This Policy is incorporated into, and is subject to, the Send Koala Terms & Conditions. Capitalized terms used but not defined in this Policy have the meaning given to them in the Send Koala Terms & Conditions.
We collect different types of information from or through the Service. The legal bases for Send Koala’s processing of Personal Data are primarily that the processing is necessary for providing the Service in accordance with our Terms of Service and that the processing is carried out in Send Koala’s legitimate interests, which are further explained in the section “How do we use your information?” of this Policy. We may also process data upon your consent, asking for it as appropriate.
When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mobile phone number, and credit card or other billing information. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with other users of the Service through communication or messaging capabilities, or send us customer-service related requests.
A Client or User may store or upload into the Service Client Data. Send Koala has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.
When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device by using various types of technology, including cookies, “pixels” or “web beacons”. This automatically collected information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with email messages, such as whether the Visitor or User opens, clicks on, or forwards a message. This information is gathered from all Users and Visitors.
We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.
We use the information – other than Client Data – to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.
From time to time, Send Koala may partner with other companies to jointly offer products, services or programs (such as webinars or downloadable content) such as our channel partners to fulfill product trials and information requests, and provide customers and prospective customers with information about Send Koala and its products. To do this, we may pass your information to them for that purpose only, and they are prohibited from using that information for any other purpose. Send Koala does not share Data about the Send Koala attendees with business partners unless: (1) you specifically opt in to such sharing via an event registration form; or (2) you attend a Send Koala event and allow the Send Koala or any of its business partners to scan your attendee badge. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms and elect not to have your badge scanned at Send Koala events. If you choose to share your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements. Send Koala may also use Data about customers and webinar attendees for marketing purposes. For example, Send Koala may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding Send Koala, its affiliates, and its partners, such as information about promotions or events.
We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, features, and functionality.
Send Koala may share Data about Send Koala website visitors, customers and webinar attendees with Send Koala’s contracted service providers so that these service providers can provide services on our behalf. These service providers are authorized to use your personal information only as necessary to provide the requested services to us. Without limiting the foregoing, Send Koala may also share Data about Send Koala website visitors, customers and webinar attendees with Send Koala’s service providers to ensure the quality of information provided, and with third–party social networking and media websites, such as Facebook, for marketing and advertising on those websites. Unless described in this Privacy Statement, Send Koala does not share, sell, rent, or trade any information with third parties for their promotional purposes.
Send Koala may also disclose your personal information if required to do so by law or in the good faith belief that such action is necessary in connection with a sale, merger, transfer, exchange or other disposition (whether of assets, stock or otherwise) of all or a portion of a business of Send Koala and/or its subsidiaries or to (1) conform to legal requirements or comply with legal process served on Send Koala or this website; (2) protect and defend the rights or property of Send Koala and this website; (3) enforce its agreements with you, or (4) act in urgent circumstances to protect personal safety or the public.
We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us to [email protected] to make your request. At your request, we will have any reference to you deleted or blocked in our database.
You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service.
You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to [email protected].
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
Send Koala has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly. If the Client requests Send Koala to remove the data, we will respond to its request within thirty (30) days. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Client who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should be sent to [email protected] with email subject “Data Subject Request”, and include sufficient information for Send Koala to identify the Client or its customer or third party and the information to delete or amend.
In compliance with the Privacy Shield Principles, Send Koala commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Pearl Lemon ltd’s Data Protection Officer at [email protected] Pearl Lemon ltd commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to data transferred from the EU and Switzerland.
In any matters relating to the EU-U.S. and Swiss-U.S. Privacy Shield Framework, Send Koala is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Send Koala shall comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to our Customers, Send Koala acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Customers in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Send Koala Customer with whom you have a direct relationship.
An external PCI compliant payment gateway (BluePay and Paypal) handles all credit card transactions and we conduct regular vulnerability checks to prevent security issues.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted using industry-standard protocols and is transmitted via TLS/SSL technology. In case of data loss or security breaches, this helps us keep confidentiality, integrity and availability of our customers personal data.
In case of a security breach, we have the policy to do an immediate investigation of the incident and report to the competent data protection authority within 72 hours or less, and also notifying all the affected data subjects of a high-risk data breach incident.
The Service may contain features or links to web sites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We have not enabled Google AdSense on our site and we don’t plan to do so in future.
If you use Chrome Extensions or Google add-ons developed by Send Koala, we may collect data such as your name, email address, through connecting to your Google Account (with your consent). This information won’t be displayed to the public nor is it ever shared without your explicit consent. As of today, we don’t use login or signup based on your Google Account.
Send Koala’s use of information received from Gmail APIs will adhere to Google’s Limited Use Requirements as scoped in https://developers.google.com/terms/api-services-user-data-policy#additional-requirements-for-specific-api-scopes
The Service is hosted in the United States or Germany. Regardless of the database being hosted in the European Union, if you choose to use the Service from the EU or other regions of the world with laws governing data collection and use that may differ from US law, then please note that you may be transferring your Client Data and Personal Data outside of those regions to the United States for storage and processing by our service providers listed in the our Terms of Service. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to the US. Also, we may transfer your data to the US, the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
Send Koala does not own, control or direct the use of any of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. Send Koala is largely unaware of what Client Data is actually being stored or made available by a Client or User to the Service and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client and its Users.
The Client or the User is the data controller under the Regulation for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.
Send Koala is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User nor is Send Koala responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
The information gathered by these third parties is used to make predictions about your interests or preferences so that they can display advertisements or promotional material on this Site and on other sites across the Internet tailored to your apparent interests. The business partners and advertising networks that serve interest-based advertisements on the Services have limited access to a small amount of information about your profile and your device, which is necessary to serve you advertisements that are tailored to your apparent interests. It is possible that they may reuse this small amount of information on other sites or services.
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email or via in-site notification within 7 business days. We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
App’s use of information received, and App’s transfer of information to any other app, from Google APIs will adhere to Google’s Limited Use Requirements.
Last Updated on 1 January 2022.