1. What data we collect
We collect the following categories of information for the purposes explained below.
- Activity on Advertisers’ Digital Properties: This is data about your browsing activity on the Advertiser’s website or app. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, whether you downloaded a white paper on a business to business website, what items you placed into your online shopping cart, what products were purchased and how much was paid.
- Device and browser information: This is technical information about the device or browser you use to access the Advertiser’s website. For example, your device’s IP address, cookie string data, operating system, and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Android Advertising ID.
- Ad data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.
- Data from Advertising Partners: This is data that we lawfully receive from other digital advertising companies that we work with (“Advertising Partners”) to help us deliver ads to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers (meaning identifiers that help identify your browser or device, but do not directly identify you as a person) which some Advertisers or other third party Advertising Platforms choose to share with us – for example, your “Customer ID” with an Advertiser, an identifier (such as a cookie) associated with a hashed version of your email address, or demographic data such as age range. We may work with our Advertisers and Advertising Partners to synchronize their unique, anonymous identifiers to our own to enable us to more accurately recognise a particular unique browser or device and the advertising interests associated with it.
- Email from Advertisers: Some Advertisers choose to share actual email addresses from their customers with us, so that (with the help of Advertising Partners) we can help the Advertiser serve targeted ads to customers. For example, if you have given ACME Soccer Ball Co. your email address, through our service, ACME Soccer Ball Co. may send you a promotional email for a soccer ball you looked at but did not purchase. Similarly if you provided your email to a software website when you downloaded a white paper, through our services the software company may send you a follow up email providing you with more information about the software company’s products or services. We use clear emails supplied by Advertisers only for the purpose of assisting that particular Advertiser with their own advertising efforts and, in some cases, so we can report performance data back to the Advertiser’s CRM / reporting system. – we do not share email addresses with other third parties for their advertising purposes.
- Hashed email addresses: If an Advertiser allows, we may collect hashed versions of the emails that are entered on that Advertiser’s site. Hashing is a “one-way function” that effectively pseudonymizes email addresses. For instance, when email@example.com is run through a typical hashing function, it becomes the following string of code: 0F0B7B1A1A7E8BDBBC6AA545F8CCD6F83671B32479271BFCB6CC8498912058D5.
- We take this step to de-identify data and protect email addresses, while being able to use an identifier to better connect devices and browsers. We describe how this helps us better provide our services in “How we use the data we collect” below.
2. How we use the data we collect
We use this data to help our Advertisers identify and serve ads to you that are more relevant to you. We also use this data to operate, improve and enhance our services including enhancing the data points we or our Advertising Partners have about a particular user, browser, or device to serve the most relevant ads to you and, in turn, improve performance of an Advertiser’s ad campaigns. Specifically, we use this data for:
- Targeting: Selecting ads that are more likely to be relevant to you based on the interests previously associated with your device and the time of day you may be most interested in viewing these specific ads. For example, we may show you ads for your favorite shopping site (or similar sites we think you may like) during lunch or commute hours.
- Frequency capping: Making sure that you don’t see the same ad too many times.
- Sequencing: If you are being served a sequence of ads, making sure we show you the right ad next in the sequence.
- Cross-device matching: Identifying all devices that are likely to be associated with you so that ads can be targeted, capped and sequenced across those devices. For example, cross-device matching helps us NOT show you ads for the shoes you were looking at on your phone but that already purchased on your tablet. Instead we’ll try to show you ads for an upcoming triathlon where you can put those shoes to work. It also helps us match devices so we can honor your opt-out choices across all devices we know are connected to the opted-out cookie.
- Attribution: Monitoring when, where, and at what price we served certain ads on behalf of an Advertiser so that we can measure our influence on the marketing result of the Advertiser’s campaigns and overall marketing strategy. For example, being able to measure if a certain ad campaign (the ads shown and to whom they were shown) actually sold more soccer balls for ACME Soccer Ball Co.
- Reporting: Providing Advertisers insights into how their ads are performing and gain insights into their customers. Reporting may include ad metrics such as impressions, clicks, and conversions (however the Advertiser may define a “conversion,” for example, a sale or a white paper download). For example, if an ad is not performing well (customers aren’t clicking on it), the Advertiser will be able to see that data and update the ad (perhaps with a better deal!). With respect to specific cookie data, we limit reporting to cookie activity on the specific Advertiser’s website and which ads were shown whether there was engagement with those ads.
Data is reported in the aggregate for the campaign and, at times, at the cookie level. For some customers, ad metrics are reported at the domain level at the contact level. For some customers, ad metrics such as impressions, clicks, conversions etc. are aggregated at the domain level (the domain representing the company/account the Advertiser wanted to target) as well as at the contact level (the individual to whom the ad is being targeted) represented with an email address that was initially provided by the Advertiser.
3. Data Sharing
We may disclose information about you:
- With an Advertiser whose Digital Properties you have visited: We may share information about how you have interacted with that Advertiser’s Digital Properties or its Ads.
- With our service providers: We contract with companies who help with parts of our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.
- With service providers to our Advertisers: Our Advertisers may contract with companies who handle data (such as managing Advertisers’ customer lists) for them.
- With our subsidiaries and related companies: But they will only process your data for the purposes already explained in this Privacy Notice.
- In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of Kalu Yala, our Advertisers or any other third party.
- To Comply with legal process: To satisfy in good faith any applicable law, legal process, or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.
- To Investigate Wrongdoing and Protect Ourselves or Third Parties: To enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
- In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).
We also share hashed email addresses (or other pseudonymous identifiers associated with those hashes), technical data that we collect about your browsing habits and your device (such as data relating to our cookies, tracking pixels and similar technologies) with other advertising companies in the digital advertising ecosystem. This enables them and us to better target ads to you.
4. Cookies and related technologies
Tracking cookies enable us to identify your device when you move between different Digital Properties, so that we can serve targeted advertising to you.
Specifically, the Kalu Yala cookie we serve through the Kalu Yala platform for this purpose is named “__Kalu Yala”.
We may also drop cookies from our Advertising Partners for the purposes described above. The Advertising Partner cookies dropped will vary depending on who the Advertisers are.
Additionally, we use non-tracking cookies (not unique) to store user decisions in terms of your ad and opt-out choices
- We may drop an __Kalu Yala cookie with value opt-out if you opt-out as described below and an Kalu Yala consent cookie to track your consent choices.
- We may drop a __consent cookie that stores the choices you have made regarding data processing and advertising by Kalu Yala.
5. Your choices and opting-out
We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:
- You can opt out of receiving personalized ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided or by clicking here. Please note that this “opt out” function is browser-specific and relies on an “opt out cookie”: thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again.
- In some cases we may link multiple browsers or devices to you. If you opt out of on a browser or device and we have more linked to you, we will extend your opt out decision to the other linked browsers and devices. Since we only link users across browsers on devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
- Kalu Yala is also a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing personalized ads from us and from other NAI approved member companies.
- We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.
- We also comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt out of receiving personalized ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website.
- Please note that when using the ad industry opt-out tools described above:
- If you opt-out your browser may still send us data, for example your IP address. However, we isolate this data and do not use it other than for accounting and, in some cases, for fraud prevention. If you have opted-out on that browser, we do not use this data to personalize ads or to track you.
- If you use multiple browsers or devices we will additionally opt out those we have linked to you. Since we may not have all your browsers or devices connected back to your user, you may need to execute this opt out on each browser or device.
- Other ad companies’ opt-outs may function differently than our opt-out.
- To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:
- iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
- For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”
Opting out will not prevent you from seeing ads, but those ads will likely be less relevant because they won’t be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.
Some internet browsers allow users to send a “Do Not Track” signal to websites they visit. We do not respond to this signal at the present time.
In addition, if you are located in a European Territory you will also have additional data protection rights. These are described under the heading “Additional data protection rights for European Territory residents” below.
6. Data retention
We retain personal data we collect directly for targeting purposes for no more than 12 months, after which time we employ measures to delete it. However for identifiable data that we hold on behalf of an Advertiser such as their email address list, we will retain until the Advertiser asks us to delete it.
Personal data collected for other purposes is held no longer than necessary for our business purposes but is anonymized. For example, we retain anonymized impression and click data to ensure we can meet auditing requirements related to services provided or to meet legal requirements.
We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
8. International transfers
We may transfer the information we collect about you to countries (including the United States of America) other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. In general, these countries will be the countries in which we, our Advertisers, or our or their service providers operate.
Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.
9. Changes to this Privacy Notice
Changes to this Privacy Notice will be posted on this page. If we make a material change to our privacy practices, we will provide notice on the site or by other means as appropriate.
If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.
10. Contact us about questions or concerns
If you have any questions about this Privacy Notice or our privacy practices, you can contact firstname.lastname@example.org
11. Who owns https://kaluyala.com and Kalu Yala’s Facebook and Instagram accounts?
Kalu Yala is owned by Kalu Yala Study Abroad, S.A., a Panama registered company 100% owned by James R. Stice, a United States citizen, and has registered tax identification numbers in Panama and the United States.