Kezana General Trading LLC and its applicable subsidiaries and affiliates (collectively, “Kezana” or “we” or “us” or “our”)* respect your privacy and are committed to protecting it through our compliance with this Privacy Policy.
Kezana wants you to have a positive experience in connection with our products and services. We want you to know that we respect the privacy and security of our users. Our goal is to provide you with an experience that delivers the information, resources and services that are helpful to you. In order to achieve this goal, we may collect information from you. We discuss our information collection practices below. This Privacy Policy sets forth the privacy principles we follow, in accordance with our operations.
Kezana is a global e-learning resource company. We produce and/or distribute a range of online resources, applications and a network of websites directed to children under the age of 16 including but not limited to those for Nahlwa wa Nahel™ and WizzKidz™ (“Services”). This Privacy Policy sets forth the privacy practices with respect to your information when you use our Services to which this Privacy Policy is linked. By using any Service, as permitted by law, you agree to the terms of this Privacy Policy.
We market and sell our products to adults who purchase or otherwise subscribe to our Services, which can then be used by children at the direction and under supervision of these adults. We respect all of our users’ privacy, but we recognize the need to provide additional privacy protections with respect to the personal information we collect from children under 16. Accordingly, our privacy practices with respect to children under 16 are set forth in our Children’s Privacy Policy.
A SPECIAL NOTE TO CHILDREN. If you are under 16, please get permission from your parent or legal guardian before using our Services. You must be 18 or older to purchase or otherwise subscribe to any Service. We do not market or sell to children under 18, and we seek consent from a parent or legal guardian wherever we identify that a minor attempts to purchase or register for a subscription to any Service.
A SPECIAL NOTE TO PARENTS. Please help us protect your children’s privacy by instructing them never to volunteer their personal information online without your permission.
For any questions on this Privacy Policy or our data practices, or to send in a data subject access request, you can contact us using one of the following methods:
*For a list of Data Protection Representatives see the table at the end of this Privacy Policy.
We collect two main types of information: personal information (“Personal Information”) and non-personal information (“Non-Personal Information”).
Personal Information is information that identifies you as an individual or relates to an identifiable individual and may include: title, date of birth, unique identifier (e.g., account number), school name, class year, company name, job function, expertise, postal address, telephone number, email address, credit card information, geolocation, certain device information, and IP address.
As a customer, prospective customer, or user of our Services, we may collect Personal Information such as your name, photo or other image or recording, contact information including phone number and email address, school name, class year and country or state of residence or school. We may also collect details of other interactions that you have with us, together with any other information that you choose to provide us with, for example, through your interactions with our customer and technical support teams. We do not however collect any unnecessary Personal Information from users (for instance, information about religious beliefs). It is impractical in most circumstances for you to remain anonymous, and we may not be able to interact with you, provide access to the Services, or answer your enquiry if we are not able to identify you or collect your Personal Information.
Non-Personal Information is any information that does not reveal your identity or does not relate to an identifiable individual. This might include anonymous identifiers and information, analytics and usage information, non-precise geolocation, and web server log files to track Website trends, administer the Website, and gather demographic information.
We may collect your Personal Information in a number of ways, including:
In the case of School Customers, we seek consent from the School Customer to be provided with user information for and on behalf of that student or teacher. In the case of individual / home subscriptions (“Home Customers”) we seek consent from the Home Customer at the time of purchasing and registering the product to use the information collected. Where the Home Customer is a student who is a minor, we ask that permission be sought by that student’s parent / legal guardian. Users who do not give this consent (or do not have this consent provided on their behalf) cannot provide us with their Personal Information and cannot use the Services. You can however withdraw your consent at any time.
If you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
We automatically collect non-Personal Information, generated from your use of our Services. We use this non-Personal Information in the aggregate. We do not combine these types of non-Personal Information with Personal Information.
Cookies: Kezana and our third-party partners may place a "cookie" or other tracking or information gathering device used in the industry in the browser files of a user's computer. A cookie is a piece of data stored on the user's hard drive containing information about the user. We use cookies to collect information about your use of our Services, which enable us to track and target the interests of our users. We then use that information to solely enhance the user’s experience within our Services. We also use cookies from third-parties for analytics purposes. Third-party cookies are covered by the third-party’s privacy policy.
Users can set their browsers or third-party software to reject cookies. The means by which you can refuse cookies through your web browser controls vary from browser-to-browser, so we recommend you visit your browser's help menu for more information. Please note that if a user rejects or disables certain cookies, the user may be unable to use portions of our Services. Some of the third-party websites we provide links to also may use cookies. We have no control over these linked websites or access to or control over cookies or other technology used by linked websites.
The following is a list of the cookies that may be used in some or all of the Services:
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Type |
Purpose |
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Essential |
We use these strictly necessary cookies to provide you with services available through our Services and to use some of its features. |
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Preference |
We use these cookies to remember your settings and preferences. |
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Security |
We use these cookies to authenticate users and help identify and prevent security risks. |
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Performance |
We use these cookies to collect information about how you interact with our Services and to help us improve them. |
In addition, some of our websites use cookies provided by third-parties in order, for example, to improve our performance or services. Some examples of cookies we use within our Websites are as follows:
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Product |
Type and Name |
Purpose |
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All Products |
Analytics Cookie from Google Analytics |
A third-party cookie provided by Google, Inc. that collects aggregate statistical data about how visitors use the Websites (i.e., what pages users visit, how long they are on the Websites, how they got there and what they click on) so that we can improve the user experience and serve up the content our visitors find most useful. You can find out more about Google’s privacy policy concerning its analytics service at Google privacy policy. |
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All Products |
Advertising Cookie from Google Adwords |
A third-party cookie provided by Google, Inc. that collects data about your activities within the Services to provide you targeted advertising, but does not personally or directly identify you. You can find out more about Google’s privacy policy concerning its advertising features at Google privacy policy. You can opt out of being tracked by Google Analytics across all websites here. You can also opt out with Ad Settings or the NAI’s consumer opt-out. |
Our websites may use social media features, such as the Facebook ‘like’ button (“Social Media Features”). These features may collect your IP address and which page you are visiting on our websites, and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on our Websites to a profile page of yours that is provided by a third-party Social Media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.
We use information we collect for the following purposes:
The Services do not provide students with any means of direct communication with each other. There are no chat rooms connected with the Services.
Access to and use of customer feedback forums is designed for use by parents, teachers and other contributors who are not legally minors.
We may use the Personal Information and non-Personal Information we collect by sharing it with third-party agents, vendors, contractors, partners, or content providers of Kezana (collectively, "Contractors") for purposes of managing purchases of our products and services, servicing our systems, and obtaining support services for our businesses. We are not in the business of selling Personal Information to third-parties or Contractors, and will share it with Contractors only as we describe in this Privacy Policy. In situations where we provide Personal Information to Contractors, we ensure access is granted to the Contractors only upon the condition that the Personal Information is kept confidential and is used only for carrying out the services these Contractors are performing for Kezana. As part of making that determination whether we will provide Personal Information to Contractors, we will obtain assurances that they will appropriately safeguard Personal Information consistent with this Privacy Policy.
The Personal Information we collect from you may be transferred to, and processed in, countries other than the country in which you live. These countries may have data protection laws that are different to the laws of your country. Specifically, the servers we use to provide our Services are located in the United States. This means that when we collect your Personal Information, we may process it in the United States or the country where you live. However, when we process your Personal Information, irrelevant of its processing location, we take appropriate safeguards, as discussed below, to require that your Personal Information remains protected in accordance with this Privacy Policy.
We may share your usage data related to our Services with our affiliates for purposes of providing or improving our Services. We will not disclose any information about your usage data related to our Services to unaffiliated third-parties, except as necessary to enhance the product experience, to enforce the terms of use, to meet our contractual obligations to report aggregated usage data to content providers, or as required by law.
We may provide data on results to schools in the case of School Customers, who use the features of our Services (such as performance reporting tools) for educational/teaching purposes. We will require School Customers to comply strictly with our instructions, use the information only for legitimate educational interests and not for any commercial purposes.
We also reserve the right to disclose your Personal Information if we are required to do so by law, or in the good faith belief that disclosure of the information is reasonably necessary to comply with legal process, and to the extent permitted by applicable local law, to respond to claims, or to protect or advance the rights, property, safety, or well-being of our company, our employees, customers, or the public.
We will not use your Personal Information for automated-decision making.
In the unlikely event that all or substantially all of the assets of Kezana are acquired, customer information, which may include Personal Information, may be one of the transferred assets unless restricted by applicable local law.
Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect Personal Information from you only (i) where we need the Personal Information to perform a contract with you or your organization, (ii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you or your School, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible impact if you do not provide your Personal Information).
Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact information provided above.
TechKnoweldge has taken appropriate technical and organizational measures to ensure that Personal Information we have collected or will collect in the future is secure. For example, we have limited the number of people who have access to Personal Information, by electronic security systems and password protections that guard against unauthorized access. As a reminder, Kezana provides links to third-party websites. These websites may not have the same privacy policies as Kezana. We take reasonable care in recommending these websites but we are not responsible for their content or privacy policies. We urge users to read the privacy statement of a third-party website when leaving our Services and linking to a third-party website.
We always use industry-standard technologies when transferring and receiving consumer data we receive. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you in connection with our Services.
We want to assure you that you have access to your Personal Information that we collect and store. Upon request, we will provide you with information about whether we hold any of your Personal Information. You may contact us using the contact information stated above to exercise the following rights:
We will respond to your request within thirty (30) days of receipt.
If you have granted consent, you can withdraw your consent at any time with future effect. Please address your withdrawal by contacting us in writing or by email at the contact information stated above.
If you are located in the EU, after May 25, 2018, you have the right to lodge a complaint with a supervisory authority in relation to the processing of your Personal Information.
We understand that you may not want to allow our disclosure of your Personal Information to our Contractors, or to let us use that information for purposes that you believe may be incompatible with the purpose for which it originally was collected (as permitted by this Privacy Policy) or that you later may authorize. Therefore, you may contact us to inform us that you do not want to permit these uses of your Personal Information. To do so, please contact us using the contact information provided above.
It is important to us that the Personal Information we collect is appropriate and relevant to the purposes for which we intend to use it. We will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the person providing the information. Kezana will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.
You may sign-up to receive email newsletters or other marketing materials from us. If you would like to discontinue receiving this information, you may immediately update your email preferences free of cost by using the “Unsubscribe” link found in emails we send to you or at your account settings on our website or by contacting us at privacy@Kezana.net.
We retain Personal Information we collect from you where we have an ongoing legitimate business interest or other legal need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no further legitimate business interest or legal need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
Upon request, Kezana will tell you if we process any of your Personal Information. Depending on your country of residency, you may have legal rights with respect to your Personal Information. As such, if you would like to manage, change, limit, or delete your Personal Information, you can do so via the account settings or by contacting us using the information provided above. We will respond to your request within a reasonable timeframe.
If we process your Personal Information based on our legitimate interests, you can object to this processing in certain circumstances. In such cases, we will cease processing your Personal Information unless we have compelling legitimate grounds to continue processing or where it is needed for compliance and/or legal reasons. Where we use your Personal Information for direct marketing purposes, you can always object or opt out by using the “Unsubscribe” link in found in emails we send to you or by contacting us at privacy@Kezana.net.
If you have any questions, comments, or concerns regarding this Privacy Policy or our practices, please contact us at privacy@Kezana.net.
We will notify you of changes to this Privacy Policy by posting an updated policy on this page. You acknowledge that any use of our Services is based on this Privacy Policy, current at the time of use. If we make any material changes, we will notify you by means of a notice via the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
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Al Manhal Data Protection Representative |
Country of Business Registration |
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[to be inserted] |
[to be inserted] |
Kezana General Trading LLC and its applicable subsidiaries and affiliates (collectively, “Kezana” or “we” or “us” or “our”)* respect your privacy and are committed to protecting it through our compliance with this Children’s Privacy Policy.
Kezana is a global e-learning resource company. We produce and/or distribute a range of online resources, applications and a network of websites directed to children including but not limited to those for Nahlwa wa Nahel™ and WizzKidz™ (“Services”). This Children’s Privacy Policy applies to information we collect from users of our Services. When we use the word “child” or “children” in this Policy, we mean a user under the age of 16. When we use the word “parent” in this Privacy Policy, we mean a child’s parent or legal guardian.
We recognize the need to provide additional privacy protections with respect to information we collect from children on our Services. This Children’s Privacy Policy explains our information collection, use, disclosure and parental consent practices with respect to the information we collect from children, and it is a part of and uses the terms that are defined in our general Privacy Policy. The provisions of this Children’s Privacy Policy will prevail in the event of a conflict with the terms of our general Privacy Policy.
We market and sell our products to adults who purchase or otherwise subscribe to our Services, which can then be used by children at the direction and under the supervision of these adults. Certain of our Services offer online learning tools that children may access and that may collect Personal Information from children. We identify below potential instances of such collection and describe how and when we will provide parental notice and seek prior verifiable parental consent.
We do not knowingly collect, use, disclose or store any Personal Information from children unless we have obtained prior verifiable parental consent. In any instance where we collect Personal Information from a child, we will not collect more Personal information than is reasonably necessary for the child to participate in the Service, and we will retain that information only as long as reasonably necessary to fulfill the request or allow the child to participate in the Service, ensure the security of our users and Services, or as required by law. In the event that we discover that we have inadvertently collected information from a child in a manner inconsistent with applicable legal requirements, we will delete that information and attempt to notify the child’s parent. If you believe that we might have collected Personal Information from your child without consent, please contact us.
As described in our general Privacy Policy set forth above, we do not allow children to purchase or otherwise subscribe to any Service; our account creation feature is intended strictly for adult teacher or parent use, and we take measures to make this apparent in order to prevent children from submitting Personal Information to our Service in this manner.
An adult teacher or parent purchaser of any Service may open an account for a child by creating the child’s student login credentials. We collect student user credentials each time a child logs in to the student portal to access the Services. In addition, the student’s user credentials are collected and displayed on the online classroom roster in the teacher portal. We will not use this information for any purposes other than authenticating the student’s login and facilitating student access to the Services. Our staff is not authorized to disclose student login information; information regarding student login credentials is strictly controlled by the teacher or parent.
We collect and retain Personal and Non-Personal Information from users who choose to send us a message or chat with us via our Services, when you send us an email, or when you sign up for a newsletter. Children are not permitted to communicate with us directly using these means, and we take measures to make this apparent in order to prevent children from submitting Personal Information to us in this manner.
Nevertheless, if a child corresponds with us, we will collect the child’s Personal Information to directly respond to the child’s request for assistance on a one-time basis, and we will delete the child’s Personal Information after responding.
We automatically receive and record certain technical information from a child’s browser, including the child’s IP address, for internal purposes only. When we collect an IP address, we combine it with other information submitted by the user’s browser, such as requests for files from the web server. We compile this information to create access logs, which we analyze to determine trends, such as which pages are used the most, which browsers are most frequently used by visitors to access the site, and which areas of the world site users are accessing our products from most frequently. Our access logs do not contain any information which can be uniquely associated with any particular IP address or Personal Information about any individual user.
Certain activities on certain Services allow children to create or manipulate content and save it on our Services. Some of these activities do not require children to provide any Personal Information. If a Service requests or allows a child to provide Personal Information in their created content, we will seek prior verifiable parental consent in order to collect that information. Examples of created content that constitute or may include Personal Information include the following:
We do not use student voice recordings or the information provided by children in open-text fields for any internal purpose; we only transmit the voice recordings and the content provided in open-text fields to the child’s teacher, where it can be reviewed or downloaded. Students may not share student voice recordings or the information provided in open-text fields with anyone else, and they cannot privately communicate with anyone using the Service.
Additional educational information is collected as the child progresses through the Service, such as amount of time logged in, reading rate, and assessment scores. This information allows the Service to adapt to the child and inform the teacher on the child’s progress.
For parent purchasers, in the event we wish to collect the Personal Information outlined above from a child, we provide parental notice and seek verifiable parental consent via the email address provided during account creation. In our initial email, we describe what Personal Information we collect from children, how we collect it, how we use it, how we disclose it, how the parent can consent to collection of such information, and your parental rights over such information. This email contains an activation link you must click. We send another email message to confirm we have obtained consent after a reasonable time delay. In this confirmatory message, we indicate how the parent can revoke consent to our collection of Personal Information.
Where a school contracts with us to offer the Services solely for the benefit of their students and for the school system and for no other commercial purpose, the school may consent to the collection of children’s Personal Information on parents’ behalf. We encourage schools and school districts using our Services to notify parents that our Services are being used in their schools.
We do not provide any child’s Personal Information to third parties - we use this information for internal purposes only.
Parents who have received access to the parent portal have access to classroom reports that show the number of activities completed by each student; each student’s progress on incomplete activities; the number and time each student logged in; the bonus and incentive stars earned; student rankings; and the accuracy level for each skill group a teacher creates.
At any time, parents or schools operating as the agent of parents can request to review any Personal Information collected about a child, have such information deleted, and/or request that there be no further collection or use of a child’s Personal Information. Adults with teacher access may remove children by deleting them from their classroom roster. Parents may do this by contacting the account holder associated with their child and requesting deletion. We take steps to confirm that anyone requesting Personal Information about a child is in fact the child’s parent or authorized school agent. A request to delete Personal Information about a child or a request that there be no further collection or use of their child’s Personal Information may lead to the termination of an account, membership or other service. Upon written request by a school, we will delete any Personal Information collected from students, and we will provide written verification that the information has been destroyed as requested.
If you no longer wish to have Personal Information of a child collected by an application installed on a mobile device, you may uninstall the application by using the standard uninstall processes available on the mobile device or via the mobile application marketplace or network.
The technical, administrative, and physical security measures we employ to safeguard and help prevent unauthorized access to all information we collect through our Services is described in our general Privacy Policy.
If you have any questions, comments, or concerns regarding this Privacy Policy or our practices, please contact us at privacy@Kezana.net.
We will notify you of changes to this Privacy Policy by posting an updated policy on this page. You acknowledge that any use of our Services is based on this Privacy Policy, current at the time of use. If we make any material changes, we will notify you by means of a notice via the Services prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.