Privacy Policy

Kount Inc. (Kount) is committed to maintaining the privacy of personal information that you provide to us when using any of our online services. This privacy policy describes how we treat the information we receive when you transmit data to any machine owned by Kount.

Web Form Information

When you submit information to Kount, we may collect personally identifiable information from you that may include your name, address, and email address. We do not knowingly collect personal information from persons under the age of 18.

Web Site Usage Information

We automatically collect IP addresses and web site usage information from you when you access any of our online services. This information helps us evaluate how our visitors and subscribers use and navigate our web sites on an aggregate basis, including but not limited to the number and frequency of visitors and subscribers to each web page, and the length of their visits.

How We Use Information Collected

We may use information in the following ways:

• For the purposes you specifically provided the information including, for example, enabling us to respond to your questions about our products and services.
• To register you as a client and establish an account for you.
• To send you email notifications about our new or existing Kount products and services, special offers, or to otherwise contact you.
• To enhance existing features or develop new features, products, and services.
• To provide advertisers and other third parties with aggregate information about our user base and usage patterns.
• To allow us to personalize the content and advertising that you and others see based on personal characteristics or preferences.
• To detect and prevent fraudulent transactions.

Except as specifically set forth in this privacy policy, we will not share your personally identifiable information outside of Kount.

We may disclose and use personally identifiable information in special circumstances where it is necessary to enforce our service agreements or terms of use (for example to protect our intellectual property rights). We may also disclose or use your personal information when we, in good faith, believe that the law may require us to do so.

Service Providers, Business Partners and Others

The Company may employ third party companies and individuals to facilitate our service, to provide the service on our behalf, to perform Site-related services (including but not limited to maintenance services, database management, web analytics and improvement of our web sites’ features) or to assist us in analyzing how our web sites and services are used. These third parties have access to your personal Information only for purposes of performing these tasks on our behalf.

Business Transfers

The Company may sell, transfer or otherwise share some or all of its assets, including your personal information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Cookies

We define a cookie as any string of data that is automatically stored on your computer upon access to our online services. Kount employs cookies to assign temporary identification numbers to machines that access our web servers. This information enables us to deliver faster service to our subscribers, prevent denial of service attacks on our systems, detect and prevent fraudulent transactions. All Kount cookies are:

• Of limited duration
• Less than 5KB in length
• Only visible to Kount web servers
• Devoid of any personally identifiable information

Security

The personally identifiable information we collect about you is stored in limited access servers. We maintain safeguards to protect the security of these servers and your personally identifiable information. We retain personally identifiable information only as long as necessary to complete a purchase, thwart fraud, provide customer service, or maintain your account with us.

U.S. - EU Safe Harbor Framework

Kount, Inc.(Kount) recognizes that the European Union (EU) has a data protection regime enacted by Directive 95/46/EC of the European Parliament ("Directive"). The Directive governs the transfer of personal data about individuals in the EU to the United States (US). Personal data is defined as any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of such person. Transfer of such personal data from the EU to the US is restricted unless there is "adequate protection" for such information when it is received in the United States. To address the restrictions in the Directive, Kount adheres to the EU Safe Harbor Privacy framework and the U.S.-Swiss Safe Harbor Framework published by the US Department of Commerce ("Safe Harbor") . Those principles include Notice, Choice, Onward Transfer, Access and Accuracy, Security, and Oversight/Enforcement. A description of the Safe Harbor principles can be found at http://www.export.gov/safeharbor/eg_main_018247.asp

Frequently asked question with regard to the Safe Harbor can be located here.

Kount is a "processor" of personal data as defined in Article 2 (e) of the Directive. Kount provides processing services in the US for its European Union business partners (EU Business Partners) which include merchants and financial institutions. Kount also provides processing for US based business partners. We act as a data processor and data importer on behalf of our EU Business Partners, and accordingly we follow the instructions provided by each EU Business Partner with regard to the collection, processing and protection of personal data provided to us by each such EU Business Partner. Each EU Business Partner acts as the data controller and data exporter for any personal data within its control. Residents in the EU should contact the applicable EU Business Partner with questions regarding the collection of their personal data.

Because Kount’s processing of the data relates to "the prevention, investigation, detection and prosecution of criminal offences," it may be exempt from portions of the Directive. More details regarding this exemption are available at this link under Article 13, Section 1 (d). Reference here.

If residents of the EU have questions regarding this policy please send an email to privacy@kount.com or written correspondence can be addressed to EU Privacy Mailbox:

Kount has further committed to refer unresolved privacy complaints under the US-EU [and EU-Swiss] Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Kount, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Policy Modifications

We may change this privacy policy from time to time. We will post any changes here, so please check back periodically.

Comments and Questions

If you have any questions, comments or concerns about our privacy policy, you may contact us at privacy@keynetics.com.

This policy was last updated 27 January 2012.