KALEO PRIVACY POLICY

Last Updated: October 20, 2023

Kaleo is a mobile app and an online platform that connects volunteers to local service opportunities that match their interests and availability to non-profit organizations’ needs in real time.  Kaleo’s mission is to make the call to serve easily actionable by connecting passionate volunteers with local non-profit organizations and other groups, while also celebrating service through storytelling.  Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.


This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy.  This policy explains your rights regarding our collection, use, sale, and sharing of your personal information. We may update and make changes to this policy from time to time, so we encourage you to review it periodically.

1.      Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Tuple Software Inc., a Delaware corporation, which owns and operates the website at http://www.kaleoapp.com/ and the mobile application known as “Kaleo.”

Personal information

Any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with any user of Kaleo.

Sensitive personal information

Personal information revealing a Kaleo user’s precise geolocation, racial or ethnic origin, religious beliefs, personal information concerning a Kaleo user’s age, health, sex life, or sexual orientation, and contents of a Kaleo user’s mail, email and text messages where Kaleo is not the intended recipient.

2.      Personal Information We Collect About You.  Users of Kaleo include faith-based and other nonprofit organizations (“Organization Members”) and individuals who set up profiles on Kaleo (“Individual Members”).  Organization Members and Individual Members are sometimes referred to collectively as “Members.”  Some content and data on Kaleo is viewable to individuals who are not Members (“Visitors”).  We collect the following categories and specific types of personal information:

Categories of Personal Information

Specific Types of Personal Information Collected

Information that you provide

Every Member of Kaleo must provide us with a name (which may be a real name or an alias) and an email address. 

You may elect to provide additional personal information on your Kaleo profile, such as your phone number, education, occupation, skills, photo, city or area, religious affiliation and specific interests. You don’t have to provide additional information on your profile; however, profile information may help you connect with the Members and volunteer opportunities that interest you. It’s your choice whether to include Sensitive Personal Information on your profile. Please do not post or add personal data to your profile that you would not want to be publicly available.

Identifiers

We assign each Kaleo user a unique personal identifier (per account email) and we also assign a unique identifier to each device on which a Kaleo user installs the app.  These identifiers are used to tag content you provide and actions you take in Kaleo.

Usage Data

We log usage data when you visit or otherwise use Kaleo, such as when you view or click on content posted by Organization Members, perform a search, install or update our mobile app, share articles, RSVP or volunteer. We use the identifiers listed above to identify you and log your use.

Characteristics of protected classifications under California or federal law

Because our primary focus is to serve faith-based and other nonprofit organizations and those individuals interested in volunteering or otherwise supporting such organizations, a Kaleo user’s religious views and other affiliations will be a natural and necessary part of the personal information we collect, but only to the extent such information is voluntarily provided by a Member either in a profile or a post, or by virtue of the Member’s other activities on Kaleo. 

Organization Members may also create interest groups or volunteer opportunities that Individual Members may choose to respond to and that may be based or otherwise focused on such things as race, color, ancestry, national origin, sexual orientation, gender identity and expression, sex, pregnancy, childbirth & related medical conditions, disability, age, military or veteran status, status as a victim of domestic violence, assault or stalking, political affiliation or activities, medical or health conditions, and marital status.

Geolocation data

Enabling use of Location data is optional.  Your location is used to find Organization Members and opportunities nearby.  We also collect geolocation data in order to better connect Members in the same geographical area.

Audio, electronic, visual, or similar information

Members may elect to post audio, visual or other material on Kaleo.

Inferences drawn from any of the information identified above to create a profile about a Member reflecting the Member’s interests, preferences, characteristics, predispositions, attitudes, abilities, and aptitudes

We use the information provided to personalize the experience of Kaleo including providing suggestions for volunteer activities.

3.      How Your Personal Information is Collected. We collect most of this personal information directly from you through your profile and your posts and other activities on Kaleo.  In addition, others may post content that includes personal information about you.  We track and log your use of Kaleo, so that when you visit Kaleo we log data such as when you view or click on content, perform a search, install our mobile application, or view or respond to Member posts.  We use the unique identifiers described above to log your use of Kaleo.

4.      Why We Use Your Personal Information. We collect and share your personal information for the following purposes:

         To provide our services on Kaleo.  We use your information to authorize your access to Kaleo and to honor your profile settings.  We use the information that we have about you to provide and personalize your experience in using Kaleo. 

         To allow you to keep in contact with the Members of your choosing.  You can “follow” Organization Members and contact them or ask them to contact you.  You may also connect with other Members on Kaleo. You can control how you can be contacted on Kaleo, which might include email, phone, text message, and push notifications. 

         To contact you about updates to Kaleo, or to send you reminders, suggestions and promotional messages from us.

         To ensure the security and integrity of Kaleo.  We use your personal information (including your communications on Kaleo) for security purposes or to prevent or investigate possible fraud or other violations of our Terms of Service and/or attempts to harm our Members, Visitors or others.  We use your data to investigate, respond to and resolve complaints and to address issues such as bugs or errors that impair the intended functionality of Kaleo.

         To comply with our legal and regulatory obligations.

         To gather insights that do not identify you.  For example, we may use your data to generate statistics about our Members.

         To facilitate a change in control or sale of our business. 

5.      How We Share Your Personal Information. Your information may be shared in the following ways:

Your profile

Any personal information that you include in your profile on Kaleo, including your name, and your photo if you have provided one, will be seen by others.  Your profile is visible to all Members and Visitors.  Optional information, such as your phone number, can be made visible to all other users.

Your comments on items

Your profile will also be visible whenever you make a comment on a request from an Organization Member. 

Requests which send your contact information

Your contact information including name, email and phone (if provided) will be shared when you take certain actions.  If you request that a specific Member contact you through Kaleo, the Member will receive a private message with your contact information.

When you respond to an Organization Member item (e.g., sign up for a volunteer opportunity), your contact information is provided to the Organization Member to facilitate coordination for that item.

Once your contact information is shared, those receiving it are responsible for properly handling and protecting that information.  Organization Members may have additional policies listed in Kaleo which govern their use of your data.

Service providers

We may use third parties to help us provide our services on Kaleo.  Such third party help may include maintenance, analysis, audit, payments, fraud detection, marketing and development.  We only allow our third party service providers to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to the extent reasonably necessary to perform their services on our behalf, and they will be obligated not to disclose or use your information for any other purpose.

Legal disclosures

We may need to disclose information about you when required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is reasonably necessary to investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies.  Other circumstances where we may need to share your information could include our need to (i) enforce our agreements with you, (ii) investigate and defend ourselves against third-party claims or allegations, (iii) protect the security or integrity of Kaleo, or (iv) exercise or protect the rights and safety of Kaleo, Members, personnel or others.

Change in control or sale

We may share your data if our business is sold to a third party.  We can also share your personal information in preparation for a sale, merger or change in control.  Any other entity which buys us or Kaleo will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

6.      How Long Your Personal Information Will Be Kept. We will keep your personal information for as long as you have an account on Kaleo. Thereafter, we will keep your personal information for as long as is necessary:

         To respond to any questions, complaints or claims made by you or on your behalf;

         To show that we treated you fairly; or

         To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

7.      Your Rights Generally.  You can change or delete your personal data in your profile, and you can change the information that is publicly available in your settings.  You can also ask us to delete or modify any of your personal information.  You can also ask us to stop using your information or to limit its use.  You can ask us for a copy of all of your personal information in our possession at any time.

You may also request that your account and personal information contained therein be closed.  You make that request in the Kaleo app on the Accounts Page.

If you close your Kaleo account, your personal information will stop being visible to others in approximately 24 hours.  Note that if you simply delete the Kaleo application from your mobile device, you may continue to have an account on Kaleo and your information will continue to be available.  We will retain de-personalized information after your account has been closed.  Information you have shared with others on Kaleo (such as responses to requests for volunteers, or comments to posts) may remain visible after you close your account or delete the information from your profile.  In addition, we cannot control any data that may be copied out of Kaleo by Members or Visitors.

8.      Under the CCPA/CPRA. If you are a resident of California, you have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

• The categories of personal information we have collected about you, including sensitive personal information;

• The categories of sources from which the personal information is collected;

• Our business or commercial purpose for collecting, selling, or sharing personal information;

• The categories of third parties to whom we disclose personal information, if any; and

• The specific pieces of personal information we have collected about you.

Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

• Provide the personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and

• The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

We do not sell or share personal information for the purpose of targeted behavioral advertising.

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;

To perform the following services: (1) Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us; (3) Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and (5) As authorized by further regulations.

We do not use your sensitive personal information for any other purposes than listed above.

Right to Deletion

Subject to certain exceptions set out below, upon receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and

• Direct any service providers or contractors to delete your personal information from their records.

• Direct third parties to whom we have sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

Please note that we may not delete your personal information if it is reasonably necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another user to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

• Deny goods or services to you;

• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• Provide a different level or quality of goods or services to you; or

• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

9.      How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by contacting us here: https://kaleoapp.com/contact. You may also email us at [email protected].

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by [website/email/phone/in writing], you will need to provide us with:

         Enough information to identify you [(e.g., your full name, address and customer or matter reference number)];

         Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

         A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.