Privacy Policy

Kumospace, Inc. (“Kumospace,” “we,” “our,” “us,”) values your privacy and is committed to protecting your Personal Information. This Privacy Policy explains our practices with respect to Personal Information that we collect from you or that you provide to us when you visit our website at https://www.kumospace.com (the “Kumospace Website”), register to use, and/or use the Kumospace virtual video chat platform (the “Kumospace Platform”).

As used in this Privacy Policy, “Personal Information” means information that identifies or that can be used to identify you, and “Services” means, collectively, the Kumospace Website and the Kumospace Platform.

This Privacy Policy does not apply to the treatment of information that a user who hosts virtual events through the Kumospace Platform (a “Kumospace Host”) collects when you use the Kumospace Platform to attend that Kumospace Host’s virtual event(s). We are not responsible for any decisions or actions taken by the Kumospace Host with respect to your information (or by any third party with whom the Kumospace Host may share your information). If applicable, please review the Kumospace Host’s privacy policy and terms of service or contact the Kumospace Host directly before submitting any Personal Information in connection with the relevant virtual event.

In addition, please note that we do not control the actions of those with whom you may interact or choose to share information during or in connection with your use of the Kumospace Platform, including other Kumospace users and any Kumospace Host. As such, your actions and any information you share on the Kumospace Platform may be viewed, captured, recorded and/or used by unauthorized persons. Therefore, please be cautious about your interactions and the information you choose to share when using the Kumospace Platform.

Please also note that as your display name (“Display Name”), customized URLs on the Kumospace Platform (“Customized URLs”), names of Floors on the Kumospace Platform (“Kumospace Floors”) and other customization features of Kumospace Floors will be displayed to other users on the Kumospace Platform, please exercise care when choosing what Personal Information you include in such names and URLs.

If you do not agree with this Privacy Policy, please do not access or use the Services.

We collect and use Personal Information depending on the context of your interactions with us. As described below, we collect some of this Personal Information when you provide it directly to us, and in some cases we receive Personal Information from third parties. We also collect certain information automatically when you interact with the Services.

If you visit the Kumospace Website, subscribe to our marketing communications, sign up to use and/or use the Kumospace Platform, we will collect Personal Information that you choose to share with us, including through forms on the Kumospace Website and within the Kumospace Platform. This Personal Information may include:

• Name;
• Company name and job title/position;
• Email address, phone number, mailing address and other contact details;
• Payment and billing information;
• Platform user account details, including username and password, Display Name, Customized URL as well as Kumospace Floor names and other information relating to customizations on the Kumospace Platform, if applicable; and
• Other information that you choose to share in connection with your request, inquiry or use of the Services.

In addition to the information that you provide directly to us, we collect some information automatically when you use the Services. The types of information that we collect automatically may include:

• Technical information about your computer, device, hardware, or software you use to access the Internet or our Services, such as IP address or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system related specifications);
• Usage and activity data, information and statistics about your interaction with the Services which may include the URLs of the Services that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, the applications and features you use, the dates, times and duration of your visits, when and how long you use those applications and features, your use of and interactions within the virtual spaces and Kumospace Floors on the Kumospace Platform, including, without limitation, the time you spend in Kumospace Floors and other usage statistics;
• Information that facilitates a safer and more personalized experience with the Services, such as user identification information, saved preferences, and device identifiers or usage information for authentication and fraud prevention purposes; and
• Information about your approximate location, which we may derive from device information such as IP address.

We collect some of this information through tracking technologies such as cookies and web beacons. For more information, please see the How We Use Cookies and Other Tracking Technologies section below.

In some cases, we receive Personal Information from third parties. For instance, if you have been invited to attend a virtual event on the Kumospace Platform by an Kumospace Host, we may receive your name and email address from the Kumospace Host to facilitate your registration and attendance.

We may also receive Personal Information from other third-party sources, including:

• Our service providers, such as online analytics providers;
• Data brokers from which we purchase demographic data to supplement the data we collect;
• Services that make user-generated content from their service available to others, such as public posts on social media networks; and
• Publicly available sources, such as business registries.

Kumospace's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

In addition, if you interact with us on social media by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or otherwise communicating with us or participating in social media activities in which we are involved, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.

We may use the Personal Information that we collect or receive through the Services for the following purposes:

• To respond to your inquiries and requests, communicate with you about the Services and otherwise provide customer support;
• To operate and provide support for your use of the Services, including to facilitate your registration for and attendance at virtual events hosted on the Kumospace Platform;
• To store information about your preferences and customize your experience on the Services;
• To analyze usage trends and patterns and measure the effectiveness of the Services;
• To perform our agreements with Kumospace Hosts, if applicable, including meeting Kumospace’s obligations, checking visits to Kumospace Floor(s) and measuring usage;
• To send you updates, newsletters and other content and to promote our products and services, including by sending you newsletters, special offers, and other information we think may be of interest to you;
• To develop and provide promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;
• To provide, administer, evaluate, troubleshoot, improve and enhance our business and the Services (including data analytics, testing, system maintenance, developing new products and services; managing our communications; and performing accounting, auditing, billing, reconciliation and collection activities);
• To create aggregated, de-identified data for our business purposes, including, to improve the Kumospace Platform and our Services;
• To comply with legal or regulatory requirements, judicial process, and our company policies (including due diligence and contracting activities);
• To secure the Services, including by protecting against and responding to actual or alleged fraud, illegal activity (such as incidents of hacking or misuse of the Services), and claims and other liabilities, including by enforcing our customer agreements and Terms of Service and to respond to trust and safety issues that may arise;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding; and
• For any other purpose that you may authorize or direct at the time we collect your Personal Information.

Please note that if information is aggregated or anonymized so that it is no longer reasonably associated or trackable to an identifiable natural person, it is no longer considered “Personal Information” under this Privacy Policy, and Kumospace may use it for any legitimate and lawful business purpose.

To accomplish the purposes set forth above, we may share your Personal Information with other parties that may include the following:

• Kumospace Hosts that host virtual events through the Kumospace Platform and that you registered to attend;
• Service providers and vendors that perform services on our behalf and under our direction or otherwise retained in connection with the Services, including analytics and cloud computing providers;
• Other third parties if we believe doing so is required or appropriate  to: (a) protect or defend the interests,  legal rights or property of Kumospace or any individual; (b) protect the rights, interest and safety and security of the Services, our organization, or members of the public; (c) detect or protect against any suspected fraud; (d) comply with applicable laws or regulations; (e) cooperate with governmental or law enforcement investigations and legal process, such as a court order or subpoena; (f) respond to your requests; and/or (g) investigate and prosecute users who engage in behavior that is illegal or harmful to others or to others’ property;
• A buyer or other successor or organization (as well as their advisors or other third parties) in connection with an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding; and
• Such other parties, or for such other purposes, as you may authorize or direct when we collect your Personal Information.

We collect information about your use of the Services through tracking technologies such as cookies, web beacons and other technologies (“Tracking Technologies”). A “cookie” is a unique alphanumeric code that is transferred to your computer to track your interests and preferences and to recognize you as a return visitor. A “web beacon” is a transparent graphic image placed on a website, e-mail or advertisement that enables the monitoring of things such as user activity and site traffic.

We and third-parties with whom we work may use Tracking Technologies on the Services to improve user experience, to help remember your preferences and allow us to bring you the content and features that are likely to be of interest to you, and to analyze the use of our Services and to improve the Services’ functionality. These third parties may collect information about your online activities over time and across different Web sites. One of the ways we do this is through the use of Google Analytics. For more information about how Google Analytics uses and processes data, please visit Google Privacy & Terms.

We provide you with choices with respect to your Personal Information. For example, you can choose not to give us the Personal Information we request, as described in the “Information You Provide Directly to Us” section of this Privacy Policy. However, in some cases, if you decide not to provide the information we request, we will not be able to provide the service or information you requested.

Other examples of your choices include:

• You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will still continue to receive administrative messages from us.
• You can browse the Kumospace Website without registering or directly submitting any information to us (although we may still collect some limited information automatically, as described above); and
• You may change your browser settings or take other steps to block, manage, or delete cookies. Our Services do not currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage cookies. In some cases, blocking or disabling cookies may cause the Services not to work as intended and some features may not be available.

The Services may contain links to websites, videos, products and services owned and operated by third parties. These third-party websites and services are not subject to this Privacy Policy. As they are not controlled by Kumospace, we are not responsible for their content or their privacy policies, which may differ from ours. We have not reviewed and make no representations about the accuracy of information on third-party websites, or about their information handling practices. Visits you make to these websites are at your own risk, and we encourage you to review their terms of service and privacy policies.

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain. However, as no electronic transmission of Personal Information can be entirely secure, we make no guarantees as to the security or privacy of your Personal Information.

We may process and store your Personal Information in the United States and in any other country where we or our or service providers operate. By your use of the Services you consent to such transfer, storage and processing and acknowledge that we will maintain your Personal Information in jurisdictions which may have different data protection rules than in your country, and that your Personal Information may become accessible as permitted by law in those jurisdictions, including to law enforcement and/or national security authorities.

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right of data portability
• Right to object
• Rights related to automated decision making including profiling

This Privacy Notice is intended to provide you with information about what personal data we collect about you and how it is used.

If you wish to confirm that we are processing your personal data, or to have access to the personal data we may have about you, please contact us.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside of Kumospace might have received the data from us; what the source of the information was (if you didn’t provide it directly to us); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Kumospace if it is inaccurate. You may request that we erase that data or cease processing it, subject to certain exceptions. You may also request that we cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data. When technically feasible, we will—at your request—provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, we will provide you with a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email us at privacy@kumospace.com. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation’s data protection authority.

Your personal data is stored by us on the servers of the cloud-based database management services we engage, located in the United States. We retain service data for the duration of the customer’s business relationship with us and for a period of time thereafter, to analyze the data for our own operations, and for historical and archiving purposes associated with our services. We retain prospect data until such time as it no longer has business value and is purged from our systems. All personal data that we control may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at privacy@kumospace.com.

This section of the Privacy Policy applies solely to consumers who reside in the State of California and to the Personal Information of a particular California consumer or household (“California Personal Information”). We describe in this section how we collect, use, and share California Personal Information to the extent we act as a “business” under the California Consumer Privacy Act of 2018 (“CCPA”), and the rights that consumers have under the CCPA; provided, however, that California Personal Information does not include, and this section of the Privacy Policy does not apply to:

• Personal information that is exempt from the CCPA;
• Personal information we collect in connection with communications or transactions with consumers who are acting as representatives of companies and other organizations that occur solely within the context of conducting due diligence regarding, or providing or receiving a product or service to or from such companies or organizations; or
• Personal Information we collect, use, and share on behalf of our customers as a “service provider” under the CCPA.

We may have collected the following categories of California Personal Information regarding consumers within the last 12 months:

• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. Some Personal Information included in this category may overlap with other categories;
• Identifiers such as your real name, alias, postal address, zip code, telephone number, email address and account name;
• Unique and online identifiers such as device identifiers, internet protocol addresses, cookie identifiers, beacon identifiers, pixel tags or mobile ad identifiers or similar technology, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device;

We may obtain the categories of California Personal Information that we collect as indicated above from the following categories of sources:

• Directly from you. For example, through website forms you complete or ordering our products and services.
• Automatically and indirectly from you, such as through logging and analytics tools, cookies, pixel tags, and other automatic data collection.
• From third parties, such as Kumospace Hosts, our service providers, consumer data resellers, services that make user-generated content available to others, communications services, and social networks and social media online services.

We may use the categories of California Personal Information that we collect, as described above, for one or more of the business purposes and commercial purposes described in the How We Use Personal Information section above.

We may disclose the categories of California Personal Information that we collect as indicated above to the categories of third parties described in the How We Share Personal Information section above.

In the preceding 12 months, we may have disclosed all of the categories of California Personal Information listed above to our service providers and other third parties when you direct us to do so, or when you use our Services to do so.

In the preceding 12 months, we have not sold California Personal Information. We do not sell California Personal Information, and we do not have actual knowledge that we sell the California Personal Information of Consumers under the age of 16.

The CCPA and other California laws provide consumers with specific rights regarding their California Personal Information. This section describes the rights you may have and explains how to exercise those rights to the extent the CCPA applies.

• Direct Marketing Disclosure Request Right. California residents who have an established business relationship with us may request information regarding third parties, if any, to whom we may have disclosed Personal Information (as defined by Cal. Civ. Code. § 1798.83(e)(7)) for the direct marketing purposes of those third parties during the preceding calendar year. Requests may be made only once per year per person. To submit a request, send an email or letter to the addresses provided in the How to Contact Us section of this Privacy Policy.
• Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the Exercising Access, Data Portability, and Deletion Rightssection below, we will disclose one or all of the following depending on the scope of the request:
• The categories of California Personal Information we collected about you over the past 12 months.
• The categories of sources for the California Personal Information we collected about you over the past 12 months.
• Our business or commercial purpose for collecting California Personal Information about you over the past 12 months
• The categories of third parties with whom we shared California Personal Information over the past 12 months.
• The specific pieces of California Personal Information we collected about you over the past 12 months.
• The categories of California Personal Information about you that we disclosed for a business purpose, to the extent we have made such disclosures.
• Deletion Request Rights.Subject to certain exceptions, you may submit a verifiable request that we delete the California Personal Information that we have collected about you.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending an email to privacy@kumospace.com, or sending your request by mail as set out in the How to Contact Us section below, with your first name, last name, and email address, and a detailed explanation of your request.

Only you, or an authorized agent registered with the California Secretary of State that you provide written permission authorize to act on your behalf, may make a verifiable consumer request related to your California Personal Information. If an authorized agent makes a request on your behalf, prior to responding we may require the authorized agent to present written and signed proof of authorization to act on your behalf, verify your identity, and confirm the authorized agent’s permission to act on your behalf directly. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent. In order to verify your request, we may ask you to provide information such as your first and last name, email address, mailing address, telephone number, or any other information necessary to verify your identity representative of that person. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.

Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.

If your request is manifestly unfounded, repetitive, or excessive, including if you have made several repetitive requests, we may charge a reasonable fee to respond. We also may decline to respond, in which case we will notify you.

Subject to certain exceptions, you will not receive discriminatory treatment for exercising your access, data portability, and deletion rights described above.

The Kumospace Website, the Kumospace Platform and the Services are not intended for children under thirteen (13) years of age. Kumospace does not market any products or services to children under thirteen (13) years of age or knowingly collect any Personal Information from children under thirteen (13) years of age. If you learn that a child has provided us Personal Information, then you may alert us at privacy@kumospace.com.

If you have any questions or comments about this Privacy Policy, if you need to report a problem, or if you would like to exercise one of your rights under this policy, please contact us at privacy@kumospace.com. Please include your name, contact information, and the nature of your request so that we can respond appropriately and promptly.

As Kumospace’s business is constantly evolving, we reserve the right to change the terms of this Privacy Policy from time to time to reflect changes in our Services, the way Kumospace operates, and regulatory and other requirements. Any changes to this Privacy Policy will be reflected on this page with a new “Last Updated” date. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Services after we post changes is deemed to be acceptance of those changes.

Last Updated: 6/22/2023