Privacy Policy

Effective Date:  August 23, 2018

Kasamba values your privacy.  This privacy policy explains what personal data we collect from you and how we use it.  This privacy policy applies if you visit or use Kasamba’s websites or mobile applications (collectively, the “Advisor Platform”).  This privacy policy also applies if you visit Kasamba’s social media or other web pages located on third-party websites.

What does Kasamba do?

What information do we collect from you?

How does Kasamba collect information from you?

How does Kasamba use the information it collects about me?

Does Kasamba use cookies?

Sharing of information collected

Access and changes to personal data

Third-party integrations

How can I review, correct, delete, transfer, or receive a copy of my information or withdraw my consent to process my personal data?

How does Kasamba keep my information secure?

Additional mobile considerations

Kasamba message boards

International data transfers

Children

Miscellaneous

What does Kasamba do?

Kasamba provides an advisor platform that allows members to locate an advisor to ask questions or request advice and/or services directly from such advisor (the “Advisor Platform”).  Kasamba, via the Advisor Platform, enables a member to communicate directly with the advisor and pay for the services purchased by the member from such advisor.

What information do we collect from you?

By visiting and/or communicating on the Advisor Platform, we may collect certain information from you, including but not limited to:

How does Kasamba collect information from you?

We collect information when you sign up to use the Advisor Platform and also when you communicate with other members of the Advisor Platform, including through:

Please note that if we receive your information from third parties as mentioned above, the data you provide to such third parties is also subject to the third party’s privacy policy.

In addition, we may collect information through the following methods if you use the Advisor Platform or visit Ksaamba’s social media pages or other pages located on third-party websites:

We may also collect information from our direct interactions with you, publicly available data or data provided by third-party sources, such as marketing opt-in lists.

How does Kasamba use the information it collects about me?

We use the information we collect to provide and improve our services, to deliver information requested by you (for example in response to technical support requests), to deliver marketing or other materials to you (including through phone calls if you provide your telephone number), or for promotions you may enter into. We process your information if you have given your consent; if it’s necessary to perform a contract with you or to take steps at your request prior to entering into a contract; if it’s necessary to comply with legal obligations; or if it’s necessary for us or a third party to pursue a legitimate interest. Kasamba may retain your information for a period of time consistent with the original purpose of collection. For example, Kasamba may retain your information during the time in which you have an account to use the Services. We may also retain your information during the period of time needed for Kasamba to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.

Does Kasamba use cookies?

We may use cookies and other identification technologies for record keeping purposes and to enhance your experience on the Advisor Platform. 

Cookies:

Cookies are small text files stored on a visitor’s web browser and applications. Cookies are often used to make web-browsing easier by performing functions such as saving passwords and maintaining lists of personal preferences regarding the use of the website.

The Advisor Platform may use the following types of cookies:

Other identification technologies that may be used by the Advisor Platform:

Third-party technologies:

Kasamba may use third-party service providers or work with affiliate or referral partners who are authorized to place cookies, pixel tags or similar technologies on the Advisor Platform with our permission.  These technologies help us compile metrics and analytics (without collecting personally identifiable information) to help improve the Advisor Platform.  Third-party cookies and technologies are covered by the third party’s privacy policy. 

 

Your choice:

Web browsers are usually set to accept cookies. However, if you prefer not to receive cookies, you typically have the option of setting your browser to refuse cookies. If your browser is set to refuse cookies, it is likely that some of the functionality offered by Kasamba will not be available or will not work as effectively for you. 

For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit www.allaboutcookies.org and www.youronlinechoices.eu.

Do Not Track

Various browsers, including Internet Explorer, Firefox and Safari, currently offer a “do not track” or “DNT” option that relies on a technology that sends a signal to websites a user visits about that user’s browser DNT preferences. While Kasamba attempts to honor the DNT instructions received from a user’s browser, Kasamba cannot guarantee that it will always respond to such signals because a common industry standard for DNT has not been adopted. Kasamba will continue to monitor developments around DNT browser technology.

Sharing of information collected

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. Kasamba does not disclose the contents of transcripts, surveys or recordings other than to service providers performing services on behalf of Kasamba, other than as provided in this privacy policy or with your permission.

For legal reasons

We may share your information if we reasonably believe that it:  (i) is necessary to comply with a legal process (such as a court order, subpoena, or search warrant) or other legal requirement of any governmental authority; (ii) would potentially mitigate our liability in an actual or potential lawsuit; (iii) is necessary to enforce this privacy policy or our Terms of Use at www.liveperson.com/policies/terms-of-use or any other agreement in place between you and Kasamba; (iv) is necessary to investigate and prevent unauthorized transactions or other illegal activities; and/or (v) is otherwise necessary or appropriate to protect our rights or property or the rights or property of any person or entity.

Various browsers, including Internet Explorer, Firefox and Safari, currently offer a “do not track” or “DNT” option that relies on a technology that sends a signal to websites a user visits about that user’s browser DNT preferences. While Kasamba attempts to honor the DNT instructions received from a user’s browser, Kasamba cannot guarantee that it will always respond to such signals because a common industry standard for DNT has not been adopted. Kasamba will continue to monitor developments around DNT browser technology.

Sharing of information collected

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. Kasamba does not disclose the contents of transcripts, surveys or recordings other than to service providers performing services on behalf of Kasamba, other than as provided in this privacy policy or with your permission.

For legal reasons

We may share your information if we reasonably believe that it:  (i) is necessary to comply with a legal process (such as a court order, subpoena, or search warrant) or other legal requirement of any governmental authority; (ii) would potentially mitigate our liability in an actual or potential lawsuit; (iii) is necessary to enforce this privacy policy or our Terms of Use at www.liveperson.com/policies/terms-of-use or any other agreement in place between you and Kasamba; (iv) is necessary to investigate and prevent unauthorized transactions or other illegal activities; and/or (v) is otherwise necessary or appropriate to protect our rights or property or the rights or property of any person or entity.

To deliver and improve the Advisor Platform

We may aggregate information so that it is not personally identifiable and use and share such aggregated information for training and quality assurance purposes and to deliver and improve the Advisor Platform.

Service providers

We may share your information when reasonably necessary with third-party service providers used to deliver and make the Advisor Platform and certain features and functionality available, including but not limited to payment processors, customer contact centers, and a third party to review Advisor profiles.

Business partners

If you accessed the Advisor Platform an affiliate or referral partner, we may share your information with such partner to optimize your experience and improve our services.

Affiliates

We may share your information with subsidiaries, parent companies, or other affiliates of the Kasamba corporate group in order to deliver and improve the Advisor Platform.

Other third parties

The Cookies section above addresses the information Kasamba or third parties collect through cookies, pixel tags, SDKs, and similar third-party technologies and how you can control cookies through your web browsers. Kasamba may also disclose your personal information to any third party with your prior consent.

Third-party integrations

From time to time, we may partner with other companies to allow Kasamba and its customers to offer integrations with the Advisor Platform.  If you use one of these integrations, Kasamba may share your data with the third-party partner, receive data about you from the third-party partner, and/or combine third-party partner data about you with information about you that we collect.  We do not control how a third-party partner may use your data.   Use of your information by the third-party partner there is governed by its privacy policies.  If you do not wish for your information to be shared in this way, you may opt not to use such integrations.

How can I review, correct, delete, transfer, or receive a copy of my information or withdraw my consent to process my information?

If you elect to engage in any communication session on the Advisor Platform, it is up to you to decide what, if any, information to provide during such session.  Depending on your request, it may not be possible for us or Advisors to fully provide all requested services to you.  Nevertheless, if you do not wish to provide certain information, then you should not do so. 

If you have signed up to receive Kasamba’s marketing or advertising communications, you may, at any time, opt out of receiving further communications by clicking on the opt-out link at the bottom of a marketing or advertising email you receive.  You may also contact us at privacy@kasamba.com to opt out or to request changes to your personal information.

You may view your communication history on the Advisor Platform by logging in and accessing your account page.

You may request to review, correct, delete, transfer, or receive a copy of any of the personal information you’ve provided to us through the Advisor Platform or withdraw your consent to Kasamba processing your personal data by contacting us at privacy@kasamba.com, and we will respond within 30 days. You may generally update your account settings, user profile, and billing information by logging in to your account.

If you believe that we have not been able to assist you with your inquiry, and you are located in the European Economic Area, you have the right to file a complaint with the relevant supervisory authority.

How does Kasamba keep my information secure?

We use security measures designed to protect against the loss, misuse and alteration of the information under our control, although data transmissions over the internet cannot be guaranteed to be absolutely secure.  Your personally identifiable information is encrypted during transmission.  In addition, transcripts that we store are maintained and archived on secure, hardened servers that are hosted on highly secure data centers.  Access to this data is protected by multiple layers of controls, including firewalls, role-based access controls, authentication mechanisms and monitoring.  Data is backed up, and archives are stored off-site in a secure location. You may review your chat history and see transcripts of chats you have engaged in.  You are only granted access to the chats you engaged in under your profile. 

Additional mobile considerations

In addition to the other terms in this policy, if you use our mobile applications or access our mobile-optimized websites, we may receive information about your mobile device, including a unique identifier for your device. 

If you receive SMS messages from Kasamba, you may opt out by following the opt-out instructions that we provide or by contacting us at privacy@kasamba.com

Kasamba message boards

Information that you share on Kasamba’s message boards become publicly available and therefore may be read, collected, copied and used by other users for any purposes at their discretion.  Because this information is publicly available, Kasamba’s privacy obligations outlined in this privacy policy do not apply to your use of any such message boards.

International data transfers

If you are located outside of the United States, please note that we may transfer your personal data outside your country of origin.  By providing or making available your personal data, you consent to that transfer. We will take steps to ensure that your data is subject to appropriate safeguards required under this privacy policy, applicable data protection laws, and appropriate legally recognized data transfer adequacy mechanisms which may include entering into European Commission-approved standard contractual clauses related to transfers of personal information (available at http://ec.europa.eu/justice/dataprotection/internationaltransfers/transfer/index_en.html) or a valid Privacy Shield certification in the case of a transfer to a Privacy Shield-certified US recipient (certifications may be viewed at https://www.privacyshield.gov/welcome). Any inquiries or complaints regarding our data privacy practices may be directed to privacy@kasamba.com or to our external Data Protection Officer Prof. Dr. Christoph Bauer at Große Bleichen 21, 20354 Hamburg, Germany. We will respond within a reasonable period of time. You also have the right to file a complaint with the appropriate supervisory authority in your jurisdiction.

Children

The Advisor Platform is not directed to individuals under 18. If you are under the age of 18, you may not use or register for the Advisor Platform or provide any personal information to us. Kasamba does not knowingly collect personal information from individuals under the age of 18. If you are a parent of an individual under 18 and believe your child has provided personal information to Kasamba, or if you are a California resident under the age of 18 and wish to remove content you have made publicly available, please contact us at privacy@kasamba.com, where you may request to exercise your applicable access, rectification, cancellation, and/or objection rights. Kasamba reserves the right to immediately terminate any member account and delete his or her information if it believes the member is under the age of 18. 

Miscellaneous

We recommend that you review this privacy policy periodically, as we may update it from time to time.  Your use of the Advisor Platform, as applicable, constitutes your consent to the new privacy policy to the fullest extent permitted by law. 

We are not responsible for and do not control the privacy practices of any of our customers or any other third party.  We encourage you to review the privacy practices of each third party. 

We welcome your feedback on our privacy policy.  Please send any comments or questions to privacy@kasamba.com or to Kasamba, Inc., Attn: Legal Department – Privacy, 475 Tenth Ave., 5th Floor, New York, NY 10018. You can also contact our external Data Protection Officer Prof. Dr. Christoph Bauer at ePrivacy GmbH at Große Bleichen 21, 20354 Hamburg, Germany.