Privacy Policy of Kiwi Browser




Kiwi Browser is a product developed in Estonia by:
  Geometry OU
  Sepapaja tn 6
  15551 Tallinn
  Harjumaa
  Estonia

Data controller is Arnaud Granal - arnaud _at_ geometry.ee

Policy summary


We are based in Europe, and respect privacy laws of Europe (generally considered as very good).

We do not collect the websites that you visit. What you do in the browser is your own freedom and responsibility.

When you enter a search query, the query is sent to the Search Engine that you have selected
(Find.Kiwi by default, Google, DuckDuckGo, or any provider of your choice).

At Kiwi Browser, we respect your privacy, and we understand the importance of the information you entrust to us. This Privacy Policy describes the practices concerning Geometry OU through the use of the (i) websites and applications (the Kiwi Browser Products) and (ii) our Search Applications made available by means of a search box on a Kiwi Browser Product or website from which you can access our search services.

Collectively, we refer to the Kiwi Browser Products and these Search Applications in this Privacy Policy as the Kiwi Browser Services.
Geometry OU respects the privacy of users of the Kiwi Browser Services, and has developed this privacy policy (the Privacy Policy) to demonstrate our commitment to protecting your privacy. This Privacy Policy is intended to describe for you the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.We encourage you to read this Privacy Policy carefully. If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us. Unless indicated otherwise Kiwi Browser Services are subject to our Terms of Service, this Privacy Policy, and for downloadable software (where applicable) the End User License Agreement. Certain Kiwi Browser Services may be subject to different privacy policies and/or terms of service as indicated on the sites or applications from where those services are available and/ or accessed.

A. Who we are

Geometry OU, an Estonian limited liability company registered at Sepapaja tn 6, 15551 Tallinn, Estonia under registry code: 14122528
Estonia is part of European Union and is subject to European Union privacy laws and guarantees.


B. What we do

We provide a browser that is free to use for Android platform.

C. How we collect information

Personal Data collected for the following purposes and using the following services:

    • Analytics

      • Facebook Analytics

        Usage Data (metrics, like how many times you opened the app or crashes) not your browsing data / history / cookies

    • Device permissions for Personal Data access

      • Device permissions for Personal Data access

        Personal Data: Approximate location permission (continuous), Calendar permission, Camera permission, Microphone permission, Motion sensors permission, Phone permission, Precise location permission (continuous), Sensors permission and Storage permission

  

    • Push notifications

      This Application may send push notifications to the User.








D. Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, Calendar permission, Camera permission, Precise location permission (continuous), Approximate location permission (continuous), Microphone permission, Phone permission, Sensors permission, Storage permission and Motion sensors permission.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
All Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service.

We may collect information from you in a variety of different ways. This is information that may identify you, and anonymous information, such as the number of your page views, link clicks, and login times. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it. We provide further detail on the type of info we collect, and how we collect it, below:

Information You Provide To Us.


We may collect and store any information you provide when using the Kiwi Browser Services or that you provide in some other manner. This information may include information such as:
Your name, email address, telephone number, username and password if, and only if, you registered or created an account using these details and asked us to store this information for processing purposes.

We also collect and store information and other content you post to the Kiwi Browser Services, where such features are made available.

Further, in order to permit us to protect the quality of our products and services, we may to the extent permitted by applicable law access your account and records on a case by case basis to investigate complaints or other allegations.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

E. Methods of processing


The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.


The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Further, in order to permit us to protect the quality of our products and services, we may to the extent permitted by applicable law access your account and records on a case by case basis to investigate complaints or other allegations.



To process your information as described above, we rely on the following legal bases:


Provide you with the Kiwi Browser Services: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to provide you with a more customized and personal experience.

Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users behavior on our services to continuously improve our offerings, ensure it is bug free, and we process information for administrative, fraud detection and other legal purposes.

Consent: From time to time, we may ask for your consent to use your information for certain specific reasons (example: on Find.Kiwi). You may withdraw your consent at any time.

G. Where do we store the information

The Data is processed at the Data Controller's operating offices (Estonia) and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

H. How long we keep the information

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

I. The use of the collected Data

The Data concerning the Usage is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Content performance and features testing (A/B testing).

The Personal Data used for each purpose is outlined in the specific sections of this document.

J. Device permissions for Personal Data access

Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.


Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy

The Data Controller is responsible for this privacy policy.


K. Data protection officer

For our EEA users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached by contacting team at geometry.ee


L. Children's privacy

Our Kiwi Browser Services are intended for general audiences over the age of 13 years old (or over the age of 16 if you are resident in the EEA). We do not knowingly collect information from children under the age of 13 years old, or 16 in the EEA. If you are not over 13 years old (or 16 years old in the EEA) then DO NOT DOWNLOAD OR USE KIWI BROWSER.


M. Your rights


Depending on your location you may have some or all of the following rights in relation to how we use your information:

Access ‑ you may request access to your information and receive copies of it;

Correction to have inaccurate/incomplete information corrected and updated;

Object to, or Limit or Restrict, Use of your Information: You can ask us to stop using all or some of your information or to limit our use of it.

Deletion - in certain circumstances, you can request a right to be forgotten (this is a right to have your information deleted or our use of your information restricted, including for example, a right to not have a users name appear in a search result). Ww will honour such requests unless we have to retain this information to comply with a legal obligation by European or Member State law or unless we have an overriding interest to retain it


Portability- in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your information to transfer to another provider)

Consent Management - Where we rely on consent to process your information, you may withdraw consent at any time and you do not have to provide a reason for your withdrawal.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

Cookies

Small piece of data stored in the User's device.


Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.