Kleinrock Digital Networks

Privacy Policy
Last Updated July 8 2019


Kleinrock Digital Networks Ltd. and its affiliated companies (hereinafter referred to as "KDNetworks" or "we") with website address http://www.kdnetworks-sl.com (the "Site") is committed to protecting and respecting your privacy. Therefore, we developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data while on our Websites. Please read carefully and familiarize yourself with our privacy practices before using our products (or services) or providing your personal data.


This policy will help you understand the following:

I           Definitions

II          How We Use Cookies and Similar Technologies

III         How We Collect and Use Your Personal Data

IV         How Long We Keep Your Personal Data

V          How We Disclose Your Personal Data

VI         How We Protect Your Personal Data

VII        Your Rights with Regards to Your Personal Data

VIII       Third-Party Service Providers and Their Services

IX         How This Privacy Policy is Updated

X          Getting Additional Information


      I.         Definitions


Affiliated Company” refers to a company that is related to KDNetworks due to joint ownership or control.


Third Parties” refer to companies or persons who do not have a related relationship arising out of joint ownership or control with KDNetworks (i.e., a non-affiliated company) or other non-related persons. Third parties can be financial or non-financial companies, or persons other than you and KDNetworks.


Personal Data” refers to any information relating to an identified or identifiable natural person.


     II.         How We Use Cookies and Similar Technologies


1.     What are cookies?


Cookies are small text files which are transferred from our websites, applications or services and stored on your device. KDNetworks websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. Cookies may be stored on your computer for a short time (such as only while your browser is open) or for an extended period of time, even years. Cookies not set by this site will not be accessible to us.


2.     Our cookie usage


§  KDNetworks and its partners use cookies or similar tracking technologies to better understand the performance of our website on your device, tell us how often you use the website, the events that occur within sessions, aggregated usage, and performance data. We do not link the information we store within the analytics software to any personal data you may submit within our website.


§  KDNetworks and our partners use cookies or similar tracking technologies to analyze trends, administer the websites, track users’ movements, around the websites, and to gather demographic information about our user base as a whole.


§  Many web browsers have Do Not Track function. Such function can issue Do Not Track request to websites. If Do Not Track is enabled on your browser, all of our websites will respect your choice.


§  As true of most websites, we gather certain information automatically.  This information may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.


§  We partner with third parties to display advertising on our website or to manage our advertising on other sites. Our third-party partners may use cookies or similar tracking technologies in order to provide you advertising based upon your browsing activities and interests.


3.     Removing/disabling cookies


Managing your cookies and cookie preferences must be done from within your browser's options/preferences. Here is a list of guides on how to do this for popular browser software:


§  Microsoft Internet Explorer

§  Microsoft Edge

§  Mozilla Firefox

§  Google Chrome

§  Safari for macOS

§  Safari for iOS


4.     More information about cookies


For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.allaboutcookies.org website.


    III.         How We Collect and Use Your Personal Data


KDNetworks collects data for efficient operations and to provide you with the best product experience. Our channels for collecting personal data include: (1) you provide us your data directly, (2) we record certain data about how you interact with our products, and/or (3) we obtain certain data about you from third parties.


The data we collect depends on the environment in which you interact with KDNetworks, the choices you make, including your privacy settings and the products and features you use.


1.     Personal data we collect


1)     Information directly provided by you


The services we provide for you require you to provide information directly to us. For instance:


a.     Creating and online account or buying goods from our online store requires you to create an account or to complete a personal profile. In these services, we may ask you to provide personal data to set up an account or a personal profile. Types of personal data include name, mobile number, email address, and password created, photos, etc.


b.     If you order products from us, request a return or refund, we may collect your delivery details, bank account number, credit card details, billing address, information for credit check and other financial information, contact and communication records, etc., so we can process your order.


c.     Some of our services allow you to communicate and share with others. The communicated or shared content may be transmitted through and stored in our system.


We may ask you to provide personal data and collect it under other circumstances, these circumstances include participating in prize draws or competitions, participating in promotional or marketing activities organized by us or our business partners, completing questionnaires, participating in user forums or blogs hosted by us or our business partners. The information you provide helps us design and improve the products, personalize your shopping experience, and provide purchase suggestions. We may match your information with third-party data to better understand your needs.


2)     Service usage information


In addition to the information you provide, we may also collect information about your use of our services through software on your device and other means. For example, we may collect:


a.     Device information — such as device name, device model, region and language settings, device identification number (IMEI number, etc.), device hardware information and status, usage habits, IP address, operating system version, and settings of the device used to access the service.


b.     Log information — such as when and how long the service is used, search terms entered through the service, and error log information of your device. We promise not to use such information for personal identification and after analyzing the error log data, we will periodically clear such data (usually within 30 days after collection).


3)     Obtaining data from a third party


Where permitted by law, we may obtain data about you from public or commercial sources and may combine it with other information received or relevant to you.


2.     How we use your personal data


We may process your personal information for the purposes described in this Privacy Policy with your consent, to perform our obligations to you, for compliance with a legal obligation to which KDNetworks is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by KDNetworks or a third party to whom it may be necessary to disclose information. KDNetworks will strictly abide by the terms of this Privacy Policy and its updates to use your personal data. Your personal data will only be used for the purpose determined at the time of collection, which has been approved by you. If there is any use other than this, we will obtain your consent in advance. Examples of related usages are as follows:


§  Provide and improve our products. The personal data we collect will be used to provide you with KDNetworks products and services, process your orders or fulfill the contract between you and KDNetworks to ensure the functionality and safety of our products and services, to verify your identity, to prevent and investigate fraud or other improper use.


§  Customer Support. We use data to diagnose product issues, support customer equipment, and provide other customer care and support services.  We also use this information to improve our products and analyze the efficiency of our business operations. However, we will not use this information to track your location. We may also collect your email address to reply your questions or comments raised in the “Contact Us” section of our websites.


§  Product Improvements. We use data to constantly improve our products, including the addition of new features and functionality. For example, we use error reports to improve security. We use mobile phone numbers obtained through offline sales channels, electronic warranties, and account registrations to conduct survey and return visit to users in order to improve user experience.


§  Advertising. The personal data we collect will be used to personalize the product and to provide you with more tailored services, for example: your information can be used to recommend and display content and advertisements tailored to you on our services, or be used to conduct research and pay return visits to customers. In order to improve our products or services, with your consent, we may match your personal data with third-party data to form a user profile so that we can conduct product development or deliver targeted product information to you (through post, email and phone).


§  Commercial Promotion Activities. If you participate in prize draws, contests or similar promotional activities held by KDNetworks, we will use the personal data you provide to manage such activities.


We will acquire your consent in advance when the information is to be used for a purpose that is not specified in this Privacy Policy. We will acquire your consent in advance when the information collected for a specific purpose is to be used for other purposes. Without consent of users, we will not provide third parties with users’ personal data and behavior data.


   IV.         How Long We Keep Your Personal Data


Our retention period for personal data is the minimum time necessary to realize the purpose of collection unless a longer retention period is required by law. Beyond the above retention period, we will delete or anonymise your personal data.


     V.         How We Disclose Your Personal Data


At times KDNetworks may make certain personal information available to affiliated companies and strategic partners that work with KDNetworks to provide products and services. Your information will not be shared with third parties for their own independent marketing or commercial purposes.


1)     Affiliated Companies: your personal data may be shared with KDNetworks affiliated companies. We only share necessary personal data subject to the purposes stated in this Privacy Policy. If the affiliated companies wish to change the purpose of processing, they will ask for your authorization and consent again.


2)     Sharing with authorized partners: to realize the purposes stated in this Policy, some of our services will be provided by our authorized partners. We may share some personal data with our partners to provide better services and user experience. Third party service providers are also used to provide you with customer service. Where a merger, acquisition or bankruptcy liquidation takes place, if the transfer of personal data is involved, we will ask the new company or organization which obtains your personal data to be subject to this Privacy Policy, otherwise we will ask such company or organization to acquire your authorization and consent again.


We will only share your personal data for lawful, legitimate, necessary, specific and clear purposes, and only personal data necessary for service provision will be shared. Our partners are not allowed to use the shared personal data for any other purposes.


We will only disclose your personal data under the following circumstances:


1)     After we obtain your explicit consent;


2)     Disclose in accordance with laws: we may disclose your personal data if it is compulsorily required by laws, such as to comply with a subpoena or other legal proceedings, legal actions or government agencies, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.


   VI.         How We Protect Your Personal Data


1.     We have taken reasonably practical and technical measures to protect the collected information related to the service. However, please note that although we have taken reasonable measures to protect your information, no websites, Internet transmissions, computer systems or wireless connections are absolutely secure.


2.     We have taken safeguarding measures in accordance with industry standards to protect the personal data you provided and prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We take all reasonably practical measures to protect your personal data.  In particular:


1)     We will de-identify your personal data to mitigate the risk that other organizations or individuals may identify you on the basis of that personal information. We periodically review practices regarding information collection, storage and possessing (including physical security measures), to prevent various systems from unauthorized access.


2)     We only allow KDNetworks employees and personnel of authorized service companies who need the personal data to process it to access such personal data, and they are subject to strict contractual confidentiality obligations. If they fail to perform these obligations, they may be held liable or their relationship with KDNetworks may be terminated.


3)     The security of your information is extremely important for us. Therefore, we endeavor to ensure the security of your personal data and implement measures such as full security encryption during storage to prevent your information from unauthorized access, use, or disclosure.


3.     In case of personal data security incident, in accordance with the requirements of laws and regulations, we will promptly inform you the basic situations and possible impact of the security incident, response measures we have taken or will take, suggestions for you regarding self-prevention and risk reduction, remedial measures for you, etc. We will inform you in a timely manner by email, post, telephone, push notification, etc. regarding the relevant situations of the incident. When it is difficult to notify each personal data subject individually, we will issue a notice in a reasonable and effective manner. At the same time, we will take the initiative to report on the handling of personal data security incident in accordance with regulatory requirements.


  VII.         Your Rights with Regards to Your Personal Data


KDNetworks will respect your legal rights to your personal data. Below are the rights that you have under law, and what KDNetworks does to protect those rights. Please note that for the sake of security, we may ask you to verify your identity before processing your request.


1.     The right to be informed:  KDNetworks is publishing this Privacy Policy to keep you informed as to what we do with your personal data. We strive to be transparent about how we use your data.


2.     The right to access: If you wish to access your personal data, you can login to your account and access the information you provided when registering.


3.     The right to rectification: If you find that there is a mistake with your personal data we process, you are entitled to ask us to make rectifications. You can rectify your information by login into your account and making necessary changes or by contacting our Data Protection Officer: privacy@kdnetworks-sl.com


4.     The right to erasure: You can submit a request to us to delete personal data if we do not have a legal reason to continue to process and hold it. You can delete your information by contacting our Data Protection Officer: privacy@kdnetworks-sl.com.


5.     The right to restriction of processing: You have the right to ask KDNetworks to restrict how we process your personal data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. You can realize your right to restriction of processing by contacting our Data Protection Officer: privacy@kdnetworks-sl.com.


6.     The right to object: You have the right to object to KDNetworks processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics. You can object KDNetworks processing your data by contacting our Data Protection Officer: privacy@kdnetworks-sl.com.


7.     The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time, and KDNetworks must stop processing your data. You can withdraw your consent by contacting our Data Protection Officer: privacy@kdnetworks-sl.com.


8.     The right to lodge a complaint: You can the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority.


We will respond and reply to your above requests as soon as possible, and generally within seven days and no later than one month upon receipt of your request. (If necessary and as permitted by law, we may extend it by an additional two months. We will inform you the reason for the extension within the aforementioned one month, for example, if the request is complex or involves a large volume of data).


VIII.         Third-Party Services Providers and Their Services


KDNetworks websites, products, applications, and services may contain links to third-party websites, products, and services. You can choose whether to access websites, products and services provided by third parties or not. For example, the “follow us” function in the official website will lead you to access to our official accounts in social network platforms (e.g. Facebook, Instagram, LinkedIn, Twitter and etc.) where you can be aware of the marketing or promotional information published by KDNetworks.


We have no control over third-party privacy and data protection policies and such third parties are not bound by this Privacy Policy. Before submitting personal data to third parties, please refer to the privacy protection privacy of such third-parties.


   IX.         How This Privacy Policy Is Updated


We reserve the right to update or modify this Privacy Policy from time to time. We will send you update notices through different channels. If we make any material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) if an email address is provided by you, otherwise we will notify you by posting notice on this website or within our devices prior to the change becoming effective.


This Privacy Policy allows adjustments, but we will not diminish your rights under this Privacy Policy without your express consent.


     X.         Getting Additional Information


If you have questions or concerns regarding our Privacy Policy or practices, please contact our Data Protection Officer at the following address:


Kleinrock Digital Networks

4v Hennessy Street,



Sierra Leone.


Email: privacy@kdnetworks-sl.com

4v Hennessy Street, Kingtom
Western Area
Sierra Leone