KulaMind Privacy Policy

Last modified: October 22, 2024

Thank you for using KulaMind, Inc. Sites ("KulaMind" or the "Company") and Apps ("the Services"). This Privacy Policy is designed to help you understand how we collect, use, disclose, and safeguard your personal information when you use our Service.

This privacy policy describes how we collect, use, or disclose information about you and your use of the Services. By accepting the KulaMind Terms of Use, you confirm that you have read and understand this Privacy Policy and you acknowledge that we will store, use, and otherwise process your information in the United States where we are located. References to "KulaMind," "Company", "we" or "us" means KulaMind Inc. except as otherwise noted in this Privacy Policy, KulaMind is the data controller responsible for the processing of your personal information as described in this Privacy Policy.

Some of our Services do not retain your personal information (such as simply visiting our website or app), while others (such as our community or app) store your personal email you use to register your account with us in accordance with this Privacy Policy. Even if you do not register with or provide any personal information to KulaMind, we collect information about your use of the KulaMind Services.

Having said that, when you use the Services, we collect information as follows:

Registration

Our primary Services require registration with KulaMind using an email address of your choice. When registering or updating your KulaMind account, you may need to provide personal information, like phone number, date of birth, or gender. You are responsible for the accuracy of this information. To operate our app and community, we collect and store information directly or indirectly from you. This data is not used for marketing and is only used as specified in our Privacy Policy.

Interactive Services

Some of our Services, such as our assessment surveys and practice tools, are interactive and may request that you submit health-related information, along with other information such as your age and gender. KulaMind may also collect, use, and store general data regarding your sessions such as timing of sessions and whether your session was completed or abandoned.

In addition, KulaMind may aggregate general information pertaining to user demographics to our business partners, for such matters as research and measurement purposes, including measuring the effectiveness of content or programs.

Correspondence Sent to KulaMind

We collect any information you give us voluntarily, such as information you write to us in an email, leave on a voicemail, or send in a letter. If you want to keep this information private or proprietary, do not send it in an email or otherwise provide the information to KulaMind.

Services and Device Information

When you use KulaMind services, we may automatically collect and store certain information from your device and browser, including:

  • Your IP address and device identifier

  • Browser details (including referring URL)

  • Your preferences and settings

  • Cookies and data about viewed content and actions (e.g., searches, ad interactions) which you can manage in your browser settings

We may also gather device-specific information, such as:

  • Device model

  • Operating system details

  • Advertising ID

If you grant permission, we may collect precise location data from your mobile device, which you can disable in your device settings.

Cookies and Other Tracking Technologies

We may use cookies and similar tracking technologies to enhance your user experience and gather information about your browsing behavior on our website. You can manage your cookie preferences through your browser settings.

Categories of Personal Information Collected

The KulaMind Services currently collects preferred name, email, age, and any content derived from our platforms. Other categories of information that might be collected include:

  1. Identifiers (contact details such as real name, alias, postal address, telephone or mobile contact number, email address and account name)

  2. Identifiers of other people (contact details such as names of loved ones)

  3. Health-related information (mental health symptoms, diagnoses, symptoms and diagnoses of loved ones)

  4. Protected Classification Characteristics (gender and date of birth)

  5. Commercial Information (transaction data, purchase history, financial details and payment information)

  6. Biometric Information (fingerprints and voiceprints)

  7. Online Activity (search behavior, and interactions online)

  8. Geolocation data (device location)

  9. Audio and Visual Information (images, audio, video, or call recordings)

  10. Professional and Employment Info (job-related data for service and employment)

This data may be gathered when you (a) seek assistance through our customer support channels, (b) participate in customer surveys or contests, (c) utilize our Services, and/or (d) reach out with inquiries.

How Your Information is Secured and Retained

The security of your personal information, including registration email, name, age, gender, and voluntarily disclosed information via our Services, is a top priority. We've implemented robust technical and organizational measures to safeguard your data from loss and unauthorized access, including:

  • Security software for confidentiality

  • Secure Socket Layer/Transport Layer Security for online data

  • Backend data stored in secure AWS storage

  • Firewalls and encryption methods

  • Routine compliance reviews

  • Restricted employee access

While we implement reasonable security measures to protect your personal information, it's important to note that no internet or wireless data transmission can be entirely secure. Therefore, you acknowledge that:

  1. The internet has inherent security and privacy limitations beyond our control.

  2. The security, integrity, and privacy of data exchanged between you and us through this site can't be guaranteed.

  3. Data transmission may be viewed or tampered with by third parties during transit.

Any transmission of personal information is at your own risk, and we are not liable for circumvention of privacy settings or security measures on our website or services.

Your Choices and Rights

Your personal data belongs to you, and you have certain rights:

  1. Right to Information: You have the right to know how we collect and use your data.

  2. Right of Access: You can request access to your data and related information.

  3. Right to Rectify: If there are errors in your data, you can request corrections.

  4. Right to be Deleted: You can ask for your data to be deleted.

  5. Right to Restrict Processing: You can block or suppress the processing of your data.

  6. Right to Data Portability: You can move, copy, or transfer your data between IT environments.

  7. Right to Withdraw Consent: You can withdraw your consent for data processing.

  8. Right to Complain: You can file a complaint with your local authority.

  9. Right to Non-Discrimination: You won't face discrimination for exercising your privacy rights, though some services may be limited if specific rights like "right to be deleted" are invoked.

How Your Information is Used

  • To provide, improve, and create new Services.

  • To respond to your inquiries and send administrative communications.

  • To gather feedback about the Services.

  • To send secure messages and personalized emails based on your interests.

  • To analyze trends, user behavior, and activity.

  • To detect and defend against fraud and threats.

  • To identify issues with the Services.

  • To conduct research and measurement activities.

  • To administer your account.

The majority of data derived from chatbot correspondence will be collected from individuals utilizing our Services. The primary use of this data is to improve the Services, specifically regarding engagement and efficacy.

Sharing Your Information with KulaMind Affiliates

Subject to your consent, we may share your information with our affiliated entities. In the event of a change in corporate control, such as a sale, merger, asset transfer, or bankruptcy, KulaMind reserves the right to transfer your personal information to the acquiring party. Your personal data will continue to be managed in accordance with this Privacy Policy, unless modifications are enacted as outlined in the "Changes to This Privacy Policy" section.

Companies and Contractors that Work with KulaMind

KulaMind collaborates with third-party firms and contractors to support our Services and the operation of our platforms. These partners may have limited access to your data while assisting us. We have strict contractual agreements in place, ensuring that these third-party service providers and contractors only use your information for the specific services they provide to KulaMind and do not disclose it for other purposes.

Compliance with Law, Regulation, and Law Enforcement Requests

To comply with legal obligations and cooperate with government and law enforcement authorities, we may disclose personal information to third parties in the following situations: (1) when required by law, such as in response to a regulation, search warrant, subpoena, or court order, (2) when we genuinely believe that disclosure is essential to safeguard our rights, ensure your safety, investigate fraud, or respond to government requests, or (3) in exceptional circumstances, such as when there is a physical threat to you or others, to protect property, or to assert legal rights.

Updating/Removing Your Personal Information

You can correct, update, or review personal information via the site or by contacting us directly. You may delete any of your provided registration information by contacting us directly. Upon your request, we will delete your registration information from our active databases and back-up media when feasible. We may not delete your data if it's needed for:

  1. Completing a transaction or providing a service you requested.

  2. Detecting and preventing security issues or illegal activity.

  3. Debugging for product functionality.

  4. Protecting free speech, legal rights, or complying with the law.

  5. Supporting research in the public interest.

  6. Internal uses aligned with your expectations.

  7. Legal obligations or compatible lawful uses.

Minors

We are committed to protecting the privacy of minors. The KulaMind Services are not designed or intended for use by children under the age of 18. The KulaMind Sites do not collect personal information from any individual known to be under the age of 18. By using the Services, you verify that you are at least 18 years old. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and promptly delete the data from our records.

Users Outside of the United States

KulaMind and our technical infrastructure are located in the United States. If you are located in another jurisdiction, you should be aware that in order to provide the Services to you, we must transfer your personal information to our servers within the United States where it will be stored and processed in accordance with this Privacy Policy. By using the Services, you consent to such collection, understanding that data protection levels may differ from your country. We take reasonable steps to protect your information, but note that it may be accessible to U.S. government agencies under U.S. legal processes.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy and any of our Services at any time. Any changes will be effective upon posting. If we make any material changes to this Privacy Policy, we may notify you as a courtesy, but we encourage you to review this policy frequently for changes. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes. Please exit the KulaMind Sites and Apps immediately and cease use of our Services if you do not agree to the terms of this Privacy Policy.