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Privacy Policy

GLOBAL PRIVACY POLICY

Last Updated: 06/28/2024

 

This Global Privacy Policy (“Policy”) describes how Kalogon, Inc. (“Kalogon” “We” “Us” “Our”) collects, uses, processes, stores, and shares your personal information when you visit, use and/or access Our services offered on Our website www.kalogon.com (“Site”) and when you download and use Our mobile app (“App”) and your linked Kalogon’s packaged smart cushion product(s) (“Products”) to the App and its related services.  

 

It’s important that you understand how We collect and use your information. If you do not wish your information to be collected, used or disclosed as described in this Policy you should not use the Site or the App. You should read this page carefully and in full. Below are the main highlights:

  • We require your consent to collect and use your personal information as described in this Policy.

  • With your given consent, We collect and use your personal information to provide and improve the Site and App, to communicate with you and manage Our relationship with you, for your experience in using the Site and App, to monitor, administer, and protect the security and integrity of the Site and App, to develop, improve or enhance the Site, App and Our Products, and to meet Our legal obligations.

  • We do not knowingly collect any personal information from children under 13 years old. 

  • We do not sell your personal information to any third parties in exchange for any money, goods or services or for any other valuable consideration, or for their own use to directly advertise their own products or services to you. 

  • We may share some or all of your personal information with Our affiliates, Our trusted sales representative partners who market and sell Our Products on Our behalf, Our third-party services providers who assist Us to offer the services of the Site and App and fulfill Our legal obligations, and to your parent, legal guardian, conservator, authorized agent, caregiver, your clinician or other health care provider (as applicable) and/or under the circumstances described in this Policy. 

  • We will honor your legal rights and choices under the laws applicable to you and Us.

  • If you have any questions, you can contact Us by sending an email to privacy@kalogon.com.

Definitions

For purposes of this Policy, the terms below will have the meanings given to them when referenced elsewhere in this Policy.

Identifiable Personal Data” as it relates to you means information that specifically identifies you, such as your: name; alias, email address; mobile, telephone number; home address; mailing address; data of birth; government-issued identification number; social security number or equivalent government-issued ID; non-public education information (such as education level and school attended); and, occupation, professional or employment-related information. Identifiable Personal Data does not include any information about you that is available or accessible in the public domain. In certain jurisdictions and foreign countries, Identifiable Personal Data also excludes:

  • Business contact information you provide to Us via the Site or App in an employment or commercial context; and,

  • Pseudonymized, deidentified or aggregated data that does not specifically identify you and cannot reasonably be linked or restored to specifically identify you; and/or 

  • Information constituting “protected health information” as that term is defined by the United States Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, as amended from time to time (HIPAA) of which is governed and will be handled by Us in accordance with HIPAA.

 

Indirect Personal Data” as it relates to you means information that does not specifically identify you, such as your: IP address, cookie identifiers, pixel tags, device fingerprint, location, browsing history on the Site or App, device type and model, device ID, advertising ID, and log information. Indirect Personal Data does not include any data about you that is available or accessible in the public domain. In certain jurisdictions and foreign countries, Indirect Personal Data also excludes:

  • Pseudonymized, deidentified or aggregated data that does not specifically identify you and cannot reasonably be linked or restored to specifically identify you; and/or 

  • Information constituting “protected health information” as that term is defined by the United States Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, as amended from time to time (HIPAA) and shall be governed and handled by Us in accordance with HIPAA.

Personal Data” as it relates to you collectively means your Identifiable Personal Data, Indirect Personal Data and Sensitive Personal Data (defined below). 

 

Sensitive Personal Data” as it relates to you means Identifiability Personal Data you provided to Us and Indirect Personal Data We collect about you when use Our services offered on the Site or when you use the App in connection with your Kalogon packaged smart cushion, such as your: precise geolocation such that it can specifically identify within a radius of 1,750 feet of your device’s past or present location that is directly linked or is reasonably capable of being linked to identify you; racial or ethnic background; contents of your mail, email and text messages; biometric data; health information. Sensitive Personal Data but does not include information about you that is available or accessible in the public domain. In certain jurisdictions and foreign countries, Sensitive Personal Data also excludes: 

  • Pseudonymized, deidentified or aggregated data that does not specifically identify you and cannot reasonably be linked or restored to specifically identify you; 

  • Information constituting “protected health information” as that term is defined by the United States Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, as amended from time to time (HIPAA), which is governed and handled by Us in accordance with HIPAA and its associated laws, rules and regulations, and/or 

  • Biometric data consisting of a photograph recorded digitally or otherwise, an audio or video recording, data from a photograph or from an audio or video recording (unless the data was generated for the purpose of identifying you), and/or facial mapping or geometry (unless the facial mapping or geometry was generated for the purpose of identifying you).

Children Under 13

The Site and App are not directed to or intended for use by children under 13 years old. We do not knowingly collect Personal Data from children under 13. If We discover We have collected Personal Data from a child under 13 without the consent of the child’s parent or legal guardian, We will take steps to stop collecting and entirely delete the child’s Personal Data. If you believe We have collected Personal Data of your child who is under 13, please let Us know by sending an email to privacy@kalogon.com   


For more information about Children’s’ Online Privacy Protection Rule (“COPPA”), please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule

Third-Party Sites and Links

The Site and App may contain links, media or other content from third parties. These links are external resources, and the third parties have their own privacy policies that govern your visit to, access of and/or use of them. If you click on a third-party link, media or other content, you will be redirected to the third-party website. We do not own or control any third-party websites or mobile apps. We do not guarantee or warrant the adequacy of protection or other collection, use or data handling practices of any third-party website or mobile app. You should read the third-party’s policies about their privacy and security practices to learn what information they collect about you, why they collect it, how they use it, how they protect it, where they store it, who they share with it and why, and their transfer practices as those are the terms that will apply as between you and the third-party and not as between you and Us.

How We Collect Your Personal Data And Why

We collect your Personal Data that is relevant and reasonably necessary for the purposes described in this Policy, and We use, share, process, store, and hold that information for the purposes described in this Policy and in accordance with the laws applicable to you and Us.

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Additional Sources From Whom We May Collect Your Personal Data

In addition to “How We Collect Your Personal Data And Why” section in this Policy, We collect Your Personal Data from the following sources:

  • From your parent or legal guardian who has consented to Our collection, use, processing, storage and/or in exercising any of your other opt-in and/or opt out rights under the law applicable to you and Us; 

  • From your legal guardian or conservator who has consented to Our collection, use, processing, storage and/or in exercising any of your other opt-in and/or opt out rights available under the law applicable to you and Us; 

  • From your designated authorized agent who acts on your behalf to exercise any of your opt out rights under the law applicable to you and Us; and/or,

  • From your clinicians or other health care providers to whom you have authorized to share your health information with Us and/or act on your behalf to consent to and/or opt out of Our collection, use, processing, sharing, and storage of your information. 

Circumstances Where We May Disclose Your Personal Data

We may disclose some or all of your Personal Data when necessary for any one or more of the following:

  • To comply with applicable federal, state, local and foreign laws governing the collection, use, processing, sharing, and storage of your Personal Data to which We are subject to; 

  • To establish, enforce, exercise, and/or defend Our legal rights in any court, administrative, enforcement, or other proceeding;

  • To comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, and/or summons by any federal, state, local or foreign authorities and/or to cooperate with law enforcement agencies concerning conduct or activity that We or a third party has a reasonable and good faith belief may or does violate applicable law; 

  • To obtain and/or maintain insurance coverage, manage risks, and/or for obtaining professional advice;  

  • To collect, use, retain, process and/or disclose your Personal Data that is pseudonymized, deidentified or aggregated data; 

  • To provide a product or service you specifically request; 

  • To perform a contract, including taking steps at your request prior to entering a contract, between you and Us; 

  • To take immediate steps to the protect an interest that is essential for the life or physical safety of you or of any other individual, and where Our processing is not manifestly based on another legal basis; 

  • To prevent, detect, protect against, or respond to security incidents, fraud, harassment, malicious or deceptive activity, and illegal activity so as to preserve the integrity and security of the Site, App and Our systems and, when applicable, to investigate, report or prosecute those responsible for such events; 

  • To engage in public or peer-reviewed scientific or statistical research in the public interest that adheres to other applicable ethics and privacy laws and is approved, monitored, and governed by an institution review board or similar oversight entity; and/or, 

  • To assist another controller, processor or third-party with whom We have a contractual relationship with to perform their obligations under applicable laws. 

Specific Third Parties With Whom We Share Your Personal Data

We share some or all of your Personal Data to Our below third-party service providers who process your Personal Data on Our behalf to support Our business operations and growth, to make available and administer the Site and App, for the security and integrity of the Site and App, to communicate with you based on your previously given consent, to manage Our relationship with you, and to comply with Our legal and compliance obligations. When required by law, We obtain and maintain data processing agreements or addendums with Our third-party service providers.

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Categories of Third Parties With Whom We May Share Your Personal Data

In addition to the “Specific Third Parties With Whom We Share Your Personal Data” identified above, We may also share some or all of your Personal Data to the below categories of third parties for the below described business, commercial and/or legal purposes.

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Location Processing and Storage

Our operations are based in the United States and We store your Personal Data in data servers located in the United States. By sending Us your Identifiable Personal Data or identifiable Sensitive Personal Data via the Site or the App, you agree and consent to the processing of such data in the United States. Should We conduct any cross-border/international transfers of your Personal Data, We will do so in accordance with applicable laws and, to the extent required by law, with your express consent. 

How Long We Retain Your Personal Data

We retain your Personal Data for so long as is reasonably necessary to fulfill Our business for which We collected your Personal Data as described in this Policy and to comply with Our legal obligations. We take commercially reasonable steps to permanently and securely delete your Personal Data We collected and hold when (1) We have a legal obligation to do so, (2) We no longer have a business, commercial, or legal purpose to retain it, or (3) if you ask Us to delete it, except if We determine that doing so would impair or violate any of Our legal or contractual obligations. We may also decide to delete your some or all of your Personal Data if We believe it is incomplete, false, inaccurate or that Our continued storage is contrary to Our legal obligations. 

To the maximum extent permitted by, and in a manner consistent with applicable law, We may retain and use pseudonymized, deidentified, and aggregated data for Our internal analytical purposes, evaluation, research, and to otherwise support the operations and growth of Our business.  

How We Protect Your Personal Data

We implement and maintain commercially reasonable and acceptable industry standard administrative, physical and security measures to protect your Personal Data from being accessed, used, destroyed, altered, lost or deleted in an unauthorized manner. From time to time, We review Our security measures and conduct data risk assessments. However, no website, mobile app, electronic system, software, platform, server, database, electronic transmission or electronic media storage is 100% secure. Therefore, We cannot guarantee the security of your Personal Data electronically transmitted to or from the Site or App. Your use of the Site and App is at your own initiative and sole risk. If a data breach occurs that compromises your Personal Data, We will notify you when required by applicable laws.

Your Privacy Rights and Choices

You may have certain rights relating to your Personal Data depending on the data privacy laws of where you reside or of your citizenship, in each case as determined by the law of your state or country. Below We address:

  • The privacy rights of residents of each state in the United States with data privacy laws currently in effect and of states whose data privacy laws are coming into effect in the latter part of 2024 and in 2025 that We know of as of the date of this Policy, and 

  • The privacy rights of residents/citizens of foreign countries with data privacy laws currently in effect as of the date of this Policy where the Site and App is made available. 

 

In each case, We will honor your privacy rights and choices as required by the laws to applicable you and Us. 

 

Email communications: if you consented to receive Our emails, you have the right at any time, regardless of where you reside, to withdraw your consent. You can do so by clicking the “unsubscribe” link located at the bottom of Our email(s) sent to and you received from Us.

United States - State Specific Privacy Rights 

As to each state addressed below, We collect and process your Personal Data as described in the sections of this Policy titled:​

California Residents

Your Privacy Rights

As a resident of California, you have the below listed rights under the California Consumer Privacy Act, as amended (“CCPA”) that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data permitted by the CCPA and other applicable laws. If you are a person with a disability and have a legal guardian, We require your legal guardian’s verifiable consent to the collection and processing of your Personal Data. If you are a child between the ages of 13-16, We require your parent’s or legal guardian’s verifiable consent to the collection and processing of your Personal Data. 

  • Right to Know and Access: You have the right to request the categories of your Personal Data We collected and hold, the categories of sources from where We collected your Personal Data, Our business purpose for collecting, selling, and sharing your Personal Data, and the specific pieces of your Personal Data We collected. 

  • Right to Correct: You have the right to correct any inaccurate Identifiable Personal Data and identifiable Sensitive Personal Data you provided Us that We hold. 

  • Right to Delete: You have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations. 

  • Right to Revoke Consent: You have the right to revoke your previously provided consent to Our collection, use, sharing and processing of your Personal Data We collected and hold.  

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that specifically identifies you or can reasonably be linked or restored to specifically identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) your access to the App but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us. 

  • Right to Opt Out of Sharing for Targeted Advertising: You have the right to opt out of Our sharing your Personal Data with third parties for targeted advertising. To learn how, please see Our Cookies Policy

  • Rights to Opt Out of Sale or Sharing as to Children: We do not sell any Personal Data. We will not share any Personal Data of individuals of whom We actually know are between the ages of 13 to 16 years old without the consent of such child’s parent or legal guardian. 

  • Right to Limit Use and Disclosure of Sensitive Personal Data: You have the right to request that We limit Our use and disclosure of your Sensitive Personal Data to that which is necessary to provide Our services as requested by you. 

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your above rights.   

  • Right to Know What Personal Data We Sold or Shared: We do not sell your Personal Data, and you have the right to receive confirmation of this from Us. You also have the right to know with whom We shared your Personal Data and receive a list of: (a) the categories of your Personal Data shared and the categories of third parties to whom your Personal Data was shared, (c) by category or categories of your Personal Data for each category to whom your Personal Data was shared, and, (d) the categories of your Personal Data We disclosed for a business purpose and the categories of the third parties to whom it was disclosed for a business purpose.  As of the date of this Policy, We have shared the following categories of your Personal Data with Our below third-party service providers who support the operations and growth of the Site and/or App and your Kalogon smart cushion you linked to your App account:

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Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Legal Guardians and Conservators

If you are an adult with a legal guardian or conservator, such legal guardian or conservator may exercise any of your above rights subject to Our being able to verify their identity and authority to act on your behalf. 

Parents and Legal Guardians

If you are between the ages of 13-16 years old, your parent or legal guardian may exercise any of your above rights subject to Our being able to verify their identify and relationship to you. 

Request Submission Process  

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. Our response to any applicable exercisable right will cover the 12-month period preceding Our receipt of your verifiable request, unless you request a longer period subject to Our being able to do so. For any periods beyond the 12-month preceding period stated in the immediately preceding sentence, Our obligation shall only apply to Personal Data We collected and hold on or after January 1, 2022. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We have the right to verify your identity when you exercise any of your rights. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also that you provide Us with additional information to verify your identity, such as your name, address, and telephone number. If Our verification process is successful, We will honor your request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 90 days by notifying you within 45 days of your request and telling you why We require an extension. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. 

Extra Requests

If requests are manifestly unfounded, excessive, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs of providing you the information or communication or taking the action requested, or (2) deny your request and notify of Our decision and the reason(s).

 

Colorado Residents

Your Privacy Rights

As a Colorado resident, you have the below listed rights under the Colorado Privacy Act (“CPA”) that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the CPA and other applicable laws.   

  • Right to Know and Access: You have the right to know what Personal Data We collected and hold and receive a copy of that data.  

  • Right to Correct: You have the right to correct your Identifiable Personal Data and any identifiable Sensitive Personal Data that you provided Us and We hold. 

  • Right to Delete: You have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data We collected and hold, except from Our records We maintain to perform your deletion request, or to the extent We must retain the data to fulfill Our legal obligations under applicable laws.

  • Right to Withdraw Consent: You have the right to withdraw your previously provided consent to the collection, use and processing of your Personal Data We collected and hold.  

  • Right to Opt Out of Selling: We do not sell Personal Data and you have the right to receive confirmation of this from Us.

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent.

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected, hold and use to evaluate, analyze or predict personal aspects that directly identifies you or could reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to use a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Portability: You have the right to receive a securely transmitted copy of your Personal Data We collected and hold in an electronic format that you can access and transmit. 

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised. Within 45 days of Our receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s). We have a right to extend the 45-day period by an additional 60 days by notifying you within 45 days of receiving your appeal and telling you why We need additional time. 

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 
Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Legal Guardian

Your legal guardian or other legal representative may act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of such person to act on your behalf. 

Request Submission Process  

You may submit a request to exercise any of your above rights by by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so can contact that business.

Identity Authentication and Process 

We must be able to verify your identity when you exercise any of your rights. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also ask you for additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor your request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and telling you why We require additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. If We have a good faith, reasonable basis to believe that your right to opt out request is fraudulent, We have the right to deny your request and will notify you of Our decision and the reason(s). 

Extra Requests

For subsequent requests made in the same year or for requests that are manifestly unfounded, excessive, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs of providing the information or communication or taking the action requested or (2) deny your request and notify you of Our decision and the reason(s).

Connecticut Residents

Your Privacy Rights

As a Connecticut resident, the Connecticut Data Privacy and Online Monitoring Act (“CDPA”) provides you the below listed rights that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data permitted by the CDPA and other applicable laws. 

  • Right to Know and Access: You have the right to request whether We are or have processed your Personal Data of which We collected and hold and receive a list identifying the categories of Personal Data that We process or have processed.  

  • Right to Correct: You have the right to request that We update or correct your Identifiable Personal Data or identifiable Sensitive Personal Data you provided to Us of which We hold. 

  • Right to Delete: You have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data of which We collected and hold, except from Our records We maintain to perform your deletion request, or to the extent We must retain the data to fulfill Our legal obligations under applicable laws.  

  • Right to Withdraw Consent: You have the right to withdraw your previously provided consent to Our collection, use and processing of your Personal Data that We hold.  

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us. 

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt In for Targeted Advertising as to Children: We will not process the Personal Data for purposes of target advertising of children of whom We actually know are between 13 to 16 years old without the consent of the child’s parent or legal guardian.

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected, hold and use to evaluate, analyze or predict personal aspects that specifically identifies you or can reasonably be linked to specifically identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to use a Kalogon product and/or the App but only to the extent Our decision results in producing legal or similarly significant effects about you.

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your express consent.

  • Right to Portability: You have the right to receive a securely transmitted copy of your Personal Data We collected and hold in an electronic format that you can access and transmit. 

  • Right to Appeal: You have the right to appeal Our denial of any right you exercised. Within 60 days of Our receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s) for Our decision.  

  • Right to file Complain: If We deny your appeal, you have the right file a complaint with the Office of the Attorney General for Connecticut. For instructions, please visit: https://portal.ct.gov/ag/common/complaint-form-landing-page.

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agents

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Legal Guardians and Conservators

If you are an adult with a legal guardian or conservator, your legal guardian or conservator may exercise any of your above rights subject to Our being able to verify their identity and authority to act on your behalf. 

Parents and Legal Guardians of Children

If you are a child between the ages of 13 to 16 years old, your parent or legal guardian may exercise any of your above opt out exercisable rights, subject to Our being able to verify their identity and relationship to you. 

Request Submission Process

You may submit a request to exercise any of your above rights by by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so can contact that business.

Identity Authentication and Process 

We must be able to verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and telling you why We require additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. If We have a good faith, reasonable basis to believe that your right to opt out request is fraudulent, We have the right to deny your request and notify you of that decision and the reason(s) for Our decision. 

Extra Requests

For a second or any subsequent requests made in the same year, or for requests that are manifestly unfounded, excessive or repetitive, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request, or (2) refuse to act on the request and notify you of the reason(s) for Our decision. 

 

Delaware Residents

 

Your Privacy Rights: Effective 01/01/2025

As a Delaware resident, starting on January 1, 2025, the Delaware Personal Data Privacy and Consumer Protection Act (“DPCPA”) provides you the below listed rights that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the DPCPA and other applicable laws. 

  • Right to Know and Access: You have the right to request whether We are or have processed your Personal Data that We collected and hold along with a copy of that Personal Data and a list of the specific third-party recipients, or the categories of such third-party recipients, with whom We shared Your Personal Data. 

  • Right to Correct: You have the right to request that We correct any of your Identifiable Personal Data or any identifiable Sensitive Personal Data you provided Us. 

  • Right to Delete: You may have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data, except from Our records We maintain to perform your deletion request, or to the extent We must retain the data to fulfill Our legal obligations under applicable laws.   

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us. 

  • Right to Opt In for Targeted Advertising As to Children: If you are between the ages of 13 and 17 years old, We will not process your Personal Data for targeted advertising purposes without your parent’s or legal guardian’s consent. 

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data that We collected, hold and use to evaluate, analyze, or predict personal aspects related to your economic situation, health, demographic characteristics, personal preferences, interests, reliability, behavior, location, or movements, but only to the extent that Our decision produces legal or similarly significant effects about you. 

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your, or your parent’s or legal guardian’s, as applicable, consent. 

  • Right to Withdraw Consent: You have the right to withdraw your previously provided consent to Our collection, use and processing of your Personal Data of which We hold. We will honor that request within 15 days of Our receipt.  

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised. Within 60 days of receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s). 

  • Right to Portability: You have the right to receive a securely transmitted copy of your Personal Data We collected and hold in an electronic format that you can access and transmit. 

  • Right to Complain: If We deny your appeal, you have the right to contact the Department of Justice for the State of Delaware and file a complaint. To learn how, please visit: https://attorneygeneral.delaware.gov/fraud/cmu/complaint/.

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Legal Guardian and Conservators

If you are an adult with a legal guardian or conservator, such legal guardian or conservator may exercise any of your above rights subject to Our being able to verify their identity and authority to act on your behalf. 

Parents and Legal Guardians 

If you are a child between the ages of 13 and 17 years old, your parent or legal guardian may exercise any of your above rights subject to Our being able to verify their identity and relationship to you.

Request Submission Process

You may submit a request to exercise any of your above rights by by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so can contact that business.

Identity Verification and Process 

We must be able verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and tell you why We need additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. If We have a good faith, reasonable basis to believe that your right to opt out request is fraudulent, We have the right to deny your request and notify you of Our decision and the reason(s). 

Extra Requests

For subsequent requests made in the same year or for any requests that are unfounded, excessive or repetitive, We may either (1) charge you a reasonable fee based on the administrative costs to comply with your request or (2) deny your request and notify of Our decision and the reason(s).    

 

Iowa Residents

Your Privacy Rights: Effective 01/01/2025

As a resident of Iowa, starting on January 1, 2025, the Iowa Consumer Data Protection Act (“OCDPA”) provides you the below listed rights that you may exercise twice a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data permitted by the OCDPA and other applicable laws. 

 

  • Right to Know and Access: You have the right to request whether We are or have processed your Personal Data of which We collected and hold and receive a list that identifies your Personal Data that We process or have processed. 

  • Right to Delete: You may have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data that We hold, except from Our records We maintain to perform your deletion request, or to the extent We must retain the data to fulfill Our legal obligations under applicable laws.

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us.  

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent.

  • Right to Portability: You have the right to receive a securely transmitted copy of the Personal Data We collected and hold about you in an electronic format that you can view and transmit. 

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Request Submission Process

You may submit a request to exercise any of your above rights by by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 90 days of receiving your verifiable request. To the extent required, We have a right to extend this 90-day period by another 45 days by notifying you within 90 days of Our receiving your request and tell you why We require additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. 

Extra Requests

For any subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive, technically unfeasible, repetitive, or if We reasonably believe that your request is not for the primary purpose of exercising the right, We may either (1) charge you a reasonable fee based on the administrative costs to comply with your request or (2) deny your request and notify you of Our decision and the reason(s). 

 

Maryland Residents

 

Your Privacy Rights: Effective 10/1/2025

As a Maryland resident, starting on October 1, 2025, the Maryland Online Data Privacy Act (“MODPA”) provides you with the below listed rights that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the MODPA and other applicable laws. If you are a person with a disability and have a legal guardian, We require your legal guardian’s verifiable consent to the collection and processing of your Personal Data.

 

  • Right to Know and Access: You have the right to request whether We are processing your Personal Data that We collected and hold, receive a copy of that data, and a list of the categories of third parties to whom We disclosed your Personal Data. 

  • Right to Correct: You have the right to request that We correct any of your Identifiable Personal Data or identifiable Sensitive Personal Data that you provided to Us of which We hold that is inaccurate. 

  • Right to Delete: You have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data that We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations. 

  • Right to Portability: You have the right to receive a securely transmitted copy of your Personal Data We collected and hold in an electronic format that you can view and transmit. 

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt In for Targeted Advertising As to Children: If We have actual knowledge that you are between the ages of 13 to 17 years old, We will not process your Personal Data without the consent of your parent or legal guardian.  

  • Right to Opt Out of Selling: We do sell your Personal Data and you have the right to receive confirmation of this from Us. 

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to use a Kalogon product and/or the App but only to the extent Our decision results in producing legal or similarly significant effects about you.

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised. Within 60 days of receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s) for Our decision. 

  • Right to File Complain: If We deny your appeal, you have the right to contact the Office of the Attorney General for the State Maryland and file a complaint. For information, please visit: https://www.marylandattorneygeneral.gov/Pages/CPD/complaint.aspx

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Legal Guardian and Conservators

If you are an adult with a legal guardian or conservator, such legal guardian or conservator may exercise any of your above rights subject to Our being able to verify their identity and authority to act on your behalf. 

Parents and Legal Guardians 

If you are a child between the ages of 13 and 17 years old, your parent or legal guardian may exercise any of your above rights subject to Our being able to verify their identity and relationship to you.

Request Submission Process

You may submit a request to exercise any of your above rights by by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above rights. To verify your identity, We may match it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and tell you why We need the additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. 

Extra Requests

For any subsequent requests made in the same year or for any requests are manifestly unfounded, excessive, technically infeasible, or repeated, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request, or (2) deny your request and notify you of Our decision and the reason(s).  

 

Montana Residents

Your Privacy Rights: Effective 10/01/2024

As a Montana resident, starting on October 1, 2024, the Montana Consumer Data Privacy Act (“MCDPA”) provides you with the below listed rights that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the MCDPA and other applicable laws. If you are a person with a disability and have a legal guardian, We require your legal guardian’s verifiable consent to the collection and processing of your Personal Data. 

 

  • Right to Access: You have the right to request a copy of your Personal Data that We collected and hold. 

  • Right to Correct: You have the to request that We correct your Identifiable Personal Data or identifiable Sensitive Personal Data of you provided to Us and We hold. 

  • Right to Delete: You may have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data that We hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations.   

  • Right to Revoke Consent: You have the right to revoke your previously provided consent to Our collection, use and processing of your Personal Data We collected and hold. 

  • Right to Portability: You have the right to receive a securely transmitted copy of your Personal Data We collected and hold in an electronic format that you can view and transmit. 

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us.

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) your access to the use of a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent.

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised. Within 60 days of Our receiving your appeal, We will inform of any action We took or did not take along with a written explanation of the reason(s).  

  • Right to Complain: If We deny your appeal, you have the right to contact the Office of Consumer Protection of Montana and file a complaint. For information, please visit: https://dojmt.gov/consumer/consumer-complaints/

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Legal Guardian and Conservators

If you are an adult with a legal guardian or conservator, such legal guardian or conservator may exercise any of your above rights subject to Our being able to verify their identity and authority to act on your behalf. 

Request Submission Process

You may submit a request to exercise any of your above rights by by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above rights. To verify your identity, We may match it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and tell you why We require additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. If We have a good faith, reasonable belief that your opt out request is fraudulent, We have the right to deny your request. In such a case, We will notify you and state the reason(s) for Our belief.

Extra Requests

For any subsequent requests made in the same year or for any requests are manifestly unfounded, excessive, technically infeasible, or repeated, We may either (1) charge a reasonable fee based on the administrative costs of comply with your request, or (2) deny your request and notify you of Our decision and the reason(s). 

 

Nebraska Residents

Your Privacy Rights: Effective 01/01/2025

As a Nebraska resident, starting on January 1, 2025, the Nebraska Data Privacy Act (“NDPA”) provides you with the below listed rights that you may exercise twice a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the NDPA and other applicable laws. 

 

  • Right to Know and Access: You have the right to know whether We process your Personal Data of which We collected and hold and receive a copy of that data. 

  • Right to Correct: You have the right to request We correct any inaccurate Identifiable Personal Data or identifiable Sensitive Personal Data you provided Us and We hold. 

  • Right to Delete: You may have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data that We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations.   

  • Right to Portability: You have the right to receive a securely transmitted copy of your Personal Data We collected and hold in an electronic format that you can view and transmit. 

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us.   

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) your access to the use of a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent.

  • Right to Appeal: You have the right to appeal Our denial of any right you exercised. Within 60 days of Our receipt, We will notify you of Our decision and the reason(s). 

  • Right to file Complain:  If We deny your appeal, you have the right to contact the Office of the Attorney General of Nebraska and file a complaint. For information, please visit: https://www.nebraska.gov/apps-ago-complaints/?preSelect=CP_COMPLAINT

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Legal Guardian and Conservators

If you are an adult with a legal guardian or conservator, such legal guardian or conservator may exercise any of your above rights subject to Our being able to verify their identity and authority to act on your behalf. 

Request Submission Process

You may submit a request to exercise any of your above rights by by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above rights. To verify your identity, We may match it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and tell you why We need additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity.  If We have a good faith, reasonable belief that your request is fraudulent, We have the right to deny your request and notify you of Our belief and tell you why.

Extra Requests

For a second or subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs of complying with your request, or (2) deny your request and notify you of Our decision and the reason(s). 

 

New Hampshire Residents

Your Privacy Rights: Effective 01/01/2025

As a New Hampshire resident, starting on January 1, 2025, the New Hampshire Expectation of Privacy Act (“NHEPA”) provides you with the below listed rights that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim certain legal exemptions as permitted by the NHEPA and other applicable laws. 

 

  • Right to Know and Access: You have the right to know whether We process your Personal Data We collected and hold and receive a copy of that data. 

  • Right to Correct: You have the right to request We correct any inaccurate identifiable Personal Data or identifiable Sensitive Personal Data you provided Us and We hold. 

  • Right to Delete: You have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data that We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations.   

  • Right to Revoke Consent: You have the right to revoke your previously provided consent to the collection, use and processing of your Personal Data that We collected and hold. We will honor your request within 15 days of Our receipt. 

  • Right to Portability: You have the right to receive a securely transmitted copy of your Personal Data We collected and hold about you in an electronic format that you can view and transmit. 

  • Right to Opt Out of Selling Your Personal Data: We do not sell your Personal Data and you have the right to receive confirmation of this from Us.  

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer ambassador or (b) your access to the use of a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you.

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent.

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised. Within 60 days of Our receiving your appeal, We will inform of Our decision and state the reason(s).  

  • Right to file Complain: If We deny your appeal, you have the right to contact the Office of the Attorney General of New Hampshire and file a complaint. For information, please visit: https://www.doj.nh.gov/consumer/complaints/index.htm

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Legal Guardian and Conservators

If you are an adult with a legal guardian or conservator, such legal guardian or conservator may exercise any of your above rights subject to Our being able to verify their identity and authority to act on your behalf. 

Request Submission Process

You may submit a request to exercise any of your above rights by by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above rights. To verify your identity, We may match it to your Identifiable Personal Information We have on file. We may also ask you for additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and tell you why We need additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity.  If We have a good faith, reasonable belief that your request is fraudulent, We have the right to deny your request and notify you of Our belief and the reason(s).

Extra Requests

For any subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs of complying with your request, or (2) deny your request and notify you of Our decision and the reason(s).

 

New Jersey Residents

Your Privacy Rights: Effective 04/15/2025

As a New Jersey resident, starting on April 15, 2025, the New Jersey Privacy Act (“NJPA”) provides you with the below listed rights that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data permitted by the NJPA and other applicable laws. If you a child between the ages of 13 to 17 years old, We require your parent’s or legal guardian’s consent to collect and use your Personal Data. 

  • Right to Know and Access: You have the right to know whether We disclosed any of your Personal Data that specifically identifies you or that could reasonably be linked or restored to specifically identify you to any third party and, if so, a list identifying the categories of those third parties who received your data limited to the prior 12 months of your request. 

  • Right to Correct: You have the right to request We correct any inaccurate Identifiable Personal Data or identifiable Sensitive Personal Data you provided Us. 

  • Right to Delete: You have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data that We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations.

  • Right to Revoke Consent: You have the right to revoke your previously provided consent to the collection, use and processing of your Personal Data that We collected and hold. We will honor your request within 15 days of Our receipt. 

  • Right to Know of Sale: We do not sell your Personal Data and you have the right to receive confirmation of this from Us.   

  • Right to Portability: You have the right to receive a securely transmitted copy of the Personal Data We collected and hold about you in an electronic format that you can view and transmit. 

  • Right to Opt In for Targeted Advertising as to Children: If We have actual knowledge that you are between the ages of 13 to 17 years old, We will not process your Personal Data for targeted advertising without your parent’s or legal guardian’s consent. 

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent. If We have actual knowledge that you are between the ages of 13 to 17 years old, We will not process your Sensitive Personal Data for targeted advertising without your parent’s or legal guardian’s consent. 

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to the use of a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised. Within 45 days of Our receiving your appeal, We will inform of Our decision and state the reason(s).  

  • Right to file Complain: If We deny your appeal, you have a right to contact the New Jersey Division of Consumer Affairs and file a complaint. For information, please visit: https://www.njconsumeraffairs.gov/Pages/Consumer-Complaints.aspx

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above rights. To verify your identity, We may match it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and tell you why We need additional time. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. If We have a good faith, reasonable belief that your request is fraudulent, We have the right to deny your request and notify you of Our belief and state the reason(s).

Extra Requests

For any subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs of complying with your request, or (2) deny your request and notify you of Our decision and the reason(s).

 

Nevada Residents

 

Your Privacy Rights

As a Nevada resident, you have the right under Nevada’s Security and Privacy of Personal Information Act to direct Us not to sell your Personal Data to third parties. For this purpose, We do not sell your Personal Data to any third party, and you have the right to receive confirmation of this from Us. You may submit a request to receive confirmation of this by sending an email to privacy@kalogon.com. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you submit a request to exercise your right. We may verify your identity by matching it to your Identifiable Personal Information you provided in your request against what We have in Our records. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 60 days of receiving your verifiable request. To the extent required, We have a right to extend this 60-day period by additional 30 days by notifying you with 60 days of Our receiving your verifiable request and telling you why We require the extension. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. 

 

Oregon Residents 

Your Privacy Rights: Effective 07/01/2024

As an Oregon resident, starting on July 1, 2024, the Oregon Consumer Privacy Act (“OCPA”) provides you with the below listed rights that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the OCPA and other applicable laws. If you are a person with a disability and have a legal guardian, We require your legal guardian’s verifiable consent to Our collection and processing of your Personal Data. Your legal guardian can also exercise any of other below listed rights, subject to Our being able to verify such person’s identity and authority to act on your behalf. 

  • Right to Know and Access: You have the right to request whether We are or have processed your Personal Data of which We collected and hold and request the categories of Personal Data that We process or have processed. 

  • Right to Correct: You have the right to request that We correct any of inaccurate Personal Data We collected and hold. 

  • Right to Revoke Consent: You have the right to revoke your previously provided consent to the collection, use and processing of your Personal Data that We collected and hold. We will honor your request within 15 days of Our receipt. 

  • Right to Delete: You may the right, under certain circumstances, to request that We permanently and completely delete your Personal Data that We hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations under.

  • Right to Portability: You have the right to receive a securely transmitted copy of the Personal Data We collected and hold about you in an electronic format that you can view and transmit. 

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us. 

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal​ Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to use a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your express consent.

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised. Within 45 days of receiving your appeal, We will inform you of any action We took or did not take and explain the reason(s).  

  • Right to Complain: If We deny your appeal, you have the right to contact the Oregon Department of Justice, Consumer Protection division and file a complaint. For information, please visit: https://www.doj.state.or.us/consumer-protection/contact-us/

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by notifying you within 45 days of your request and telling you why We require an extension. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required and We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. 

Extra Requests

Except for a request to verify that We corrected any inaccuracies you reported to Us or a request to verify the deletion of your Personal Data, for any subsequent requests made in the same year or for requests that are manifestly unfounded, excessive, technically infeasible, or repeated, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request, or (2) deny your request and notify you of Our decision and the reason(s).

 

Tennessee Residents

Your Privacy Rights: Effective 07/01/2025

As a resident of Tennessee, starting July 1, 2025, the Tennessee Information Protection Act (“TIPA”) provides you with the below listed rights that you may exercise twice in a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the TIPA and other applicable laws. If you are a person with a disability and have a legal guardian, We require your legal guardian’s verifiable consent to Our collection and processing of your Personal Data. Your legal guardian can also exercise any of other below listed rights, subject to Our being able to verify such person’s identity and authority. 

  • Right to Know and Access: You have the right to request whether We process your Personal Data We collected and hold, and a copy of that data. 

  • Right to Correct: You have the right to request that We correct inaccurate Personal Data We collected and hold.

  • Right to Delete: You may have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data We collected and hold, except from Our records We maintain to perform your deletion request, or to the extent We must retain the data to fulfill Our legal obligations.

  • Right to Portability: You have the right to receive a securely transmitted copy of the Personal Data We collected and hold about you in an electronic format that you can view and transmit. 

  • Right to Opt Out of Selling: We do not sell any of your Personal Data and you have the right to receive confirmation of this from Us.  

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to use a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your express consent.

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised.  Within 60 days of receiving your appeal, We will inform of any action We took or did not take and explain the reason(s) for Our decision. 

  • Right to File Complaint: If We deny your appeal, you have the right to contact the Office of the Attorney General of Tennessee and file a complaint. For information, please visit: https://www.tn.gov/attorneygeneral/working-for-tennessee/file-a-consumer-complaint.html

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your above rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by notifying you within 45 days of your request and telling you why We need additional time. If We cannot verify your identity, We have the right to deny your request.  If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity.

Extra Requests

For any subsequent requests made in the same year, or for any requests are manifestly unfounded, excessive, technically infeasible, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request, or (2) deny your request and notify you of Our decision and the reason(s).

 

Texas Residents

Your Privacy Rights: Effective 7/1/2024

As a Texas resident, starting on July 1, 2024, you have the below listed rights under the Texas Consumer Data Protection Act (“TCDPA”) that you may exercise twice a year.  However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the TCDPA and other applicable laws.

 

  • Right to Know and Access: You have the right to ask Us whether We process your Personal Data that We collected and hold and receive a copy of that data.  

  • Right to Correct: You have the right to request that We correct inaccurate Personal Data We collected and hold. 

  • Right to Delete: You may have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data of which We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations under applicable laws. 

  • Right to Portability: You have the right to receive a securely transmitted copy of the Personal Data We collected and hold about you in an electronic format that you can view and transmit. 

  • Right to Opt Out of Selling: We do not sell any of Your Personal Data and you have the right to receive confirmation of this from Us. 

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to the use a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent.

  • Right to Appeal: You have a right to appeal Our denial of any right you exercised. Within 60 days of receiving your appeal, We will inform you of Our decision and explain the reason(s).   

  • Right to File Complaint: If We deny your appeal, you have the right to contact the Attorney General of Texas and file a complaint. For information, please visit: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your opt out rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise your right. We may verify your identity by matching it to your Identifiable Personal Information you provided in your request against what We have in Our records. We may also ask you to provide your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and telling you why We require the extension. If We cannot verify your identity, We have the right to deny your request. If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. 

Extra Requests

For any subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive, or repetitive, We may either (1) charge a reasonable fee based on the administrative costs of performing your request, or (2) deny your request and notify you of Our decision and the reason(s).

 

Utah Residents

Your Privacy Rights

As a Utah resident, you have the below listed rights under the Utah Consumer Privacy Act (“UCPA”) that you may exercise once a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the UCPA and other applicable laws.

  

  • Right to Know and Access: You have the right to request if We process your Personal Data We collected and hold and receive a copy of that data.  

  • Right to Delete: You have the right request We delete your Personal Data We collected and hold, except from Our records We maintain to perform your deletion request, or to the extent We must retain the data to fulfill Our legal obligations. 

  • Right to Portability: You have the right to receive a securely transmitted copy of the Personal Data We collected and hold that you can view and transmit. 

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us.  

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Legal Guardians and Conservators

If you are an adult with a legal guardian or conservator, such legal guardian or conservator may exercise any of your above rights subject to Our being able to verify their identity and authority to act on your behalf. 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and telling you why We need additional time. If We cannot verify your identity, We have the right to deny your request.  If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. If We have a good faith, reasonable basis to believe your request is fraudulent, We have the right to deny your request and, in this case, We will notify you and state the reason(s) for Our belief. 

Extra Requests

For any subsequent requests made in the same year or for any requests that are excessive, repetitive, technically infeasible, manifestly unfounded, or if the individual making the request is believed or known to be as part of an organized effort to harass, disrupt, or impose an undue burden on the resources of Our business, We have the right to either (1) charge a reasonable fee based on the administration costs of complying with the request, or (2) deny your request and notify you of Our decision and the reason(s). 

 

Virginia Residents

 

Your Privacy Rights 

As a Virginia resident, the Virginia Consumer Data Protection Act (“VCDPA”) provides you with the below listed rights that you may exercise twice a year. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the VCDPA and other applicable laws.

 

  • Right to Know and Access: You have the right to know whether We process your Personal Data that We collected and hold and receive a copy of that data.  

  • Right to Correct: You have the right to ask that We correct any inaccurate Personal Data We collected and hold. 

  • Right to Delete: You have the right, under certain circumstances, to request that We permanently and complexly delete your Personal Data that We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations.  

  • Right to Portability: You have the right to receive a securely transmitted copy of the Personal Data We collected and hold about you in an electronic format that you can view and transmit

  • Right to Opt Out of Selling: We do not sell your Personal Data and you have the right to receive confirmation of this from Us. 

  • Right to Opt Out of Targeted Advertising: You have the right to opt out of Our processing your Personal Data for targeted advertising purposes. To learn how, see Our Cookies Policy

  • Right to Opt Out of Profiling: You have the right to opt out of the automated processing of your Personal Data We collected and use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to use of Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Appeal: You have the right to appeal Our denial of any right you exercised. Within 60 days of Our receiving your appeal, We will inform of any action We took or did not take and explain the reason(s). 

  • Right to File Complaint: If We deny your appeal, you have the right to contact the Office of the Attorney General of Virginia and file a complaint. For information, please visit: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint

  • Right of No Retaliation: We will not retaliate or discriminate against you for exercising any of your rights.  

 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business.

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request within 45 days of receiving your verifiable request. To the extent required, We have a right to extend this 45-day period by another 45 days by notifying you within 45 days of your request and telling you why We need additional time. If We cannot verify your identity, We have the right to deny your request.  If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. 

Extra Requests

For any subsequent requests made in the same year or for any requests that are manifestly unfounded, excessive or repetitive, We may either (1) charge a reasonable fee based on the administrative costs to comply with your request, or (2) deny your request and notify you of Our decision and the reason(s).

 

Foreign Countries – Country Specific 

As to each country addressed below, We collect and process your Personal Data as described in the sections of this Policy titled:

 

 

By using the Site or App, you acknowledge and agree to Our storing your Personal Data in the United States.

When required by law, if We intend to transfer your Personal Data to a third party overseas, We will provide you with advance notice along with the specific pieces or categories of your Personal Data to be transferred, the name and contact information of the recipient, and a method and procedure for you to opt out, object to, or withdraw your consent if you so wish.

 

Australia  

Under the Australia Privacy Act (“APA”), you have certain rights as to your Personal Data. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the APA and other applicable laws. 

If you are under the age of 15, We require your parent or legal guardian’s consent, and your parent or legal guardian may also exercise your other rights subject to Our being able to verify their identity and relationship to you. If you are a person with a physical or mental disability and have a legal guardian, We require your or your legal guardian’s verifiable consent to the collection and processing of your Personal Data and your legal guardian may exercise your other rights subject to Our being able to verify their identity and authority to act on your behalf. If you are a person with a limited understanding of the English language, We require the consent of your legal guardian, an individual who serves as your power of attorney, the “person responsible” for you (such as your spouse, partner, caregiver, family member or close friend), or the person who you nominate to act on your behalf; and, as to each, such persons can also exercise any of your other below rights so long as We are able to verify their identity and the authority to act on your behalf. 

  • Right to Know and Access:  You have the right to receive request whether We are processing your Personal Data and, if so, a copy of that data along with a description of the business purpose of Our processing, the categories of your Personal Data being processed, and a list identifying the recipients or categories of recipients to whom We have disclosed your Personal Data.

  • Right to Correct: You have the right to request We update or correct inaccurate, incomplete or out-of-date identifiable Personal Data or identifiable Sensitive Personal Data We collected and hold.  

  • Right to Delete: You have the right, under certain circumstances, to request We delete your Personal Data We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations.  

  • Right to Object: You have the right to object, under certain circumstances, to Our use or disclosure of your Personal Data, such as where Our use or disclosure is not necessary for any of Our business purposes or to comply with Our legal, regulatory or contractual obligations. 

  • Right to Withdraw Consent: You have the right to withdraw your previously provided consent to Our collection, use, or disclosure of your Personal Data at any time; however, your withdrawal will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your withdrawal.  

  • Right to Limit or Restrict Processing: You have right, under certain circumstances, to request that We limit or stop processing some or all of your Personal Data. 

  • Right to Opt Out of Direct Advertising: You have the right to opt out of receiving direct advertising from Us. You can Opt Out by selecting the “unsubscribe” link at the bottom of any of Our emails you received.  

  • Right to Portability: You have the right to receive a copy of your Personal Data We collected and hold in a readable format that you can access and transmit. 

  • Right to Complain: If you believe We mishandled your Personal Data, you have the right to complain to the Office of the Australian Information Commissioner by visiting: https://forms.business.gov.au/smartforms/servlet/SmartForm.html?formCode=APC_PC&tmFormVersion

 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com and We will respond to your request within a reasonable time of Our receipt of your verifiable request (typically within 30 days). Your Personal Data may be processed in responding to these rights. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business. If We are unable to honor your request, We will let you know why and the reason(s). Our response to your request will be provided free of charge. However, if We find your request to be vexatious, usually complex or requires a significant amount of time and resources for Us to fulfill, We have the right to charge you a reasonable fee based on the administrative costs to comply with your request, and in such case, We will let you know before We take any action to comply with your request and the amount of the fee to do so. If We are unable to honor your request, We will let you know and the reason(s).

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above rights. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business. If Our verification process is successful, We will honor the request. If We cannot verify your identity, We have the right to deny your request.

European Union, European Economic Area and United Kingdom

If you are located in the EU, the EEA or UK and We collect and hold your Personal Data, you have the below rights under the General Data Protection Regulations (“GDPR”). However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the GDPR and other applicable laws.

  • Right to Know and Access:  You have right to request whether or not We are processing your Personal Data We collected and hold, and, if so, receive a copy of that data along with a statement that describes Our business purposes for Our processing, lists the categories of your Personal Data We process, and lists the recipients or categories of recipients to whom We have disclosed or intend to disclose the data.  

  • Right to Correct: You have the right to request that We update, complete, or correct any of Identifiable Personal Data or identifiable Sensitive Personal Data you provided Us and We hold. 

  • Right to Erase: You have the right, under certain circumstances, to request that We permanently and completely delete your Personal Data We collected and hold, except from Our records We maintain to perform your deletion request or to the extent We must retain the data to fulfill Our legal obligations.  

  • Right to Object or Limit Processing: You have the right, under certain circumstances, to object to Our processing of your Personal Data We collected and hold (such as where We no longer have a business purpose or where the accuracy of your Identifiable Personal Data or identifiable Sensitive Personal Data is disputed as inaccurate but only during the period of time in which We can verify the accuracy of that data). 

  • Right to Withdraw Consent: You have the right to partially or entirely withdraw consent you have previously given to Us at any time; however, your withdrawal will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your withdrawal.  

  • Right to Portability: You have the right to receive a copy of your Personal Data you requested in a common, structured and readable format that you can access and transmit.  

  • Right as to Automated Processing: You have the right not to be subject to a decision based solely on the automated processing of your Personal Data We collected, including profiling, of which We use to evaluate, analyze or predict personal aspects that directly identifies you or can reasonably be linked to identify you and is in connection with (a) your application to become a Kalogon Flyer or (b) for your access to use a Kalogon product and/or the App, but only to the extent Our decision results in producing legal or similarly significant effects about you. 

  • Right to Complain: If you believe Our denial of any request you submitted to Us violates your rights or that We have mishandled your Personal Data in violation of your legal rights, you have the right to file a complaint with the applicable Supervisory Authority of the European Data Protection Board. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en

 

Transfer to Third Countries or International Organizations

We do not transfer your Personal Data to any third country or international organization that the EU Commission has determined does not have an adequate level of protection. To the extent We intend to make such a transfer, We notify you in advance and state the safeguards We will implement to protect your Personal Data.

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com  and We will respond within a reasonable time of Our receipt of your verifiable request (typically within 30 days). Your Personal Data may be processed in responding to your request. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business. If We are unable to honor your request, or if your request is unjustified or excessive, We will let you know why and the reason(s). Our response to your request is free of charge, unless We find your request to be unjustified or excessive and, in this case, We will notify you and state the fee. For additional copies, We may also charge you a fee based on the administrative costs of complying with your request and, in this case, We will know you in advance and the fee amount.  If We are unable to honor your request, We will let you know and the reason(s). 

Identity Verification and Process 

We must be able to verify your identity or the person you have authorized to act on your behalf as well as the authority of such person. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor your request. If We cannot verify your identity or the identify of your authorized person exercising your right, We have the right to deny the request.  

 

India

Under the India Digital Personal Data Protection Act (“DPDPA”), you have certain rights with respect to your Personal Data that We collect, process and hold as described here. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the DPDPA and other applicable laws.

If you are between the ages of 13 and 17 years old, We require your parent’s or legal guardian’s verifiable consent to the collection, use and processing of your Personal Data, and your parent or legal guardian may exercise your other rights subject to Our being able to verify their identity and relationship to you. If you are a person with a disability and have a legal guardian, We require your or your legal guardian’s verifiable consent to the collection and processing of your Personal Data, and your legal guardian can exercise your other rights subject to Our being able to verify your legal guardian’s identity and authority to act on your behalf. 

  • Right to Know and Access: You have the right to know whether We are processing your Personal Data that We collected and hold and receive a summary of (a) that data, (b) Our processing activities with respect to that data, and (c) the identity of third parties with whom We have shared your Personal Data along with a description of the Personal Data shared.

  • Right to Correct, Complete, Update and Erase: You have a right to request that We correct, update, complete or erase your some or all of your Personal Data We collected and hold, except from Our records We maintain to perform your request or to the extent We must retain the data to fulfill Our legal obligations. 

  • Right to Withdraw Consent: You have the right to withdraw your previously given consent at any time; however, your withdrawal will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your withdrawal.  

  • Right to Nominate: You have the right to nominate any other individual to exercise any of your above rights on your behalf in the event of your death, subject to Our being able to verify that person’s identity and authority to act on your behalf. 

  • Right to Complain: If you believe We have not honored any of your rights, you can submit a complaint to Us by sending an email to privacy@kalogon.com.  

 

Request Submission Process

You may submit a request to exercise any of your above rights by completing a request via email to privacy@kalogon.com and We will respond within a reasonable time of Our receipt of your verifiable request (typically within 30 days) and without undue delay. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient, so We process your request. Your Personal Data may be processed in responding to your request. If you are exercising a right that is the responsibility of another business, We will let you know so you can contact that business. Our response to your request is free of charge, unless We find your request to be false or frivolous in character and, in this case, We will notify you and state the reason(s) and the fee amount. If We are unable to honor your request for any other reason, We will let you know and why. 

Identity Verification and Process 

We must be able to verify your identity. As part of this process, We may verify your identity by matching it to your Identifiable Personal Information you provided in your request against what We have in Our records. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request. If We cannot verify your identity, We have the right to deny your request.

Japan 

Under the Japan Act on the Protection of Personal Information (“JAPPC”), you have certain rights with respect to your Personal Data that We collect, process and hold. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the JAPPC and other applicable laws.

 

  • Right to Know and Access:  You have the right to request whether We are processing any Personal Data about you of which We collected and hold, and, if so, a statement of whether that Personal Data can be used to specifically identify you. You also have the right to receive a copy of that data along with a description of the business purposes of Our processing and list of the recipients or categories of recipients to whom We have shared your Personal Data.

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent.

  • Right to Correct: You have the right to request We update or correct inaccurate Personal Data that is identifiable Personal Data and/or identifiable Sensitive Personal Data you provided to Us and We hold. 

  • Right to Delete: You have the right, under certain circumstances, to request that We permanently and completely delete your Identifiable Personal Data and/or identifiable Sensitive Personal Data that We hold, except that We may retain records of Our processing and performance of your deletion request, to fulfill Our legal obligations, and, if applicable, if your deletion request would be costly or prove difficult for Us then We will take necessary alternative and commercially reasonable measures to protect your Personal Data. 

  • Right to Object to Direct Marketing: You have the right to object to Our processing of your Personal Data We collected, hold and use for Our own direct marketing purposes. 

  • Right to Withdraw Consent: You have the right to partially or entirely withdraw consent you have previously given to Us at any time; however, your withdrawal will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your withdrawal.  

  • Right to Consent or Opt Out of Overseas Transfer: If We intend to transfer your Personal Data to a third party overseas, We will notify you in advance and provide you with the choice to consent or opt out of having your Personal Data transferred, including information about the measures We use to securely transfer your Personal Data, the pieces of your Personal Data that does or can specifically identify you, the contact information of the overseas third party recipient, and how you can consent or opt out of the transfer. 

  • Right to Complain: If you believe We have not honored any of your rights, you can submit a complaint to Us by sending an email to privacy@kalogon.com

 

Request Submission Process

You may submit a request to exercise any of your above rights by completing a request via email to privacy@kalogon.com and We will respond within a reasonable time of Our receipt of your verifiable request (typically within 30 days). We have the right to charge you a reasonable fee based on the actual costs We incur to comply with your request and will let you know in advance if We intend to charge a fee and the fee amount. If your request is submitted in an incorrect manner or is deficient, We will notify you and tell you what additional information We need to process your request. If you are exercising a right that is the responsibility of another business, We will inform you so that you can contact that business. If We decide not to disclose all or part of your Personal Data, or if the Personal Data you request does not exist or it is difficult for Us to fulfill your request, We will notify you as promptly as possible. 

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request. If We cannot verify your identity, We have the right to deny your request.  If there is no reasonable method by which We can verify your identity to the degree of certainty required, We will state this in Our response and explain why We have no reasonable method by which We can verify your identity. 

 

Philippines

Under the Philippines Data Privacy Act (“PDPA”), you have certain rights with respect to your Personal Data that We collect, process and hold as described here. However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the PDPA and other applicable laws.

 

  • Right to Know and Access:  You have the right to request whether or not We process your Personal Data and, if so, a description of that data and the purpose, scope and method of Our processing, the sources from where We obtained the data, the names and addresses of the third-party recipients or class of third-party recipients to whom We have disclosed the data and the reasons for the disclosure, whether any automated data about you will or likely will be solely used for any decision that significantly affects or will affect you, and the date of when your data was last accessed or modified. 

  • Right to Rectification: You have the right to request that We correct any inaccurate or wrong Personal Data We collected and hold, unless We determine your request is vexatious or otherwise unreasonable. If We fulfill your request, We will maintain, by accessible means, both the new and the retracted data and provide with you with a copy of the new and the retracted information as well as inform any third-party recipients who previously received the data and direct them to correct the data.  

  • Right to Object: You have the right to object to the processing of your Personal Data We collected and hold for direct marketing, automated processing or profiling purposes.  

  • Right to Withhold Consent: You have the right to withhold your consent to Our collection, use, processing and disclosure of all or any of your Personal Data.  

  • Right to Withdraw Consent: You have the right to partially or entirely withdraw your previously given consent at any time; however, your withdrawal will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your withdrawal.  

  • Right to Suspend, Withdraw, Block, Remove or Delete: You have the right to direct Us to suspend, withdraw or order the blocking, removal or deletion of your Personal from Our filing systems upon discovery and substantial proof that your Personal Data is incomplete, outdated, false, unlawfully obtained, used for unauthorized purposes or is no longer necessary for the purposes for which We collected it. In addition, your lawful heirs and assigns may exercise your rights for after your death or when you are incapacitated or incapable of exercising this right. In the case of deletion, We may retain records of Our processing and performance of this deletion request and to fulfill Our legal obligations.  However, your exercise of any of these rights will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your request as permitted by applicable laws.   

  • Right to Portability: You have the right to receive a copy of your Personal Data in a common readable and structured format that you can access and transmit.  

 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com and We will respond within a reasonable time of Our receipt of your verifiable request (typically within 30 days). If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. Your Personal Data may be processed in responding to your request. If you are exercising a right that is the responsibility of another business, We will let you know and direct you to contact that business. If your request is vexatious or otherwise unreasonable, We have the right to deny your request and, in this case, We will notify you and state the reason(s). If We are unable to honor your request for any other reason, We will let you know and the reason(s). 

Identity Verification and Process 

We must be able to verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request. If We cannot verify your identity, We have the right to deny your request and will notify you and tell you why.  

 

South Korea

You have certain rights under South Korea’s Data Protection Law (“SKDPL”). However, these rights are not absolute, and in certain cases We may deny your request and/or claim legal exemptions for certain types of Personal Data as permitted by the SKDPL and other applicable laws. 

  • Right to Consent: You have the right to decide whether or not to consent to the processing of your Personal Data and determine the scope of your consent to which We may process your Personal Data.  

  • Right to Know and Access: You have the right to know if We process your Personal Data We collected and hold and receive a copy of that data.  

  • Right to Correct: You have a right to request that We correct, update, or change your Identifiable Personal Data or identifiable Sensitive Personal Data you provided to Us and We hold.

  • Right to Delete: You have the right to request We delete your Personal Data We collected and hold, except that We may retain records of Our processing and performance of your deletion request and to fulfill Our legal obligations.

  • Right to Withdraw Consent: You have the right to withdraw your previously given consent at any time; however, your withdrawal will not affect the lawfulness of Our prior collection, use, processing or sharing of your Personal Data made prior to Our receipt of your withdrawal.  

  • Right to Opt In for Sensitive Personal Data: We will not process your Sensitive Personal Data without your consent.

  • Right to Withdraw Consent for Business Transfer: If We intend to transfer your Personal Data due to a business transfer (described in the “Categories of Third Parties With Whom We May Share Your Personal Data” section of this Policy), We will provide you with advance notice along with the name and contact information of the recipient and a method and procedure for you to withdraw consent if you so wish.

  • Right to Withdraw Consent for Overseas Transfer: You have the right to withdraw your consent with respect to the transfer of your Personal Data to an overseas recipient. In this case, if We intend to do so, We will provide with you advance notice along with the name and contact information of the recipient and a method and procedure for you to withdraw your consent if you so wish.  

 

Authorized Agent

You may designate another person to serve as your authorized agent to act on your behalf to exercise any of your opt out rights, subject to Our being able to verify the identity and authority of your designated authorized agent. 

Request Submission Process

You may submit a request to exercise any of your above rights by sending an email to privacy@kalogon.com and We will respond within 30 days of Our receipt of your verifiable request. If your request is submitted in an incorrect manner or is deficient, We will provide you with specific directions on how to submit the request in a correct manner or so that it is not deficient. Your Personal Data may be processed in responding your request. If you are exercising a right that is the responsibility of another business, We will direct you to contact that business. Our response is free of charge, unless We find your request to be manifestly unfounded, excessive or repetitive in character. If We are unable to honor your request, or before We charge a fee, We will let you know. 

Identity Verification and Process

We must be able verify your identity when you exercise any of your above listed rights. To verify your identity, We may match your information on your request it to your Identifiable Personal Information We have on file. We may also ask you to provide additional information, such as your name, address, and telephone number. If Our verification process is successful, We will honor the request. If We cannot verify your identity, We have the right to deny your request and, in this case, We will let you know and why. 

 

Governing Law and Forum

Except to the extent expressly stated in the immediately below paragraph, this Policy shall be governed by and construed in accordance with the internal laws of the State of Florida, without giving effect to any choice or conflict of law provision or rule. By accessing and/or using the Site or App, you accept and submit to the personal jurisdiction and exclusive venue of the courts located within Brevard County in the State of Florida to resolve any dispute or claim arising from or relating to this Policy.  

If you are a citizen of a country in the European Union, the governing law and forum shall be the laws and courts of your habitual residence. For citizens or residents of other foreign countries, if your country mandates that the governing law and forum be the laws and courts of your regular residence or citizenship, We will honor and comply with such law.

Changes to This Policy

We may add to, change, or otherwise update this Policy from time to time. We will post all changes to this Policy on this webpage. The updated policy will be effective as of the date it was posted. If We make material changes, We will let you know by emailing you to the email address you provided and/or alert you by a notice alter made directly within the App. Your continued use of this Site or App after the “Last Updated” date indicated at the top of this Policy will constitute your acceptance and agreement to any changes and to Our collection and use of your personal information according to the terms and condition of Our then-current Policy. If you do not agree with this Policy, you should not use the Site or App.

Contact Us

If you have any questions about this Policy, you may contact Us using any of the below contact details:    

 

By Mail: Kalogon, Inc., Attn: Tim Balz, Privacy Officer, 2412 Irwin Street Melbourne, Florida 32901, USA

By Email: privacy@kalogon.com 

By Telephone: +1 (312) 465-4504 during Kalogon’s normal business hours, Monday through Friday, 9:00 a.m. to 5:00 p.m. Eastern Standard Time (EST). 

Categories of Third Parties With Whom We May Share Your Personal Data
Specific Third Parties With Whom We Share Your Personal Data 
Circumstances Where We May Disclose Your Personal Data
Additional Sources From Whom We May Collect Your Personal Data
How We Collect Your Personal Data And Why
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