Kioga Inc. Privacy Policy

5. Data Processing Contexts / Notice at Collection

Through Our Site

Generally

When you use our Site, we automatically collect and process Identity Data, Inference Data, General Location Data, and Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through our Site, such as operating our Site, delivering webpages, or logging activities for security purposes. We may also process this Personal Information for our Business Purposes (as defined below).

Cookies and Similar Tracking Technologies

We process Identity Data, Device/Network Data, Contact Data, Inference Data, Transaction Data, and General Location Data in connection with our use of cookies and similar technologies on our Site. We may collect this data automatically.

We and authorized third parties may use cookies and similar technologies to process such data for the following purposes:

• for “essential” purposes necessary for our Site to operate (such as maintaining user sessions, content delivery, and the like);
• for “functional” purposes, such as to enable certain features of our Site (for example, to allow a customer to maintain an online shopping cart or similar tool); and
• for “analytics” purposes and to improve our Site, such as to analyze the traffic to and on our Site (for example, we can count how many people have looked at a specific page, or see how visitors move around the Site when they use it, to distinguish unique visits/visitors to our Site, and what website they visited prior to visiting our Site, and use this information to understand user behaviors and improve the design and functionality of the Site).

We may also process this Personal Information for our Business Purposes. See the “Rights and Choices” section below for information regarding opt-out rights for cookies and similar technologies.

Please note, in some cases, third parties may view, edit, or set their own cookies or place web beacons on our Site. We, or these third-party providers, may be able to use these technologies to identify you across websites, devices, sites, and services. Third parties have their own privacy policies and their processing is not subject to this Policy.

The third-party technologies we currently use on our Site include HubSpot, which helps us understand Site traffic and manage inquiries submitted through our forms; Microsoft Clarity, which captures how visitors interact with our Site (for example, clicks, scrolling, and page navigation) through heatmaps and session replays so we can improve its design and usability; and the LinkedIn Insight Tag, which provides us with aggregated reports about the professional characteristics of Site visitors (such as industry, company, and job function) and helps us measure and, where applicable, target our LinkedIn advertising. Clarity masks text entered into form fields. For more information, see the HubSpot Privacy Policy (https://legal.hubspot.com/privacy-policy), the Microsoft Privacy Statement (https://privacy.microsoft.com/privacystatement), and the LinkedIn Privacy Policy (https://www.linkedin.com/legal/privacy-policy). LinkedIn members can manage how LinkedIn uses this data for advertising in their LinkedIn ad settings (https://www.linkedin.com/psettings/advertising).

When You Contact Us

When you contact us using a contact phone number, contact us box, via email, or otherwise request information from us, we process Personal Information such as Identity Data, Device/Network Data, and any Personal Information contained within any User Content you provide. We use Identity Data, Contact Data, and User Content as necessary to communicate with you about the subject matter of your request and related matters. We may also process this Personal Information for our Business Purposes.

Through Social Media Posts

We process Identity Data, Contact Data, and User Content if you interact with or identify us on social media or communication Site (e.g. if you post User Content that engages with or tags our official accounts). We process this Personal Information for our Business Purposes.

Posts may be public, or reposted on our Service. Content you provide may be publicly available when you post it on our Service, or in some cases, if you reference, engage, or tag our official social media accounts or communications Site.

Through Informational or Promotional Communications

We process Device/Network Data, Contact Data, Identity Data, and Inference Data in connection with marketing emails or similar communications, and when you open or interact with those communications (“Marketing Communications”).

You may receive Marketing Communications if you consent and, in some jurisdictions, where permitted by law, e.g. following an inquiry or transaction that allows us to send marketing communications without consent. Marketing communications will include information about our Services, investments, and other promotional material we believe will interest you.

We process this Personal Data to contact you about relevant products or services and for our Business Purposes. You can withdraw your consent to receive Marketing Communications by clicking on the unsubscribe link in an email, or by contacting us. See the “Rights and Choices” section below for information regarding opt-out rights for Marketing Communications.

6. Purposes of Processing

Business Purposes

In addition to the processing described above, we generally process Personal Information for several common purposes in connection with our business. Please see below for more information regarding the purposes for which we process your Personal Information.

Operate our Site and Fulfill Obligations

We process any Personal Information as is necessary to operate our Site, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and Services you request.

Internal Processes and Service Improvement

We may use any Personal Information we process through our Services in connection with our improvement of the design of our Services. For example, we process Personal Information to better understanding how our Site is used or functions, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to the use of the Site, and for ensuring the security and stability of the Site. Additionally, we may use Personal Information to understand what Services or parts of our Site are most relevant to users, how users interact with various aspects of our Site, how our Site perform or fail to perform, etc., or we may analyze use of the Site to determine if there are specific activities that might indicate an information security risk to the Site or our users.

Security and Incident Detection

We may process Personal information in connection with our legitimate interest in ensuring that our Site is secure, identify and prevent crime, prevent fraud, and verify or authenticate users/individuals. Similarly, we process Personal information as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns, and characteristics, maintain and analyze logs and process similar Personal information in connection with our information security operations and related.

Aggregate Analytics

We process Personal Information as necessary in connection with our creation of aggregate analytics relating to how our Site is used, the pages and content users view, and to create other reports regarding the use and performance of our Site, and other similar information and metrics. The resulting aggregate data will not contain information from which an individual may be readily identified.

Compliance, Safety & Public Interest

Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Information subject to this Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Information in extraordinary circumstances.

Corporate Events

Your Personal Information may be processed as part of routine corporate operations, as part of corporate reorganizations, or any business transition, such as a merger, acquisition, liquidation, or sale of assets.

7. Data Sharing

Personal Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with specific business purposes, described below.

Service Providers

In connection with our general business operations, product improvements, to enable certain features, and in connection with our other lawful business interests, we may share Personal Information with service providers or subprocessors who provide certain services to us, or process data on our behalf. For example, we may use third party hosting providers to host our sites or content, and we may disclose information as part of our own internal operations, such as security operations, internal research, etc.

Social Media Companies

We may share certain Personal Information with social media companies when you interact with us on social media. We may allow these third parties to operate through our Service, such as through a social media icon link on our homepage. We do not share Contact Data collected in connection with our promotional communications with these parties.

Corporate Events

Your Personal Information may be disclosed to a third party in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Information may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Affiliates

In order to streamline certain business operations and develop products and Site that better meet the interests and needs of our clients, partners, and users, we may share your Personal Information with any of our current or future affiliated entities, subsidiaries, and parent companies.

Legal Disclosures

In limited circumstances, we may, without notice or your consent, access and disclose your Personal Information, our correspondence with you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Information as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Information to such parties.

8. Your Rights & Choices

Your Rights

Applicable law may grant you rights in your Personal Information. These rights vary based on your location, state/country of residence, and may be limited by or subject to our own rights in your Personal Information. You may submit requests to exercise rights you may have by contacting us using the contact information above.

Note: We are able to fulfill rights requests regarding Personal Information that we control or process. We may not have access to or control over Personal Information controlled by third parties. Please contact the third party directly to exercise your rights in third party-controlled information.

Verification of Rights Requests

We verify all rights requests to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Information. For example, we may require that you verify that you have access to the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

Your Choices

You may have the following choices regarding the Personal Information we process, to the extent required under applicable law:

Consent

If we rely on your consent to our processing of Personal Information, you may withdraw your consent at any time. You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email (for email), or for other communications, by contacting us using the information above. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Email Marketing

You have the choice to opt-out of or withdraw your consent to email marketing communications. You may exercise your choice via the links in our communications.

Cookies & Similar Tech

If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies and certain similar technologies using your browser’s settings menu. You must opt out of the use of some third party site directly via the third party.

Do Not Track

Our Site does not respond to your browser’s do not track signal.

9. Security

We implement and maintain reasonable security measures to safeguard the Personal Information you provide us. However, we sometimes share Personal Information with third parties as noted above, and though we may take certain measures to help ensure the security of your Personal Information, we do not control third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Information or any other information you provide us will remain secure.

10. Data Retention

We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.

11. International transfers

We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Information may be processed in the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Information in foreign countries. Contact us for more information regarding transfers of data to the U.S.

12. Children

Our Services are neither directed at nor intended for use by persons under the age of 13 in the US. We do not knowingly collect information from such individuals. If we learn that we have inadvertently done so, we will promptly delete such Personal Information if required by law. Do not access or use our Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

13. Changes to Our Policy

We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Site following notice of any changes indicates acceptance of any changes.