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Privacy Policy

Effective as of October 2018

We at Kithward Inc. (“KW,” “we,” “us,” or “our”) have created this Privacy Policy because we know that you care about how information you provide to us is used and shared.  This Privacy Policy relates to the information collection and use practices of KW in connection with our Website and Services.


The Information We Collect and/or Receive

In the course of operating the Website and the Services, and/or interacting with you, KW will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1. Personal Information

We do not collect any personal information from you, unless you provide such information voluntarily, such as by registering with us as an CBLS or a Consumer, by posting User Content, or by sending us an e-mail.  Consumers may register with us via social media platforms such as Facebook or Google. Such social media platforms are operated by the social networks themselves and are subject to their terms of use and privacy policies.  If you use such third-party social media platforms, you are authorizing KW to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that Facebook or such other third parties could provide to us through their application programming interface (“API”).  Such information may include, without limitation, your first and last name, Facebook username, Facebook profile picture, unique Facebook identifier and access token, and e-mail address.  All information we collect and/or receive under this section is collectively called “Personal Information.”

2. Business Information.

We collect information about CBLS, including their business names, locations, business hours, amenities and offerings, contact information, and other relevant information, both directly from CBLS and from publicly available records (“Business Information”).  

3. Other Information.

In addition to the Personal Information and Business Information, we may automatically collect or receive additional information regarding you and your use of our Website, your interactions with us and our advertising, as well as information regarding your computer or other devices used to access our Website and use of our Services (collectively, the “Other Information”).  Such Other Information may include:

a. From Your Activity  

  • IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
  • Browser type and language;
  • Referring and exit pages and URLs;
  • Date and time;
  • Details regarding your activity on the Website, such as search queries, amount of time spent viewing pages, and other performance and usage data.

b. About Your Device  

  • Type of device;
  • Advertising Identifier (“IDFA” or “AdID”);
  • Operating system and version (e.g., iOS, Android or Windows);
  • Carrier; and
  • Network type (WiFi, 3G, 4G, LTE).

c. From Cookies

We may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them and other technologies to help us collect data and to enhance your experience with the Website.  Cookies are small text files a website can use to recognize a repeat visitor to the website. We may use cookies for various purposes, including to:

  • authenticate users;
  • personalize your experience;
  • analyze which portions of the Website are visited or used most frequently; and
  • measure and optimize advertising and promotional effectiveness.

If you do not want KW to deploy cookies in your browser, you can opt out by setting your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software.  If you choose to disable cookies in your browser, you can still use the Website and Services, although your ability to use some of the features may be affected.

d. Third-Party Analytics and Remarketing

We, the Website, and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, and ad servers with which we may work use third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Website and mobile and Internet usage.  These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

For more information on these third parties, including how to opt out from certain data collection, please visit the sites below.  Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website.

For Google Analytics, please visit

For Mixpanel, please visit

e. From You.   

Additional information that you voluntarily provide to us, such as ratings of CBLS and other information that does not identify you personally.

The Information Collected by or Through Third-Party Advertising Companies

We may share Other Information about you with third parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, and retargeting), analyzing, managing, reporting, and optimizing of ads).  These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect Other Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.  In addition, we may receive Other Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.

Neither we nor any third party acting on our behalf employs behavioral advertising or retargeting in connection with users whom we know to be under 13 years old.

How the Information is Used and Shared  

You authorize us to use the Personal Information, the Business Information, and the Other Information (collectively, the “Information”) to provide and improve our Website and Services; to solicit your feedback; to inform you about our products and Services and those of our promotional partners and participating organizations; and for ad optimization.     

You also authorize us to use and/or share Information as described below.

  • We may employ other companies and individuals to perform functions on our behalf.  Examples may include providing technical assistance, customer service, marketing assistance, and administration of our rewards and promotional programs.  These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

  • In an ongoing effort to better understand our users, the Website, and the products and services of KW and our promotional partners, we may analyze certain Other Information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Website and/or such products and services.  This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties, including registered CBLS. We may also disclose aggregated user statistics in order to describe the Website and the Services to current and prospective business partners and investors and to other third parties for other lawful purposes.

  • We may share some or all of your Information with any of our parent companies, subsidiaries, or other companies under common control with us.

  • As we develop our businesses, we might sell or buy businesses or assets.  In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

  • To the extent permitted by law, we may also disclose the Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of KW or others.

Accessing and Modifying Information and Communication Preferences

If you have provided us any Personal Information and Business Information, you may access, remove, review, and/or make changes to the same by logging onto your account on the Website, or by contacting us as set forth below.  In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any KW marketing e-mail. We will use commercially reasonable efforts to process such requests in a timely manner.  You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to the Website (e.g., requests for support).

Sharing of Your Information with Non-Affiliated Third Parties

We will not share your Personal Information with non-affiliated third parties that may use such information to market to you, without obtaining your opt-in consent. For example, we may offer you a product opportunity that requires us to share your Personal Information with non-affiliated third parties that may use such information to market to you. We will obtain your opt-in consent to such sharing of your Personal Information when we present you with the terms of such offer.  If you have opted-in for this kind of sharing, then you may: (i) choose to opt-out of such sharing by contacting us at; or (ii) request certain information regarding our disclosure of such information to such non-affiliated third parties by contacting us at Further, if you would like to opt-out of our sharing of your Information with our affiliates so that such affiliates can use your Information to market to you, please contact us at

How We Protect Your Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.  Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet.  In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notices to Non-U.S. Residents

The Website and its servers are operated in the United States and elsewhere.   Please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.  If you are located outside the United States and choose to use the Website, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

External Websites

The Website may contain links to third-party websites.  KW has no control over the privacy practices or the content of these websites.  As such, we are not responsible for the content or the privacy policies of those third-party websites.  You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Important Notice to Non-U.S. Residents

The Site and our servers are operated in the United States.  Please be aware that your Information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin.  If you are located outside the United States and choose to use the Site and/or Service, you do so at your own risk.


The Website is not directed to children under the age of 13.  KW adheres to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect Personal Information from any child under the age of 13.  We ask that minors (under the age of 13) not submit any Personal Information to us. If you are under the age of 13, you may use the Website only with the consent of your parent or guardian.

If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with KW may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes.  If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to with “Privacy Policy” in the subject line.

In addition, KW does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.  For instructions on how to opt out of third-party interest-based advertising, please see the section on how to opt out of third-party Interest-based advertising above.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time. Any such changes will be posted on the Website.  By accessing the Website after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes.  Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information.  Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at with “Privacy Policy” in the subject line.