy should first contact KillB at: [email protected] or
[email protected]
Exercising Your Rights
To exercise any of the rights above, please contact us as noted in the “Contact Us” section in Appendix B. We will fulfill your request within 30 days of receipt. Please note that the above rights may be limited in the following situations:
- Where fulfilling your request would adversely affect other individuals, company trade secrets, or intellectual property;
- Where there are overriding public interest reasons; or
- Where we are required by law to retain your personal information.
Contacting Us
To submit questions about Appendix B or to update or request changes to personal information, please contact us as outlined in the Privacy Policy or contact our Legal team at
[email protected].