Kahua Privacy Policy

Welcome to the service provided by Kahua, Inc. (“Kahua”, “Kahua.com”, “we”, “us” and/or “our”). This Privacy Policy has been created to provide information about our company, our website, our applications and the services we provide (collectively the “Services”) to our visitors and users (“you” and/or “your”). This Privacy Policy sets forth Kahua’s policy with respect to information, including personally identifiable data (“Personal Data”) and other information, that is collected from visitors and users of the Services.

Information We Collect

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Services: We collect Personal Data and other information from you when you voluntarily provide such information (like your calendar or email), such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services.

We also automatically collect certain information when you use the Services, such as a device identifier (but not the UDID), Internet Protocol (IP) address, operating system and your activity on the Services. This information is treated as Personal Data if it is combined with or linked to any of the Personal Data mentioned above.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data via the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Kahua and the authorized third parties referred to herein located in the United States.

Other Information

Non-Identifiable Data: When you interact with Kahua through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Kahua may store such information itself or such information may be included in databases owned and maintained by Kahua’s affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of users of our Services, the number of visitors to each page of our website and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, Kahua may conduct research on its user demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Kahua may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Kahua may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Our Use of Your Personal Data and Other Information

Kahua uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Kahua and its subsidiaries and affiliates (the “Kahua Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Kahua Services. Kahua and Kahua Related Companies may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

If Kahua intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information

Kahua is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Service Providers: We will share your Personal Data with service providers who are working with us in connection with the operation of the Services (these service providers have access to your Personal Data only to perform services on our behalf and are obligated not to disclose it or use it for any other purposes).

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with Kahua Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: Kahua, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Kahua may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Kahua, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties.

Your Choices

You can visit the Services without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Kahua Services.

Certain information is required to provide individualized services to each user of our mobile application. If you choose not to provide any Personal Data, you will not be able to use our services.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Kahua other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Kahua through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as discussion forums (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Kahua shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Third-Party Links

Kahua provides third-party links as a service to our users. Kahua is not responsible for the content on these sites, nor does our inclusion of a third-party site imply an endorsement with that link or the entity hosting that site. Kahua makes no representations whatsoever about any other websites that you access through this site. The policies and procedures we described here do not apply to the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Minor’s Privacy

Kahua places a high priority on protecting the privacy of minors. Our site is not designed to attract children. Kahua does not knowingly collect Personal Data from children under the age of 18. If you are under the age of 18, you must obtain consent from your parents or legal guardians before disclosing personal information to us. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to Kahua through the Services without the consent of their parent or legal guardian, please contact us, and we will endeavor to delete that information from our databases.

Security

Kahua takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error-free. In particular, e-mail sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Data to Kahua via the Internet.

EU-US and US-Swiss Privacy Shield

Kahua complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Kahua has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Pursuant to the Privacy Shield, Kahua remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

In compliance with the US-EU and Swiss-US Privacy Shield Principles, Kahua commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Kahua at: [email protected]

Kahua has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Our organization is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, an individual can invoke binding arbitration. We will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In addition, our organization retains liability in cases of onward transfers to third parties.

Other Terms and Conditions

Your access to and use of the Services is subject to the Terms of Service.

Changes to Kahua’s Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for Kahua to make changes to this Privacy Policy. Kahua reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting Kahua

To keep your Personal Data accurate, current, complete or limit or delete it, please contact us as specified below. We will take reasonable steps to update, correct, limit or delete Personal Data in our possession that you have previously submitted via the Services if requested via email to our Support team at [email protected]

Please also feel free to contact us if you have any questions about Kahua’s Privacy Policy or the information practices of the Services.

You may contact us as follows: [email protected]

Effective date February 21, 2017