PRIVACY POLICY
This Privacy Policy governs any information you provide on this site as well as your user account.
  1. Overview
  2. Collected Information
  3. Information Use and Disclosure
  4. Information Security
  5. Accessing and Updating Your Information
  6. Contacting Us
  1. Overview
    In order to operate the Kinsail service and to reduce the risk of fraud, Kinsail Corporation, ("Kinsail" or "we") must ask you to provide us information about yourself and your credit card and/or bank account. This Privacy Policy describes the information we collect and how we use that information.

    Kinsail takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the Kinsail family of web sites, whether the services are offered by Kinsail or by its subsidiaries.

    By way of Kinsail's privacy policy, we endeavor to clearly notify you of:
    1. The personally identifiable information of yours that is collected by Kinsail;
    2. The organization collecting the information;
    3. How the information may be used;
    4. Any parties with whom the information may be shared;
    5. Any options available to you in regards to the collection, use and distribution of the information;
    6. The security procedures and policies that are in place to protect the loss, misuse or alteration of information under Kinsail's control;
    7. How any inaccuracies in the information can be corrected.
    If you have questions or concerns regarding this Privacy Policy, you should first contact Kinsail using our contact form.

    By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Kinsail User Agreement. This Privacy Policy will take effect on January 1, 2002. This Privacy Policy was last updated on January 1, 2007.

    Please note that your personal information will be stored and processed on our computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of your country but Kinsail will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the Kinsail service.

    Notification of Changes
    This policy may be revised over time as new features are added to the Kinsail service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 days' notice of the amended Privacy Policy (if you have closed your Kinsail account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner).

    We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Kinsail Web site at www.kinsail.com at any time for the most current version of our Privacy Policy.

    Any of the Kinsail family of web sites may include links to third party Web sites. These sites are governed by their own privacy statements, and Kinsail is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.

    A Special Note About Children.
    Children are not eligible to use our service and we ask that minors (under the age of 18) have a parent of legal guardian submit any necessary information to us or use the service on the child's behalf.

  2. Collected Information
    Required Information
    To open a Kinsail account, you must provide your name, address, phone number, and e-mail address. In order to make payments through Kinsail, you must provide credit card, debit card or bank account information. This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and checking account fraud, and to contact you should the need arise in administering your account.

    Transaction Information
    When you use Kinsail to pay for any goods or services, we collect and capture the information related to each transaction, including the amount of the transaction, the type of transaction, and any other information pertinent to the transaction. We retain this information for each of your transactions through Kinsail. We also collect the Internet address (IP address) of the computer or device you use to access your Kinsail account, in order to help detect possible instances of unauthorized transactions.

    Information About You From Third Parties
    In order to protect all our customers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you use a credit card or debit card through Kinsail, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to Kinsail, and that the card has not been reported as lost or stolen.

    If you are using Kinsail to process transactions on your company or organizations behalf, in some circumstances we may conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service such as Dun & Bradstreet. If you incur a debt to Kinsail, we may conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. Kinsail, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account, and reserves the right to close an account based on information obtained during this credit review process.

    Additional Verification
    If we cannot verify the information that you provide, we may ask you to send us additional information by fax (such as your drivers' license, credit card statement, and/or a recent utility bill or other information linking you to the applicable address) or to answer additional questions online to help verify your information.

    Web Site Usage Information
    Because of the way that Internet-based communication standards operate, when you arrive at or leave the Kinsail Web site, we automatically receive the Web address of the site that you came from or are going to. While you are on one of the Kinsail family of web sites, we also collect information on which pages you visit, the type of web browser you use, and the times you access our Web site. We use this information only to try to understand our customers' preferences and usage patterns better and to manage the load on our servers, so as to improve our service and your experience with Kinsail. We do not track the Web sites that you visit before or after you leave the Kinsail site.

    Our Use of "Cookies"
    "Cookies" are small files of data that reside on your computer and allow us to recognize you as a Kinsail customer if you return to the Kinsail site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your Kinsail account by entering your e-mail address and password. These cookies are in a format that is readable only to the Kinsail servers and is secured using a combination of security measures. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

    We also use longer-lasting cookies in conjunction with our web site traffic information collection to better understand our customers preferences and usage patterns. These longer-lasting cookies contain no personally identifiable information.

    Customer Service Communications
    If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Kinsail to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

    Questionnaires, Surveys and Profile Information
    From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.


  3. Information Use and Disclosure
    Internal Uses
    We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order:
    1. to provide our services and process your transactions,
    2. to provide customer service,
    3. to determine your eligibility to receive offers for special features or products, and
    4. to improve our products and services.
    At your option (as indicated in your Kinsail Profile settings), we use the information you provide to access specific third party services on your behalf and perform the actions that you request us to perform.

    We authorize access to individually identifiable information about our users only to those employees who require it to fulfill their job responsibilities.

    Disclosure to Other Kinsail Customers
    If you are a company or organization for whom Kinsail accepts transactions on your behalf, we may display your Web site address (URL) and customer service contact information that you provide us to Kinsail users. For any transactions that are processed by the Kinsail system, credit card number, bank account and other financial information will NEVER be revealed to anyone to whom you have paid or who has paid you through Kinsail, except with your express permission or if we are required to do so pursuant to a subpoena or other legal process.

    If you are buying goods or services and paying through Kinsail, the seller of the goods or services may request that you provide a mailing address that Kinsail has confirmed as matching the billing address in the credit card system. You do not have to provide this information. If you do not provide the information, however, the seller may choose not to accept your Kinsail payment and not to complete the transaction.

    Disclosure to Third Parties Other Than Kinsail Customers
    Kinsail will not sell or rent any of your personally identifiable information to third parties. Kinsail will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission (and with other Kinsail customers as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.
    1. We share information with companies that help us process the transactions you request and protect our customers' transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. See "Information About You From Third Parties" in Section II above. We may disclose the information we collect from you to companies that market Kinsail-related products and services on our behalf. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.
    2. We may disclose the information we collect (but not your bank account or credit card information) to other institutions with whom we have joint marketing agreements for the products that Kinsail is jointly marketing with these institutions. These institutions are subject to confidentiality agreements with us and other legal restrictions that prohibit using the information except to market the specified Kinsail-related products or services, unless you have affirmatively agreed or given your prior permission for other uses.

      If you do not want Kinsail to share any of your information with these financial institutions who are our joint marketing partners, please log in to your account to set your preferences on the Edit Account tab to indicate that you do not want to receive Partner/Third-Party Promotions.
    3. We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information (but not bank account or credit card information) to victims who request it.
    4. We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
    5. When a user signs up for a co-branded version of Kinsail through links to Kinsail from our co-branded partner's website, Kinsail will share with the co-branded partner that user's name, e-mail address and physical address in order to provide enhanced integration between Kinsail's services and the services of our co-branded partner.
    6. We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
    7. We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in California. However, this aggregated information is not tied to personally identifiable information.
    8. As with any other business, it is possible that Kinsail in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by Kinsail, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section I above.
    9. We share your information with our parent, subsidiaries, affiliates and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
    Our Contacts with Kinsail Customers
    We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a Kinsail account, to send you notice of transactions that you complete through Kinsail, to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

    We also use your e-mail address to send you other types of communications that you can control, including the Kinsail periodic updates, tips, customer surveys and notice of special third-party promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your user account on the Kinsail Web site and changing your preferences in the Edit Account tab. You can also change your choices at any time through the same procedure.

    In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

    Internet Address Information
    We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.

    Your Use of Information and Our Services
    In order to facilitate the interactions between Kinsail users and clients, our service allows you limited access other users' information. As a client you may have access to the email address and other contact or shipping information of the user, and as a user you may have access to the email address and other contact information of the client.

    Any information that you enter into the Kinsail system, except protected payment information details, is available for your review and, in some case, edit via your user account. You can remove your payment details at any time by logging into your user account and clicking on the Edit Account tab. If you wish to completely close your account with Kinsail, you may do so by contacting our customer support department using our contact form.

    Kinsail does not tolerate spam and junk email. Therefore, without limiting the foregoing, you may not add a Kinsail user to your mail list (email or physical mail) without their express consent after adequate disclosure. We strictly enforce our Anti-Spam Policy. To report Kinsail-related spam to Kinsail, please contact us.

  4. Information Security
    Kinsail is committed to handling your customer information with the highest standards of information security. Your credit card and bank account information are stored only in encrypted form on computers that are not directly connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes. If you have any questions about Kinsail's security practices, please contact us .

    The security of your Kinsail account also relies on your protection of your Kinsail password. You may not share your Kinsail password with anyone. Kinsail will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the Kinsail website, which will always have a URL beginning with https://secure.kinsail.com/, https://ssl.kinsail.com/, or https://www.kinsail.com/.

    Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with https://secure.kinsail.com/secure/ should be treated as unauthorized and suspicious and should be reported to Kinsail immediately using contact us . If you do share your Kinsail password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at https://secure.kinsail.com/secure/myaccount/ and changing your Profile settings, and also contact us right away as described in Section 6 below.

  5. Accessing and Updating Your Information
    You can review the personal information you provided us and make any desired changes to such information, or to the settings for your Kinsail account, at any time by logging in to your account on the Kinsail Web site and changing your preferences in the "Edit Account" tab. You can also close your account by contacting us using our contact form. If you close your user account, we will mark your account in our database as "Closed," but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.

  6. Contacting Us
    If you have any questions about this privacy statement, Kinsail's information practices, or your dealings with Kinsail, you can contact us using our contact form, call 703-994-4194 Monday through Friday between the hours of 9am and 6pm Eastern Time, or write us at Kinsail, 6878 Fleetwood Road, Unit E, McLean, VA 22101.
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