General

WE2STARS COMPANY LIMITED is committed to protecting the privacy of your personal information. Through our Kasapoole products, we provide consumers with various products and services that let you stay connected to the ones you love. This Kasapoole Privacy Policy (the “Policy”) sets forth our policies and procedures regarding the collection, use and sharing of your personal information. We also explain the steps we take to protect your information and how you can limit the collection, use and sharing of your information.

This Kasapoole Privacy Policy (the “Policy”) sets forth our policies and procedures regarding the collection, use and sharing of your personal information. We also explain the steps we take to protect your information and how you can limit the collection, use and sharing of your information

This Policy applies to the following unless otherwise noted:

1. Users of our Kasapoole products and services. 
2. Users and visitors of the Kasapoole website
3. members of any Kasapoole loyalty or rewards program; and 
4. Users of our Kasapoole calling application

When we use the term “Services” it refers to the Kasapoole Products, the Kasapoole Website and the Kasapoole App collectively. When we refer to WE2STARS or “us,” or “we,” we’re talking about WE2STARS COMPANY LIMITED

This Policy does not apply to other products or services offered by WE2STARS COMPANY LIMITED including money transfer, domestic bill payment and international bill payment, and to any information collected during transactions for those products and services.

We may update this Policy from time to time and you should review it periodically for changes. Any updated Policy will be posted on the Kasapoole Website and the Kasapoole App

2. Information We Collect

WE2STARS receives and collects both personal and non-identifying information from you when we operate and provide you with the Services, when you install, access or use the Services and when you communicate with us. Personal information means information either on its own or in conjunction with other data that enables a specific person to be identified but does not include “de-identified,” “anonymous,” or “aggregate” information, which is not otherwise associated with a specific person. Non-identifying information means information that by itself cannot be used to identify a specific person (e.g., ZIP Code).

A. Information You Provide. Depending on the particular Service, you may provide the following personal information:

1. name
2.  address
3.  email address
4.  Mobile or other phone number
5.  payment information, including credit or debit card details
6.  other personal information necessary to verify you and/or your phone number
7.  other personal information you provide to us for customer support purposes, surveys, sweepstakes or product feedback

B. Information We Collect. Depending on the particular Service, we may automatically collect the following information:

• Kasapoole security code, password and login credentials
• Service-related diagnostic and performance information, including how you use our Services and performance logs  Call records, frequently called numbers, and network traffic data
• Messages sent with our Services, including chats, photos, videos and voice messages
• Personal, phone or social network contact information
•  Information about your device, including model, Browser, operating system, platform type, application software, mobile network, device identifiers and numbers, and Internet connection speed
•  Browser, searching and buying activity
• IP address 
• Kasapoole Website visited and websites you come from and go to next
•  Kasapoole App feature usage and stored content
•  Certain data on your device, including your contacts, the phone numbers in your mobile address book, favorite lists and other installed apps
• Device identification number
• Geolocation and device location information if you use our location features
• Transactional information when you purchase a KASAPOOLE Product

C. Information Provided by Third Parties. When you install, access or use the Services we may obtain the following information from third-party sources:

• credit information from credit reporting agencies
• Transactional information when you purchase a Kasapoole Product, including receipts or information from app stores or other third parties processing your payment
• Aggregate information from outside companies that collect consumer information such as demographic and interest data (examples of this information include gender, age range, sports enthusiast, or pet owner)
• Unique marketing and/or device IDs, contact and other marketing lead information from third parties, including from app stores
• Users of our Services may provide us with your email address or phone number through the purchase/use of a Service, our refer-a-friend programs, their mobile address book or social networking platforms
•  Other information from third parties that helps us operate, provide, understand, customize, support and market our Services

3. How We Use Information

We use all the information we collect and receive to help us operate, provide, improve, understand, customize, support, and market our Services. In addition, we use your information for general, operational and administrative purposes, including maintaining your account, authenticating you and contacting you. As used in this Policy, the terms “use,” “using” and “processing” information include using cookies or other similar technologies on a computer/phone/device, subjecting the information to statistical or other analysis and using or handling information in any way, including but not limited to, scanning, collecting, storing, evaluating, aggregating, modifying, deleting, using, combining, disclosing and sharing information among our affiliates both in and outside the United States and to select service providers and vendors.

A. Our Services. We analyze how our customers use our Services and use that information to evaluate and improve our Services, to research, develop, and test new services and features, and to conduct troubleshooting activities. For example:

• We communicate with you about our Services and features and let you know about our terms and policies and other important updates;
• We may target particular advertisements or other content to you based on information we have collected or you provided
•  We may digitally scan content stored in the KASAPOOLE App, including without limitation, your user information and message content, and use this information to provide you with targeted information and advertising;
• We use your information to respond to you when you contact us. Our communications with you, including phone conversations, chats and emails, may be monitored and recorded by us for quality assurance or for legal, regulatory or training purposes; and
• We verify accounts and activity, and promote safety and security, such as by investigating suspicious activity or violations of our terms, to ensure our Services are being used legally.

B. Web Technologies. The KASAPOOLE Website and KASAPOOLE App may use certain web technologies such as “cookies” or “web beacons.” We use cookies, small text files stored locally on your computer or device to serve as markers, to operate, provide, improve and customize our Services and your experiences. For example, we use cookies to understand which of our FAQs are most popular and to show you relevant content related to our Services. Additionally, we may use cookies to remember your choices, such as your language preferences. Web beacons are used to tell us how and when pages in our sites are visited, by how many people, their point of origin and operating system and to monitor performance with our Services. These technologies do not collect personal information. We do not honor any web browser “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of information about your online activities over time and across third-party websites or online services. We use and share this data and information to deliver customized content and advertising, to ensure that you see the correct product information, to manage the frequency with which you see an advertisement, to tailor advertisements to better match your interests, and to understand the effectiveness of our advertising. The content may be delivered on the KASAPOOLE Websites, on nonWE2STARS COMPANY LIMITED websites, on the KASAPOOLE App, by our representatives, and via email, SMS, push notifications or other WE2STARS COMPANY LIMITED services. In addition, if you respond to or interact with a particular advertisement, you may later receive a targeted advertisement as a result of an ad server or ad network concluding that you fit within a particular audience we are trying to reach.

C. Web Analysis. We use certain Google Analytics Advertising Features, including Remarketing and Demographics and Interest Reporting. Google Analytics is a web analysis service provided by Google that allows us to collect data about the traffic on the KASAPOOLE Website through Google cookies and other identifiers, which enables us, among other things, to create user segments based on demographic or interest data and to deliver relevant advertising. Google utilizes the data collected to track and examine the use of our websites to prepare reports on the activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. You may be able to opt out of the Google Analytics Advertising Features through your browser ads settings or by visiting Google’s Ads Settings page.

D. KASAPOOLE App.We engage certain service providers and vendors who use mobile software development kits to passively collect information from users of the KASAPOOLE App. We use this data primarily to help us deliver personalized notifications and to identify you uniquely across other devices or browsers for the purposes of customizing advertisements or content.

4. How We Share Information

We share all the information we collect and receive with our affiliates, both in and outside Ghana, and to select service providers and vendors, to help us operate, provide, improve, understand, customize, support, and market our Services, and for general, operational and administrative purposes, including maintaining your account,authenticating you and contacting you. When we share information with our service providers and vendors, we require them to use your information only in accordance with our instructions and terms or with express permission from you and not to sell your information. In addition, you share your information as you use and communicate through our Services.

A. Information Shared Within the WE2STARS Family of Companies. We share information within the WE2STARS family of companies, including our affiliates both in and outside Ghana (collectively, the “WE2STARS Family of Companies”) primarily to operate, provide, support and market our Services. For example, if you purchase a KASAPOOLE Product, then we share your purchase information with various WE2STARS affiliates in order to process your transaction.

B. Information Shared with Our Service Providers and Vendors. We work with various service providers and vendors for a variety of business purposes such as to help us offer, operate, provide, improve, understand, customize, support and market our Services. We share information with these service providers and vendors to the extent reasonably necessary for them to perform work on our behalf. For example, we may provide your credit card information and billing address to our payment processing company solely for the purpose of processing payment for a transaction you have requested. In addition, WE2STARS shares certain information, including unique marketing identifiers, email addresses and mobile phone numbers, with some of our service providers and vendors, including Google and Facebook, for marketing, advertising and analysis purposes, including the delivery of advertising campaigns and preparing and sharing aggregate business and marketing reports, demographic profiling and to deliver targeted advertising about products and services. When we share information with our service providers and vendors, we request that these parties protect your information and limit their use of the data to the purposes for which it was provided and not to sell your information. WE2STARS does not sell, rent or lease its customer lists to third parties. Finally, if you purchase products or services offered jointly by WE2STARS and one of our service providers or vendors, your customer information may be received by both WE2STARS and the service provider or vendor that is providing the product or service. For these jointly offered products and services, you should also review the other company's privacy policy, which may include practices that are different from the practices described here.

C. Special Circumstances. We may share information in certain special circumstances. For example:

• to comply with valid legal process including subpoenas, court orders and search warrants, and as otherwise permitted or required by law;
•  to assist law enforcement in cases involving danger of death or serious physical injury to any person or in other emergencies;
• to protect our rights or property, or the safety of our customers or employees;
•  to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of our Services and to protect our network, Services, devices and users from such use;
• to advance or defend against complaints or legal claims in court, administrative proceedings and elsewhere; • to prospective purchasers of all or part of our business or assets;
• to outside auditors, lawyers and regulators; and
• with your consent.

D. Information Shared with Advertising Entities or Social Networks. You may see third-party advertisements on KASAPOOLE Products, the KASAPOOLE Websites and/or the KASAPOOLE App. Some advertisements are chosen by companies that place advertisements on behalf of advertisers. These companies, often called ad servers, may place and access cookies on your device to collect information about your visit. The information they collect from our sites is in a form that does not identify you personally. This information may be combined with similar data obtained from other websites to help our advertisers better reach their targeted audiences. Targeting may be accomplished by tailoring advertising to interests that they infer from your browser of our sites and your interaction with other websites where these ad servers also are present. If you choose to interact with specific advertisers who advertise on the KASAPOOLE Websites or the KASAPOOLE App, the information you provide to them is subject to the conditions of their specific privacy policies. The KASAPOOLE Websites and KASAPOOLE App also include plug-ins and widgets that may provide information to their associated social networks or entities about the WE2STARS page you visit, even if you do not click on or otherwise interact with the plug-in or widget.

5. Your Rights and How to Limit Sharing Of Information

You have choices about how we use and share your information and there are additional protections that may apply with regard to certain information we collect.

A. Customer Proprietary Network Information (CPNI). CPNI is information made available to us solely by virtue of our relationship with you that relates to the type, quantity, destination, technical configuration, location, and amount of use of the telecommunications and interconnected VoIP services you purchase from us, as well as related billing information. You have a right, and we have a duty, under federal law to protect the confidentiality of your CPNI. We use and share your CPNI within the WE2STARS Family of Companies and with/to their agents, contractors and partners for marketing purposes, including to offer you services that are different from the services you currently purchase from us. If you don’t want your CPNI used for the marketing purposes described above, please notify us online at support@kasapoole.org Unless you notify us, we may use your CPNI as described above and your choice will remain valid until you notify us that you wish to change your selection. Your decision about use of your CPNI will not affect the provision of any Services you currently have with us. Note: This CPNI notice may not apply to residents of certain states, including Arizona.

C. Online Information. You have choices about whether certain information collected on the KASAPOOLE Websites and KASAPOOLE App is used to customize advertising based on predictions generated from your visits over time and across different websites and apps. Similarly, many mobile devices offer controls you can set to limit the advertising use of information collected across mobile apps on your device. Please note that many opt-outs use browser cookies or device controls and are specific to the device and browser you are using. If you buy a new computer, change web browsers or devices or delete the cookies on your computer, you may need to opt out again. In addition, ads you receive may still be tailored using other techniques such as publisher, device or browser-enabled targeting. You should check the privacy policies of the products, sites, apps and services you use to learn more about any such techniques and your options. You also can limit the collection of certain website information by deleting or disabling cookies. Most browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Disabling cookies may prevent you from using specific features on our sites and other websites, such as ordering products or services and maintaining an online account.

6. Other Information

A. Keeping Children Safe. WE2STARS does not knowingly market to or collect information from children under the age of 16 without obtaining verifiable parental consent. If you allow a child to use your device or our Services, you should be aware that their information could be collected as described in this Policy. We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission.

B. Security. WE2STARS has technical, organizational and physical safeguards in place to help protect against unauthorized access to, use or disclosure of the information we collect and store. Employees are trained on the importance of protecting privacy and on the proper access to, use and disclosure of customer information. WE2STARS secures information on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. We use Secure Socket Layer (SSL) encrypted protection to protect the personal information transmitted to the KASAPOOLE Website. The KASAPOOLE Website and KASAPOOLE App are PCI compliant in connection with your credit card information. Although we work hard to protect your information that we collect and store, no program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose that information. WE2STARS COMPANY LIMITED maintains security and incident response plans to handle incidents involving unauthorized access to the information we collect or store. If you become aware of a security issue, please contact us.

C. Contact Information. If you have questions, concerns or suggestions related to our Policy or our privacy practices you may contact us at:

WE2STARS COMPANY LIMITED WE2SEAFOODS BUILDING,

AFKO JUNCTION, TEMA FISHING HARBOR, TEMA, GHANA

Telephone: +233 54 528 8162

Email: support@kasapoole.org

D. Links to and from non-WE2STARS COMPANY LIMITED Websites and Content. The KASAPOOLE Websites and KASAPOOLE App may contain links to nonWE2STARS COMPANY LIMITED sites. In addition, WE2STARS COMPANY LIMITED or Kasapoole content may be included on websites that are not associated with WE2STARS COMPANY LIMITED. We have no control over these non-WE2STARS COMPANY LIMITED sites and are not responsible for the content on these sites or platforms or the privacy policies and practices employed by these sites and platforms. We recommend that you review the policies and practices of the sites you visit.

E. Social Networking. Some of our Services may allow you to participate in blog discussions, message boards, chat rooms, and other forms of social networking and to post reviews. Please be aware that these forums are accessible to others. We urge you to not submit any personal information to these forums because any information you post can be read, collected, shared, or otherwise used by anyone who accesses the forum. WE2STARS is not responsible for the information you choose to submit in these forums. If you post content to information-sharing forums, you are doing so by choice and you are providing consent to the disclosure of this information. F. Changes to this Policy. We reserve the right to make changes to this Policy, so please check back periodically for changes. You will be able to see that changes have been made by checking to see the effective date posted at the beginning of the Policy.