PRIVACY POLICY www.konnectagain.com PART 1. GENERAL:
1.1 This Privacy Policy (the “Policy”) is a legal agreement between you (the “End User” or "you") and
KONNECTAGAIN, a limited company, whose operational place of business is at the Mainport Monahan
Road Blackrock Cork, Republic of Ireland, Companies Registration Office number 548250 for your
licensed use of and access to www.Konnectagain.com (the “Website”), [and the multi-Solution
smartphone and tablet software application (the “Application”) (together the Website and the
Application are hereafter described as the “Solution”) and your access to the education assessment and
monitoring services provided by Konnectagain and as described on the Website from time to time (the
"Services") in accordance with the terms of this Agreement.
1.2 Save as otherwise expressly defined in this Policy, or where a contrary intention is stated, each term and
phrase defined in the EULA shall, when used in this Policy have the meaning given to it in that
agreement.
1.3 Konnectagain respects the privacy of all End Users of the Solution and the Services. We are committed to
protecting the privacy of our End Users and we strive to provide a safe and secure End User experience.
1.4 This Policy sets out the types of information we collect and hold about you and which you submit to us
by means of the Solution, the purposes for which such information is collected, the uses made of such
information, details of any persons to whom we disclose such information and other steps we take to
protect your privacy.
1.5 Please be advised that all personal identifiable information (“Relevant Personal Data”) that you may
provide to us relating to you via the Solution, will be treated in accordance with the provisions of the
Data Protection Acts, 1988 and 2003 and any replacement or amending legislation.
1.6 You should read this Policy carefully before accessing or using the Solution.
1.7 You explicitly accept, without limitation or qualification, to the collection, use and transfer of the
Relevant Personal Data provided by you in the manner described in this Policy. IF FOR ANY REASON YOU
DO NOT AGREE TO THE PROVISIONS OF THIS PRIVACY POLICY, THEN YOU SHOULD NOT USE THE
SOLUTION OR, IF YOU HAVE ALREADY USED THE SOLUTION, THEN YOU SHOULD CEASE SUCH USE OR
ACCESS WITH IMMEDIATE EFFECT.
PART 2. POLICY SCOPE:
2.1 This Policy applies to the Solution and any other website or application notified to you in advance, which
is owned and or controlled by Konnectagain, its transferees or assignees. It is the policy of Konnectagain
to comply with Data Protection Laws regulating the collection, retention and processing of Relevant
Personal Data and accords certain rights to such Data Subjects in respect of their personal data.
KonnectAgain Privacy Policy Page 1 of 6 2.2 The Solution may contain links to other applications/websites over which Konnectagain has no control.
This includes third parties that embed our technology in their applications or link to our technology in
support of the Services. Konnectagain is not responsible for the privacy policies or practices of other
applications to which the Services are linked. We encourage you to review the privacy policies of those
other applications so you can understand how they collect, use and share your information. We do,
however, work with third parties to ensure that you are provided with the necessary information and are
provided with the opportunity to make your choice.
2.3 Please see the following list of 3rd Party analytic, survey, support and commentary platforms which are
used as part of the Services:
Google Analytics: http://www.google.com/intl/en/analytics/index.html
Google Maps: http://www.google.com/intl/en_ie/policies/privacy/
PART 3. END USER FOCUS
3.1 INFORMATION WE COLLECT AND RETAIN
3.1.1. General: Our primary goal in collecting Relevant Personal Data and user information is to provide you
with the best and most useful content to help improve your experience with the Solution. In addition to
any information you choose to submit to us, we or selected third parties, may use a variety of
technologies that store or access information already stored on a personal computer, laptop, tablet
and/or mobile phone (each a device) interacting with the Solution.
3.1.2 We collect certain kinds of information about our users for the following reasons:
a) To provide personalized services unique to individual users;
b) To help us monitor and improve the services we offer;
c) To verify your identity as an End User of the Solution and of a particular End User Account; and
d) To monitor use of the Solution to ensure the highest levels of security and safety are maintained.
3.1.3. Technologies we use: A few of the methods that may be used to store or access information already
stored on your device include the following (and in future other technology and methods will be
developed):
a) Cookies - a cookie is a text file placed on a device when a user visits a website. Cookies can be read by
the website on your subsequent visits. The information stored in a cookie may relate to your browsing
habits on the web page, or a unique identification number so that the website can ‘remember’ you on
your return visit. Cookies can be temporary (e.g. session) or permanent (e.g. persistent). They can also
be first party (e.g. placed by us) or third party (e.g. placed by a third party application)
The following is a listing of the main cookies used on our site together with brief details of the
information they store and for what purpose;
i)
Site performance cookies: This type of cookie remembers your preferences/settings for tools found on
the Solution.
ii) Analytics cookies: Every time a user visits our website, web analytics software provided by a third party
generates an anonymous analytics cookie. These cookies can tell us whether or not you have visited the
site before. Your browser will tell us if you have these cookies, and if you don't, we generate new ones.
This allows us to track how many individual unique users we have, and how often they visit the site.
Unless you are signed in to the Solution, these cookies cannot be used to identify individuals; they are
used for statistical purposes only. If you are logged in, we will also know the details you gave to us for
this, such as email address and password.
iii) Registration cookies: When you register with the Solution, we generate cookies that signal whether you
are signed in or not. Our servers use these cookies to work out which type of account you are signed in
with, and if you are allowed access to a particular service. It also allows us to associate any comments
you post with your End User Account. Konnectagain support a ‘keep me signed in’ feature resulting in no
need for you to sign in each time you close your browser or shut down your computer. You may select a
‘keep me signed in’ checkbox on the login page, which functions to keep you signed in for the duration
of your session and may last longer. We combine information from your registration cookies with
analytics cookies, which we could use to identify which pages you have seen on the Solution.
iv) Third party cookies: these are cookies found in other companies’ internet tools which we are using to
enhance our site, for example:
KonnectAgain Privacy Policy Page 2 of 6 Flash cookies—a Flash cookie (or locally shared object) is a data file placed on your device via the Adobe
Flash plug-in that may be built-in to or downloaded by you to your device. This can operate across all
your browsers.
HTML5—HTML5 cookies can be programmed through HTML5 local storage and do not require a plug-in
ETag or entity tag—an opaque identifier assigned by a web server to a specific version of a resource
found at a URL that acts as a form of device identifier.
Google Analytics Please note, the companies that generate these cookies have their own privacy policies Konnectagain
has no access to read or write these cookies, other than allowing them to be served, we have no role to
play in these cookies at all (although we may use statistical information arising from these third party
cookies and provided to us by third parties, to improve the targeting of content to End Users). These
third party cookies may be used by those third parties to anonymously target to you on other websites,
based on your visit to the Solution.
3.1.5. Your consent and your right to refuse the use of information collection technologies:
We obtain your consent to our information collection technologies through our opt-in mechanism on
registration and by providing you with transparent information in this Policy and providing you with the
opportunity to make your choice. You have the right object to the use of information collection
technologies. Regular cookies may generally be disabled or removed by tools that are available as part of
most commercial browsers, and in some but not all instances can be blocked in the future by selecting
certain settings. Each browser you use will need to be set separately and different browsers offer
different functionality and options in this regard. Also, these tools may not be effective with regard to
Flash cookies or HTML5 cookies. For information on disabling Flash cookies go to Adobe’s website
(www.adobe.com). Please be aware that if you disable or remove these technologies some parts of
our Platform website will not work and that when you revisit Konnectagain, your ability to limit
cookies is subject to your browser settings and limitations. Find out more about turning off cookies
on your browser at www.cookiecentral.com. 3.1.6. What we use the information for:
a) Non Personal:
As detailed above, we collect a certain amount of statistical, behavioural and non-personal information in
relation to your use of the Platform and the Services, including the content accessed, the Services you
access, referring website addresses, the number of visitors to the Platform and this information is used
to improve Platform functionality by making it easier to navigate, troubleshooting problems and by
allowing for us to provide relevant information on individual sections of the Platform.
b)
Relevant Personal Data:
In addition to collecting such statistical and non-personal information, we also collect Relevant Personal
Data from you when you contact us or you use any communication services which are made available on
the Platform. This may include among other items, such information as your name, email address, home
address, telephone number, billing information and any other information we reasonably require to
verify you as the End User Account holder. This information will only be kept by Konnectagain for the
duration of the existence of the registered account, plus a reasonable time, to facilitate back up and
subseqent access by you at a later time.
3.1.7 How information Is used:
We use the information submitted to and gathered, to support the Platform and the Services, we
aggregate data, provide reports, respond to any queries you may have, operate and improve the
Platform, and strive to foster a positive End User experience and delivery of the Services.
User Generated Content and private End User to End User correspondence is encrypted. Konnectagain
prides itself on its personal privacy and security based approach to the Platform. In short, we know that
our End Users are creating User Generated Content, they are communicating with each other and that
they are sharing information through the use of our Platform, but we do not know what that
information, data or communication is. We will not access this information without due cause in
accordance with the terms of this Policy.
KonnectAgain Privacy Policy Page 3 of 6 3.1.8. Registration:
By registering with Konnectagain, by managing your account, by using the Platform and the Services or
opting in when presented with choices, you have consented to Konnectagain’s use of your information,
subject to local law, in the following ways:
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to allow you to create an account;
to create a profile for you based on information that you have provided to us;
to contact you about Konnectagain updates, informational and service-related communications,
including important security updates;
to inform you of other products or services available from Konnectagain or its affiliates;
to enable you to provide feedback, to contact us and for us to respond to you;
to conduct surveys, questionnaires, promotions and contests;
to generate internal reports and information;
to allow you to your Alumni Network or Educational Institution;
to allow you to connect with the third party websites and applications linked to our Solution;
The only people that will contact you as a consequence of use of the Services are Konnectagain
employees or representatives and other End Users depending on your End User interactions with the
Solution.
All such contact will be performed in a secure manner through your account.
However, please note, if you post personal information in an area of the Solution which is a public area
or is capable of being accessed, used and stored by others around the world, including those in countries
that might not have legislation adequately guaranteeing the protection of your personal information, you
agree to hold Konnectagain harmless in respect of such action and any and all direct, indirect and
consequential losses arising therefrom. While Konnectagain takes measures to safeguard your
information from unauthorised access, Konnectagain does not accept responsibility for the use of
information posted or otherwise made available in a public area of the Solution, whether open to other
users where it would not normally have been or open to the public domain around the world. Please
ensure that you do not post sensitive information, including personal information to any public area of
the Solution. Furthermore, you are specifically precluded from removing content, whether User
Generated or otherwise, and posting it on third party platforms that are not expressly listed as
connected with Konnectagain either in this Policy or the EULA. A breach of this condition shall be
considered to be a material breach of the terms of the EULA and this Policy and is terminable at the
discretion of the Company.
Please note that ideas you post and information you share may be seen and used by other users, and
Konnectagain cannot guarantee that other users will not use the ideas and information that you share on
Konnectagain. Therefore, if you have an idea or information that you would like to keep confidential
and/or don't want others to use, or that is subject to third party rights that may be infringed by your
sharing it, do not share it on Konnectagain. KONNECTAGAIN IS NOT RESPONSIBLE FOR AN END USER'S
MISUSE OR MISAPPROPRIATION OF ANY CONTENT OR INFORMATION POSTED, UPLOADED, OR TRANSMITTED
WITHIN THE SOLUTION.
3.2. DISCLOSURE OF INFORMATION TO OTHERS
3.2.1. We disclose your information to third parties. This could be personal, behavioural, indirect or nonpersonal information. The rules governing such disclosure are set out below.
3.2.2. We may share your information with third parties who help us in the delivery of our own Services to
you. We disclose information to companies and individuals we employ or use to perform functions on our
behalf including the Educational Institution. Examples include hosting our web servers, analysing data,
providing marketing assistance, and providing customer service. These companies and individuals will
have access to your personal information as may be necessary to perform their functions, but they may
not share that information with any other third party or use that data for any other purpose. We will
remain the data controller of your Relevant Personal Data and be responsible for any information shared
in this way.
3.2.3. We also share aggregated anonymous information about visitors to the Solution with clients, partners,
the Educational Institutions and the Alumni Networks utilising our Solution and other third parties so that
KonnectAgain Privacy Policy Page 4 of 6 they can understand the kinds of visitors to the Solution and how those visitors use the Solution. Such
aggregated data does not identify users individually.
3.2.4. We disclose information if legally required to do so, or at our discretion pursuant to a request from a
governmental entity or if we believe in good faith – after considering your privacy interests and other
factors – that such action is necessary to: (a) conform to legal requirements or comply with legal
process; (b) protect our rights or property or our affiliated companies; (c) prevent a crime; or (d)
protect the personal safety of users or the public.
3.2.5. We may disclose and transfer such information to a third party who acquires any or all of
Konnectagain’s business units, whether such acquisition is by way of merger, consolidation or purchase
of all or a substantial portion of our assets. In addition, in the event Konnectagain becomes the subject
of an insolvency proceeding, whether voluntary or involuntary, Konnectagain or its liquidator,
administrator or receiver may sell, license or otherwise dispose of such information in a transaction
approved by the court. You will be notified of the sale of all or a substantial portion of our business to a
third party by email or through a prominent notice posted on the Sites.
3.2.6. Please note that certain information, statements, data, and content (such as photographs and videos)
which you may submit to Konnectagain, or groups or teams you choose to join might, or are likely to,
reveal your gender, ethnic origin, nationality, age, and/or other personal information about you. You
acknowledge that your submission of any information, statements, data, and content to us is voluntary
on your part.
3.2.7. Please note that you control the flow of information to and from your Konnectagain account and it is
based on the privacy settings in your account, which dictate what people can and cannot see or do. You
should review your permission settings on a regular basis so that you are fully aware of the information
being provided to other End Users.
3.3. POSTING TO PUBLIC AREAS
3.3.1. Please remember that if you post any Relevant Personal Data in public areas of the System, such
information may be collected and used by others over whom Konnectagain has no control. We cannot
control the use made by third parties of information you post or otherwise make available in public areas
of Konnectagain.
3.4. ACCESS, RECTIFICATION AND REMOVAL
3.4.1. You may have access to, review, correct, update, change or delete your account profile information at
any time. This is completed by simply logging into your account and making the necessary changes. Such
access must be completed through the verification or authentication log in process. Access may be
denied if you fail to enter the correct information.
3.4.2. Konnectagain retains all the information gathered about you in an effort to make your repeat use with
us more efficient, practical and relevant until you change or remove your personal data as described
herein. Under law, you have a right to access the personal information that we hold about you, for which
we may charge a fee. If you wish to access such information, please send an email to
info@Konnectagain.com.
3.4.3. We will respond to information access requests within 30 days of receipt. If we require additional time
to provide access to your information, we will acknowledge receipt of your request within 30 days and
promptly supplement our response within the time period required by applicable law.
3.4.4. If you wish to hibernate or close your account altogether, please contact us at:
info@Konnectagain.com.
a) Hibernation: You may, if this option is available to you, put your account on standby through your
account settings. This allows you to de-activate the account for a period of time and to re-activate it at
such time as you wish. You will be able to retrieve all your information and data as if you had never gone
chosen to hibernate.
b) Full Account Deletion: An email will be sent to you to confirm that your personal information has been
deleted (save for an archival copy which is not accessible by you or third parties on the Internet). The
archival copy is retained only for as long as Konnectagain reasonably considers necessary for audit,
security and record purposes. We will also retain logs, demographic, indirect, and statistical information
KonnectAgain Privacy Policy Page 5 of 6 that may relate to you and your account but do not identify you personally. If your personal information
was previously accessed by others using our Solution, we are not able to delete the information or copies
thereof from their systems.
3.4.5. If your account is terminated for any reason in accordance with the EULA and/or you do not log into
your account for a significant period of time, it will expire and be scheduled for deletion. Our current
expiration and deletion period is 36 months; we may extend or reduce this period in order to adjust to
changing patterns. If we change the period, we will update this notice. You will always receive an email
from us before we delete your account, and you always have the ability to delete your account at any
time by logging into your account. Deletion of expired accounts occurs on a periodic basis and includes
the deletion of all applicable account data including contact information.
3.4.6. If you do not want your information to be processed as described by this Policy, you may revoke your
consent to our Policy. If you wish to do so, please contact us at: info@Konnectagain.com. However,
please note that if you do withdraw your consent, you will not be able to use the Solution and the
Services and your account and profile information will be deleted.
PART 4. CONTACT
4.1 Unless you have indicated otherwise by ticking the "opt out" box when registering with us, we can use
your personal information to provide you with details of our services, products and promotions, including
contacting you by email. If at any time you no longer wish to receive such emails, you can unsubscribe
by clicking on the applicable link contained in the information email sent to you. You can also adjust
your registration details and opt out of receiving such emails and other communications by ticking the
appropriate "opt out" box or configuring this setting in your account settings.
PART 5. CHANGES
5.1 If we decide to materially change the substance of this Policy, we will, where required, contact you via
the email address that you maintain in your account. We will also post those changes through a
prominent notice on the Solution so that you will always know what information we gather, how we
might use that information, and to whom we will disclose it.
KonnectAgain Privacy Policy Page 6 of 6