Advisor Privacy Policy

Welcome to Kasamba's Advisor Privacy Policy. This Privacy Policy applies to you if you are a Member, Advisor or other visitor to Kasamba's advisor services platform ("Kasamba's Advisor Services Platform") made available at www.kasamba.com ("Kasamba's Advisor Services Site") and at other third party websites. Members, Advisors and all other visitors to Kasamba's Advisor Services Site and/or Kasamba's Expert Advisors Platform are referred to in this policy as "you" or an "Advisor Services Visitor". This Privacy Policy applies regardless of whether you are using a computer, a mobile device or other device to visit Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform.

You are considered to be a "Member" if you register to be a member on Kasamba's Advisor Services Platform and your member application is accepted. You are considered to be an "Advisor" if you complete the advisor application on Kasamba's Advisor Services Platform and your profile has been activated by Kasamba. Please note that this Privacy Policy applies to all Advisor Services Visitors regardless of whether or not such visitor is a Member or an Advisor.

This Privacy Policy does not apply to visitors to LivePerson's corporate website at www.liveperson.com. For privacy terms applicable to those visitors, please click here. This Privacy Policy also does not apply to visitors to the websites of LivePerson's business customers. For privacy terms applicable to those visitors, please click here.

This Privacy Policy explains how Kasamba and certain third parties may collect, use, and disclose "Personal Information" and other information we obtain via Kasamba's Advisor Services Site and via Kasamba's Advisor Services Platform (together, “Data”).

Personal Information Defined. Kasamba considers "Personal Information" to include information that alone or when in combination with other information may be used to readily identify or contact you, such as: name, address, email address, or phone number. Kasamba does not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.

Use and Acceptance. By using Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform, you agree to this Privacy Policy. If you do not accept this Privacy Policy, you must not use Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform.

New Uses of Personal Information and Other Information. From time to time, Kasamba may use Data for new, unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change regarding information previously collected, Kasamba will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

What information is collected from Advisor Services Visitors and how is it collected?

  • Communications with Advisors and Members. If you engage in a communication with an Advisor or a Member using Kasamba's chat, email, voice or other communication products or services made available to you by Kasamba via Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform, you may voluntarily provide, or otherwise be asked to provide, Personal Information such as your name, contact information and other information to facilitate service. By providing Personal Information and other information via Kasamba's communication products or services, you consent to Kasamba collecting and processing such information for the purposes outlined in this Privacy Policy.

    Kasamba maintains transcripts ("Transcripts") of chats, emails and other written communications conducted between you and any Advisor or Member using Kasamba's products and services. Kasamba may, in accordance with applicable law (including laws related to notice and/or consent), record and maintain recordings of voice communications ("Recordings") between you and any Advisor or Member.

  • Communications with Kasamba. If you engage in a communication with Kasamba related to Kasamba's Advisor Services Platform or Kasamba's Advisor Services Site using Kasamba's chat, email, voice or other communication products or services made available to you by Kasamba, or if you engage in a pre- or post-interaction survey ("Survey") related to any such communication, you may voluntarily provide, or otherwise be asked to provide, Personal Information such as your name, contact information and other information to facilitate service. By providing Personal Information and other information via Kasamba's communication products or services, you consent to Kasamba collecting and processing such information for the purposes outlined in this Privacy Policy.

    Kasamba maintains Transcripts of communications that are conducted between you and Kasamba. Kasamba also maintains copies of Surveys and Kasamba may, in accordance with applicable law (including laws related to notice and/or consent), record and maintain Recordings of voice communications between you and Kasamba.

  • Browser Information and Usage Information. We log web browser information (e.g., Internet Protocol addresses and browser types) and other usage information from Kasamba's Advisor Services Site and Kasamba's Advisor Services Platform such as page view tallies, time spent on each page, geographic location information, page browsing information, subject matter browsing information and operating system information. If the Advisor Services Visitor is using a mobile or other portable device to visit or access Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform, we may collect hardware information related to the device used by the Advisor Services Visitor. Your browser may be set to limit or prevent any of the browser information described above from being transmitted. If so, Kasamba's Advisor Services Site, Kasamba's Advisor Services Platform or certain communication tools, or other features or functions offered as part of Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform, may not be available to you.

  • Member Account. In order for a visitor to use many of the features or offerings on Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform, the visitor may be required to open a member account and provide Personal Information. Many services require payment of a fee. Before using pay services, the Member would be required to provide payment information via the members account. Kasamba uses a third party credit card processor to process and store credit card information submitted via the Member’s account.

    Kasamba may allow Advisor Services Visitors to sign in to Kasamba's Advisor Services Platform and/or enroll as a Member by using the sign-in credentials used by such visitor on a third party social media website (e.g., Facebook). By signing in or enrolling using the third party website’s credentials, the Advisor Services Visitor consents to Kasamba collecting and maintaining the information provided via such third party website. Kasamba is not responsible for the privacy practices of any third party website.

  • Requests for Information, News and other Content. When you sign up to become a Member or an Advisor, you may sign up to receive information, news and other content related to new and existing products and services related to Kasamba's Advisor Services Site, Kasamba's Advisor Services Platform and events and other information related to Kasamba that may be of interest to you. You may also sign up to receive information, news and other content from third parties whose services and/or products we believe may be of interest to you. You will be asked to provide Personal Information, such as contact details and other information, relevant to delivering such news and information. We maintain all such information.

  • Technical Support Requests. If you need technical support related to Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform, you will need to complete a form for the purposes of defining and clarifying your technical support request. When submitting a technical support request, you will be asked to provide Personal Information, including an email address and a description of the issue. We maintain copies of all technical support requests and other information submitted with or related to such requests.

  • Promotions. From time to time, we may offer promotions on Kasamba's Advisor Services Site or via Kasamba's Advisor Services Platform. If we do, and if you wish to participate, you may be required to provide Personal Information, such as contact information and other information. We maintain such information.

  • Advisor Services Applicants. If a visitor wishes to apply to be an Advisor on Kasamba's Advisor Services Platform, the visitor will be required to submit Personal Information as requested. Any information supplied by or on behalf of a visitor for purposes of becoming an Advisor may be maintained by Kasamba as well as third party affiliates and other third parties. Please note that Kasamba may have additional privacy terms that apply to Advisor applicants. Such terms will be made available when an applicant applies to be an Advisor or when an applicant otherwise accesses his or her account.

  • Cookies. Kasamba's services use cookies and other similar technologies such as pixel tags to collect and store information that is generated automatically as you use the services, including your preferences and anonymous usage statistics.

    Similar cookies and other technologies are used by our partners, which may also include Flash cookies. Flash cookies are set through a mechanism in Adobe Flash Player. With Flash cookies your data is stored in multiple places and it may be restored once you delete it. To control flash cookies, modify the settings on the Macromedia website here. HTML5 has a local storage feature that, when used, allows for quicker access to a website upon a return visit. HTML5 is currently supported by some mobile devices and desktop browsers. HTML5 data is not stored in a browser's "cookies" file. Most browsers also give you the ability to control cookies, usually through the settings menu - your browser's help feature will explain how. Additionally, certain of our partners allow you to opt-out of their use of cookies by clicking here. The choices you make on these sites are browser-specific. So, if you use a different browser, you will need to opt out again. If a browser is set to refuse cookies, it is possible that some of the functionality offered by Kasamba will not be available or will not work as effectively for you.

How does Kasamba use and disclose information it collects from Kasamba Users?

  • Transcripts, Surveys and Recordings. Kasamba may access and use Transcripts, Surveys and Recordings for purposes of performing or delivering a service to an Advisor Services Visitor, providing maintenance or support services for an Advisor Services Visitor, for training and quality assurance purposes, for purposes of investigating any claim made by or related to an Advisor Services Visitor, for purposes of improving our services and/or for other lawful purposes. Third-party service providers retained by Kasamba to perform services on behalf of Kasamba may also have access to Transcripts, Surveys and Recordings for purposes of performing or delivering a service to Kasamba, providing maintenance or support services, for training and quality assurance purposes, for purposes of investigating any claim made by an Advisor Services Visitor or related to an Advisor Services Visitor’s use of the services, for purposes of improving our services and/or for other lawful purposes.

    Advisors with whom a Member or other Advisors Services Visitor communicates have access to the Transcripts and Recordings between them. Kasamba has no control over the privacy practices of such Advisors. You are encouraged to verify the privacy practices of Advisors before you communicate with them.

  • Browser Information and Cookies. We use browser information, cookies and pixel tags to determine whether a communication service or marketing material should be deployed on your browser when you are visiting Kasamba's Advisor Services Site or using Kasamba's Advisor Services Platform. We may also use browser information, cookies and pixel tags: to determine how you arrived at Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform, to determine whether you are a return visitor, to help us improve our product and service offerings, for quality assurance and training purposes, to help diagnose problems with our servers, to gather broad demographic information, to administer and optimize our services, to deliver marketing or other materials to you on behalf of third parties and for other lawful purposes. Information collected by third party operators themselves is governed by their own privacy policies.

  • Aggregate Information. We may aggregate information so that it is not Personal Information, and we may use and share such aggregated information for training and quality assurance purposes, for purposes of delivering our services, for purposes of expanding and improving our services and for other lawful purposes.

  • Third Parties. Kasamba does not sell, trade or rent Personal Information provided by you in any Transcript, Survey or Recording for direct marketing or any other purpose, except as provided in this Privacy Policy or with your permission. Except as described in this Privacy Policy, Kasamba does not divulge the content of Transcripts, Surveys or Recordings to third parties or vendors performing services on behalf of Kasamba.

    If you accessed Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform via a third party website, you may be subject to terms and conditions that apply to that third party website. As mentioned below, Kasamba is not responsible for the privacy practices of any third party. Kasamba may share your Personal Information, including your email address, with the third-party website from which you accessed Kasamba's services for its business purposes, including to optimize your experience and to improve its services.

    Kasamba uses third party data facilities and other third party service providers to perform services that are routinely handled by such providers. Such providers may store and, if applicable, process Personal Information and non-Personal Information in keeping with the service that they provide. We may also share weblog data and other similar non-Personal Information Data with third parties. For example, we may share traffic data for the Site with a third party that analyzes and publishes Website traffic surveys.


  • Legal Reason to Disclose. Kasamba may disclose your information including Personal Information if: (i) Kasamba reasonably believes that disclosure is necessary in order to comply with a legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirement of any governmental authority, (ii) disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) reasonably necessary to enforce this Privacy Policy, our Terms of Use or our agreement with an Advisor Services Visitor, (iv) disclosure is intended to help investigate or prevent unauthorized transactions or other illegal activities (including any claim that a Member did not authorize charges incurred via Kasamba's Advisor Services Platform or via Kasamba's Advisor Services Site), or (v) necessary or appropriate to protect our rights or property, or the rights or property of any person or entity.

Special Notice to Kasamba Users located in countries other than the United States

If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, including those whose privacy laws may be more restrictive than U.S. law, please note that you are transferring your personal data to the United States to Kasamba. By providing your personal data you consent to that transfer.

Message Boards, Communities, Blogs

If you use any message board, community (including any Advisor Services community or forum) or blog made available on Kasamba's Advisor Services Site or Kasamba's Advisor Services Platform you should be aware that any information you submit via those services may be read, collected, copied and used by other users, and could be used to send you unsolicited messages. Kasamba may access and use any such information for purposes of performing or delivering a service to an Advisor Services Visitor, for purposes of providing maintenance or support services, for training and quality assurance purposes, for purposes of investigating any claim, for purposes of improving our services and/or for other lawful purposes. For the avoidance of doubt, Kasamba is not responsible for the information that you choose to submit or post via any of those services and Kasamba is not responsible for how any such information may be used by others or responded to by others. Kasamba's privacy obligations set forth in this Privacy Policy are not applicable to your use of any message board, community or blog on Kasamba's Advisor Services Site, on Kasamba's Advisor Services Platform or on any third party website. Additional terms made available via any such message board, community and/or blog may apply to your use of any of the foregoing.

How does Kasamba protect your information?

  • Security. Data transmissions over the Internet cannot be guaranteed to be fully and absolutely secure. Our website and our services have security measures in place designed to protect against the loss, misuse and alteration of the information under our control. Our security measures include the measures described below.

  • Encryption and Firewalls. Chat transcripts are encrypted during transmission. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All Transcripts are maintained and archived on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. Advisers and Members may review their chat history and see Transcripts of chats that they have engaged in. Advisoers and Members are only granted access to the chats that they engaged in under their Advisor profile or Member profile. Data is backed up regularly and archives are stored off-site in a secure location.

Additional terms that may apply to your information

  • Safe Harbor. Kasamba complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries. The company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the company's certification, please visit http://www.export.gov/safeharbor/.

  • Kasamba's Advisor Services Platform made available on Third Party Websites. Kasamba's Advisor Services Platform may be made available on third party websites. In addition, links to Kasamba's Advisor Services Site and Kasamba's Advisor Services Platform may be made available on third party websites. Kasamba is not responsible for and does not control the privacy practices of any third party. Accordingly, we encourage you to review the privacy practices of each website that you use or visit.

  • Business Transfers. In the event that all or substantially all of Kasamba's assets have been acquired, or in the event of any merger, bankruptcy or reorganization involving Kasamba, all Transcripts, Recordings and Surveys, as well as all other information about you and your use of our services will likely be included in the acquired or merged assets.

  • Choice Regarding Personal Information. If you elect to engage in any communication using our services, it is up to you to decide what, if any, information to provide during such session. Depending on your request or the means of communication it may not be possible to communicate with you or address all of your questions without providing some information. Nevertheless, if you do not wish to furnish certain information, then you should not do so.

  • Your California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the address referenced below.

  • Children's Privacy. Kasamba does not encourage participation or visitation by children. Visitors who are known to be under the age of 16 are prohibited from becoming Members or Advisors. Kasamba does not knowingly collect personally identifiable information from children under the age of 16.

Contacting Kasamba

Kasamba welcomes your feedback on our Privacy Policy. Please send your comments to privacy@liveperson.com or to: LivePerson, Inc., Attn: Legal Department – Privacy, 475 10th Avenue, 5th Floor, New York, NY 10018.

Changes to this Privacy Policy

We recommend that you review this policy periodically, as we may update it from time to time. Your use of any Kasamba service offered on Kasamba's Advisor Services Site or via Kasamba's Advisor Services Platform following a change to this Privacy Policy represents your consent to the new Privacy Policy to the fullest extent permitted by law.

Definitions

Cookies are pieces of information that some websites transfer to a visitor’s web browser accessing the website and are used for record-keeping purposes at many websites. Use of cookies makes web-surfing easier by performing certain functions such as saving passwords, lists of potential purchases and personal preferences regarding the use of the particular website, and ensuring that the user does not see the same ad repeatedly.

Encryption is the process of transforming information into unreadable text so that it is only legible to those possessing an encryption key. The process of making encrypted information readable again is referred to as decryption.

Pixel tags are small graphic images that are embedded in a web page or email for purposes of tracking activity on web pages or whether a user has opened or accessed an email. A pixel tag may be set to identify on what browser and computer it was viewed, whether that browser has cookies received from a server associated with the pixel tag, and whether the web page or email with the pixel tag was forwarded or copied.

Web browser is a software program that allows a user to access, retrieve and view information on the World Wide Web. Examples of browsers include Internet Explorer, FireFox, Google Chrome and Safari.

Last updated: May 4, 2016.