Privacy Principles for the Kindsight Service

Last modified: April 20, 2012

At Kindsight, we respect and recognize the importance of privacy. That is why we continually strive to operate our business alongside our Internet Service Provider (ISP) partners with the goal of providing unparalleled transparency and consumer choice.

This Statement of Privacy Principles describes our technology and the assurances we seek to obtain from our ISP partners that they will deploy the Kindsight service in a manner that respects subscriber privacy. We believe our technology sets a new standard in the online domain and that these Principles meet or surpass the guidance set forth by agencies and other bodies that regulate or address privacy and online advertising issues, such as the Federal Trade Commission (FTC), the Interactive Advertising Bureau (IAB), and the Network Advertising Initiative (NAI).

This Statement of Privacy Principles applies to the products and services licensed by Kindsight to our ISP partners. These services may be branded as “Kindsight” or as an ISP-branded service, and we refer to them collectively herein as the “Kindsight service.” We seek assurances from our ISP partners that they will possess all authorizations necessary to deploy the Kindsight service pursuant to this Statement of Privacy Principles. We also expect our ISP partners to keep their subscribers informed of the steps they take to protect their privacy; so, to the extent an ISP uses the Kindsight service, we expect its usage to be disclosed, in a manner consistent with these principles, in the ISP’s privacy policy.

Questions about an ISP’s privacy policy should be directed to the ISP. If you have questions about this Statement of Privacy Principles, please feel free to email us at privacy@kindsight.net or write to us at:

Privacy Department
c/o Kindsight, Inc.
755 Ravendale Drive
Mountain View, CA  94043
USA

Consumer Choice

The Kindsight service is opt-in.

Kindsight believes in setting the highest standard for transparency and consumer choice. As a result, we expect our ISP partners to obtain the subscriber’s consent before activating the Kindsight service for the subscriber’s household. This means we assume the subscriber’s household to be “opted out” of the Kindsight service unless and until the subscriber opts-in to the Kindsight service.

As with other changes the subscriber makes to his/her broadband service, only the account owner or someone acting on his/her behalf may opt-in to the service for the household. To communicate this opt-in has occurred, the subscriber will receive: a service activation notice via email; a notice with the subscriber’s monthly Internet service invoice (either by mail and/or online); as well as a monthly email that shows their security status, and, if they selected the no-cost option, a reminder of this consent and links to how to disable the service or change their subscription type.

This reinforcement is consistent with our goal of securing clear and informed consent from the subscriber.

The Kindsight service has multiple subscription types.

The Kindsight service will be offered by our ISP partners for a fee or, like many other Internet applications, at no cost through relevant advertising. Subscribers will select one of these subscription types when they sign-up for the service.

The subscriber can switch between these subscription types at any time by going to the Kindsight service portal for his/her ISP and following the instructions posted there.

The subscriber can discontinue the Kindsight service at any time.

The subscriber can discontinue (i.e., opt-out of) the service at any time by going to the Kindsight service portal for his/her ISP and following the instructions posted there. Instructions for opting-out also will be included as part of the service activation notice.

Information Collection and Use

The subscriber’s Internet traffic is analyzed for threats.

The Kindsight service uses advanced threat detection technologies to analyze consumer Internet traffic for attacks and other malicious activities that could place the subscriber’s personal information or computer at risk. When the Kindsight service detects a threat, an alert is communicated to the subscriber via the ISP’s security portal and/or email and/or text message.

This service can be offered at no cost through advertising.

Our ISP partners may provide their subscribers with a free trial of the Kindsight service, after which subscribers will be provided with an option of continuing the Kindsight service for a fee or, like many Internet applications, at no cost through relevant advertising. If the subscriber selects the no-cost option, then in addition to analyzing the subscriber’s Internet traffic for online threats, our technology will also analyze the subscriber’s Internet traffic to display relevant ads on the ISP’s and selected partner web sites. The subscriber will NOT see more ads or pop-ups as a result of this service.

While analyzing a subscriber’s Internet traffic for threats at no cost, our ISP partners will continually score the online activity related to your household Internet protocol (IP) address. Scoring is the process of analyzing, but not storing, web sites visited and searches conducted to assign a numeric value to various interest categories. Using your household IP address, relevant ads may be shown on the pages you visit if the scoring suggests an interest in a pre-existing category. These scores are not shared with advertisers or publishers. It will not store web sites or searches against a person, computer or household.

Our technology uses an innovative, privacy-centric approach to infer interests. Instead of using cookies to track an individual, our technology creates “characters”. A “character” is a summary of scores in various interest categories based upon online activities. An individual’s online activity will most likely generate several characters and individuals with similar browsing patterns will typically be inferred to the same character within the household. When our technology estimates a match between browsing patterns and a previously created character, then the online activity is scored and these scores are added to that “character”. If no match is found, then a new “character” is created. When a “character” visits the ISP’s or partner web sites, then the ads the character sees at these sites may be more relevant. In the future, browsing patterns may match a totally different character or cause a new character to be created. At no point is the subscriber’s online activity stored against a character nor can any character be attributed to any actual person, computer, or browser. At no point are these characters given to or shared with partner web sites, publishers or advertisers.

Let’s look at an example: if our technology recognizes a browsing pattern and that online activity includes a number of searches for hotels in a certain city or visits to a few travel sites looking for an inexpensive flight to that destination, our technology will create a character and assign this character a high score for the travel category. The Kindsight service will NOT store which web sites the individual in the subscriber’s household visited, which searches they conducted or any other online activities against any individuals, any characters, or the subscriber’s household. The next time our technology infers this character from the browsing patterns of the subscriber’s household and the character visits a partner web site, our technology may show an ad about travel instead of a potentially irrelevant ad.

Subscribers who have opted-in to the no-cost option may view their inferred interest categories at a certain point in time by visiting the Interests page on the Kindsight service portal for their ISP from a computer in their home network.

As previously noted, the Kindsight service analyzes Internet traffic for advertising purposes only for subscribers that have expressly opted-in to the no-cost identity theft protection service option. If the subscriber selects the paid subscription option, then the subscriber’s ISP will analyze the Internet traffic only for attacks and other malicious activities that could place the subscriber’s personal information or computer at risk (i.e., the subscriber’s Internet traffic will not be analyzed or used for purposes of relevant advertising).

No Personally Identifiable Information (PII) collected.

Unlike other popular Internet-based applications, the Kindsight service does NOT collect or process personally identifiable information such as names and addresses. As explained below, information recognized by our service as personal or sensitive in nature is immediately removed and never stored.

No inspection of email or instant messages for advertising purposes.

Other than looking for attacks and malicious activities, our service does NOT read or analyze the content of emails or instant messages for advertising purposes.

No encrypted Internet traffic is analyzed.

Internet traffic that is encrypted (e.g., https) is not analyzed for any purpose.

All sensitive sites are immediately filtered.

The Kindsight service does NOT analyze, for advertising purposes, any traffic related to sites that Kindsight classifies as sensitive, including but not limited to sites related to pornography, sexuality, health, politics, hate, violence, drugs, and criminal behavior. Such traffic is, however, analyzed in connection with the detection of attacks and other malicious activities, provided the subscriber has opted-in to that aspect of the service.

No altering of Internet traffic and no performance impact.

When you visit websites or perform other online activities, the Kindsight service is designed to not interrupt, affect, or inject anything in the communication between the subscriber’s computer and any Internet content. The Kindsight service does not slow down the subscriber’s computer or his/her Internet connection.

No additional ads or pop-ups

With the no cost option of the Kindsight service, the subscriber will not see any additional ads or pop-ups. Kindsight and our ISP partners will acquire ad space on partner websites and display ads that may be more relevant in these acquired spaces.

Other uses

Our ISP partners may store fully anonymized and aggregated data regarding sites visited and searches conducted by subscribers for the purpose of continually improving the Kindsight service. None of this anonymized and aggregated data can be attributed to any individual, computer or household.

Web sites may be crawled to look for potential threats and/or to categorize the web page contents to assist in serving ads to those subscribers that opt-in to the no-cost service. The crawler abides by the Robot Exclusion Standard to ensure the system does not crawl any pages whose content the web site owner does not want the system to crawl. More details can be found here.

As is true of most Web sites, the Kindsight service portal also gathers certain information automatically and stores it in log files, for example Internet protocol (IP) addresses, referring/exit pages, and date/time stamps. This information is used to analyze trends, generate portal metrics, and improve the service as a whole.

Our ISP partners also may audit or analyze the effectiveness of the Kindsight service, to ensure its proper functioning and to improve Kindsight offerings.

Cookies

Kindsight service does NOT use cookies to track your interests.

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. A persistent cookie remains on your hard drive for an extended period of time. Session cookies expire when you close your browser.

The Kindsight service offered through our ISP partners does NOT use 3^rd party or persistent cookies to create characters and score your online activity (i.e., web sites visited and searches conducted) or to handle opt-in/opt-out of the Kindsight service.

Third-party cookies may be used on the Kindsight service website to more efficiently acquire advertising space, from publisher websites, where relevant ads may be displayed to users that have opted-in to the no-cost option.

Third-party cookies may also be used on the Kindsight service website to measure the effectiveness of the Kindsight service portal and/or promotional activities for the Kindsight service.

Session cookies are used on the Kindsight service website to make it easier for you to navigate that site. This session cookie expires when you close your browser.

Communications

Registering for the Kindsight service.

When a subscriber signs up for the Kindsight service, the Kindsight service asks for the subscriber’s preferred email address and/or text message address in order to send service activation notices, monthly reports, and/or alerts to the subscriber when a threat is detected on one of the computers in the subscriber’s home network.

The Kindsight service uses the subscriber’s email address and/or text message address for the purpose of sending alerts and will, either through Kindsight or its partner ISP, communicate with the subscriber according to the preferences the subscriber sets. At no point will the Kindsight service sell or share these email addresses and/or text message addresses with other third parties.

Service-related announcements.

The Kindsight service may send the subscriber a welcome email to verify the subscriber’s username and password and also may send the subscriber monthly reports and service-related announcements when it is necessary to do so.

The Kindsight service will communicate with the subscriber in response to subscriber inquiries, to provide the services requested, and to manage the subscriber’s account.

Clear gifs are used to gauge effectiveness of communications

The Kindsight service may use clear gifs in some HTML-based emails to gauge the effectiveness of these communications.

Invite Your Friends feature

If you use the Invite Your Friends feature, the Kindsight service will ask for your friend’s email address and send a one-time email inviting them to sign-up for the service. These email addresses are not stored.

Information Sharing

The subscriber’s information is NOT shared with third parties.

The Kindsight service treats the subscriber’s information with strong privacy in mind, and does NOT share or sell the subscriber’s information to third parties such as advertisers.

As with most websites, our ISP partners may be passed an IP address, referring URL or other ad selection parameters during the ad serving process. This is a standard practice and done to assist in content and ad selection as well as to prevent “click fraud.”

Technology Integrity

Technology within the Kindsight service processes information only for the purposes set forth in this Statement of Privacy Principles. We review our technology’s data collection, storage and processing practices to ensure that it collects, stores and processes only the minimal amount of information necessary to provide or improve the Kindsight service. Our technology provides appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Although no data security system is 100 percent secure, we take all reasonable steps to ensure that subscriber data is protected and that our technology performs as outlined in these Privacy Principles.

Changes to this Statement of Privacy Principles.

Please note that this Statement of Privacy Principles may change from time to time, so please review it frequently. We will not reduce the subscriber’s rights in this Statement of Privacy Principles without the subscriber’s consent.

If we decide to change these Privacy Principles, we will post those changes to this privacy web page and other places we deem appropriate so that you are aware of the changes.

Contact Us

If you have any additional questions or concerns about these Privacy Principles, please feel free to contact us any time through email at privacy@kindsight.net or at:

Privacy Department
c/o Kindsight Inc.
755 Ravendale Drive
Mountain View, CA  94043
USA