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Privacy Policy

Revised: 29 January, 2021

1. Introduction​

This privacy policy (this “Policy”) aims to give you information on how Kanalo Inc. (“Kanalo”, “we”, “us”, or “our”) collects and processes your personal data through your use of this website, the service described and made available on it, and interactions with our staff (referred to collectively in this Policy as the “Services”). It also outlines the privacy rights and protections that relate to our handling of your personal data.

This policy only applies to the personal data described in section two, for which Kanalo is the data controller under the General Data Protection Regulation law (GDPR) of the European Union (EU). This policy does not apply to any content, data or information processed, stored, or hosted by our customers using the Services in connection with an Kanalo account; in such case Kanalo is a data processor for its customers.

By using any of the Services, you consent to:

  • the collection and use of your personal data (as described in section two), as set forth in this Policy;
  • the use of essential cookies (as described in section two);
  • emails sent to you for account management purposes; and
  • emails sent to notify you of promotions and other activity.

The Services are not intended for persons under the age of 16. By consenting, you confirm that you meet this requirement, and, if you are under the age of 18, you have received permission from your parent or guardian before using the Services or sending us personal information.

Changes to the policy​

This policy is kept under regular review and may be modified from time to time. If we make any changes to this Policy, we will post the amended policy and change the "Revised" date on this page.

Contact and questions​

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact our Data Protection Officer at privacy@kanalo.dev.

The Services may include links to or may interact with third party websites or applications. We do not control these third party sites or applications, and are not responsible for their privacy policies or content.

2. Data We Collect About You​

Personal data is any information about an individual from which that person can be identified, or data that could reasonably be linked to them. We may collect, use, store and transfer different kinds of personal data about you which are grouped together as follows:

  • Identifiers and Professional Information includes your real name, log-in credentials, Internet Protocol (IP) address, job title or position, identity of your employer or organization.
  • Contact Data includes billing and postal addresses, email addresses and telephone numbers.
  • Commercial and Activity Data includes details about products and services you have purchased from us, and interactions with our website.
  • Marketing and Communications Data includes your preferences in receiving marketing materials from us and related third parties, and your communication preferences.

We also collect, use, and share non-personal and aggregated data such as statistical data, data sent automatically by your device, or data derived from your personal data that will not directly or indirectly reveal your identity. This policy does not restrict or limit our collection and use of non-personal or aggregated data.

We do not collect any Special Categories (as defined by the GDPR) of personal data about you, nor do we collect any information about criminal convictions and offences.

3. How Your Personal Data Is Collected​

The sources we use to collect data from and about you include:

  • Direct interactions, by using the Services or any other website or application we provide, by requesting information, or by contacting us.
  • Third parties we work with, including business partners, analytics providers, search information providers, and providers of technical, payment and delivery services

We do not support the “Do Not Track” header, but we are not aware of any processes collecting personal information about your activities on our websites over time and across third party websites and services, nor do we knowingly collect such information.

If you fail to provide personal data​

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, or provide incorrect data, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at that time.

We use Google Analytics to analyze visits to our website. This process uses cookies, small files stored on your computer that may identify your browser and collect certain information about you. You may decline the use of cookies through your browser settings or another application, though this may affect your ability to use the Services. For further details about how Google Analytics uses your information, see this page.

4. How Your Personal Data Is Used​

The most common circumstances in which we will use your personal data are the following:

  • Where we need to perform a contract we have entered into with you, or are about to enter into, or to otherwise fulfill the reason you provided the information. This includes:
    • administering your account with us;
    • using your information to deliver or contact you regarding your contract or purchases; and
    • contacting you about any changes to our service or contract.
  • Where it is necessary for our legitimate interests or those of a third party (as defined in the GDPR) and your interests and fundamental rights do not override those interests, or you have consented to the particular use of your data. This includes:
    • maintaining the security and integrity of the Services and our other assets, including protecting against malicious, fraudulent, or illegal activity;
    • delivering relevant content to you;
    • making suggestions and recommendations to you about goods, services, or offers that may be of interest to you;
    • testing, researching, analyzing, troubleshooting, and otherwise developing our products and services;
    • establishing, exercising and/or defending our legal rights including in any legal proceedings; and
    • evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets in which personal information is among the assets transferred.
  • Where we need to comply with a legal or regulatory obligation. This includes:
    • responding to law enforcement requests or court orders;
    • undertaking conflict of interest checks; and
    • adhering to data protection rules or other regulatory requirements.

Sale of personal data​

We do not sell any of your personal data, nor do we share personal data with third parties for marketing purposes.

Opting out​

You can ask us to stop sending you marketing messages at any time by contacting us.

5. Disclosures of Your Personal Data​

We may share your personal data with third parties for the purposes set out in section four. The parties we may disclose your personal data to include:

  • Third Party Services (see below).
  • Third parties in connection with the sale, transfer or merger of our shares, business, or assets, or acquisition of other businesses. If there is a change in our ownership, the new owners may use your personal data in the same way as set out in this Policy.
  • Our affiliated entities and our service providers, consultants or other contractors. This use of personal data will be subject to security or confidentiality obligations consistent with this policy and applicable law.

We may also disclose personal data in order to comply with any legal obligation, to enforce our terms and agreements, or to protect the rights, safety and property of Kanalo, our employees, our customers, or others.

We require all third parties to whom we disclose your personal data to keep it confidential. We only allow third party service providers to use your personal data for the purposes specified in our contract with them.

Third Party Services​

Third Party Services are either: (a) service providers acting as processors, who provide IT and system administration services and secure cloud-based information services; (b) professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers, who provide consultancy, banking, legal, insurance and accounting services; or (c) payment processing providers who provide secure payment processing services.

6. Data Security​

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, or disclosed in an unauthorised way. In addition, we limit access to your personal data to those who have a business need to know. They will only process your personal data on our instructions and they have a duty to keep such information confidential. However, the transmission of data via the internet is not completely secure, and any transmission is at your own risk.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data Retention​

We retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8. Your Rights​

Depending on your circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to:

  • Access your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Correct incomplete or inaccurate personal data. We may need to verify the accuracy of the new data you provide to us.
  • Delete your personal data. This enables you to ask us to delete or erase personal data where there is no legitimate reason for us to continue to possess or process it. If we are not able to comply with your request for deletion, we will notify you of the reason at the time of your request.
  • Object to further processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
  • Withdraw consent at any time for processing your personal data where we are relying on consent as the basis for processing. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Requests made through your account are considered to be sufficiently verified for requests relating to the personal data associated with that account.

We do not charge a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. If this is the case, we will inform you as to why we made that decision and provide a cost estimate before processing your request. Alternatively, we could refuse to comply with your request in these circumstances.

We will endeavour to respond to all legitimate requests within 45 days of receipt. If we require more time, we will notify you of the reason and timeline in writing by mail or electronically.