Last Modified: May 3, 2021
Throughout this Policy, we refer to the term “Personal Information.” “Personal Information” means data which identifies, describes, is associated with, or could be linked to an individual, such as a name, birthdate, postal address, email address, telephone number, driver’s license number, Social Security Number or other government-issued identification number, credit card number, or other unique identifiers.
Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. Also, we may collect information related to businesses, companies, institutions, or other entities rather than individuals (“Business Information”). We do not consider Business Information, such as title, employer’s name, work email, work phone number, work address, and other similar business information, to be Personal Information.
Information we Collect
We collect information about you in two ways: 1) directly from you; and 2) indirectly from you via your use of the Site.
Information Collected Directly From You
When you contact us using our Site or in connection with the Site you are posting material, completing applications, purchasing products or services, or requesting additional services, we will collect certain Personal Information about you so that we may adequately respond to your inquiry or offer services to you such as your first and last name, postal address, email address, phone number, your profession within the mineral industry and whether you are a mineral owner. Although we limit access to certain pages, please utilize the privacy settings for additional security features by logging into your account. Information Collected Indirectly from You When you visit our Site, we may collect information about your visit and maintain that information in our web server logs, which are records of the activities on our Site. The servers automatically capture and store the information electronically. Examples of the information we may collect include: Internet Protocol (IP) address; browser type and language; Internet Service Provider (ISP), referring and exit websites and applications; operating system; date/time stamp of activity; clickstream data; whether you are a first-time or a returning user; links you clicked on while in the Site; and your flow and navigation path through the Site. We use this information in a deidentified and aggregated fashion to help us administer the site, analyze its usage, protect the website and its content from inappropriate use, and improve your Site experience. In some of our email messages, you will find a “click-through URL” linked to content on our Site. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click such links in our email messages.
We use technologies, such as “cookies,” so we can remember certain information about you, remember your preferences, or recognize you when you return to the Site. Cookies also help us compile aggregate data about Site traffic and Site interaction so that we can improve our Site and protect our Site from fraud.
A cookie is a text file that is stored on your computer. As text files, cookies cannot read information on your hard drive, run programs, or deliver viruses to your computer.
Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. If you decline cookies, you may find that you cannot access all our Site’s features.
During your browsing session, we use “session” cookies to store information and monitor Site function. These session cookies are installed during your browsing session and are deleted when the browsing session has ended.
We also use log files when you visit our Site. Log files track IP addresses, browser type, Internet Service Provider (ISP) identity, referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information in our legitimate interest in administering the Site, preventing fraud, tracking website navigation in the aggregate, and gathering broad demographic information for aggregate use.
Web beacons, also known as clear GIFs, are often used in combination with cookies. Often transparent, these images are part of web pages, and allow us to count users who have visited certain pages and to generate statistics about how our Site are used. They are not used to access Personal Information
Pixel tags enable us to send email messages in a format that customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to you.
We use third-party website analytics software from third-party providers [e.g., Hubspot Google Analytics, GA Connector, Live Chat, Crazy Egg, DialogueTech, Facebook Pixel] in connection with our Site to gather data such as age, gender, and interests to provide advertising targeted to suit your interests and preferences.
This analytics software helps us target our online ads based on information collected directly from you or by automated means, like cookies. These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.
You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at https://support.google.com/adwordspolicy/answer/1316548?hl=en and edit or opt-out of your Google Display Network ads preferences at http://www.goog.com/ads/preferences/.
KEDI utilizes Google Analytics, Google Search Console, and Google Ad Manager analytics software provided by Google. This software collects anonymous information that is not used to identify a particular user. This information helps us better understand how visitors use our Site, detect and defend against fraud and other security risks, and present advertisements, products, and/or services of interest to you.
To learn more about how Google Analytics collects and processes data, please visit “How Google users data when you use our partners; Site or apps”, located at www.google.com/policies/privacy/partners/. To learn about how to opt out of Google Analytics, please visit http://tools.Google.com/dlpage/gaoptout/.
Our Site is not directed at children. We do not knowingly collect Personal Information from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the information in the “Questions and Contact Information” section, below, and we will take steps to remove such Personal Information from our systems.
Use of Personal Information
We only use your Personal Information for the original purposes it was given and to further our legitimate business interests, such as to verify your identity, to transact business, to provide information about our company and products and services, and to communicate with Site visitors. Personal Information is used also to provide you with a more enjoyable, convenient online experience. We may use your Personal Information to send you requested information, to personalize content for you, to compile, analyze, and better understand user data, demographics and behavior, and to detect, investigate, and prevent activities that may violate our policies or be illegal. We may also use your Personal Information to communicate with you about products and services we believe you might find of interest and to administer marketing materials and surveys in which you might participate.
We also use the information automatically collected about you during your use of the Site, as described above, to improve the effectiveness of our website, operations, mobile experience, or marketing efforts, to prevent against fraud and theft, and otherwise to protect our Site’s visitors and our business. Our employees, agents, or contractors may view your Personal Information to perform their jobs and address your needs. We authorize their access to your Personal Information on a need-to-know basis to provide you with our products or services, or for one of the other reasons listed in this section, and always in connection with a contractual obligation to protect the privacy of that information.
We may also provide your Personal Information to Stripe, a third-party software vendor who assists us with processing credit cards. Stripe may be given the Personal Information identified above or information about your credit or debit card to allow us to complete your purchases of products or services. Stripe uses that information only to complete your purchases and orders and deletes that information once orders are complete. We may also use information you provide to us to communicate with you in the future. If you do not wish to receive such communications, you may opt out (unsubscribe) as described below in the “Access and Consent to Use of Your Personal Information” and “Questions and Contact Information” section.
Disclosure of Your Information
We will not sell, rent, or lease any Personal Information we collect from you to others. We will not make your Personal Information available to any unaffiliated parties, except as follows:
- • To employees, contractors, agents, website vendors, and/or contractors who may use it on our behalf of or in connection with their relationship with us;
- • To our affiliates, service providers, and third-parties [e.g., Google Analytics and Stripe] for marketing purposes, building targeted ad campaigns, and completing your order of products or services.
In addition, we may share aggregate, non-individual information, incapable of identifying a person, with third parties for lawful purposes. We will not disclose any of your Personal Information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under circumstances described in this Policy.
We also allow search engines such as Google, Bing and others to index the Site, which means that any information submitted via this Site is subject to public view. Search engines are a large part of how people find the Site, and are thus a crucial factor in what makes the Site valuable. We consider all personal contact information posted by Users within forum posts as spam and subject to deletion without notice. The default privacy settings on the Site allow your posts and profile to be publicly viewable. Feel free to adjust your privacy settings as you see fit.
Access and Consent to Use of Your Personal Information
If you believe that the Personal Information that we have collected about you is incomplete, inaccurate, or not up to date, or if you would like to review and/or request changes or deletion of that information, please see the contact information in the “Questions and Contact Information” section.
If you do not consent or want to withdraw your consent for us to collect, use, or disclose your Personal Information as described in this Policy, please use the contact information provided in the “Questions and Contact Information” section. In your request, please identify the Personal Information at issue and the collection, use, or disclosure you wish to stop.
Denying or withdrawing consent may not allow us to provide you with some or all the products, services, or information you request. You may opt-out of receiving marketing-related emails, targeted advertising messages, or promotional offers from KEDI by clicking the “unsubscribe” link at the bottom of any email you receive from us or emailing us at email@example.com.
Your California Privacy Rights
If you are a California resident, you may have certain rights with respect to your Personal Information including the following rights:
- The right to know, by way of our Policy and any specific inquiries you direct to us, where Personal Information we have about you comes from, what we use that information for, whether it is being disclosed or sold, and to whom it is being disclosed or sold;
- The right to “opt-out” of KEDI’s sale of your Personal Information to any third parties, in the event KEDI sells data;
- The right, with some exceptions, to have your Personal Information deleted from KEDI’s possession or control; and
- The right to receive equal service and pricing from KEDI even if you exercise any of your privacy rights.
California Civil Code Section 1798.83 permits users of the Site who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. A California resident may also use an authorized agent to submit a right to access request or a request to delete. To make such a request, to learn more, or if you have any questions or concerns about your California privacy rights, please visit the Privacy Notice for California Residents as shown below.
California “Do Not Track” Disclosure
“Do Not Track” is a preference you can set in your web browser to let websites you visit know that you do not want them collecting data about you. At this time, this Site does not respond to Do Not Track or other similar signals.
European Economic Area
The following section, in conjunction with the information above, describes KEDI’s data practices in accordance with the GDPR.
Legal Basis of Processing
- • Individuals have given their consent for one or more specific purposes. Note: Under some jurisdictions, Personal Information may be processed until the individual objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to United Kingdom and European data protection laws;
- • Provision of Personal Information is necessary for the performance of an agreement and/or for any pre-contractual obligations thereof;
- • Processing is necessary for compliance with a legal obligation;
- • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Golden Goal; and
- • Processing is necessary for the purposes of the legitimate interests pursued by Golden Goal or by a third party.
Access to Information and Your Rights
For United Kingdom and EU residents subject to the GDPR, you have certain rights relating to your Personal Information, subject to local data protection laws. These rights may include:
- • To access your Personal Information held by us (right to access);
- • To rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete (right to rectification);
- • To erase/delete your Personal Information, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
- • To restrict our processing of your Personal Information to the extent permitted by law (right to restriction of processing);
- • To transfer your Personal Information to another controller or processor, to the extent possible (right to data portability);
- • To object to any processing of your Personal Information carried out on the basis of our legitimate interests (right to object). Where we process your Personal Information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
- • To the extent we base the collection, processing, and sharing of your Personal Information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
To exercise these rights, please submit your specific request by using the information in the “Questions and Contact Information” section below.
Timeframe for Responding to Requests
KEDI will respond to your request within thirty (30) days of receipt. The period of response may be extended to forty-five (45) or sixty (60) days if more time is required. In that event, we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
Security of your Personal Information
We are committed to protecting the information we receive from you. We take appropriate security measures to protect your information against unauthorized access to or unauthorized alteration, disclosure or destruction of data. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on our system. KEDI uses SSL Protocol and SSL Encryption for this purpose.
When personal information (such as a credit card number) is transmitted by KEDI to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.
Links to Other Websites
Retention and Accuracy of Personal Information
We do our best to ensure that the Personal Information we hold, and use is accurate. We rely on the individuals we do business with to disclose to us all relevant information and to inform us of any changes. Personal Information is kept only for so long as is required, in accordance with our records retention policy and legal and regulatory requirements.
We may maintain your Personal Information on computers and servers located outside of your state of residence, country, or economic region. However, we only process, store, and collect data, including Personal Information, in the United States.
Changes to the Policy
From time to time, we may change this Policy and will notify you of material changes by posting the changed or modified Policy on our Site. Any changes will be effective immediately upon the posting of the revised Policy unless otherwise specified.
Questions and Contact Information
If you have any questions, wish to access, correct, or amend your Personal Information or unsubscribe, want to register a complaint or simply want more information, you may contact us at:
KED Interests, LLC
California Privacy Notice
Last Modified: May 3, 2021
When we use the term “Personal Information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Any other terms defined in the CCPA have the same meaning when used in this Privacy Notice.
Personal Information We Collect We collect Personal Information from and about you for a variety of purposes. To learn more about the types of Personal Information we collect, the sources from which we collect or receive Personal Information, and the purposes for which we use this information, please refer to the “Information We Collect” section in our Policy.
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
Categories Examples Collected Categories of Sources Identifiers A real name, Internet Protocol address, email address, or other similar identifiers. Y Direct user entry into online forms or through email communications; Google Analytics, Shopify, Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories. Y Direct user entry data into online application forms Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). N N/A Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Y Shopify, Google Analytics Biometric information Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. N N/A Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Y Google Analytics Geolocation data Physical location or movements. Y Google Analytics Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. N N/A Professional or employment-related information Current or past job history or performance evaluations. N N/A Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. N N/A Inferences drawn from other Personal Information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. N N/A
Not included in the definition of Personal Information is information that is publicly available, information that has been de-identified or aggregated, or information exempt from the purview of the CCPA, such as:
- Protected Health Information (“PHI”) governed and protected by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; and
- Personal Information regulated by certain industry-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Purposes for Collection, Use, and Disclosure of Personal Information
Generally, we may collect, use, or disclose the Personal Information about you for one or more of the following purposes: (a) To fulfill or meet the reason you provided the information; (b) To administer our Site; (c) To market to you; (d) To address and remedy any inquiries or complaints made by or about you related to our services; (e) To recognize you and remember your information when you return to our Site; (f) To help maintain the safety, security, and integrity of our services, technology assets, and business; (g) To operate, maintain, and provide to you the features and functionality of our services; (h) To personalize your experience and to deliver custom content and product and service offerings relevant to your interests; and (i) To respond to law enforcement requests.
We may also use or disclose your Personal Information in accordance with your consent, when required by law to do so, or if it is necessary for a corporate transaction (such as a merger or acquisition). We will not collect additional categories of Personal Information or use the Personal Information for materially different, unrelated, or incompatible purposes without providing you additional notice.
Sharing of Personal Information
We may share the information we collect as described in this section of the Privacy Notice. We may share this information for the following reasons:
We may share the information we collect with KEDI affiliates to, among other things, provide the services you have requested or authorized and to help us manage the availability and connectivity of the Site.
With Employees, Contractors, and Agents
We may share information we collect with our employees, contractors, and agents, including third-party service providers, that perform services and functions at our direction and on our behalf, but their use of such information shall be limited to the performance of their duties and is consistent with our purposes for using such information.
With Other Third Parties for a Business Purpose or as Permitted or Required by Law:
We may share information about you with other parties [e.g., Google Analytics, GA Connector, Live Chat, Crazy Egg, DialogueTech, Facebook Pixel] for our business purposes or as permitted or required by law, including: (a) to comply with a law, legal process or regulations; (b) responding to or cooperating with law enforcement authorities, other government officials or other third parties pursuant to a subpoena, a court order or other legal process; (c) to protect the vital interests of a person; (d) to protect our property, services and legal rights; (e) to companies we plan to merge with or be acquired by; and (f) to support our audit, compliance and governance functions.
California Rights and Choices
The CCPA provides California residents with certain rights regarding their Personal Information (subject to certain limitations at law). The following section describes your CCPA rights and explains how to exercise those rights.
Right to Access and Portability
California residents have the right to request that we disclose certain information about our collection and use of Personal Information over the last twelve (12) months. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will disclose to you the following:
- The categories of Personal Information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting or selling that Personal Information;
- The categories of third parties with whom we share that Personal Information;
- The specific pieces of Personal Information we collected about you (also called a data portability request); and
- If we disclose your Personal Information for a business purpose, identifying the Personal Information categories disclosed.
We will deliver a verifiable access request and the accompanying information to you in a portable, easily readable electronic format.
Right to Deletion
The CCPA allows California residents the right to request that we delete any Personal Information about you that we collect and retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will delete (and in turn direct our service providers to delete, if applicable) your Personal Information from our records, unless an exception applies.
We may deny a deletion request if retaining the information is necessary to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity;
- Debug products to identify and repair errors that impair existing intended functionality;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Enable solely internal uses that are reasonably aligned with consumer expectations;
- Comply with a legal obligation and requests from law enforcement agencies; and
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Opt-Out of the Sale of Your Information
We do not sell data, as it is defined in the CCPA, will not sell Personal Information in the future, and in the preceding twelve (12) months, have not sold any Personal Information.
To exercise the access and deletion rights under the CCPA as described above, please submit a verifiable consumer request by completing the online form or firstname.lastname@example.org.
Verifiable Consumer Requests
A verifiable consumer request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. These requests for access, which can only be made twice during a twelve (12) month period, and deletion must:
- Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Timeframe for Responding to Requests and Format
We will respond to your request within thirty (45) days of receipt.
The period of response may be extended to sixty (60) or ninety (90) days if more time is required. In that event, we will inform you of the reason and extension period in writing.
Fee We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
No Discrimination The CCPA prohibits a business from discriminating against California residents for exercising the rights outlined above. We will not discriminate against you for submitting such requests by:
- Denying goods or services to you;
- Charging different prices or rates for goods or services, including through the use of discounts, benefits, or other penalties;
- Providing a different level or quality of goods or services; and
- Suggesting a different price or quality of goods or services will apply if rights are exercised.
No Financial Incentive
We do not offer any financial incentives or price or service differences in an attempt to influence a resident’s decision whether or not to exercise a right afforded to the consumer under the CCPA.
Our Site is not directed at children. We do not knowingly collect Personal Information from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the information in the “Contacting Us” section, below, and we will take steps to remove such Personal Information from our systems.
A California resident may use an authorized agent to submit a right to access request or a request to delete. To use an authorized agent, the California resident must provide the agent with written authorization. In addition, the California resident may be required to verify their own identity with us. KEDI may deny a request from an agent that does not submit proof that they have been authorized by the California resident to act on their behalf. Such requirements, however, will not apply where a California resident has provided the authorized agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.
Updates to this Privacy Notice
We may update or change this Privacy Notice. The effective date at the top of this page states when this Privacy Notice was last revised. Any change to this Privacy Notice will become effective when we post the revised Privacy Notice on our Site. Your use of our Site means you accept our Privacy Notice.
If any change may materially and negatively affect the privacy of your Personal Information, we will use reasonable efforts to notify you in advance and give you a reasonable time to object to any changes.
We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and share Personal Information.
Contacting Us Use the contact information below if you have questions, concerns or complaints about this Privacy Notice or our privacy practices or would like additional information about KEDI’s privacy practices.
KED Interests, LLC
Email Address: email@example.com