This privacy noticefor Koloni, Inc. ("Company," "we,""us," or "our"), describes how and why wemight collect, store, use, and/or share ("process") yourinformation when you use our services ("Services"), such aswhen you:

  • Visit our website at http://www.koloni.io or any website of ours that links to     this privacy notice
  • Download and use our mobile application (Koloni), or     any other application of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales,     marketing, or events

Questions orconcerns? Reading this privacynotice will help you understand your privacy rights and choices. If you do notagree with our policies and practices, please do not use our Services. If youstill have any questions or concerns, please contact us at info@koloni.me.

 

 

SUMMARY OF KEY POINTS

 

This summary provideskey points from our privacy notice, but you can find out more details about anyof these topics by clicking the link following each key point or by using ourtable of contents below to find the section you are looking for. You can alsoclick here to go directly to our table of contents.

 

What personalinformation do we process? Whenyou visit, use, or navigate our Services, we may process personal informationdepending on how you interact with Koloni, Inc. and the Services, thechoices you make, and the products and features you use. Click here to learn more.

 

Do we process anysensitive personal information? We may process sensitive personal information whennecessary with your consent or as otherwise permitted by applicable law.Click here to learn more.

 

Do you receive anyinformation from third parties? We may receive information from public databases,marketing partners, social media platforms, and other outside sources.Click here to learn more.

 

How do you process myinformation? We process yourinformation to provide, improve, and administer our Services, communicate withyou, for security and fraud prevention, and to comply with law. We may alsoprocess your information for other purposes with your consent. We process yourinformation only when we have a valid legal reason to do so. Click here to learn more.

 

In what situations andwith which types of parties do we share personal information? We may share information in specificsituations and with specific categories of third parties. Click here to learn more.

 

How do we keep yourinformation safe? We haveorganizational and technical processes and procedures in place to protect yourpersonal information. However, no electronic transmission over the internet orinformation storage technology can be guaranteed to be 100% secure, so wecannot promise or guarantee that hackers, cybercriminals, or other unauthorizedthird parties will not be able to defeat our security and improperly collect,access, steal, or modify your information. Click here to learn more.

 

What are your rights? Depending on where you are locatedgeographically, the applicable privacy law may mean you have certain rightsregarding your personal information. Click here to learn more.

 

How do I exercise myrights? The easiest wayto exercise your rights is by filling out our data subject request formavailable here: http://www.koloni.io/legal, or by contacting us. We will consider andact upon any request in accordance with applicable data protection laws.

 

Want to learn moreabout what Koloni, Inc. does with any information we collect?Click here to review the notice in full.

 

 

TABLE OF CONTENTS

 

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TOPROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOURPERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKINGTECHNOLOGIES?

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

8. IS YOUR INFORMATION TRANSFERREDINTERNATIONALLY?

9. HOW LONG DO WE KEEP YOUR INFORMATION?

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

11. WHAT ARE YOUR PRIVACY RIGHTS?

12. CONTROLS FOR DO-NOT-TRACK FEATURES

13. DO CALIFORNIA RESIDENTS HAVE SPECIFICPRIVACY RIGHTS?

14. DO WE MAKE UPDATES TO THIS NOTICE?

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THEDATA WE COLLECT FROM YOU?

 

1. WHAT INFORMATION DOWE COLLECT?

 

Personal information youdisclose to us

 

In Short: We collect personal information that youprovide to us.

 

We collect personalinformation that you voluntarily provide to us when you register on theServices, express an interest in obtaining information about us or ourproducts and Services, when you participate in activities on the Services, orotherwise when you contact us.

 

Personal InformationProvided by You. The personalinformation that we collect depends on the context of your interactions with usand the Services, the choices you make, and the products and features you use.The personal information we collect may include the following:

  • names
  • phone numbers
  • email addresses
  • mailing addresses
  • usernames
  • passwords
  • contact preferences
  • contact or authentication data
  • billing addresses
  • debit/credit card numbers

Sensitive Information. When necessary, with your consent or asotherwise permitted by applicable law, we process the following categories ofsensitive information:

  • financial data

Payment Data. We may collect data necessary to processyour payment if you make purchases, such as your payment instrument number(such as a credit card number), and the security code associated with yourpayment instrument. All payment data is stored by Braintree. You may findtheir privacy notice link(s) here: https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

 

Social Media LoginData. We may provide youwith the option to register with us using your existing social media accountdetails, like your Facebook, Twitter, or other social media account. If youchoose to register in this way, we will collect the information described inthe section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

 

Application Data. If you use our application(s), we alsomay collect the following information if you choose to provide us with accessor permission:

  • Geolocation Information. We may request access or permission     to track location-based information from your mobile device, either     continuously or while you are using our mobile application(s), to provide     certain location-based services. If you wish to change our access or permissions,     you may do so in your device's settings.
  • Mobile Device Access. We may request access or permission     to certain features from your mobile device, including your mobile     device's camera, bluetooth, sms messages, and other     features. If you wish to change our access or permissions, you may do so     in your device's settings.
  • Mobile Device Data. We automatically collect device     information (such as your mobile device ID, model, and manufacturer),     operating system, version information and system configuration information,     device and application identification numbers, browser type and version,     hardware model Internet service provider and/or mobile carrier, and     Internet Protocol (IP) address (or proxy server). If you are using our     application(s), we may also collect information about the phone network     associated with your mobile device, your mobile device’s operating system     or platform, the type of mobile device you use, your mobile device’s     unique device ID, and information about the features of our application(s)     you accessed.
  • Push Notifications. We may request to send you push     notifications regarding your account or certain features of the     application(s). If you wish to opt out from receiving these types of     communications, you may turn them off in your device's settings.

This information isprimarily needed to maintain the security and operation of our application(s),for troubleshooting, and for our internal analytics and reporting purposes.

 

All personalinformation that you provide to us must be true, complete, and accurate, andyou must notify us of any changes to such personal information.

 

Informationautomatically collected

 

In Short: Some information — such as your InternetProtocol (IP) address and/or browser and device characteristics — is collectedautomatically when you visit our Services.

 

We automaticallycollect certain information when you visit, use, or navigate the Services. Thisinformation does not reveal your specific identity (like your name or contactinformation) but may include device and usage information, such as your IPaddress, browser and device characteristics, operating system, languagepreferences, referring URLs, device name, country, location, information abouthow and when you use our Services, and other technical information. Thisinformation is primarily needed to maintain the security and operation of ourServices, and for our internal analytics and reporting purposes.

 

Like many businesses,we also collect information through cookies and similar technologies.

 

The information wecollect includes:

  • Log and Usage Data. Log and usage data is     service-related, diagnostic, usage, and performance information our     servers automatically collect when you access or use our Services and     which we record in log files. Depending on how you interact with us, this     log data may include your IP address, device information, browser type,     and settings and information about your activity in the Services (such as the date/time stamps associated with your usage,     pages and files viewed, searches, and other actions you take such as which     features you use), device event information (such as system activity,     error reports (sometimes called "crash dumps"), and hardware     settings).
  • Device Data. We collect device data such as     information about your computer, phone, tablet, or other device you use to     access the Services. Depending on the device used, this device data may     include information such as your IP address (or proxy server), device and     application identification numbers, location, browser type, hardware     model, Internet service provider and/or mobile carrier, operating system,     and system configuration information.
  • Location Data. We collect location data such as     information about your device's location, which can be either precise or     imprecise. How much information we collect depends on the type and     settings of the device you use to access the Services. For example, we may     use GPS and other technologies to collect geolocation data that tells us     your current location (based on your IP address). You can opt out of     allowing us to collect this information either by refusing access to the     information or by disabling your Location setting on your device. However,     if you choose to opt out, you may not be able to use certain aspects of     the Services.

Information collectedfrom other sources

 

In Short: We may collect limited data from publicdatabases, marketing partners, social media platforms, and otheroutside sources.

 

In order to enhanceour ability to provide relevant marketing, offers, and services to you andupdate our records, we may obtain information about you from other sources,such as public databases, joint marketing partners, affiliate programs, dataproviders, social media platforms, and from other third parties. Thisinformation includes mailing addresses, job titles, email addresses, phonenumbers, intent data (or user behavior data), Internet Protocol (IP) addresses,social media profiles, social media URLs, and custom profiles, for purposes oftargeted advertising and event promotion. If you interact with us on asocial media platform using your social media account (e.g., Facebook orTwitter), we receive personal information about you such as your name, emailaddress, and gender. Any personal information that we collect from your socialmedia account depends on your social media account's privacy settings.

 

2. HOW DO WE PROCESSYOUR INFORMATION?

 

In Short: We process your information to provide,improve, and administer our Services, communicate with you, for security andfraud prevention, and to comply with law. We may also process your informationfor other purposes with your consent.

 

We process yourpersonal information for a variety of reasons, depending on how you interactwith our Services, including:

  • To facilitate account creation and     authentication and otherwise manage user accounts. We may process your information so you     can create and log in to your account, as well as keep your account in     working order.
  • To deliver and facilitate delivery of     services to the user. We may process your information to provide you with the     requested service.
  • To respond to user inquiries/offer     support to users. We may process your information to respond to your     inquiries and solve any potential issues you might have with the requested     service.
  • To send administrative information to     you. We may process     your information to send you details about our products and services,     changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We may process your information to     fulfill and manage your orders, payments, returns, and exchanges made     through the Services.
  • To enable user-to-user     communications. We     may process your information if you choose to use any of our offerings     that allow for communication with another user.
  • To request feedback. We may process your information when     necessary to request feedback and to contact you about your use of our     Services.
  • To deliver targeted advertising to you. We may process your information to     develop and display personalized content and advertising tailored to your     interests, location, and more.
  • To protect our Services. We may process your information as     part of our efforts to keep our Services safe and secure, including fraud     monitoring and prevention.
  • To identify usage trends. We may process information about     how you use our Services to better understand how they are being used so     we can improve them.
  • To save or protect an individual's vital     interest. We may     process your information when necessary to save or protect an individual’s     vital interest, such as to prevent harm.

 

3. WHAT LEGAL BASES DOWE RELY ON TO PROCESS YOUR INFORMATION?

 

In Short: We only process your personal information whenwe believe it is necessary and we have a valid legal reason (i.e., legal basis)to do so under applicable law, like with your consent, to comply with laws, toprovide you with services to enter into or fulfill our contractual obligations,to protect your rights, or to fulfill our legitimate business interests.

 

If you are located inthe EU or UK, this section applies to you.

 

The General DataProtection Regulation (GDPR) and UK GDPR require us to explain the valid legalbases we rely on in order to process your personal information. As such, we mayrely on the following legal bases to process your personal information:

  • Consent. We may process your information if you     have given us permission (i.e., consent) to use your personal information     for a specific purpose. You can withdraw your consent at any time.     Click here to learn more.
  • Performance of a Contract. We may process your personal     information when we believe it is necessary to fulfill our contractual     obligations to you, including providing our Services or at your request     prior to entering into a contract with you.
  • Legitimate Interests. We may process your information     when we believe it is reasonably necessary to achieve our legitimate     business interests and those interests do not outweigh your interests and     fundamental rights and freedoms. For example, we may process your personal     information for some of the purposes described in order to:

§  Develop and display personalized and relevantadvertising content for our users

§  Analyze how our services are used so we canimprove them to engage and retain users

§  Diagnose problems and/or prevent fraudulentactivities

§  Understand how our users use our products andservices so we can improve user experience

  • Legal Obligations. We may process your information     where we believe it is necessary for compliance with our legal     obligations, such as to cooperate with a law enforcement body or     regulatory agency, exercise or defend our legal rights, or disclose your     information as evidence in litigation in which we are involved.
       
       
  • Vital Interests. We may process your information     where we believe it is necessary to protect your vital interests or the     vital interests of a third party, such as situations involving potential     threats to the safety of any person.

 

If you are located inCanada, this section applies to you.

 

We may process yourinformation if you have given us specific permission (i.e., express consent) touse your personal information for a specific purpose, or in situations whereyour permission can be inferred (i.e., implied consent). You can withdraw yourconsent at any time. Click here to learn more.

 

In some exceptionalcases, we may be legally permitted under applicable law to process yourinformation without your consent, including, for example:

  • If collection is clearly in the interests     of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection     and prevention
  • For business transactions provided     certain conditions are met
  • If it is contained in a witness statement     and the collection is necessary to assess, process, or settle an insurance     claim
  • For identifying injured, ill, or deceased     persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has     been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with     consent would compromise the availability or the accuracy of the     information and the collection is reasonable for purposes related to     investigating a breach of an agreement or a contravention of the laws of     Canada or a province
  • If disclosure is required to comply with     a subpoena, warrant, court order, or rules of the court relating to the     production of records
  • If it was produced by an individual in     the course of their employment, business, or profession and the collection     is consistent with the purposes for which the information was produced
  • If the collection is solely for     journalistic, artistic, or literary purposes
  • If the information is publicly available     and is specified by the regulations

 

4. WHEN AND WITH WHOM DOWE SHARE YOUR PERSONAL INFORMATION?

 

In Short: We may share information in specificsituations described in this section and/or with the following categoriesof third parties.

 

Vendors, Consultants,and Other Third-Party Service Providers. We may share your data with third-party vendors, serviceproviders, contractors, or agents (“third parties”) who perform servicesfor us or on our behalf and require access to such information to do thatwork. We have contracts in place with our third parties, which aredesigned to help safeguard your personal information. This means that theycannot do anything with your personal information unless we have instructedthem to do it. They will also not share your personal information with anyorganization apart from us. They also commit to protect the data they hold onour behalf and to retain it for the period weinstruct. The categories of third parties we may share personalinformation with are as follows:

  • Ad Networks
  • Cloud Computing Services
  • Communication & Collaboration Tools
  • Data Analytics Services
  • Data Storage Service Providers
  • Finance & Accounting Tools
  • Order Fulfillment Service Providers
  • Payment Processors
  • Product Engineering & Design Tools
  • Performance Monitoring Tools
  • Social Networks
  • Sales & Marketing Tools
  • User Account Registration &     Authentication Services
  • Website Hosting Service Providers

We also mayneed to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your     information in connection with, or during negotiations of, any merger,     sale of company assets, financing, or acquisition of all or a portion of     our business to another company.
  • When we use Google Maps Platform APIs. We may share your information with     certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To     find out more about Google’s Privacy Policy, please refer to this link. We obtain and store on your device     ('cache') your location. You may revoke your consent anytime by contacting     us at the contact details provided at the end of this document.
  • Affiliates. We may share your information with our     affiliates, in which case we will require those affiliates to honor this     privacy notice. Affiliates include our parent company and any     subsidiaries, joint venture partners, or other companies that we control     or that are under common control with us.
  • Business Partners. We may share your information with     our business partners to offer you certain products, services, or     promotions.

 

5. WHAT IS OUR STANCE ONTHIRD-PARTY WEBSITES?

 

In Short: We are not responsible for the safety ofany information that you share with third parties that we may link to or whoadvertise on our Services, but are not affiliated with, our Services.

 

The Services maylink to third-party websites, online services, or mobile applications and/orcontain advertisements from third parties that are not affiliated with us andwhich may link to other websites, services, or applications. Accordingly, we donot make any guarantee regarding any such third parties, and we will not beliable for any loss or damage caused by the use of such third-party websites,services, or applications. The inclusion of a link towards a third-partywebsite, service, or application does not imply an endorsement by us. We cannotguarantee the safety and privacy of data you provide to any third parties. Anydata collected by third parties is not covered by this privacy notice. We arenot responsible for the content or privacy and security practices and policiesof any third parties, including other websites, services, or applications thatmay be linked to or from the Services. You should review the policies of suchthird parties and contact them directly to respond to your questions.

 

6. DO WE USE COOKIES ANDOTHER TRACKING TECHNOLOGIES?

 

In Short: We may use cookies and other trackingtechnologies to collect and store your information.

 

We may use cookies andsimilar tracking technologies (like web beacons and pixels) to access or storeinformation. Specific information about how we use such technologies and howyou can refuse certain cookies is set out in our Cookie Notice.

 

7. HOW DO WE HANDLE YOURSOCIAL LOGINS?

 

In Short: If you choose to register or log in to ourservices using a social media account, we may have access to certaininformation about you.

 

Our Services offer youthe ability to register and log in using your third-party social media accountdetails (like your Facebook or Twitter logins). Where you choose to do this, wewill receive certain profile information about you from your social mediaprovider. The profile information we receive may vary depending on the socialmedia provider concerned, but will often include your name, email address,friends list, and profile picture, as well as other information you choose tomake public on such a social media platform.

 

We will use theinformation we receive only for the purposes that are described in this privacynotice or that are otherwise made clear to you on the relevant Services. Pleasenote that we do not control, and are not responsible for, other uses of yourpersonal information by your third-party social media provider. We recommendthat you review their privacy notice to understand how they collect, use and shareyour personal information, and how you can set your privacy preferences ontheir sites and apps.

 

8. IS YOUR INFORMATIONTRANSFERRED INTERNATIONALLY?

 

In Short: We may transfer, store, and process yourinformation in countries other than your own.

 

Our servers arelocated in the United States. If you are accessing our Services fromoutside the United States, please be aware that your information maybe transferred to, stored, and processed by us in our facilities and by thosethird parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONALINFORMATION?" above),in the United States, and other countries.

 

If you are a residentin the European Economic Area (EEA) or United Kingdom (UK), then thesecountries may not necessarily have data protection laws or other similar lawsas comprehensive as those in your country. However, we will take all necessarymeasures to protect your personal information in accordance with this privacynotice and applicable law.

 

European Commission'sStandard Contractual Clauses:

 

We have implementedmeasures to protect your personal information, including by using the EuropeanCommission's Standard Contractual Clauses for transfers of personal informationbetween our group companies and between us and our third-party providers. Theseclauses require all recipients to protect all personal information that theyprocess originating from the EEA or UK in accordance with European dataprotection laws and regulations. Our StandardContractual Clauses can be provided upon request. We have implementedsimilar appropriate safeguards with our third-party service providers andpartners and further details can be provided upon request. 

 

Binding CorporateRules:

 

These include a set ofBinding Corporate Rules ("BCRs") established and implementedby Koloni, Inc.. Our BCRs have been recognized by EEA and UK dataprotection authorities as providing an adequate level of protection to thepersonal information we process internationally. You can find a copy of ourBCRs here: __________.

 

9. HOW LONG DO WE KEEPYOUR INFORMATION?

 

In Short: We keep your information for as long asnecessary to fulfill the purposes outlined in this privacy notice unlessotherwise required by law.

 

We will only keep yourpersonal information for as long as it is necessary for the purposes set out inthis privacy notice, unless a longer retention period is required or permittedby law (such as tax, accounting, or other legal requirements). No purpose inthis notice will require us keeping your personal information for longerthan the period of time in which users have an account with us.

 

When we have noongoing legitimate business need to process your personal information, we willeither delete or anonymize such information, or, if this is not possible (forexample, because your personal information has been stored in backup archives),then we will securely store your personal information and isolate it from anyfurther processing until deletion is possible.

 

10. HOW DO WE KEEP YOURINFORMATION SAFE?

 

In Short: We aim to protect your personal informationthrough a system of organizational and technical security measures.

 

We have implementedappropriate and reasonable technical and organizational security measuresdesigned to protect the security of any personal information we process.However, despite our safeguards and efforts to secure your information, noelectronic transmission over the Internet or information storage technology canbe guaranteed to be 100% secure, so we cannot promise or guarantee thathackers, cybercriminals, or other unauthorized third parties will not be ableto defeat our security and improperly collect, access, steal, or modify yourinformation. Although we will do our best to protect your personal information,transmission of personal information to and from our Services is at your ownrisk. You should only access the Services within a secure environment.

 

11. WHAT ARE YOURPRIVACY RIGHTS?

 

In Short: In some regions, such as theEuropean Economic Area (EEA), United Kingdom (UK), and Canada, you have rightsthat allow you greater access to and control over your personalinformation. You may review, change, or terminate your account at anytime.

 

In some regions(like the EEA, UK, and Canada), you have certain rights under applicabledata protection laws. These may include the right (i) to request access andobtain a copy of your personal information, (ii) to request rectification orerasure; (iii) to restrict the processing of your personal information; and(iv) if applicable, to data portability. In certain circumstances, you may alsohave the right to object to the processing of your personal information. Youcan make such a request by contacting us by using the contact details providedin the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

 

We will consider andact upon any request in accordance with applicable data protection laws.

 

If you are located inthe EEA or UK and you believe we are unlawfully processing your personalinformation, you also have the right to complain to your local data protectionsupervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

If you are located inSwitzerland, the contact details for the data protection authorities areavailable here: https://www.edoeb.admin.ch/edoeb/en/home.html.

 

Withdrawing yourconsent: If we arerelying on your consent to process your personal information, which may beexpress and/or implied consent depending on the applicable law, you havethe right to withdraw your consent at any time. You can withdraw your consentat any time by contacting us by using the contact details provided in thesection "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating yourpreferences.

 

However, please notethat this will not affect the lawfulness of the processing before itswithdrawal, nor when applicable law allows, will it affect theprocessing of your personal information conducted in reliance on lawfulprocessing grounds other than consent.

 

Opting out ofmarketing and promotional communications: You can unsubscribe from our marketing andpromotional communications at any time by clicking on the unsubscribe linkin the emails that we send, or by contacting us using the details providedin the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed fromthe marketing lists. However, we may still communicate with you — for example,to send you service-related messages that are necessary for the administrationand use of your account, to respond to service requests, or for othernon-marketing purposes.

 

Account Information

 

If you would at anytime like to review or change the information in your account or terminate youraccount, you can:

  • Contact us using the contact information     provided.

Upon your request toterminate your account, we will deactivate or delete your account andinformation from our active databases. However, we may retain some informationin our files to prevent fraud, troubleshoot problems, assist with anyinvestigations, enforce our legal terms and/or comply with applicable legalrequirements.

 

Cookies and similartechnologies: Most Web browsersare set to accept cookies by default. If you prefer, you can usually choose toset your browser to remove cookies and to reject cookies. If you choose toremove cookies or reject cookies, this could affect certain features orservices of our Services. To opt out of interest-based advertising byadvertisers on our Services visit http://www.aboutads.info/choices/.

 

If you have questionsor comments about your privacy rights, you may email us at info@koloni.me.

 

12. CONTROLS FORDO-NOT-TRACK FEATURES

 

Most web browsers andsome mobile operating systems and mobile applications include a Do-Not-Track("DNT") feature or setting you can activate to signal your privacypreference not to have data about your online browsing activities monitored andcollected. At this stage no uniform technology standard for recognizing andimplementing DNT signals has been finalized. As such, we do not currentlyrespond to DNT browser signals or any other mechanism that automaticallycommunicates your choice not to be tracked online. If a standard for onlinetracking is adopted that we must follow in the future, we will inform you aboutthat practice in a revised version of this privacy notice.

 

13. DO CALIFORNIARESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

 

In Short: Yes, if you are a resident of California, youare granted specific rights regarding access to your personal information.

 

California Civil CodeSection 1798.83, also known as the "Shine The Light" law, permits ourusers who are California residents to request and obtain from us, once a yearand free of charge, information about categories of personal information (ifany) we disclosed to third parties for direct marketing purposes and the namesand addresses of all third parties with which we shared personal information inthe immediately preceding calendar year. If you are a California resident andwould like to make such a request, please submit your request in writing to ususing the contact information provided below.

 

If you are under 18years of age, reside in California, and have a registered account withServices, you have the right to request removal of unwanted data that youpublicly post on the Services. To request removal of such data, please contactus using the contact information provided below and include the email addressassociated with your account and a statement that you reside in California. Wewill make sure the data is not publicly displayed on the Services, but pleasebe aware that the data may not be completely or comprehensively removed fromall our systems (e.g., backups, etc.).

 

CCPA Privacy Notice

 

The California Code ofRegulations defines a "resident" as:

 

(1) every individualwho is in the State of California for other than a temporary or transitorypurpose and

(2) every individualwho is domiciled in the State of California who is outside the State ofCalifornia for a temporary or transitory purpose

 

All other individualsare defined as "non-residents."

 

If this definition of"resident" applies to you, we must adhere to certain rights andobligations regarding your personal information.

 

What categories ofpersonal information do we collect?

 

We have collected thefollowing categories of personal information in the past twelve (12) months:

 

Category

Examples

Collected

A. Identifiers

Contact details,  such as real name, alias, postal address, telephone or mobile contact number,  unique personal identifier, online identifier, Internet Protocol address,  email address, and account name

 

YES

B. Personal  information categories listed in the California Customer Records statute

Name, contact  information, education, employment, employment history, and financial  information

 

YES

C. Protected  classification characteristics under California or federal law

Gender and date of  birth

 

YES

D. Commercial  information

Transaction  information, purchase history, financial details, and payment information

 

YES

E. Biometric information

Fingerprints and  voiceprints

 

NO

F. Internet or other  similar network activity

Browsing history,  search history, online behavior, interest data, and interactions with our and  other websites, applications, systems, and advertisements

 

NO

G. Geolocation data

Device location

 

YES

H. Audio,  electronic, visual, thermal, olfactory, or similar information

Images and audio,  video or call recordings created in connection with our business activities

 

NO

I. Professional or  employment-related information

Business contact  details in order to provide you our services at a business level or job  title, work history, and professional qualifications if you apply for a job  with us

 

NO

J. Education  Information

Student records and  directory information

 

NO

K. Inferences drawn  from other personal information

Inferences drawn  from any of the collected personal information listed above to create a  profile or summary about, for example, an individual’s preferences and  characteristics

 

NO

 

We may also collectother personal information outside of these categories instances where youinteract with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer     support channels;
  • Participation in customer surveys or     contests; and
  • Facilitation in the delivery of our     Services and to respond to your inquiries.

How do we use andshare your personal information?

 

Koloni, Inc. collectsand shares your personal information through:

  • Beacons/Pixels/Tags

More information aboutour data collection and sharing practices can be found in this privacy notice.

 

You can opt out fromthe selling of your personal information by disabling cookies in CookiePreference Settings and clicking on the Do Not Sell My Personal Informationlink on our homepage.

 

You may contactus by email at info@koloni.me, or by referring to the contactdetails at the bottom of this document.

 

If you are using anauthorized agent to exercise your right to opt out we may deny a request if theauthorized agent does not submit proof that they have been validly authorizedto act on your behalf.

 

Will your informationbe shared with anyone else?

 

We may disclose yourpersonal information with our service providers pursuant to a written contractbetween us and each service provider. Each service provider is a for-profitentity that processes the information on our behalf.

 

We may use yourpersonal information for our own business purposes, such as for undertakinginternal research for technological development and demonstration. This is notconsidered to be "selling" of your personal information.

 

Koloni, Inc. hasdisclosed the following categories of personal information to third parties fora business or commercial purpose in the preceding twelve (12) months:

  • Category A. Identifiers, such as contact details like your     real name, alias, postal address, telephone or mobile contact number,     unique personal identifier, online identifier, Internet Protocol address,     email address, and account name.
  • Category B. Personal information, as     defined in the California Customer Records law, such as your name, contact     information, education, employment, employment history, and financial     information.
  • Category C. Characteristics of protected     classifications under California or federal law, such as gender or date of     birth.
  • Category D. Commercial information, such     as transaction information, purchase history, financial details, and payment     information.
  • Category G. Geolocation data, such as     device location.

The categories ofthird parties to whom we disclosed personal information for a business orcommercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONALINFORMATION?".

 

Koloni, Inc. hassold the following categories of personal information to third parties in the precedingtwelve (12) months:

  • Category B. Personal information, as     defined in the California Customer Records law, such as your name, contact     information, education, employment, employment history, and financial     information.

The categories ofthird parties to whom we sold personal information are:

  • Data Analytics Services
  • Retargeting Platforms
  • User Account Registration &     Authentication Services
  • Affiliate Marketing Programs
  • Ad Networks

 

Your rights withrespect to your personal data

 

Right to request deletionof the data — Request to delete

 

You can ask for thedeletion of your personal information. If you ask us to delete your personalinformation, we will respect your request and delete your personal information,subject to certain exceptions provided by law, such as (but not limited to) theexercise by another consumer of his or her right to free speech, our compliancerequirements resulting from a legal obligation, or any processing that may berequired to protect against illegal activities.

 

Right to be informed —Request to know

 

Depending on thecircumstances, you have a right to know:

  • whether we collect and use your personal     information;
  • the categories of personal information     that we collect;
  • the purposes for which the collected     personal information is used;
  • whether we sell your personal information     to third parties;
  • the categories of personal information     that we sold or disclosed for a business purpose;
  • the categories of third parties to whom the     personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for     collecting or selling personal information.

In accordance withapplicable law, we are not obligated to provide or delete consumer information thatis de-identified in response to a consumer request or to re-identify individualdata to verify a consumer request.

 

Right toNon-Discrimination for the Exercise of a Consumer’s Privacy Rights

 

We will notdiscriminate against you if you exercise your privacy rights.

 

Verification process

 

Upon receiving yourrequest, we will need to verify your identity to determine you are the sameperson about whom we have the information in our system. These verificationefforts require us to ask you to provide information so that we can match itwith information you have previously provided us. For instance, depending onthe type of request you submit, we may ask you to provide certain informationso that we can match the information you provide with the information wealready have on file, or we may contact you through a communication method(e.g., phone or email) that you have previously provided to us. We may also useother verification methods as the circumstances dictate.

 

We will only usepersonal information provided in your request to verify your identity orauthority to make the request. To the extent possible, we will avoid requestingadditional information from you for the purposes of verification. However, ifwe cannot verify your identity from the information already maintained by us,we may request that you provide additional information for the purposes ofverifying your identity and for security or fraud-prevention purposes. We willdelete such additionally provided information as soon as we finish verifyingyou.

 

Other privacy rights

  • You may object to the processing of your     personal information.
  • You may request correction of your     personal data if it is incorrect or no longer relevant, or ask to restrict     the processing of the information.
  • You can designate an authorized agent to     make a request under the CCPA on your behalf. We may deny a request from     an authorized agent that does not submit proof that they have been validly     authorized to act on your behalf in accordance with the CCPA.

To exercise theserights, you can contact us by email at info@koloni.me, or byreferring to the contact details at the bottom of this document. If you have acomplaint about how we handle your data, we would like to hear from you.

 

14. DO WE MAKE UPDATESTO THIS NOTICE?

 

In Short: Yes, we will update this notice as necessaryto stay compliant with relevant laws.

 

We may update thisprivacy notice from time to time. The updated version will be indicated by anupdated "Revised" date and the updated version will be effective assoon as it is accessible. If we make material changes to this privacy notice,we may notify you either by prominently posting a notice of such changes or bydirectly sending you a notification. We encourage you to review this privacynotice frequently to be informed of how we are protecting your information.

 

15. HOW CAN YOU CONTACTUS ABOUT THIS NOTICE?

 

If you have questionsor comments about this notice, you may contact our Data Protection Officer(DPO), Kate Lyon, by email at info@koloni.me, by phoneat 5152316414, or by post to:

 

Koloni, Inc.

158 Touhy Ct

Des Plaines, IL 60018

United States

 

16. HOW CAN YOU REVIEW,UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on theapplicable laws of your country, you may have the right to request access tothe personal information we collect from you, change that information, ordelete it in some circumstances. To request to review, update, or delete yourpersonal information, please visit: http://www.koloni.io/legal.

 

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