Last Updated: January 30, 2023

This Privacy Policy describes how Kemper Development Company and our subsidiaries and affiliated companies (collectively, “KDC,” “we,” or “us”) collect, use, and disclose information about you. This Privacy Policy applies to information we collect when you access or use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”). We may provide different or additional notices of our privacy practices with respect to certain products or services, in which case this Privacy Policy will not apply.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

Information You Provide to Us
We collect information you provide directly to us. For example, we collect information directly from you when you participate in any interactive features of the Services, create an account, fill out a form, submit or post content through our Services, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, sign up for free WiFi at one of our commercial properties, or otherwise communicate with us. The types of information about you that we collect include your name, date of birth, email address, postal address, phone number, and any other information you choose to provide. Additionally, if you make a purchase, we work with a third-party payment processor to collect and process your payment information.

Information We Collect Automatically
We automatically collect certain information about your interactions with us or our Services, including:
● Activity Information: We collect information about your activity on our Services, such as which of our coupons or promotions you use and what locations or merchants you use them with.
● Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
● Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
● Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources
We obtain information from other sources. For example, we may collect information from third parties, such as data analytics providers. This information includes name, date of birth, email address, and postal address.

Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your general location based on your IP address.

USE OF INFORMATION 

We use the information we collect to through our Services for purposes described in this Policy or disclosed to you on, or in connection with, our Services. We also use the information we collect to:

• Provide, maintain, improve, and develop new products and services, including to debug and repair errors in our Services;
• Personalize your experience with us;
• Send you technical notices, security alerts, support messages and other transactional or relationship messages;
• Communicate with you about products, services, and events offered by KDC and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, and activities in connection with our products and services;
• Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of KDC and others;
• Comply with our legal and financial obligations;
• Create de-identified, anonymized or aggregated information; and
• Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION 

We share personal information in the following circumstances or as otherwise described in this policy:
● We share personal information with vendors that access personal information to perform work for us, such as companies that assist us with web hosting, payment processing, customer service, and marketing and advertising.
● We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
● We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of KDC, our users, the public, or others.
● We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
● We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
● Personal information is shared between and among KDC and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
● We share personal information with your consent or at your direction.
We also share aggregated or de-identified information that cannot reasonably be used to identify you.

ADVERTISING AND ANALYTICS 

We engage others to provide analytics services and serve advertisements across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by KDC and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Google). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

KDC is headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we will take steps to ensure that your personal data receives an adequate level of protection in accordance with applicable law.

YOUR CHOICES

Account Information
You may update and correct certain account information at any time by emailing us at info@kemperdc.com. If you wish to deactivate your account, please email us at info@kemperdc.com, but note that we may retain certain information as required by law or for our legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences
You may opt out of receiving promotional emails from KDC by following the instructions in those communications or by emailing us at info@kemperdc.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at:

Kemper Development Company
575 Bellevue Square
Bellevue, WA 98004

Telephone: (425) 454-8096
Email: info@kemperdc.com

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to access and analyze data more easily.