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Privacy Policy

Last Updated: June 6, 2023

Kaleidoscope Group, PBC (“Kaleidoscope,” “we,” or “us”) respects your privacy and is committed to protecting personal information. This Privacy Policy (the “Policy”) explains our online and offline practices collecting information in connection with our Services, how we collect, use, and share such information, and certain rights and options you may have regarding your personal information. For the purposes of this Policy, “Services” means our end-to-end scholarship and grant management software connecting sponsors with applicants, as well as our website (the information and materials made available via our website) located at https://www.mykaleidoscope.com/.  

Important Information About This Policy

By providing us with personal information or using the Services, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Services or provide us with your information. 

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements.  To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates.

As a software and professional services provider, we may collect information from applicants when they apply to specific awards that is required by and specific to the award sponsor. When we collect award-specific application information, we are acting as a service provider on the award sponsor’s behalf. As such, we recommend you review the award sponsor’s privacy policies to learn more about their data collection, use, and disclosure practices.

We also ask that where we have an ongoing relationship with you, and any of the data you have provided is no longer accurate, that you keep us informed of this so we can amend our records accordingly. 

Information We Collect and Receive

         A.      Personal Information

For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. The types of personal information we may collect through the Services can be grouped as follows:

  • – First name, last name, email address (business or personal), position, name and mailing address of your organization, billing address, and telephone number (business or personal).
  • – If you are an applicant, your academic year, school information, graduation year, GPA, areas of studies, athletics information, transcripts, or other education records you may submit in connection with an application.
  • – If you are an applicant, your employment history, resume, or employment-related references.
  • – If you are an applicant, gender, ethnic, religious or spiritual identity, citizenship information, self-identified disability, or veteran status or affiliation.
  • – If you are an applicant, letters of personal reference, essays, artwork, creative materials or works, or other documents and personal materials an award sponsor may request from you in connection with your application.
  • – Details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
  • – Details regarding your preferred methods for distributing or receiving scholarship awards or funds, the details of any awards received or distributed, including dates of distribution or award, amounts, and designated applicants and schools.
  • – If you are an applicant, your bank account information for the purposes of receiving any applicable award deposits.

We collect this information when you visit or navigate the Services, fill in forms on the Services, fill out an application for an award via the Services, register as a contributor and submit information via the Services, request information on the Services, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.

Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”  We may also collect information about you from third-party sources and information about you that is publicly available. 

B.    Automatically Collected Usage and Device Information

Like most websites, the Services uses various technologies to automatically collect information about visitors.  Those technologies include:   

  • Cookies.  Cookies are small text files that a website transfers to a visitor’s device for recordkeeping purposes.  We use cookies to personalize visitors’ experiences on the Services, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze the Services traffic.   We use both session and persistent cookies on the Services and we use different categories of cookies:
    • Essential cookies. We may use cookies to remember information that changes the way the Services behaves or looks, such as a user’s language preference on the Services.
    • Analytics cookies. We may use analytics cookies to track information how the Services is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Services to see how our users react to them.

For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.  Please note that if cookies are disabled (such as essential cookies), you may not be able to enjoy certain features of the Services.

  • Log Files and Device Identifiers.  We use log files to track actions occurring on the Services and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
  • Web beacons and other technologies.  The Services may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users.  Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.
  • Analytics.  The Services may also use various third-party analytics tools, including, but not limited to, Google Analytics.  You can find more information about how data is collected and processed in connection with the Google Analytics service here.  You can also read Google’s privacy policy here.

The information collected through these technologies may be combined with personal information or aggregated with other information from Website visits.  We may share information about your use of the Services with our advertising and analytics partners, who may combine it with other information that you previously provided to them.

         C.      Information from Other Sources

We may obtain both personal and non-personal information about you from other users of the Services, business partners, vendor partners, contractors, suppliers, and other third parties and add it to other information we have collected.  We, and the third parties we engage, may combine information we collect from you over time, and across the Services, with information obtained from other sources.  This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

         D.      Social Media

If you interact with us on any social media platform: (i) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (ii) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts.  Social media platforms operate independently from Kaleidoscope and we are not responsible for the personal information that you choose to submit or link on any social media platform.  We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.

How We Use Personal Information

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

  • Providing the Services, including facilitating the connection of applicants and award providers in connection with facilitating applications and awards.
  • Negotiating, entering into, and managing our relationship and agreements with you or your organization, including providing our services to you or your organization. 
  • Providing and optimizing your experience accessing or using the Services and ensuring that our content is presented to you in the most effective manner.
  • Responding to your inquiries and communicating with you, including regarding our services, our agreements with you or your organization, and other issues.
  • Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
  • Managing customer service issues, including issues relating to the performance of the Services, technical concerns, and related feedback.
  • Developing, updating, and improving our Services, customer service, and customer experience, and otherwise improving our knowledge and insights regarding potential education services or those who partner with us for our services.
  • Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Services or the use of our services.
  • Enforcing our agreements, complying with our legal or regulatory obligations, and defending or advancing legal claims.
  • Notifying you about changes to the Services, our business, or material changes to this Policy.
  • Providing you with surveys or otherwise soliciting feedback from you.
  • Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Personal Information” below.

Our Marketing Efforts

We may send you direct marketing communications from time to time including news, updates, offers, and other announcements relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe from our marketing communications using the functionality in the communication you have received or by contacting us at the information below.

Disclosure of Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

In addition, we may share your information with the following types of entities:

  • Business partners, service providers, and third-party vendors necessary for the performance of any contract we enter into with you. For example, we may share your personal information with our IT and system administration providers, cloud hosting providers, customer service software providers, and payment processors.
  • Other users of the Services who have access to personal information you have posted or shared in a public forum or user-accessible means via the Services or expressly requested that we provide to other users, such as award providers receiving applications or contributors asked to submit applicant information.
  • Marketing and advertising vendors that may assist with lead generation, hosting information relating to potential scholarship providers and potential users of our services, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
  • Analytics vendors in order to understand the Services traffic and usage patterns, optimize the Services, and identify potential new partners or users of our services.
  • Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
  • Our professional advisors, such as lawyers, accountants, and other similar advisors, or investors who have a need to know the information.
  • Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
  • Other parties for any purpose we disclose at the time you provide the information.

Protection of Personal Information

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification.  Please be aware that no data transmission over the Internet is 100% secure.  While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Your Choices About Personal Information

We respect your right to make choices about the ways we collect, use, and disclose your information.  We try to offer you meaningful choices regarding your personal information.  Some choices you have regarding personal information include the following.

  • Marketing Emails – As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “unsubscribe” or similar link in any such promotional emails and following the instructions provided.
  • Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies.  Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same.  Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Services.
  • Google Analytics and Google Ads – As discussed above, we use Google Analytics and other Google tools in connection with the Services.  If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use.  You can find more information on how Google uses information it collects here.
  • Declining to Provide Information – You can choose not to provide us with information we may request through the Services, but that may result in you being unable to use certain features of the Services, request information about our Services, or initiate other transactions with us.
  • Do Not Track Mechanisms – Please note thatthe Services does not honor “Do Not Track” signals, and such signals will not impact the operation of the Services. 
  • Jurisdiction-Specific Choices—Please review the “Rights Afforded to Certain Individuals” section below to learn more about the choices that may be available to you based on where you reside.

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.

Rights Afforded to Certain Individuals

  1.  California Residents

California Civil Code § 1798.83 (California’s Shine the Light Act) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

  1. Notice for Nevada Residents

Under Nevada law, Nevada “consumers” may request that “operators” of internet sites and online services refrain from the “sale” of their “covered information” to third parties (as such terms are defined under Nevada law).  “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online.  As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and service of interest to you and in the other ways described above.  We do not believe that our sharing in this regard would qualify as a sale under Nevada law. 

  1. Canadian Residents

If you reside in Canada, various Canadian laws, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), may provide you certain rights with respect to your personal information, including the right to request information about the collection, use, or disclosure of your personal information, to request access to your personal information, and to challenge the accuracy and completeness of your personal information and have it amended as appropriate.

If you are a Canadian resident and would like to make a request regarding your personal information, please send a request to privacy@mykaleidoscope.com with the subject line, “Canada Resident Request,” or otherwise contact us using the information in the “How to Contact Us” section below. We will attempt to respond to your request as quickly as possible but may ask you to provide additional information to enable us to locate the personal information or determine how it has been used or disclosed. We will provide you access, as appropriate, at minimal or no cost to you.

  1. EU/UK Residents
    1. Rights under GDPR

The European Union’s General Data Protection Regulation and the United Kingdom’s version of the same (collectively, the “GDPR”) afford certain rights to individuals in the European Economic Area (“EEA”).  If you are in the EEA, United Kingdom, or Switzerland you have the following rights.  Note, however, that not all rights apply in all circumstances.

  • Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you
  • Right to rectify your personal information: if you discover that the information, we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).
  • Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute, and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
  • Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
  • Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
  • Right to data portability: you have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.

With regard to the personal information discussed in this Policy, we are typically the “data controller” for such information under the GDPR.  As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to privacy@mykaleidoscope.com with the subject line, “GDPR Request.”  This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond.  Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months.  Please note that we may need to request specific information from you to help us confirm your identity.  If you are located in the EEA, UK, or Switzerland and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA, UK, or Switzerland. 

  1. Lawful Basis under GDPR

We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so.  We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.

Purpose/ActivityType of Information Basis of Processing
To enter into and subsequently to manage our business relationship with you or your company, including: Negotiating, entering into, and performing agreements with your company Responding to inquiries and providing customer support and serviceManaging and processing transactions for our servicesNotifying you about changes to our website, business terms, or this PolicyCommunicating with you and responding to your inquiries regarding our services, agreements with you or your company, and other issuesContact Information
Award Information
Communications Information
Financial Information
Technical Support Information		Necessary for our legitimate interests (to manage our business relationships and administer our operations including through the keeping of appropriate records)Performance of a contract with youNecessary to comply with legal obligations

To administer our business of providing scholarship related software and services: Processing applications for various awardsFacilitating the process of an award, including depositing awards into recipients’ financial accountsContact Information
Academic Information
Employment History or Information
Demographic Information
Application-Related Information
Award Information
Financial Information		Necessary for our legitimate interests (to manage our business relationships and administer and facilitate our operations including our professional and software services)Performance of a contract with you
To administer and protect our business and website including: Maintaining business records for legal purposes and to comply with tax requirements Defending and advancing legal claims Enforcing our rights under any agreements Ensuring effective security for our services and website Conducting website maintenance  Identify and address security risks and unlawful activityContact Information
Award Information
Financial Information
Technical Support Information
Communications Information
Device and Usage Information		Necessary for our legitimate interests (running our business, facilitating administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)Necessary to comply with legal obligations
To make decisions about how best to deliver relevant website content and advertisements to you, and otherwise market to you, and to better understand the effectiveness of our marketing effortsMarketing Information
Award Information
Communications Information
Device and Usage Information		Necessary for our legitimate interests (better understanding website functionality and how website users navigate and interact with the site)
To advance and promote our business interests including contacting you regarding products, services, or promotions that may be of interest to your company, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our products/services, customer service, and marketing effortsContact Information
Marketing Information
Award Information
Device and Usage Information  		Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business)
  1. Transfers from EEA, Switzerland, or UK

If we transfer personal information from the EEA, United Kingdom, or Switzerland to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the European Commission (such as the United States), we will rely on Standard Contractual Clauses (SCC) that have been approved by the European Commission as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors that contain SCCs and define data protection standards to be employed by each (sub)processor.

International Transfers

Kaleidoscope is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations located in the United States.  You understand and consent that information you provide may be transferred to the United States.  You also understand that the data protection laws in the United States may be different from those of the country where you reside.  When we transfer personal information to the United States, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.

Links to Third-Party Websites

The Services may contain links to third-party websites. For example, the Services may link out to an article on a third-party news source or publisher website. Such websites have separate privacy policies that you should review.  We do not control these third-party websites and are not responsible for the content of linked websites or those companies’ data-handling practices.

Children’s Privacy

For more information about how we collect, use, and disclose the personal information of children under the age of 13, please review our Children’s Privacy Policy.

Changes to this Policy

Please note that we may change this Policy from time to time.  If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the Services after any changes is deemed to be acceptance of those changes.  Accordingly, we encourage you to check the Policy periodically for updates.

How to Contact Us

For questions or more information about our privacy practices, please contact us by e-mail at privacy@mykaleidoscope.com or by using the contact information provided below:

Kaleidoscope Group, PBC
212 3rd Ave N
Suite 318
Minneapolis, MN 55401

Last updated: January 3, 2020

Kaleidoscope Group, PBC (“us”, “we”, or “our”) operates the https://www.mykaleidoscope.com website (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.mykaleidoscope.com

Definitions

  • Service is the https://www.mykaleidoscope.com website operated by Kaleidoscope Group, PBC
  • Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
  • Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Cookies are small pieces of data stored on your device (computer or mobile device).
  • Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
  • Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
  • Data Subject (or User) is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

Kaleidoscope Group, PBC uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Kaleidoscope Group, PBC legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Kaleidoscope Group, PBC may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it’s not overridden by your rights
  • To comply with the law

Retention of Data

Kaleidoscope Group, PBC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Kaleidoscope Group, PBC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Kaleidoscope Group, PBC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, Kaleidoscope Group, PBC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Kaleidoscope Group, PBC may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Kaleidoscope Group, PBC
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

“Do Not Track” Signals Under California Online Privacy Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Kaleidoscope Group, PBC aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Kaleidoscope Group, PBC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing

Kaleidoscope Group, PBC uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

  • Google AdWords remarketing service is provided by Google Inc.You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Especially For Children Under 13

1. Our collection of personal information on Platforms that are directed to children under 13 (“Children’s Platforms”) is intended to follow the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children under the age of 13.
2. We will obtain parental consent before asking for personal information on our Children’s Platforms, unless the request for information falls within an exception that would be permitted under COPPA.
3. We do not make personal information collected from children publicly available nor do we enable children to do so on our Platforms. We will not condition a child’s participation in any activity or service on the disclosure of more personal information than is reasonably necessary to participate in an activity.
4. Parents may contact us (at help@mykaleidoscope.com) to review, update or delete any of their children’s personal information that we may have collected and to elect for us not to collect any additional personal information from their children.
5. We will update this Privacy Policy from time to time by posting the updated Privacy Policy online. We will not change how we handle previously collected information without providing notice and obtaining parental consent where necessary.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective, and update the “last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

Cookies Policy

Last updated: January 3, 2020

Kaleidoscope Group, PBC (“us”, “we”, or “our”) uses cookies on the https://www.mykaleidoscope.com website (the “Service”). By using the Service, you consent to the use of cookies.

Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies

Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.

Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

How Kaleidoscope Group, PBC uses cookies

When you use and access the Service, we may place a number of cookies files in your web browser.

We use cookies for the following purposes:

  • To enable certain functions of the Service
  • To provide analytics

We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:

  • Essential cookies. We may use cookies to remember information that changes the way the Service behaves or looks, such as a user’s language preference on the Service.
  • Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them.

Third-party cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

What are your choices regarding cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

Where can you find more information about cookies

You can learn more about cookies and the following third-party websites:

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