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Privacy Policy: Kuula Website and Mobile Application

Last Updated: July 29, 2020

Welcome to Kuula’s Privacy Policy! Kuula is a video and streaming platform purpose-built for the health and wellness space for both teachers and students. We take the hassle out of scheduling, payments, delivery, and discovery, while enhancing quality, community, and support — so that you can focus on enjoying your classes, wherever in the world you may be.

I. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy describes the types of personal information Kuula, Inc. (the “Company,” “us,” “we” or “our”) collects through www.kuula.tv (the “Site”) or the Kuula Camera mobile application (the “Application” and, together with the Site, the “Service”), and how we collect, use, and share that information. This Privacy Policy does not govern our collection of personal information through any other means other than through the Service.

Our processing of personal data, such as your name, address, e-mail address, or telephone number, has been designed to be consistent with the requirements of applicable privacy laws, including, but not limited to, the General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”). The purpose of this Privacy Policy is to provide to the users and potential users of our Service information about the nature, scope, and purpose of the personal data we collect, use and process and to advise data subjects of their rights. Whether we serve as the data controller or processor, Kuula has implemented numerous technical and organizational measures to ensure the protection of personal data processed through the Service. However, Internet-based data transmissions may have security gaps, so please understand that absolute protection is not assured.

By using the Service, you explicitly accept, without limitation or qualification, our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access, browse, or use the Site or Service, or download, install, or use the Application.

II. PERSONAL INFORMATION WE COLLECT

A. Information You Give Us
You may be asked to provide personal information to submit or request information from us, or to use the Service, including to create an account / profile on the Application. This information may include information such as your name, e-mail address, postal address, mobile phone number, date of birth, a photo and a user name, as well as additional profile and demographic information. Once you provide us with personal information about you, you are no longer anonymous to us.

Except for physical location information and tracking technologies (as described below), you do not have to give us any personal information to browse this Site. However, you may be asked to provide personal information to submit or request information from us, or to use the Service offered through this Site and the Application. Once you provide us with your personal information, you are no longer anonymous to us. This information may include:

B. Location Information.
In order to access and use the Service, you consent to our collection and use of your physical location information if you use the Service on a location-enabled device (including GPS, cellular, and Wi-Fi networks) or from your browser.

C. Automated Information Collection

We (and our affiliates and business partners) may collect certain information about your use of the Service through the use of tracking/recording technologies or by other passive means. This “passively collected” information may include, but is not limited to, the domain name of the website that allowed you to navigate to the Service, search engines used, the internet protocol (IP) address used, the length of time spent using the Service, the pages you looked at while using the Service, other websites you visited before and after using the Service, the type of internet browser you have, the frequency with which you use the Service, and other relevant statistics, including the following:

III. Use of Personal Information

Kuula complies with its obligations under GDPR by: keeping personal data up to date where needed based on the purposes for which the personal data is being processed; by not collecting or retaining excessive amounts of data; by ensuring that appropriate technical measures are in place that are designed to protect personal data from loss, alteration, misuse, unauthorized access and disclosure as it is transmitted, stored, or otherwise processed, and by using appropriate measures to securely destroy personal data when it is no longer needed by Kuula.

Personal information collected through the Service may be used or disclosed by us and our affiliates for purposes of:

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

IV. Personal Information We Share

We do not sell, rent, trade, or otherwise share personal information collected through the Service, except we may share information as described below:

V. Aggregate Information

We may compile de-identified personal information and other information collected through the Service on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Service, demographic information about users of the Service, and individual purchase preferences. Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Policy, and for any other lawful purpose.

VI. Your Choices

If at any time you decide that you no longer wish to receive notices from us regarding the Service, you may indicate this preference by contacting us at support@kuula.tv.

You can configure your browser not to accept certain automated data collection technologies such cookies, which are small files placed on the hard drive of your computer, or to notify you when a cookie is being sent. However, selection of certain settings, such as disabling of tracking when using the Service, may result in your being unable to access certain functions of our Service.

Unless subject to an exemption under the GDPR, if your personal data is subject to the GDPR, you have the following rights with respect to your personal data:

The Company may transfer personal data to and on behalf of clients and third parties with whom the Company has an existing service agreement or as part of our legal obligations, each of which shall be subject to the Company policies, and only to the extent necessary for purposes of legitimate interests pursued by the data controller (or by a third party).

F. Further processing
If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

VII. Information Storage and Security

We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Service. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Service. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

VIII. A Special Note about Children

Children are not eligible to use the Service, and we ask that minors (children under the age of 16) not submit any personal information to us. If you are a minor, you can use the Site only in conjunction with your parents or guardians.

IX. Privacy Notice for California Residents

If you are a California resident, you have the right under California’s “Shine the Light” law (Section 1798.83 of the California Civil Code) to receive once a year, free of charge: (1) information identifying each third party company to whom we may have disclosed, within the past year, personal information pertaining to you for that company’s direct marketing purposes; and (2) a description of the categories of personal information disclosed to that third party company in the immediately preceding calendar year. If you are a California resident and would like to make this request, please email support@kuula.tv.

Additionally, the California Consumer Privacy Act of 2018 (CCPA) provides California residents with specific rights regarding their personal information. The remainder of this section describes your rights under the CCPA and how to exercise those rights:

Access to Specific Information, Data Portability, and Deletion Request Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you: (a) the categories of personal information we collected about you; (b) the categories of sources for the personal information we collected about you; © our business or commercial purpose for collecting or selling that personal information; (d) the categories of third parties with whom we share that personal information; (e) the specific pieces of personal information we collected about you (also called a data portability request); and (f) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing (1) sales, identifying the personal information categories that each category of recipient purchased; and (2) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request through one of the Company’s contact methods listed in Section XII below. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may make a verifiable consumer request for access or data portability twice within a 12-month period. The request must: (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. If we find that your verifiable consumer request unless is excessive, repetitive, or manifestly unfounded, we may charge a fee to respond to it, and will provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at support@kuula.tv. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at support@kuula.tv. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; © provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

X. External Links

The Service may contain links to various websites that we do not control. When you click on one of these links, you will no longer be transacting business through the Service. Third party websites maintain their own privacy policies, and we do not exercise any control over any of the third party websites that may be linked to the Service. If you visit a website that is linked to the Service, you should consult that website’s privacy policy before providing any personal information. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.

XI. Special Admonitions for International Use

All matters relating to the Service are governed exclusively by the laws of the State of North Carolina in the United States of America and not the jurisdiction in which you are located. If you are located outside of the United States of America and you contact us, please be advised that any information you provide to us will be transferred to the United States of America and that by submitting information, you explicitly authorize such transfer.

XII. Updates to this Privacy Statement

We may change or update the Service or any of our policies and procedures without prior notice. We will post a notice on this Service to advise you of any significant changes to this Privacy Policy and indicate via the “Last Updated” legend at the top of this Privacy Policy when it was most recently updated. Your continued use of the Service signifies your continued assent to the terms of this Privacy Policy, as updated or amended at that time.

XIII. Questions and Consumer Requests Regarding this Policy

If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:

Website: www.kuula.tv

Email: support@kuula.tv

Postal Address:
Kuula, Inc.
Unit 42988, PO Box 6945, London, W1A 6US


In certain circumstances, Kuula, Inc. is the data controller for the purposes of GDPR or other data protection laws applicable in Member states of the European Union and other provisions related to data protection.

Any data subject may, at any time, contact us directly with any questions and suggestions concerning data protection. We encourage interested persons to raise any concerns about the collection, use, or processing of personal data using the contact information provided. In the event of a privacy related issue or complaint, we will investigate and attempt to promptly resolve any complaints and disputes regarding use and disclosure of personal data.

Should you have cause to complain about how we handle your personal data, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the Information Commissioner’s Office (ICO). For further details on how to complain to the ICO, please follow the links below: https://ico.org.uk/concerns/ or https://ico.org.uk/global/contact-us.

For complaints that cannot be resolved, if your personal data is subject to the GDPR, we commit to cooperating with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, and comply with the advice given by the panel or Commissioner about personal data transferred from the EU or Switzerland. In order to facilitate the handling of complaints, individuals in the EU can choose to contact their national DPA or use the form located at this link:

http://ec.europa.eu/newsroom/document.cfm?doc_id=42962

Individuals in Switzerland can contact the Swiss Information Commissioner by visiting:

https://www.edoeb.admin.ch/edoeb/de/home.html

This independent dispute resolution process is provided at no cost to the individual.