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Privacy Policy

Updated as of April 01 2023

This Privacy Policy of KOIN (the “Policy”) is hereby made effective as of December 8, 2017, by KOIN Network, LLC, a Florida limited liability company (“KOIN” or “We”), and, without waiving or otherwise releasing any right or obligation under any prior privacy policy or similar document or agreement of KOIN, hereby amend and restate any such prior privacy policy.

By participating in KOIN’s referral programs (hereinafter the “Programs”), and/or use of our website with a homepage available at and other related websites (the “Websites”), software applications (including mobile APPs), interactive features, and/or any services provided or operated by us (in the aggregate, the “Services”) you thereby (i) agree and acknowledge that you have read and understood this Policy, and (ii) acknowledge and consent to the learning, collection and use of your Personal Information (hereinafter defined) as described in this Policy. If you do not agree with any portion of this Policy, you are prohibited from participating in the Program and/or using or accessing the Websites and/or the Service.

In General

When participating in the Programs and/or using or accessing the Websites and/or the Services, you will provide certain information to KOIN and, during your use of the Services, KOIN will learn, collect and use certain additional information about you for various purposes, as more fully set forth in this Policy. Even though KOIN will learn, collect and use information about you, KOIN will not lease, sell, share or otherwise provide your Personal Information (as hereinafter defined) to any third party without your consent, except as provided herein.

What We Learn, Collect and Use

Upon your initial participation in the Programs and/or registration for the Services, KOIN will learn, collect and use certain personal data and information about you and, as you use the Services KOIN will continue to learn, collect and use additional personal data and information (all such personal data and information is collectively referred to herein as, “Personal Information”).

Registration. In order to become a user of the Services, you must provide us with Personal Information, including, without limitation, name, email address, and possibly in the future, other information as set forth in this data points collected list. Without providing Personal Information, you cannot create or maintain a user account. At the time of initial registration KOIN may collect certain other Personal Information from you including, without limitation, demographic information, such as location and age. Furthermore, KOIN may request or collect Personal Information from you during any registration process which KOIN may use to provide or improve the Programs and/or the Services or may use as is otherwise provided herein. KOIN may store Personal Information, and it may be included in databases owned and maintained by KOIN’s affiliates, agents or service providers.

Using the Services. When you use and interact with the Services, KOIN also receives and stores additional Personal Information, which may or may not be personally identifying information. Such information includes, without limitation, your internet protocol address, browser types, domain name, and other statistical data involving your use of the Services, as further set forth in the data points collected list. Such information is collected passively using various technologies or may be provided by you through communications with the Services or KOIN.

KOIN uses “cookies” A cookie is a piece of information that the Services give to your computer when you access the Services. Cookies are used by KOIN to track your usage of the Services, trends on the usage of the Services, and to improve the Services and analyze and assess changes to, successes and failures of the Services and any portions thereof.

For security purposes and to ensure the availability of the Services, KOIN also uses software programs to monitor network traffic, to identify unauthorized attempts to upload or change information, or otherwise cause damage to the Services or KOIN.

Based on how the internet operates, when you visit the Services we automatically receive the uniform resource locator of the prior webpage that you were on and of the webpage where you go after the Services. KOIN also receives the internet protocol address of your computer, the type of operating system and web browser you are using, your location, date and time of your access, pages viewed on the Services and other information related to your visit to the Services.

KOIN also collects information when you interact with KOIN customer service in order to assist you and to improve the operation of the Services.

How We Use Your Personal Information

KOIN uses your Personal Information in connection with the operation, development and improvement of the Services, the operation of your user account, and for other uses consistent with this Policy. KOIN may use your Personal Information for any internal purpose, including, without limitation the development and operation of the Services and the development of additional services and products by KOIN or its affiliates, and to communicate with you regarding the Services, your account or other services or products offered by KOIN. Please be aware that you are responsible for the payment of any fees or costs incurred by you in connection with receipt of communications from KOIN, including data, internet, cellular carrier or other similar fees.

KOIN recognizes the importance of the privacy of its users and does not lease, sell, share or otherwise provide Personal Information to third parties, except as provided herein. KOIN will not disclose or provide your Personal Information to any third party except:

  • as otherwise described in this Policy;

  • as otherwise required by law or to comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures;

  • as reasonably necessary to respond to claims of a violation of the rights of third parties, whether or not the third party is a user, individual, entity or government agency;

  • for any internal purpose of KOIN, including, without limitation, to manage your user account, subscription and other billing purposes, to respond to your inquiries, to allow outside vendors to perform services required by the Services, and to otherwise manage and operate the Services and develop new services and products;

  • as reasonably necessary to enforce the Terms and Conditions of Service and use of the Websites (collectively “TOS”);

  • as reasonably necessary to detect, prevent and address fraud and other illegal activity and to prevent death or imminent bodily harm; or, as reasonably necessary to protect the rights and property of KOIN or its officers, directors, shareholders, employees or agents.

  • KOIN may provide aggregated anonymous data about the usage of the Services to third parties for purposes that we deem, in our sole discretion, to be appropriate, including, without limitation, to prospective advertisers or investors.

KOIN may post and use any testimonials that you have provided about the Services, and KOIN may post examples of content created through the Services, in connection with the marketing and promotion of the Services. Testimonials and other marketing, promotions and advertisements may include obfuscated Personal Information (such as first name and general location) that you have provided to KOIN.

KOIN may also disclose your Personal Information to a third party as part of a sale of the assets of KOIN, as the result of a change in control of the company, or in connection with an investment in KOIN by a third party. Any third party to which KOIN transfers or sells KOIN’s assets will have the right to continue to use your Personal Information.

Access to and Protection of Your Personal Information. You have a right to access, modify, correct and request that KOIN internally delete any Personal Information provided to or obtained by the Services or KOIN. If you update, modify or correct any Personal Information, we may keep copies of your Personal Information prior to such update, modification or correction for uses provided for in this Policy. You may request internal deletion of your Personal Information at any time by contacting KOIN in the manner provided on the Services. KOIN will endeavor to respond to your request in a timely manner.

Any Personal Information that you provide to KOIN will be protected in a commercially reasonable manner.

Transmission and Storage of Data

KOIN respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. The EU-US Privacy Shield is the agreed upon system between the European Commission and the United States for handling transatlantic data flows. Included in the EU-US Privacy Shield are vigorous standards that must be met by companies handling Europeans’ personal data, along with tough enforcement of these standards. Also, you may review here the General Data Protection Regulation (GDPR) that went into formal effect May 25, 2018. U.S. companies, such as KOIN, importing personal data from European countries are subject to the GDPR and are otherwise required to commit to robust obligations on how personal data is processed and individual rights are guaranteed. KOIN pledges its commitment to meeting the standards put in place by the EU-US Privacy Shield, as well as the GDPR. Companies who publish their commitments to the EU-US Privacy Shield will be under the scrutiny of the Department of Commerce, as the act of publishing a commitment makes it enforceable under U.S. law by the US. Federal Trade Commission. Similarly, KOIN shall be subject to the provisions of the GDPR to the extent any users of its Websites and Services are citizens/residents of the European Union. Similarly, KOIN shall be subject to the provisions of the GDPR to the extent any users of its Websites and Services are citizens/residents of the European Union.

Privacy Shield and the GDPR

KOIN complies with both the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce, and the GDPR regarding the collection, use, and retention of personal information transferred from the European Union to the United States.

Specifically with regard to the Privacy Shield, KOIN has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit

In compliance with the Privacy Shield Principles, KOIN commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact KOIN at: KOIN has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit for more information or to file a complaint. The services of dispute resolution are provided at no cost to you. Each individual has, under certain conditions, the possibility to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. The following link to the Privacy Shield Annex I contains additional information: In compliance with the Privacy Shield, KOIN shall not be held liable for third-party service providers processing personal information in violation of Privacy Shield Principles, unless it is proven that KOIN is solely responsible for the third-party service providers’ action in violation of the Principles.

With regard to the GDPR, KOIN remains committed to fulfilling its duties and obligations to this rule to the extent its users of the Services are residents and/or citizens of the European Union. You may review here the General Data Protection Regulation (GDPR) that went into formal effect May 25, 2018. U.S. Specifically, KOIN will reconfirm with current users, and confirm with new users of its Websites and Services that it has your consent to collect your information, as further set forth in our data points collected list. We will also inform users on how their information is being used, enable users to access their collected data points if requested, and allow users to request that certain personal information be removed from the internet. Additionally, KOIN will make every effort to report any data breaches within 72 hours. Users will have the right to opt out of sensitive data collection, with the understanding that continued access and use of the Websites and/or Services may be dependent upon KOIN’s ability to capture and use certain data points.


KOIN reserves the right to amend, restate or otherwise modify this Policy at any time without notice to you. As a user of the Services you are required, and hereby agree, to review the Policy frequently. Should KOIN elect to amend, restate or otherwise modify this Policy in a material manner, KOIN will post a notice of such material amendment, restatement or modification on the Services so that you may review the changes to the Policy. If you object to any such changes to the Policy, you may, as your sole right and remedy, close your user account. By continuing to use the Services after such notice has been posted on, you thereby consent to any such changes to the Policy and agree to be bound by the then current version of this Policy.

In the event that the terms of this Policy conflict with or are inconsistent with any provision of the TOS, the TOS shall govern.

Any claim under this Policy or otherwise related to the Services or KOIN shall be governed by the laws of the State of Florida without regard to its conflict of law provisions, and shall be exclusively resolved by a state or federal court located in Broward County, Florida. You agree to submit to the personal jurisdiction of the courts located within Broward County, Florida, for the purpose of litigating all such claims.

If any provision of this Policy is found by a court of competent jurisdiction or arbitrator to be illegal, void, or unenforceable, the unenforceable provision will be modified so as to render it enforceable and effective to the maximum extent possible in order to effect the intention of the provision; and if a court or arbitrator finds the modified provision invalid, illegal, void or unenforceable, the validity, legality and enforceability of the remaining provisions of this Policy will not be affected in any way.

Any questions on this Policy or the privacy practices of KOIN or the Services should be directed to

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