PRIVACY POLICY
Effective Update: December 1, 2023

Kaleidoscope Compass (“us”, “we”, or “our”) operates the www.KaleidoscopeCompass.com website and the KaleidoscopeCompass mobile application (hereinafter referred to as the “Service”).

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

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

DEFINITIONS

Service
Service means the www,KaleidoscopeCompass.com website and the Kaleidoscope Compass mobile application operated by Kaleidoscope Compass

Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small files stored on your device (computer or mobile device).

Data Controller
Data Controller means the natural or legal person who (alone or jointly or in common with other persons) determines the purposes for which and how personal information is processed. For this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively.

Data Subject (or User)
Data Subject is any living individual using our Service and is the subject of Personal Data.

 Information Collection and Use
We collect various types of information to provide and improve our Service.

Types of Data Collected

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

Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any or all communications from us by following the unsubscribe link or the instructions provided in any email we send.
Usage Data
– We may also collect information your browser sends whenever you visit our Service or access the Service through a mobile device (“Usage Data”).
– This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
– When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, the kind of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking & Cookies Data
– We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
– Cookies are files with a small amount of data, which may include an anonymous unique identifier.
– Cookies are sent to your browser from a website and stored on your device. Other tracking technologies such as beacons, tags, and scripts are also used to collect and track information and to improve and analyze our Service.
– You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may be unable to use some portions of our Service.

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

Use of Data
Kaleidoscope Compass uses the collected data for various purposes:
– To provide and maintain our Service
– To notify you about changes to our Service
– To allow you to participate in interactive features of our Service when you choose to do so
– To gather analysis or valuable information so that we can improve our Service
– To monitor the usage of our Service
– To detect, prevent, and address technical issues
– To provide you with news, special offers, and general information about other goods, services, and events that we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

OUR COMMITMENT TO DATA PROTECTION LAWS

Privacy regulation is changing. We know you must select products that comply with all applicable data protection laws and use personal data in compliant ways. Learn more about how Google is complying with specific privacy laws below.

GDPR

The General Data Protection Regulation (EU GDPR) went into effect on May 25, 2018, replacing the 1995 EU Data Protection Directive. On January 1, 2021, the retained EU law version of the EU GDPR went into effect in the UK (UK GDPR). The EU GDPR and the UK GDPR (together, the GDPR) lay out specific requirements for businesses and organizations under the EU GDPR that are established in Europe or who serve users in Europe and who, under the UK GDPR, are established in the UK or who serve users in the UK. The GDPR regulates how businesses collect, use, and store personal data.

Legal Basis for Processing Personal Data under the General Data Protection Regulation
If you are from the European Economic Area (EEA), Kaleidoscope Compass’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Kaleidoscope Compass may process your Personal Data because:
– We need to perform a contract with you
– You have permitted us to do so
– The processing is in our legitimate interests; your rights do not override it.
– To comply with the law

Retention of Data
Kaleidoscope Compass will retain your Personal Data only as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
– Kaleidoscope Compass will also retain Usage Data for internal analysis purposes. Usage Data is generally kept for a shorter period, except when this data is used to strengthen security or improve the functionality of our Service, or we are legally obligated to retain this data for more extended periods.

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

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

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

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

US States Privacy Laws
New data protection laws, which apply to the collection and processing of personal information, will be coming into effect in California, Colorado, Connecticut, Virginia and Utah in 2023.

Restricted data processing & service provider terms
Restricted data processing is intended to help advertisers, publishers, and partners meet their own compliance needs. When you enable restricted data processing, Google restricts how it uses certain data to only undertake certain activities.

We are also offering service-provider and processor terms to help advertisers, publishers and partners prepare for these laws. In certain circumstances, we will act as your service provider (or processor) in handling data processed while restricted data processing is enabled. You should review these terms carefully to ensure they meet your compliance needs. Restricted data processing operates differently across our products.

Advertisers, publishers, and partners should ensure that the use of Google products and services, including restricted data processing, meets their compliance requirements. In some products, restricted data processing can be enabled for all users in applicable US states, or only for those users who an advertiser, publisher, or partner indicates should have it enabled.

Advertisers and publishers should evaluate their use of Google products and services, including restricted data processing, with their legal advisors, to determine their compliance requirements. Please see this article to learn more about restricted data processing.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

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

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

These third-parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
• We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network.
– For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privac hl=en

Links to Other Sites
– Our Service may contain links to other sites that we do not operate. If you click a third-party link, you will be directed to the third-party site. We strongly advise you to review every site’s privacy policy. We have no control over and assume no responsibility for any third-party sites or services’ content, privacy policies, or practices.

Children’s Privacy
– Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

LGPD
The Lei Geral de Proteção de Dados (LGPD) is a new Brazilian privacy law that took effect on September 18, 2020. While enforcement powers by the Brazilian DPA are postponed to August 1, 2021, the LGPD can still be enforced by other governmental authorities, such as public prosecutors and consumer protection agencies, who can apply sanctions based on the Civil and Consumer Protection Code.

Terms & contractual protections
Google already offers data protection terms for its Ads products under the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). We will update those existing Ads data protection terms to add LGPD-specific terms. Google’s status under the LGPD as either a controller or processor for each Ads product will be the same as under the GDPR. The LGPD terms will be incorporated into our existing Ads data protection terms, so no action is required to accept the LGPD terms where the existing Ads data protection terms already form part of your contract. If your existing contract does not incorporate our existing Ads data protection terms, please review the product-specific Help Centers in Resources for Advertisers and Publishers for more information on how to accept the terms in the relevant Ads product UI.

COMPANY RIGHTS

Changes to This Privacy Policy
– We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
– We will inform you via email and/or a prominent notice on our Service before the change becomes effective and update the “effective date” at the top of this Privacy Policy.
– You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us
If you have any questions about this Privacy Policy, please contact us:
– By email: marcy@KaleidoscopeCompass.com
– By mail: Kaleidoscope Compass LLC
519 W. Taylor St., #307
Santa Maria, CA 93458