Effective Date: June 1, 2024

Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Kluz Venture’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

Privacy Policy Table of Contents

• What this Privacy Policy Covers
• Personal Data
• How We Share Your Personal Data
• Tracking Tools, Advertising and Opt-Out
• Data Security and Retention
• Personal Data of Children
• State Law Privacy Rights
• Changes to this Privacy Policy
• Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual, and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control, or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

The chart below details the categories of Personal Data that we collect and have collected over the past 12 months. We may also collect other categories of Personal Data that you choose to provide to us, such as when you email us or interact with free-form fields on our website.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us:

• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you use our chat features.
• When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically:

• Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
• From your IP address, which may identify your general geographic location (e.g., city/town, state).
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Third Parties

Social Networks

If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Executing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data.

Marketing the Services or Other Offerings

• Marketing and selling the Services or other offerings.
• Showing you advertisements, including interest-based or online behavioral advertising.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Compliance, Enforcement and Protection

• Complying with applicable laws, regulations, court orders or other legal processes.
• Preventing, detecting and investigating security incidents, fraud and other potentially illegal, harmful, unethical or prohibited activities.
• Protecting the rights, property or safety of you, Kluz Ventures or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section.

Service Providers. 

These parties help us provide the Services or perform business functions on our behalf. Examples include:

• Hosting, technology and communication providers.
• Support and customer service vendors.
• Email and other communications providers.
  • Some of our communications providers enable chat features that you can use to communicate with us. We and these providers may monitor, record and use information about pages visited, your IP address, your general geographic information (e.g., city, state), and other information you share through our chat features for the purposes described in this Privacy Policy. 
• Analytics services providers.
  • Some of our analytics services providers employ session replay technologies that employ software code to record users’ interactions with the Services in a manner that allows replays of those user sessions. The replays include users’ clicks, mouse movements, scrolls and keystrokes during those sessions. These replays help us diagnose usability problems and identify areas for improvement.
• Product fulfillment and delivery providers.

Advertising Partners.

These parties help us market our services and provide you with other offers that may be of interest to you. They include:

• Ad networks.
• Data brokers.
• Marketing providers.

Business Partners.

These parties partner with us in offering various services. They include:

• Businesses that you have a relationship with.
• Companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access or Authenticate

• Third parties you access through the services.
• Social media services.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Compliance, Enforcement and Protection” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above. 

Business Transfers

Your Personal Data that we collect may be transferred to a third party if we undergo or are undergoing a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part) or acquires some or all of our assets that include your Personal Data. We may also share your Personal Data with parties to such transactions (or proposed transactions) and their advisors while we are negotiating the transactions. Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for lawful business purposes, including to analyze, build and improve the Services and promote our business. We do not to attempt to reidentify de-identified information that we derive from Personal Data where prohibited by law, except that we may do so to test whether our de-identification processes comply with applicable law.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base, operate and improve our Services and facilitate advertising. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies:

Essential Cookies. Required for providing you with features or services that you have requested. For example, certain Cookies enable you to log in to secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

Functional Cookies. Used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Performance/Analytical Cookies. Allow us to understand how visitors use our Services. These Cookies do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses Cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

Retargeting/Advertising Cookies. Served by our advertising partners to help them collect data about your device and online activity on the Services and other online services so that they can provide advertising that they believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.” 

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. 

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

You can also opt-out of targeted advertising—and sharing personal information for the purposes of targeted advertising—by enabling the Global Privacy Control (GPC) for each participating browser system that you use or by clicking the Do Not Sell or Share My Personal Information link in the footer of our site. Learn more about GPC at the Global Privacy Control website: www.globalprivacycontrol.org.

Information about Interest-Based Advertisements

We may serve advertisements, and also allow advertising partners such as third-party ad networks, ad servers, ad agencies, ad technology vendors and research firms, to collect Personal Data about our users to serve advertisements to them through the Services and other online services or platforms. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers or advertising partners may deliver Cookies, including a file from an ad network to you through the Services. Web beacons enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

To make choices about Interest-Based Ads, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the Digital Advertising Alliance’s or Network Advertising Initiative’s consumer opt-out pages, which are located at www.aboutads.info/choices or http://www.networkadvertising.org/choices/, respectively. 

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services or fulfill the purposes for which we collected it as described in this Privacy Policy, such as to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable laws, rules or regulations. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

We do not knowingly collect or solicit Personal Data about children under 18 years of age. If you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please email us at info@kluzventures.comcom.

State Law Privacy Rights

Exercising Your Rights

The sections below describe the privacy rights that residents of the relevant states have under applicable law. Unless we specify a different request mechanism, requests to exercise these rights can be submitted by:

Emailing us at: info@kluzventures.com

Calling us at: 1-301-279-0002

The rights described above are not absolute, and, in certain cases, are subject to exemptions and limitations. We may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We need to verify your identity to process your requests to exercise your rights to Know, Access, Correction and Deletion described below, and we reserve the right to confirm your state residency. 

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.

Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers in our capacity as their service provider or processor. If we are processing your Personal Data on behalf of a customer as its service provider/processor, you should contact the customer that collected your Personal Data in the first instance to address your rights with respect to such data.

California Residents

This section applies to California residents, who have the rights described below under the California Consumer Privacy Act (“CCPA”). See the Exercising Your Rights section above for information on how to exercise these rights.

Right to Know

You have the right to request the following information about our collection and use of your Personal Data:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting, sharing or selling your Personal Data.
• The categories of Personal Data that we sold, shared or disclosed for a business purpose.
• The categories of third parties to whom the Personal Data was sold, shared or disclosed for a business purpose.

Right to Access

You have the right to request a copy of the Personal Data we have collected about you.

Right to Correction

You have the right to ask us to correct inaccurate Personal Data that we have collected about you.

Right to Deletion

You have the right to request that we delete the Personal Data that we have collected from you.

Right to Opt-Out of Sales or Sharing of Personal Data

You have the right to opt-out of any “sales” or “sharing” of Personal Data, as those terms are defined under the CCPA. Our practices regarding sales and sharing currently and during the past 12 months are as follows:

• The interest-based advertising services described above may be classified under the CCPA as “sharing” of Personal Data from which you have the right to opt-out. That is because the providers of these services use our users’ Personal Data (including Identifiers and Internet Activity Information) to show you ads they think may interest you on other online services. To request to opt-out of this “sharing” of your Personal Data, click the Do Not Sell or Share My Personal Information link in the footer of our site. Your request to opt-out will apply only to the browser and the device from which you submit the request.

• We do not otherwise “sell” Personal Data as defined by the CCPA. We have no actual knowledge that we have sold or shared the Personal Data of California residents under 16 years of age.

Right to Non-discrimination

You have the right to exercise your rights under the CCPA free from discrimination as prohibited by the CCPA.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to limit the use and disclosure of certain “sensitive personal information” as defined under CCPA for certain purposes restricted by the CCPA. We do not use or disclose sensitive personal information for such purposes.

“Shine the Light” Requests

Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes as well as the categories of personal information disclosed. You may send us requests for this information to info@kluzvenrtures.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address, and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Colorado Residents

This section applies to Colorado residents, who have the right under Colorado’s Consumer Privacy Act (“CPA”) to:

• Confirm whether or not we are processing their Personal Data and to access such Personal Data;
• Obtain a copy of the Personal Data they previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows them to transmit the data to another business without hindrance, where the processing is carried out by automated means;
• Correct inaccuracies in their Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data;
• Delete Personal Data we received from or obtained about them; and
• Opt-out. Opt-out of the processing of their Personal Data for purposes of (i) targeted advertising, (ii) sales of Personal Data for money, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To opt-out of the processing of Personal Data for purposes of targeted advertising subject to the CPA click the Do Not Sell or Share My Personal Information link in the footer of this site. We do not sell Personal Data for money or profile consumers in a manner that has legal or similarly significant effects on them. You can submit requests to exercise your other privacy rights as described in the Exercising Your Rights section above. You may ask to appeal our decisions in response to your requests to exercise these rights by emailing info@kluzventures.com.

Connecticut Residents

This section applies to Connecticut residents, who have the right under Connecticut’s Data Privacy Act (“CTDPA”) to:

• Confirm whether or not we are processing their Personal Data and to access such Personal Data;
• Obtain a copy of the Personal Data they previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows them to transmit the data to another business without hindrance, where the processing is carried out by automated means;
• Correct inaccuracies in their Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data;
• Delete Personal Data we received from or obtained about them; and
• Opt-out. Opt-out of the processing of their Personal Data for purposes of (i) targeted advertising, (ii) sales of Personal Data for money, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To opt-out of the processing of Personal Data for purposes of targeted advertising subject to the CTDPA click the Do Not Sell or Share My Personal Information link in the footer of this site. We do not sell Personal Data for money or profile consumers in a manner that has legal or similarly significant effects on them. You can submit requests to exercise your other privacy rights as described in the Exercising Your Rights section above. You may ask to appeal our decisions in response to your requests to exercise these rights by emailing info@kluzventures.com.

Utah Residents

This section applies to Utah residents, who have the right under the Utah Consumer Privacy Act (“UCPA”) to:

• Confirm whether or not we are processing their Personal Data and to access such Personal Data;
• Obtain a copy of the Personal Data they previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows them to transmit the data to another business without hindrance, where the processing is carried out by automated means;
• Delete Personal Data we received from or obtained about them; and
• Opt-out. Opt-out of the processing of their Personal Data for purposes of (i) targeted advertising, (ii) sales of Personal Data for money, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To opt-out of the processing of Personal Data for purposes of targeted advertising subject to the UCPA click the Do Not Sell or Share My Personal Information link in the footer of this site. We do not sell Personal Data for money or profile consumers in a manner that has legal or similarly significant effects on them. You can submit requests to exercise your other privacy rights as described in the Exercising Your Rights section above. You may ask to appeal our decisions in response to your requests to exercise these rights by emailing info@kluzventures.com.

Virginia Residents

This section applies to Virginia residents, who have the right under Virginia’s Consumer Data Protection Act (“VCDPA”) to: 

• Confirm whether or not we are processing their Personal Data and to access such Personal Data;
• Obtain a copy of the Personal Data they previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows them to transmit the data to another business without hindrance, where the processing is carried out by automated means;
• Correct inaccuracies in their Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data;
• Delete Personal Data we received from or obtained about them; and
• Opt-out. Opt-out of the processing of their Personal Data for purposes of (i) targeted advertising, (ii) sales of Personal Data for money, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To opt-out of the processing of Personal Data for purposes of targeted advertising subject to the VCDPA click the Do Not Sell or Share My Personal Information link in the footer of this site. We do not sell Personal Data for money or profile consumers in a manner that has legal or similarly significant effects on them. You can submit requests to exercise your other privacy rights as described in the Exercising Your Rights section above. You may ask to appeal our decisions in response to your requests to exercise these rights by emailing info@kluzventures.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data for money to third parties who intend to license or sell that Personal Data. You can exercise this right by emailing us at info@kluzventures.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. However, the Company does not sell Personal Data for money.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice by placing a notice on the Kluz Ventures website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• Email us at: info@kluzventures.com
• Call us at: 1-301-279-0002