KEYBOARD FOR XIAOMI PRIVACY NOTICE
1. OUR APPROACH TO PRIVACY
1.1 ekatoX Singapore Private Limited, 137 Telok Ayer Street, #08-01, Singapore 068602 ("ekatoX", "we", "our" or "us") is committed to respecting your privacy. This privacy notice sets out how we collect, store, process, transfer, share and use information that identifies or is associated with you ("personal information")
1.2 EkatoX operates a service, which we make available through an application available for download on your device (the "Keyboard for Xiaomi App"), that allows you to create customised keyboards on your device (your "Keyboard for Xiaomi"), and to send emojis, stickers and GIFs (the "Keyboard for Xiaomi Service").
1.3 This privacy notice applies to the Keyboard for Xiaomi Service. Please ensure that you have read and understood this privacy notice before accessing or using the Keyboard for Xiaomi Service.
2. WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL INFORMATION
EkatoX may use proprietary software licensed to it by third party entities for the purpose of collecting and processing your personal information. As a result of the use of such software, your personal information may also be collected by Facebook, Google, Appsflyer and Paytm.
EkatoX is the controller of the personal information we hold about you in connection with your use of the Keyboard for Xiaomi Service. This means that we determine and are responsible for how your personal information is used.
3. HOw WE Process Personal Information and on Which BAsis
3.1 How we process personal data depends on how you interact with us and which functionalities you decide to use. This means that we may process the following data:
(b) Information you submit into the search fields, for example, the search service on the keyboard using the Keyboard for Xiaomi. In order to offer the most relevant results to you, we will collect words and phrases that you enter into the search fields.
(c) If you choose a personalised theme for your Keyboard for Xiaomi. If you choose a personalised theme for the Keyboard for Xiaomi and upload to the platform of the Keyboard for Xiaomi, we will process information such as the background picture, text colour, font and any custom skins or other features that you choose for your Keyboard for Xiaomi.
(d) Your preferences and settings. We may collect information such as your settings regarding data sharing, the use of specific functions (including the Key Sounds function), and the level of access that you grant EkatoX to your device.
(e) Information collected from third party social media companies. If you connect to your Keyboard for Xiaomi account by logging in to your social media account, we will access information your username and profile image, in accordance with, and only if permitted by, your privacy settings on that social network.
(f) Information collected from third party apps, such as third party app development and analytics platforms. We may collect information from third party apps. This information may include your IP address, statistics regarding your use of the Keyboard for Xiaomi and Keyboard for Xiaomi Service and any crashes or problems experienced while using the Keyboard for Xiaomi and Keyboard for Xiaomi Service.
(g) Usage information collected automatically. We may collect usage information automatically. For example, information about your device and its software and about the way you use the Keyboard for Xiaomi Service and Keyboard for Xiaomi, such as the type of device, physical dimension, division ration, CPU type, memory capacity, operating system version, version of the Keyboard for Xiaomi Service and Keyboard for Xiaomi, keyboard type and typing performance when using the Keyboard for Xiaomi Service and Keyboard for Xiaomi, crash information (such as defects that occurred), and unique ID for each Keyboard for Xiaomi.
3.2 We provide you with an option to opt-out from many of these functions via the settings of either your device (camera and microphone use) or the Keyboard for Xiaomi App. If you opt-out, we will be no longer able to access the personal data relating to the part of the Keyboard for Xiaomi Service that you opted-out from. However, please note that if you opt-out we will also no longer be able to provide you with that part of the Keyboard for Xiaomi Service.
When you exercise your option to opt-out from any of these functions by toggling a feature ‘off’ in the settings, a written communication on your behalf will automatically be sent to EkatoX and will be constituted as withdrawal of consent from sharing the corresponding information necessary for the functionality. You may start using the functions again by toggling the feature ‘on’ in the settings, which will automatically send a written communication on your behalf to EkatoX and will be constituted as express consent for collection and use of the data required for the functionality as per the terms of this Privacy Notice and the Terms of Use.
3.3 The table in the Annex sets out more information about what personal information may be transferred to EkatoX and the purposes and lawful bases for such transfers.
3.4 We may anonymise and aggregate any of the personal information we collect (so that we can no longer identify you, directly or indirectly). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Keyboard for Xiaomi Service and developing new products and features. We may also share such anonymised and aggregated information with others.
4. How long we will store your personal information
4.1 We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in the Annex, including for the purposes of our legitimate business interests and in satisfying any legal or reporting requirements.
4.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
5. RECIPIENTS OF PERSONAL INFORMATION
We may share your personal information with the following (as required in accordance with the purposes set out in the Annex):
(a) Our affiliates. We may share personal information with other entities owned by or under common ownership with EkatoX to provide, develop and improve the Keyboard for Xiaomi Services and to determine products and services that may be of interest to you.
(b) Service providers and advisors. We may share your personal information with third party vendors and other service providers. In particular, such services may include professional services, such as legal and accounting services, payment processing, mailing, email or chat services, fraud prevention, web hosting, or analytic services. Any such service providers will – by appropriate data processing agreements – be bound only to process personal information on our behalf and under our instructions, unless such service providers act as independent or joint controllers.
(c) Purchasers and third parties in connection with a business transaction. Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, asset or share sale, reorganisation, financing, change of control or acquisition of all or a part of our business, in addition to bankruptcy, liquidation and similar actions. In such cases we may transfer or disclose your personal information to the limited extent necessary to the applicable third party.
(d) Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary: (i) to comply with the law, or to comply with the reasonable requests of law enforcement and other government agencies; (ii) to detect and investigate illegal activities and breaches of agreements, including our Terms of Service (iii) to protect the security or integrity of our Keyboard for Xiaomi Service; and/or (iv) to exercise or protect the claims, rights and property of EkatoX , or the rights, property or personal safety of its users or others.
(e) Otherwise with consent. We may disclose your personal information to certain other third parties with your explicit consent.
6. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
6.1 Storage of Data, Security and Transfers. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, alteration, and unauthorised disclosure or access. All data that we collect, both personal information and non-personal information, will be stored by our cloud hosting provider on secure servers in India. All data that we collect is stored in data centres hosted by Amazon India located in India, with their corporate address at The Capital, Plot No. C-70, G-Block, 7th Floor, Bandra Kurla Complex, Bandra East, Mumbai 400051. Please note that although we implement and ensure reasonable measures to protect your personal information, no websites, internet transmissions, computer systems or wireless connections are absolutely secure. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers. Some non-personal information we collect may be transferred to and processed in countries outside of the India, namely to counties where we and/or our third-party service providers have operations. By using the Keyboard for Xiaomi Service and agreeing to the terms of use and this privacy notice, you hereby consent to such transfer of data. In the event of such a transfer, please note that different countries or regions may offer different levels of data protection. We will take measures to ensure that the data we collect is processed in accordance with this privacy notice and applicable laws. This means that we will ensure that: (i) data is transferred to countries recognised as offering an equivalent level of protection as compared to the level of protection in the country you are located; and (ii) the transfer is made pursuant to appropriate safeguards, and the information is processed and stored as per the reasonable security practices and procedures mandated by the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 or any other law pertaining to protection of data in force in India at the relevant time.
6.2 If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice.
7. your rights in respect of your personal information
7.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
(a) Right of consent or refusal to give consent: Before we start collecting your personal information, you have the right to refuse to grant us consent. We shall collect your personal information only upon receiving express consent in writing from you. You can give your consent for our collection and processing of your personal information upon clicking the ‘I Agree’ option, which is made with this Privacy Policy. Similarly, you may choose to refuse to give your consent upon clicking the ‘I Refuse’ option, which is made available with this Privacy Policy. You understand that once you click on the ‘I Agree’ option, this will amount to you granting us your consent in writing, for the collection and usage of your Personal Information in accordance with this Privacy Policy.
(b) Right of access. You have the right to obtain access to your personal information. This includes the right to obtain:
(i) confirmation of whether we are processing your personal information;
(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
(iii) information about the categories of recipients with whom we may share your personal information and if those recipients are located in third countries; and
(iv) a copy of the personal information we hold about you.
(c) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
(d) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay. However, you understand and agree that we do not hold any responsibility towards the accuracy or authenticity of the user data which you have submitted or we have collected through your use of the Keyboard for Xiaomi service.
(e) Right to erasure. You have the right to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
(f) Right to restriction. You have the right to require us to limit the purposes for which we process your personal information (for example, where the accuracy of the personal data is contested by you), for a period of time that enables us to verify the accuracy of that personal data.
RIGHT TO OBJECT. You also have the right to object to any processing based on our legitimate interests, at any time, where your objection is raised on grounds relating to your particular situation. Should you decide to object to the processing of your personal data, we will stop processing personal data concerning you, unless we can demonstrate compelling reasons for continuing to process your personal data that override your interests, rights and freedoms, or where we process your personal data to establish, exercise, or defend our legal claims. You can object to direct marketing activities for any reason at any time.
(h) Right to withdraw consent. We do not need your consent for all of the processing activities we undertake. However, if we rely on your consent as the lawful basis for our processing (as identified in the Annex), and you have provided such consent for the processing of your personal information, you have the right to withdraw your consent at any time. If you withdraw your consent this will not affect the lawfulness of our use of your personal information before your withdrawal. You can withdraw your consent to the processing of your personal information, the basis of which is set out in the Annex, by updating your settings of your device (camera and microphone use) and prohibiting any further collection or processing of your personal data or in Keyboard for Xiaomi App, by following the process laid down in Clause 3.2 of this Privacy Notice. If you withdraw your consent, we may no longer be able to provide you with the corresponding feature of the Keyboard for Xiaomi Service, except in the cases where you make use of the opt-out option as explained above under "Personal information processed locally by the Keyboard for Xiaomi Service on your device".
7.2 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy notice.
7.3 Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights.
7.4 Right to lodge a complaint. You also have the right to lodge a complaint to a competent data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the United Kingdom, your local data protection authority is the Information Commissioner's Office, which can be contacted here.
8.1 We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of the Keyboard for Xiaomi Service. We may share, or we may permit the following third party online advertising networks, social media companies and other third party services, to collect information about your use of the Keyboard for Xiaomi Service (in accordance with their own policies regarding privacy which you can access below) over time so that they may play or display ads on other websites, apps or services you may use (including Facebook), and on other devices you may use. A list of entities apart from EkatoX who may collect your information is provided below:
(i) Facebook, Inc. (to access Facebook’s privacy policy click here)
(ii) Google, Inc. (to access Google’s privacy policy click here)
(iii) Appsflyer, Ltd. (to access Appsflyer’s privacy policy click here)
(iv) One97 Communications, Ltd. (“Paytm”) (to access Paytm’s privacy policy click here)
8.2 These third parties may collect (or we may share) mobile identifiers such as your Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of the Keyboard for Xiaomi Service, and information about which advertisements you have seen or clicked on.
8.3 We and our third-party partners mentioned above use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
8.4 We and our third-party partners may also link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to the Keyboard for Xiaomi Service on that device. We may also work with third party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as a user ID) with third party advertising partners to help recognise you across devices. We and our partners can use this cross-device linkage to serve interest-based advertising and other personalised content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.
8.5 You may be able to limit the use of these identifiers for interest-based advertising on a particular device through the settings on your device, by selecting "limit ad tracking" (iOS) or "opt out of interest based ads" (Android). You may also be able to opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
8.6 To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:
(a) the Network Advertising Initiative’s ("NAI") online resources, at http://www.networkadvertising.org/choices;
(b) the Digital Advertising Alliance’s ("DAA") resources at www.aboutads.info/choices; and/or
(c) Your Online Choices at www.youronlinechoices.eu.
8.7 Please note that opting-out of receiving interest-based advertising through online resources from the NAI, DAA or Your Online Choices will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device that you use.
8.8 Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.
8.9 Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.
9. LINKS TO THIRD PARTY SITES
The Keyboard for Xiaomi Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
10. OUR POLICY TOWARDS CHILDREN
The Keyboard for Xiaomi Service is not directly offered to any child as defined by applicable laws and regulations of each jurisdiction (a “Child” or “Children”). We do not knowingly collect or solicit personal information from Children. In the event that we learn that we have inadvertently collected personal information from a Child, we will delete that information as quickly as possible. If you believe that we might have any information from a Child, please contact us using the details at the end of the privacy notice.
11. CHANGES TO THIS PRIVACY NOTICE
We may update this privacy notice from time to time, and you should review this page periodically. When we change this privacy notice, we will update the "last modified" date at the end of this privacy notice. Changes to this privacy notice are effective when they are posted on this page.
12. NOTICE TO YOU
If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the lawful and most effective way to get in contact with you. We will usually do this through email or by placing a notice on the Keyboard for Xiaomi Service. The fact that we may send notices to you will not stop you from being able to opt-out of certain types of contact as described in this privacy notice.
13. Grievance Redressal
In case of any discrepancy or grievance regarding the information shared with us, you may address your concerns to our designated Grievance Officer:
Mr./Ms.: Natalia
e-mail Address: ekatoxsapps@gmail.com
Contact Number: +65 69569141
14. CONTACTING US
14.1 Please contact ekatoxsapps@gmail.com if you have any questions, comments and requests regarding this privacy notice.
14.2 This privacy notice was last modified on January 21, 2021
ANNEX – PERSONAL INFORMATION YOU SHARE WITH US
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Category of Personal Information |
How we may use the Personal Information |
Legal Bases for Processing |
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Your transaction history. If you subscribe to any of the VIP Features or purchase special skin types in Keyboard for Xiaomi, we will be informed by the payment service provider that you have paid for this service of the Keyboard for Xiaomi Service. We will not collect any of your bank account information, bank card information nor any other financial information.
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We use this information to provide you with the selected feature of the Keyboard for Xiaomi Service.
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The processing is necessary for the performance of a contract with you.
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We use this information for internal statistics to improve the Keyboard for Xiaomi Service, including fixing problems with payments for premium content.
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The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Keyboard for Xiaomi Service and to improve the Keyboard for Xiaomi Service generally. |
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Information you submit into the search fields, for example, the search service on the keyboard using the Keyboard for Xiaomi. In order to offer the most relevant results to you, we will collect words and phrases that you enter into the search fields. |
We use the data to offer the most relevant results to you. |
The processing is necessary for the performance of a contract with you.
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We use this information to analyse your searches to identify services that may be of interest to you for the purposes of interest-based advertising, and to simplify how you use the Keyboard for Xiaomi Service and improve the functionality of the Keyboard for Xiaomi Service. |
The processing is necessary for our legitimate interests, namely to provide interest-based advertising services to our partners and to develop and improve the Keyboard for Xiaomi Service. |
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If you choose a personalised theme for your Keyboard for Xiaomi. If you choose a personalised theme for the Keyboard for Xiaomi and upload to the platform of the Keyboard for Xiaomi, we will process information such as the background picture, text colour, font and any custom skins or other features that you choose for your Keyboard for Xiaomi. |
We process this information so that you can upload personalised theme for your Keyboard for Xiaomi. |
The processing is necessary for the performance of a contract with you.
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Your preferences and settings. We will collect information relating to your preferences and settings, such as your settings with regard to data sharing, and the use of specific functions (including the Key Sounds function) and the level of access to your device that you grant to the Keyboard for Xiaomi Service. |
We use this to ensure that we only collect data in accordance with your preference and settings. |
The processing is necessary for the performance of a contract with you. |
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We use the information to simplify how you use the Keyboard for Xiaomi Service and to improve the functionality of the Keyboard for Xiaomi Service. |
The processing is necessary for our legitimate interests, namely developing and improving the Keyboard for Xiaomi. |
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Information collected from third party social media companies. If you connect to your Keyboard for Xiaomi account by logging in to your social media account, we will access information your username and profile image, in accordance with, and only if permitted by, your privacy settings on that social network. |
We use this to enable you to access your Keyboard for Xiaomi from other devices, to customise your profile and to associate your social media account with your use of the social features of the Keyboard for Xiaomi Service. |
The processing is necessary for the performance of a contract with you. |
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We use the information to simplify how you use the Keyboard for Xiaomi Service and improve the functionality of the Keyboard for Xiaomi Service. |
The processing is necessary for our legitimate interests, namely developing and improving the Keyboard for Xiaomi. |
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Information collected from third party apps, such as third party app development and analytics platforms. Where we collect information from third party apps, this information may include your IP address, statistics regarding your use of the Keyboard for Xiaomi and Keyboard for Xiaomi Service and any crashes or problems experienced while using the Keyboard for Xiaomi and Keyboard for Xiaomi Service. |
We use this information to resolve crash problems and other issues you may experience when using the Keyboard for Xiaomi Service. |
The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Keyboard for Xiaomi Service and to improve the Keyboard for Xiaomi Service generally. |
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We use this information to tailor the Keyboard for Xiaomi Service to you in order to optimise your experience when using the Keyboard for Xiaomi Service. |
The processing is necessary for our legitimate interests, namely to tailor the Keyboard for Xiaomi Service to the user. |
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Usage information collected automatically. We may collect usage information, for example, information about your device and its software and about the way you use the Keyboard for Xiaomi Service and Keyboard for Xiaomi, such as the type of device, physical dimension, division ration, CPU type, memory capacity, operating system version, version of the Keyboard for Xiaomi Service and Keyboard for Xiaomi, keyboard type and typing performance when using the Keyboard for Xiaomi Service and Keyboard for Xiaomi, crash information (such as defects that occurred), and unique ID for each Keyboard for Xiaomi. |
We use this information to provide custom, personalised content and information, including advertising presented by the EkatoX group. |
The processing is necessary for our legitimate interests, namely tailoring the Keyboard for Xiaomi Service to the user and serving targeted advertisements. |
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We use this information to identify you across multiple devices. |
The processing is necessary for our legitimate interests, namely tailoring the Keyboard for Xiaomi Service to the user and serving targeted advertisements. |
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We use this information to ensure and monitor the effectiveness of the Keyboard for Xiaomi Service. |
The processing is necessary for our legitimate interests, namely monitoring and resolving issues with the Keyboard for Xiaomi and the Keyboard for Xiaomi Service generally, and developing, maintaining or improving the Keyboard for Xiaomi Service. |
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We use this information to monitor aggregate metrics such as the total number of visitors, traffic, usage, and demographic patterns on the Keyboard for Xiaomi Service for generating statistics. |
The processing is necessary for our legitimate interests, namely monitoring and resolving issues with the Keyboard for Xiaomi and the Keyboard for Xiaomi Service generally, and developing, maintaining or improving the Keyboard for Xiaomi Service. |
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We use this information to diagnose or fix technology problems. |
The processing is necessary for our legitimate interests, namely monitoring and resolving issues with the Keyboard for Xiaomi and the Keyboard for Xiaomi Service generally, and developing, maintaining or improving the Keyboard for Xiaomi Service. |
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We use this information to develop and enhance the Keyboard for Xiaomi Service. |
The processing is necessary for our legitimate interests, namely developing, maintaining or improving the Keyboard for Xiaomi Service. |
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All of the above personal information. |
We may process personal information to comply with legal obligations (such as tax and commercial obligations). |
The processing is necessary for our compliance with legal obligations. |
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All of the above personal information. |
We may process personal information to pursue or defend against legal claims, and to protect and defend our rights and property and the rights, property or personal safety of its users or others. |
The processing is necessary for our legitimate interests, namely to pursue or defend against legal claims, and to protect and defend our rights and property and the rights, property or personal safety of its users or others. |