This is privacy policy (the "PrivacyPolicy") that governs how Kolahawk LTD ("Kolahawk") collects, uses, discloses, and otherwise processes Personal Information (defined below) in connection with www.kolahawk.com (the “Site”) and any other website that links to this Privacy Policy. This Privacy Policy also applies to the Personal Information Kolahawk receives when customers (“Customers”) use the Site in connection with Kolahawk’s web analytics services (the “Service”). As used herein, the terms “You” or “your” shall apply to individual users of the Site, or in connection with your use of the Service. If You have any questions or comments regarding this Privacy Policy, please contact us at privacy@kolahawk.com.

1. What is Personal Information?

Kolahawk is committed to respecting your privacy and recognize the need for appropriate protection and management of any Personal Information that is shared as part of using the Service. As used in this Privacy Policy, “ PersonalInformation” is information that, either alone or in combination with other information, identifies an individual. When Kolahawk combines other information (i.e., information that does not, on its own, identify You) with your Personal Information, Kolahawk treats the combined information as Personal Information.

2. When Personal Information is Collected

A. Personal Information Collected via the Site. Kolahawk’s Site may collect the following types of information in connection with the Service:

1. Contact, Account, and Billing Information. Kolahawk processes Personal Information that You provide through creation and management of your account, such as your name, e-mail address, and phone number. Kolahawk also processes, via a third-party service provider, payment information for billing purposes. Kolahawk processes this Personal Information only as necessary to provide the Service to You under the Terms of Service (the “Agreement”). For example, Kolahawk uses this information to bill You for your use of the Service; respond to your inquiries regarding the Service; facilitate Kolahawk’s account recovery services in the event You or one of your users forgets their log-in credentials; and for other purposes related to the reasons for which You provide your Personal Information. Kolahawk may use your email address to contact You from time to time in furtherance of Kolahawk’s legitimate interests to provide You with information regarding the Service, such as invoices, payment receipts, and information regarding critical updates to your subscription. Unless You opt out using the process described in Section 6, below, Kolahawk may also send You a newsletter with tips and tricks for maximizing your use of the Service, as well as information on new or additional features.
2. Blog Comments. If You choose to post comments on the Kolahawk blog, Kolahawk requires You to provide your name and your email address (Kolahawk does not publish your email address). By posting a comment, You consent to Kolahawk’s publication and storage of your blog comment. You may withdraw your consent by submitting a request to remove the post to privacy@kolahawk.com. Please be aware that whenever You voluntarily disclose Personal Information online, the information You post becomes public and can be collected and used by others and indexed in search engines.
3. User ID and Password Information. Kolahawk processes Customers’ user ID and password information to enable them to log into and use the Service. Kolahawk processes this Personal Information only as necessary to provide the Service to You under the Agreement. In the event You are able to log into the Site or Service through a social networking site (e.g., Facebook or Twitter), Kolahawk may receive Personal Information in accordance with the privacy policy of that site, which Kolahawk may add to Personal Information You have previously provided.
4. IP Address and Header Information. Kolahawk automatically collects certain information when You visit our Site, such as IP address and Header Information. “Header Information” is information such as browser type, geolocation, operating system, language, screen resolution, referring URL, etc. provided to our web server by your browser. Kolahawk has a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, and to track user trends.
5. Traffic Data. Like their Customers, Kolahawk uses the Service to generate useful insights about its website’s visitors’ use of the Site. Kolahawk uses the data generated and collected (“Traffic Data”) from the Service (described below) to further our legitimate business interests in analyzing the effectiveness of the Site and Service, so Kolahawk can improve the look, function and content of the Site and. Kolahawk only collects keystroke data when You enter data into form fields on the Site that do not require or prompt You to provide sensitive information. You can opt-out of our processing of your Traffic Data by clicking the “Do not track me” button near the top of this page.
6. Contact Information. As a visitor to the Site, Kolahawk may collect your name, email, and free form text entry if You choose to contact us through our “Contact Us” page. Kolahawk processes this Personal Information to address your comments or questions and Kolahawk may send You commercial or transactional emails as a result. You can opt-out of commercial emails any time by following the process set forth in Section 6.

B. Personal Information Collected from the Service. Kolahawk processes Personal Information collected from the Service on behalf of Kolahawk Customers. Customers are responsible for determining the purposes and lawful basis for the processing of their Personal Information. Kolahawk strongly advises members of the public to review privacy notices on any Customer website to determine what information is collected and how it is processed by that Customer website. As a visitor of one of the Kolahawk Customer websites, Kolahawk may collect the following categories of Personal Information through the Service:

1. Traffic Data. As part of the Service, Kolahawk collects information relating to traffic on the Customer’s website(s), such as; pages visited, the visitor’s mouse movements and clicks, keystroke data, HTML data on a page visited by a visitor if such HTML data includes Personal Information (collectively, “TrafficData”). Kolahawk uses Traffic Data to provide Customers with real-time analytics and uptime monitoring. Although Kolahawk encourages Customers to process Personal Information responsibly and provide features intended to minimize the impact of the Service on visitor’s privacy, Kolahawk does not have control over how Customers use Traffic Data. For example, Customers have the ability to link Traffic Data with available Personal Information (e.g., account information You have provided them). As another example, although Kolahawk may implement features that enable its Customers to create profiles of individual visitors, the Customer—and not Kolahawk—determines whether to use that profiling information for targeted advertising or other purposes. Customers have the ability to configure the Service to change the amount and type of Traffic Data collected on the Customers’ websites. For example, by default, Kolahawk disables the collection of keystroke data on Customers’ websites. Keystroke data is only captured if the Customer changes this default setting to enable keystroke collection, and even then only for each text field that the Customer has explicitly authorized keystroke collection. As another example, Kolahawk allows Customers to scramble the text within any HTML data processed by the Service. When this feature is enabled, Kolahawk renders any Personal Information within HTML data undecipherable through scrambling. For more information on the manner in which Kolahawk Customers have implemented the Service on their websites, Kolahawk recommends that You review such Customers’ individually posted privacy policies.
2. IP Address and Header Information. Through the Service, Customers collect and use IP address and Header Information from visitors when they browse their websites. Kolahawk processes your IP address to help a Customer identify your internet service provider and the geolocation from which You are accessing the Customer website. Kolahawk processes Header Information on behalf of its Customers to determine which websites originated traffic into Customer Websites, the type of browser You are using, and information about your device and operating system. These details are useful to Customers to help them identify issues with and improve their websites. To help protect your privacy, Kolahawk allow Customers to enable IP address masking, which is a feature that removes the last three digits of your IP address before storing it on the Kolahawk servers.
3. Derived Data. All of the data Kolahawk collects through the Service, including Personal Information, relates to a visitor’s use of a single Customer website. Kolahawk does not track visitors across Customer websites. However, Kolahawk does aggregate (i.e., combine your data with the data of others to create a statistical summary that removes all personally identifiable information) Traffic Data to further our legitimate interests in providing statistical benchmarking data and vertical-driven insights to the Kolahawk Customers. This data, when stripped of all personally identifiable information in combination with the data of others to create a statistical summary, is identified as Derived Data (as defined in the Terms of Service)

3. How Kolahawk Uses Cookies and Similar Technology

To help operate the Site and Service, enhance your experience, and collect information about online activity, Kolahawk places small data files on your device known as “cookies,” or other similar technologies (e.g., pixel tags, web beacons, local shared objects). Cookies and similar technologies enable Kolahawk to personalize the Site, help make the Site load faster (through “load balancing” technology) and enable Customers to collect useful data with the Service. These technologies may allow Kolahawk and its Customers to store and manage your preferences and settings; measure and analyze how You use the Site and Services and effectiveness of Kolahawk communications; offer targeted products, programs, and services; and help Kolahawk improve its products, services, and security.

The table below explains the types of cookies Kolahawk uses on its websites and why they are used. Also provided are examples of the cookies set by Kolahawk, with explanations of their purpose. Please note that this is not an exhaustive list, but rather aims to be a representative summary.

You may wish to restrict the use of cookies or completely prevent them from being set. If You disable cookies though, please be aware that some of the features of the Kolahawk Site or Service may not function correctly. Most modern browsers allow You to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or You can use the help option in your browser for more details:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web and iOS.

To find out more on how to manage and delete cookies, visit https://aboutcookies.org/. For more details on your choices regarding use of your web browsing activity for interest-based advertising You may visit the following sites:

• networkadvertising.org
• optout.aboutads.info
• youradchoices.com
• youronlinechoices.eu

On a mobile device, You may also be to adjust your settings to limit ad tracking.

You may see a “cookie banner” on our websites. If You are visiting one of the Kolahawk Customer’s sites from the EU, then Kolahawk does not set, or allow its ad partners to set, cookies that are used to show You targeted ads before You click to accept. When You consent in this manner, Kolahawk and its advertising partners may set advertising cookies on the site You are visiting and on other of our websites, dashboards, and services. Kolahawk will display the banner to You periodically, just in case You change your mind.

4. The Purposes and Use of Personal Information

If You submit or Kolahawk collects Personal Information through the Site or the Service, then such Personal Information may be used to:

• Provide, analyze, administer, improve, and personalize the Service;
• Contact You in connection with the Service, notifications, programs or offerings that You may have registered for;
• Send You updates and promotional materials;
• Provide personalized advertising to You;
• Identify and authenticate your access to the parts of the Site or Service that You are authorized to access;
• For recruiting and human resources administration purposes; and
• Protect Kolahawk rights and/or property and to ensure the technical functionality and security of the Service.

5. To Whom Personal Information Is Disclosed

Kolahawk will not disclose your Personal Information except as set forth in this Privacy Policy or with your consent. For example, Kolahawk does not sell, lease, or exchange your Personal Information, but if this were to change in the future, Kolahawk would first obtain your express prior consent. This section describes to whom Kolahawk discloses Personal Information, and for what purposes:

1. Our Customers. As part of the Service, Kolahawk provide each Customer with access to Derived Data and other data collected through the Service on its behalf. Kolahawk also provides Customers with aggregated (i.e., a statistical summary of data from all of Kolahawk Customer websites combined) and anonymous (i.e., no individual visitor, or personally identifiable information, can be identified in the data) Derived Data.
2. Our Service Providers. Kolahawk employs service providers to perform tasks on its behalf and to assist in providing the Site and Service. For example, Kolahawk may share your Personal Information with service providers who assist in the performance of core Site and Service functions (such as hosting, data storage, and security) related to the operation of the Site or Service and/or by making certain interactive tools available to You as a Customer or visitor. Kolahawk also uses third parties for technical and customer support, application development, tracking and reporting functions, quality assurance, and other services. In the performance of the Service, Kolahawk may share Personal Information from or about You with these third parties so that it can deliver the highest quality user experience. Kolahawk uses commercially reasonable efforts to only engage with third parties that post a publicly available privacy policy.
3. Our Customers’ Service Providers. Kolahawk may, at the direction of its Customers, provide data, including Personal Information, to third-party service providers on the Customers’ behalf. This enables the Customers to integrate the Service with other services they use, such as customer relation management systems. For more information on the manner in which Customers have implemented the Service on their websites, including integrations with third-party services, Kolahawk recommends that You review such Customers’ posted privacy policies.
4. Social Media Services. Third-party social networks that provide interactive plug-ins or social networking features on the Site (for example, to allow You to “Like” a page), may use cookies or other methods (for example, web beacons) to gather information regarding your use of the Kolahawk websites and apps. The use of such information by a third party depends upon the privacy policy available on that social network’s website, which Kolahawk encourages You to carefully review. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of the Kolahawk Site with any of your Personal Information that they may have.
5. Advertising. Kolahawk engages advertising services to assist in advertising its brand and the Service. From time to time, those services target advertisements on third-party websites based on cookies or other information indicating previous interaction with the Site.
6. Google Analytics. Kolahawk uses Google Analytics, an analytics service, along with its own Service, to help analyze the traffic on the Site. For more information on Google Analytics’ processing of Personal Information, please see “How Google uses data when You use Kolahawk partners sites or apps.” You can opt out of Google Analytics by installing Google’s opt-out browser add-on.
7. Companies Involved in Mergers and Acquisition Transactions or Change of Control.
   In some cases, Kolahawk may choose to buy or sell assets. In these types of transactions, user data (including Personal Information) is typically one of the business assets transferred. Moreover, if Kolahawk, or substantially all of its assets, were acquired, user data would be one of the assets that is reviewed and transferred or acquired by a third party. Kolahawk may transfer or assign this Privacy Policy and any Personal Information to a third party entity in the event of some other change of control (such as the result of a bankruptcy proceeding).
8. Law Enforcement, Government Agencies, and Courts.
   Kolahawk may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of a Customer or any other person. Kolahawk may also disclose Personal Information to investigate or prevent a violation by You of any contractual or other relationship with Kolahawk (such as a violation of the Terms of Service) or your illegal or harmful activity.

6. How You Can Opt-Out

You may choose not to receive future promotional or advertising emails from Kolahawk by selecting an unsubscribe link at the bottom of any email that You receive from Kolahawk. Additionally, You may send a request specifying your communications preferences to privacy@kolahawk.com. You cannot opt out of receiving transactional emails related to the performance of the Service. Please note that even if You opt out of receiving the foregoing emails, Kolahawk may still send You a response to any “Contact” request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).

At the top of this page and in the link provided here, Kolahawk provides access to a data privacy management tool that allows You to opt out of being tracked by the Kolahawk Service.

7. Personal Information from Children

Kolahawk does not knowingly provide access to the Service to children under the age of sixteen (16). If Kolahawk learns that it has collected Personal Information from children, and there is no lawful basis to process such Personal Information under applicable law, Kolahawk will promptly take steps to delete all such Personal Information.

8. Retention of Personal Information

Kolahawk will retain your Personal Information for the period necessary to fulfill the purposes for which your Personal Information has been collected as outlined in this Privacy Policy, unless a longer retention period is required by law. Where feasible, Kolahawk disposes of data, including Personal Information, on a regular schedule. For example, Kolahawk disposes of Traffic Data collected on behalf of its Customers after thirty (30) days, unless the Customer has purchased a longer storage period. Notwithstanding the foregoing, such data retention period shall not exceed one (1) year.

9. How We Protect the Confidentiality and Integrity of Your Personal Information

Kolahawk has implemented security measures to protect Personal Information from loss, misuse, and alteration. Kolahawk uses industry-standard practices such as encrypted storage, firewalls, and password protection systems to safeguard the confidentiality of Personal Information. Kolahawk takes steps to help ensure its employees and contractors are aware of their information security obligations, and further restricts employee and contractor access to Personal Information. Despite efforts to store Personal Information in a secure operating environment that is not available to the public, Kolahawk cannot guarantee the security of Personal Information during its transmission or storage on our systems. Further, while Kolahawk attempts to ensure the integrity and security of Personal Information, it cannot guarantee that the security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information. Kolahawk does not represent or warrant that Personal Information about You will be protected against, loss, misuse, or alteration by third parties.

10. Links to Third Party Websites

The Kolahawk Site may contain links to third party websites. Please be aware that Kolahawk is not responsible for the privacy practices of third party websites You choose to visit. If You provide any information directly to parties other than Kolahawk, different rules may apply to the use or disclosure of that information. Kolahawk encourages You to investigate and ask questions before disclosing your Personal Information to third parties.

11. Your California Privacy Rights.

In performing Kolahawk’s Service for its Customers, Kolahawk operates as a “Service Provider” under Cal. Civ. Code § 1798.100, otherwise known as the “California Consumer Privacy Act of 2018” or “CCPA”. In fulfilling its obligations to our Customers as a Service Provider, Kolahawk may process certain Personal Information under instruction from our Customers to fulfill a legitimate “Business Purpose” under the CCPA, which may include any one or more of the following activities: maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, providing advertising or marketing services, providing analytic services, or providing similar services. Kolahawk does not disclose or resell Personal Information for any other commercial purpose, except in certain cases where the Personal Information has been pseudonymized or is considered aggregated consumer information.

Subject to applicable exceptions under the CCPA, Kolahawk will delete Personal Information of a consumer from its records upon the direction of its Customers in response to a consumer’s verifiable request to delete Personal Information. In the event Kolahawk receives such a request directly, it will forward it to the respective Customer without delay and shall not take further action until such time as directed by Customer. If You have any questions regarding our role as a Service Provider, or if You would like to request information regarding the disclosure of Personal Information about You by Kolahawk to third parties for the third parties’ direct marketing purposes, please complete and submit the Access Request Form or send an email to privacy@kolahawk.com.

12. GDPR Policy (for European Data Subjects only).

Kolahawk has created this General Data Protection Regulation (“GDPR”) Policy to explain how Kolahawk collects and process Personal Information about You as a data subject. As used in this Section 12, a “data subject” is an identified or identifiable person who is located in the European Union/European Economic Area (“EU/EEA”), and “process”or “processing” means any operation or set of operations which is performed on Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1. Kolahawk’s Basis for Processing. The following sets out four (4) lawful basis under the GDPR to which Kolahawk may process your Personal Information:

2. Data Subject Privacy Rights. In certain circumstances, local data protection laws and certain local laws (including the GDPR) may give You rights with respect to Personal Information if You are located in the EEA. These rights differ by country/region, but may include access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Information collected via the Site. You may exercise these rights at any time by submitting a Data Subject Access Request or sending an email to privacy@kolahawk.com, and Kolahawk will comply with all applicable laws. Kolahawk also provides Customers with access to—and the ability to edit or delete—certain categories of Personal Information through the Account Management page. Kolahawk has appointed EU Business Partners as its representative in the EU for the purposes of Article 27 of GDPR. You may contact the EU representative, as well as Kolahawk directly with any query that You may have in relation to your personal data. The contact details are as follows:
   
   EU Business Partners
   10 Ashe Street, Clonakilty, County Cork, P85 E4303, Ireland
   info@eubusinesspartners.com
   Flor McCarthy, Director
   
   Depending on where You live, You may have the right to lodge a complaint with a supervisory authority or other regulatory agency if You believe that Kolahawk has violated any of the rights concerning Personal Information about You. Kolahawk encourages You to first reach out at privacy@ouckyorange.com, to provide an opportunity to first address your concerns directly.
   
   Kolahawk does not have control over the processing of Personal Information by its Customers. Thus, if You would like to exercise your rights concerning Personal Information processed through the Service—beyond using the opt-out feature to object to Kolahawk’s tracking of You—You should reach out to the Customer directly. If You need help contacting one of the Customers, please let Kolahawk know and they will happy to help connect You if possible.
3. Personal Information Transferred from the EU or Switzerland to the United States. Kolahawk complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the EU and the United Kingdom and/or Switzerland, as applicable to the United States in reliance on Privacy Shield. Kolahawk has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. A violation of Kolahawk’s commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the policies in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
   
   To learn more about the Privacy Shield program, and to view the certification page, to the extent available, please visit the certification page here. In compliance with the Privacy Shield Principles, Kolahawk commits to resolve complaints about your privacy and Kolahawk’s collection or use of Personal Information about You. Persons from the EU or Switzerland who have inquiries or complaints regarding this Privacy Policy should first contact Kolahawk via email at: privacy@kolahawk.com.
   
   Kolahawk has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If You do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.
   
   These recourse mechanisms are available at no cost to You. Damages may be awarded in accordance with applicable law. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the Privacy Shield, Kolahawk is potentially liable.
   
   Pursuant to the Privacy Shield, Kolahawk remains liable for the transfer of Personal Information to third parties acting as its agents unless Kolahawk can prove they were not a party to the events giving rise to the damages.

13. Changes to the Privacy Policy

Kolahawk may revise and update this Privacy Policy at any time and will post the updated Privacy Policy to the Site. If these changes are material (i.e., changes believed to be of importance to You), Kolahawk will post notice of material changes on the Site. Where required by applicable law, Kolahawk will obtain your consent. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY SHALL BE EFFECTIVE IMMEDIATELY UPON POSTING TO THE SITE.

14. Contact

If there are any questions regarding this Privacy Policy You may contact Kolahawk using the information below:

http://help.kolahawk.com
privacy@kolahawk.com