Kolu Privacy Policy: Your Privacy Rights

The Effective Date of this Privacy Policy is July 25, 2017

PLEASE READ THE PRIVACY POLICY AND TERMS OF SERVICE CAREFULLY BEFORE USING THE KOLU PLATFORM.  BY USING THE KOLU PLATFORM, YOU SIGNIFY YOUR ASSENT TO BOTH THE TERMS OF SERVICE AND THE PRIVACY POLICY. 

The Global Hiker, LLC, doing business as Kolu (“Kolu” or “we” or “our” or “us”), a Delaware limited liability company, operates an online platform linking travelers with local guides who offer personalized tours, whether through our website (www.koluapp.com) (the "Site")  or mobile applications (as more comprehensively defined in our Terms of Service and referred to herein as the “Kolu Platform”). The Kolu Platform and any non-third party content therein is owned and operated by Kolu.

Please read the following sections carefully, as they contain the privacy policies covering the use of your information obtained through your use of the Kolu Platform (the “Privacy Policy”). Additionally, you should review our Terms of Service.  Inquiries or concerns regarding these Terms of Service or the Privacy Policy may be sent to aj@koluapp.com.  If you see an undefined term in the Privacy Policy, it has the same definition as in our Terms of Service.

At Kolu we share your concerns about privacy. We have created this Privacy Policy in order to demonstrate our firm commitment to privacy. The following discloses our information gathering and dissemination practices for the Kolu Platform.


NOTICE TO CALIFORNIA RESIDENTS

Except as expressly identified below, we do not disclose a User’s personal information to any third party. Thus, under California Civil Code Sections 1798.80-1798.84, Kolu has no obligation to a California resident to provide further information regarding Kolu’s use of the California resident’s personal data. Any inquiries regarding the Terms of Service or this Privacy Policy can be directed to the contact identified above.


NOTICE TO UTAH RESIDENTS

Except as expressly identified below, we do not disclose a User’s personal data to any third party.


INFORMATION COLLECTION

We may collect personal data from our Users when providing certain services. We recognize two kinds of personal data that deserve different levels of protection:

  • Personally identifiable information includes, for example, your name, address, e-mail address, phone number, and date of birth.
  • Payment/Financial Information includes bank account and/or credit card information combined with your name or account number. Our third-party payment processor will store you Payment/Financial Information and their use of your information is governed by their privacy policy, viewable at [https://stripe.com/us/privacy].

Kolu collects personally identifiable information only when there is a legitimate need to do so.  If your relationship with us includes providing us with sensitive data, we will endeavor to protect that information using commercially reasonable measures. Except as provided herein, we will not distribute sensitive data outside of Kolu and our affiliates.


INFORMATION USE

How Your Non-Personally Identifiable Information May Be Used: 

  • To customize the advertising and content you see within the Kolu Platform;
  • To improve the performance or layout of the Kolu Platform;
  • To develop new services and ideas; and
  • To better administer and troubleshoot our systems.

 

How your Personally Identifiable Information May be Used:

  • To provide you Kolu’s services via the Kolu Platform;
  • To evaluate and improve the services offered to Users and the User’s experience;
  • To provide access to certain password protected areas of the Kolu Platform;
  • To fulfill your requests for information;
  • To verify age of Users; and
  • To contact you about Kolu’s services and those of our affiliates, based on the preferences you have indicated.

 

Kolu will give you the opportunity to limit or "opt out" of receiving any unsolicited information from us containing information regarding Kolu’s services, information you specifically request, or information we determine you may find useful as a result of your use of the Kolu Platform.


NFORMATION SHARING AND DISCLOSURE

Kolu will only share personally identifiable information about you to other companies or people when:

  • We need to share such information to provide the service you have requested;
  • We need to send such information to companies who work on behalf of Kolu to provide a service to you (unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us);
  • We find that your actions on our Kolu Platform violate the Terms of Service, any of our usage guidelines for specific services, or any agreement; and
  • We are required to respond to or initiate subpoenas, court orders, or legal process.

IP ADDRESS

We may log all connections to our web servers. Those log files will include your Internet Protocol (“IP”) address. An IP address is NOT personally identifiable information, but rather is general information about your location, connection to the Internet, and your Internet Service Provider (“ISP”). We use your IP address to help diagnose problems with our server and to administer the Kolu Platform. Additionally, we will use your IP address to track your navigation of the Kolu Platform and we may use your navigation history in current and future marketing efforts to you and to others.


COOKIES

Cookies” are small pieces of information stored in a User's browser that give that User a unique identification. The Kolu Platform may insert Cookies into your browser or device that identify you as a previous User of the Kolu Platform and contain non-personally identifying information regarding you and your navigation of the Kolu Platform. In some instances, these Cookies may be used by Kolu or other websites during your future navigation of the Internet to target specific advertisements to you based on your previous use of the Kolu Platform. The Kolu Platform may also read Cookies already stored within your browser to identify non-personal information about you and communicate this information to other advertisers. All Cookies are established on a per session basis, and are not permanently stored on your machine. For more information about Cookies, please visit www.AboutCookies.org.


CLEAR GIFS

We may also employ a software technology called “Clear Gifs” (also known as web beacons) that help us better manage content on our Site by informing us what content is effective. Clear Gifs are tiny graphics with a unique identifier, similar in function to Cookies, and are used to track the online movements of Web Users. Clear Gifs and Cookies are not tied to a User's personally identifiable information.


CONTACT OR REGISTRATION FORM

In the event you register for a Kolu Account on the Kolu Platform, request additional information via the Kolu Platform, or voluntarily supply information to Kolu using the Kolu Platform, you agree to the following terms regarding your contact and personal information in addition to the general terms of this Privacy Policy. The Kolu Platform's contact and/or registration forms request that Users provide contact and other personal information (such as one or more of their name, mailing address, telephone number, e-mail address, date of birth, and age). We use this contact and personal information to send you additional information about our services. A User's contact and personal information may also be used by us to contact the User directly. We reserve the right to use your contact and personal information with Kolu’s service providers, business partners, or for billing or payment processing. We will also disclose your contact and personal information when required by law or in response to a request from a law enforcement agency or authority.  Other than the above uses, Kolu will not share your contact or personal information with any third party.


COMMITMENT TO CHILDREN’S PRIVACY

In compliance with the Children's Online Privacy Protection Act, 15 U.S.C., §§ 6501-06 and 16 C.F.R., §§ 312.1-312.12, the Kolu Platform does not permit children under 13 years of age to become Users, and we do not collect information from children. By using the Kolu Platform, you represent that you are 13 years of age or older. If you are between 13 and 18 years of age (“Minors”), you can only use the Kolu Platform or any services facilitated by use of the Kolu Platform with the consent of a parent or lawful guardian. Only Minors accompanied by parents or lawful guardians may use the Kolu Platform to arrange guided tours or participate in any other services enabled by the Kolu Platform. Such accompanying parent or guardian bears full responsibility for the safety, conduct, liabilities, or other activities of the Minor. No personally identifying information regarding Minors shall be shared, except in ways that are necessary to deliver the services being arranged, and then only with express permission of the parent or lawful guardian.


SECURITY

The Kolu Platform includes security measures in place to protect against the loss, misuse and alteration of the information under our control; however, Kolu does not guarantee the performance or adequacy of such security measures.


LINKS TO OTHER WEB SITES

The Kolu Platform may contain links to other websites that are not owned or operated by Kolu. Kolu is not responsible for the privacy policies or practices of third parties or the content or security of such third-party websites. User hereby assumes all risk associated with the employing of any third party and obtaining their goods or services.


CHANGES TO THIS PRIVACY POLICY

This Privacy Policy describes the types of information we currently collect through your use of the Kolu Platform, and the ways we use and protect that information. From time to time, we may collect different types of information and use that information in different ways - for example, when we add features or services to the Kolu Platform. In these cases, we may edit this Privacy Policy to explain the new practices. Because protecting your privacy is very important to us, we do not expect major changes. However, if we do any material changes in our practices, we may include announcements on the Kolu Platform so that you will know to review the revised Privacy Policy. In any event, by accessing and navigating the Kolu Platform, you are agreeing to be bound by the then-current Privacy Policy. This Privacy Policy is also subject to the Terms of Service located on the Kolu Platform, and the Terms of Service take precedence over any conflicting provision in this Privacy Policy.