Effective Date: February 21, 2023
Kala Pte. Ltd. (“Kala,” “we,” “us” or “our”) respects the privacy of visitors to our websites, apps and online services and values the confidence of our customers, partners, and employees. This Privacy Policy sets forth Kala’s practices regarding the collection, use and disclosure of information that you may provide through the websites that we operate, their subdomains, and all portals (“Websites”), our mobile applications (“Apps”), all other products, services, events or interactive features (“Services”) that link to this Privacy Policy, as well as Personal Information provided to Kala by any means. Additional privacy disclosures may be made at the time of collection of the information. WE DO NOT SELL YOUR PERSONAL INFORMATION. Please read the entire Privacy Policy before using our Websites, Apps or Services. By using the Websites, Apps or Services, you agree to abide by the terms of this Privacy Policy. This Privacy Policy is also part of our Terms of Use, which govern your use of the Websites and Apps.
We may ask you for some or all of the following types of information when you access various content or features of the Websites, Apps or Services, submit content, or directly contact us:
Contact information, such as name, email address, postal address, and telephone number;
Online identifiers, such as Internet Protocol (IP) address, cookies, username, and password;
Information from social media accounts;
Annotations you make in the App or on the Websites (for your privacy, we discourage you from including sensitive health or other personal information in your annotations; any annotations made by you are at your own discretion and your own risk);
Financial information, such as credit card, debit card or bank account number, if necessary for payment (we do not store this information);
Search queries;
Other Personal Information that may be contained in employment applications, including submissions of your professional or educational background, your contact
information and other information contained in resumes, cover letters, recommendations, and references;
Personal Information contained within correspondence and other information that you send to us.
We also may collect certain information automatically when you visit the Websites and Apps, including:
Your IP address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
Other unique identifiers, including mobile device identification numbers (e.g., IDFA, Android/Google Advertising ID, IMEI);
Your browser type and operating system;
Your device characteristics;
Sites you visited before and after visiting the Websites and Apps;
Pages you view and links you click on within the Websites and Apps, including remembering you and your preferences;
Your device location and/or other geolocation information, including the zip code, state, or country from which you accessed the Websites and Apps;
Information collected through cookies, web beacons and other technologies;
Information about your interactions with email messages, such as the links clicked on and whether the messages were received, opened, or forwarded;
Standard Server Log Information.
We may use cookies, pixel tags and similar technologies to automatically collect this information. Cookies are small bits of information that are stored by your computer’s web browser.
Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Websites or Apps, you consent to our use of cookies and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you
may not be able to use certain online products, services or features on the Websites or Apps.
We may use information that we collect through the Websites, Apps or in person for a variety of purposes, including to:
Operate and improve our Websites, Apps and Services;
Understand you and your preferences to enhance your experience and enjoyment using our Websites, Apps and Services;
Process employment applications;
Respond to your comments and questions and provide customer service;
Maintain your account;
Verify your identity and for fraud prevention;
Provide and deliver products, information, and services you request and identify your preferences;
Process your payments or purchases;
Meet our audit, compliance, and regulatory obligations;
Send you information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
Communicate with you about upcoming events and news about products, information and services offered by Kala or our selected partners;
Link or combine with other Personal Information we get from third parties, to help understand your needs and provide you with better service;
Assist when it is necessary for emergency medical purposes or to protect your or another person’s vital interests;
Comply with a law, court order, or other judicial or administrative process;
Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and
As otherwise described to you at the point of collection or with your consent.
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information
we collect. We do not sell your Personal Information. We may need to provide your Personal Information to others in the
following instances:
Corporate Parents and Affiliates. As applicable, we may share your information with affiliated entities for a variety of purposes, including business, operational and marketing purposes.
Service Providers. We may share your information with service providers that perform certain functions or services on our behalf (such as to host the Websites and Apps, manage databases, process payments or other data, perform analyses or send communications for us).
Other Parties When Required by Law or as Necessary to Protect the Websites and Apps. We may disclose your information to third parties in order to: protect the legal rights, safety and security of Kala, affiliates and the users of our Websites and apps; enforce our Terms of Use; prevent fraud (or for risk management purposes); and comply with or respond to law enforcement or legal process or a request for cooperation by a government entity, whether or not legally required.
In Connection with a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.
Other Parties with Your Express or Implied Consent. We may share information about you with third parties when you consent to such sharing.
Aggregate Information. We may disclose to third parties information that does not describe or identify individual users, such as aggregate usage data or demographic reports for the Websites and Apps. (This is not considered Personal Information.
In addition, we may allow third parties to place and read their own cookies, web beacons and similar technologies to collect information through the Websites and Apps. For example, our third-party service providers may use these technologies to collect information that helps us with traffic measurement, research, and analysis. Please note that you may need to take additional steps beyond changing your browser settings to refuse or disable some of these technologies. If you choose to refuse, disable, or
delete these technologies, some of the functionality of the Websites and Apps may no longer be available to you. You understand that when you use the Websites and Apps, these analysis providers may collect information related to your use of the Websites and Apps.
We maintain a variety of security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide through the Websites and Apps. However, no data transmission over the Internet or stored on a server can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction or inadvertent disclosure of your information. Please see our Terms of Use for additional information.
Response to “Do Not Track” Signals
Do Not Track (“DNT”) is a web browser setting that requests a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to Websites, analysis companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. However, because there currently is no industry standard concerning what, if anything, Websites should do when they receive such signals, we currently do not take action in response to these signals.
Kala respects the privacy of children, and no part of our Site is targeted to attract anyone under the age of 13. Kala does not knowingly collect, use, or disclose Personal Information from children under the age of 13 without prior parental consent.
Users from ages 13 to 15 must represent and warrant that they are visiting the Site under the supervision of a parent or guardian, and we may ask your parent or guardian to provide prior written consent for you to use the Site. By providing your consent, you agree that we may collect, use, and disclose your child’s Personal Information consistent with this Privacy Policy. If you believe we have information regarding a child under the age of
16 that you have not authorized, you may contact us at [email protected].
Your Choices Regarding Your Personal Data
If you receive emails or other communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly at our contact information below. If you opt out, we may still send you non-promotional emails, such as emails about our ongoing business relations. You may also request changes or updates to your Personal Information by sending a request at our contact information below.
International Transfers of Information
If you are visiting the Site from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Site will be created on servers located in the United States, and all information you provide will be maintained on web servers and
systems located within the United States. Your information, including your Personal Information, may be transferred to – and maintained on --- computers located in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. Your consent to this Privacy Policy, followed by your submission of your information represents your agreement to the collection, storage, processing and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States.
Kala will take all the steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.
Your Additional Data Protection Rights Under the General Data Protection Regulation (GDPR)
If you are a resident of or located within the European Economic Area (EEA), you have certain additional data protection rights.
These rights include:
The right to access, update or delete the information we have about you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Information.
The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Kala relied on your consent to process your Personal Information.
Legal Bases for Processing Personal Information Under the GDPR
Kala is a controller of Personal Information. Kala’s legal bases for collecting or processing your Personal Information are as follows:
We need to provide a service to you;
You have given us your consent to do so;
The processing is in our legitimate interests and it is not overridden by your rights; or
To comply with the law.
Kala will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Kala will also retain Personal Information and usage data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.
Disclosure of Personal Information
Kala may disclose your Personal Information in the good faith belief that such action is necessary to:
To comply with a legal obligation or in response to valid requests by public authorities or as otherwise set forth in this Privacy Policy;
To protect and defend the rights or property of Kala;
To prevent or investigate possible wrongdoing in connection with the Service;
To protect the personal safety of users of the Service or the public; and/or
To protect against legal liability.
Exercising Your Rights Under the GDPR
If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the details in the Contact Information section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.
Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.
Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory
authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us at [email protected].
For more information about the GDPR, please contact your local data protection authority in the EEA.
Your Additional Data Protection Rights Under the Lei Geral de Proteção de Dados (LGPD)
If you are located in the national territory of Brazil, you have certain additional data protection rights. These rights include:
The right to confirmation of the existence of the processing;
The right to access the data;
The right to correct incomplete, inaccurate or out-of-date data;
The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;
The right to the portability of data to another service or product provider, by means of an express request;
The right to delete personal data processed with the consent of the data subject;
The right to information about public and private entities with which the controller has shared data;
The right to information about the possibility of denying consent and the consequences of such denial; and
The right to revoke consent.
Legal Bases for Processing Data Under the LGPD
Kala’s legal bases for collecting or processing your Personal Information are as follows:
We need to provide a service to you;
You have given us your consent to do so;
The processing is in our legitimate interests and it is not overridden by your rights; or
To comply with the law.
Kala will process and retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the
extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Kala will also retain Personal Information and usage data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.
Exercising Your Rights Under the LGPD
If applicable, you may exercise any of your rights under the LGPD by submitting a verifiable data subject request to us by using the details in the Contact Information section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Brazil in your request. We may
require you to confirm your identity and/or legal standing for the request as well as your residency in order to obtain the information. We will respond to your request within 15 days.
As a convenience to our visitors, the Websites and Apps may link to a number of sites, services and other content that are operated and maintained by third parties. These third parties operate independently from us, and we do not control their privacy practices. You are encouraged to use common sense when sharing your Personal Information, and you should be aware when you leave our Site to visit another Site. None of the links on this Site should be deemed to imply that Kala endorses the content or has any affiliation with the persons or entities associated therewith. This Privacy Policy does not apply to third-party content. We encourage you to review the privacy policies of any third party to whom you provide information.
Kala may work with certain third-party social media providers to offer you their social networking services through our Websites
and Apps. For example, you can use third-party social networking services such as Facebook to log into your Kala account. These social networking services may be able to collect information about you, including your activity on our Websites and Apps. These third-party social networking services also may notify your friends, both on our Websites and Apps and on the social networking services themselves, that you are a user of our Websites and Apps or about your use of our Websites and Apps, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.
This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the policy in the upper left corner of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this
Privacy Policy regarding use or disclosure of Personal Information, we will provide advance notice through the Websites and Apps. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. If you are concerned about how your Personal Information is used, please visit our Site often for this and other important announcements and updates.
If you have any questions about this Privacy Policy, please contact us at: