MILGO
PRIVACY POLICY

Last Updated: May 30, 2024

Kayma Labs Ltd. (“Company,” “we,” or “us”) respects your privacy and is committed to protecting it, including any Personal Information (defined below) you share with us, through our compliance with this Privacy Policy (this “Policy”).

This Policy describes the types of information we may collect from you or that you may provide when you visit the website https://milgo.io/en and/or purchase, register with, access, visit, or otherwise use (collectively, “interact”) our web application at app.milgo.io (“Milgo”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.  We follow this Policy in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain practices or regions.  Those terms are to be read in conjunction with this Policy.

This Policy applies to information we collect in digital form or in non-digital form which is digitized subsequently:

  • On and through Milgo.
  • In email, text, electronic messages, telephone calls, and other communications between you and us.
  • Through inquiries about or engagement in our implementation and usage consulting services and institute success services (“Consulting Services”).

Milgo and our Consulting Services are collectively referred to herein as our “Service”.

This Policy does not apply to:

  • Information collected by us offline and which is not digitized subsequently or through any other website not operated by us.
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through Milgo (such as for example, the data a third party may collect when you click on a hyperlink on Milgo if that hyperlink takes you to a third-party website). To clarify, a third party may have its own privacy policy governing disclosure of relevant information.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to disclose any information to us or use our Service. By accessing or using our Service, you agree to this Policy and confirm that you have read and understand it. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Service after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates. If we collect additional Personal Information, you will be required to agree with our policies and practices.

1. Children’s / Minors’ Privacy

We recognize the need to provide further privacy protections with respect to Personal Information we may collect from individuals who are under 18 years in age (“children/minors”). Some of the features on Milgo are age-gated so that they are not available for use by children/minors, and we do not knowingly collect Personal Information from children/minors in connection with those features. While we intend to collect Personal Information from children/minors, we take additional steps to protect children/minors’ privacy, where necessary, including:

  • Notifying the school, district, or other educational agency or institute who has engaged us, that we will be collecting Personal Information for the use and benefit of the students and the institute in the educational context (the “Covered Institute”) about our information practices with regard to children/minors, including the types of Personal Information we may collect from children/minors, the uses to which we may put that information, and whether and with whom we may share that information.
  • Requiring a Covered Institute to obtain consent from parents, legal/lawful guardians and representatives (each a “Parent”) for the collection of Personal Information from their children/minors prior to implementing student engagement with our Service. This is in addition to the consent obtained by Milgo prior to use of our Service.
  • Limiting our collection of Personal Information from children/minors to no more than is reasonably necessary to provide our Service.
  • Coordinating with the Covered Institution to give Parents access to the Personal Information we have collected from their children/minors.
  • Complying with Parents’ correction, deletion, or other applicable rights requests in coordination with the Covered Institute.

For additional information about our practices regarding the Personal Information of children residing in the United States, please see our U.S. Children’s Privacy Notice.

2. FERPA Compliance Statement

This Policy is designed to also comply with the Family Education Rights and Privacy Act (“FERPA”), a federal legislation in the U.S. We only collect student information pursuant to a contract with a Covered Institution, for the use and benefit of the students and the Covered Institution, as authorized by the Covered Institution. Under FERPA, we function as a “school official,” and only process students’ information for educational purposes pursuant to 34 CFR § 99.31(a)(1)(i)(B). Please note that in the event we receive a subpoena or judicial order for the disclosure of education records, we will notify the associated Covered Institute prior to fulfilling the request in accordance with § 99.31(a)(9).

3. Information We Collect & How We Collect It

We collect two basic types of information:

  • Information that identifies (whether directly or indirectly) a particular individual, such as your name, postal address, email address, and telephone number (“Personal Information”); and
  • Information that does not directly or indirectly identify, and cannot reasonably be used to identify an individual (“Anonymous Information”). When Anonymous Information is directly or indirectly associated with Personal Information, the resulting information is also treated as Personal Information.

We may use Personal Information and Anonymous Information to create a third type of information: information about groups or categories of individuals, which does not identify and cannot reasonably be used to identify an individual (“Aggregate Information”).

We collect this information from and about you:

  • When you directly provide it to us, such as when you fill in forms or complete surveys on Milgo, create an account, or contact us directly (whether by phone, email, or through an electronic contact form).
  • Automatically from you when you use Milgo, such as your usage details, IP address, and information collected through cookies and other analytic tracking technologies (see Information We Collect Through Automatic Data Collection Technologies).
  • From third parties, such as site or platform providers, about use of Milgo on third-party platforms and devices, in which cases, we presume that they have the respective Authorization for the effective processing of Personal Information.

This information includes:

  • Information that you provide by filling in forms and completing surveys on or through Milgo, such as your first name and surname, physical address, email address, age, username, and password. This includes information provided at the time of registering with or logging in to Milgo, scheduling and receiving our Service, purchasing products, posting text uploads (“Uploads”), subscribing to our promotional email correspondence, or requesting further information or services. We may also ask you for information when you report a problem with our Service.
  • Records and copies of your correspondence (including any information you provide to us, such as your name, email, and telephone number), if you contact us.
  • The process of providing our Consulting Services and any resulting service contract or other transaction with you, which may require you to provide additional information, such as financial information.
  • Your search queries on Milgo.

Although your Uploads will not be published or displayed (hereinafter, “posted”) on public areas of Milgo, or transmitted to other users of Milgo or third parties, any information you provide in your Uploads is provided at your own risk and volition. We do keep records of your Uploads, meaning that we will collect any information you voluntarily provide us, which may include sensitive information (as defined under applicable law) such as your protected class information. Although we limit access to our Uploads and observe reasonable security safeguards to prevent breaches of personal data, please be aware that no security measures are perfect or impenetrable. Therefore, in spite of implementing appropriate technical and organizational measures, we cannot and do not guarantee that your Uploads will not be viewed by unauthorized persons. Nevertheless, in the event of a personal data breach, we will take appropriate action as required under the applicable law.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with Milgo, we may use automatic data collectiontechnologies to collect certain information about your equipment, browsing actions, andpatterns, including:

  • Details of your visits to Milgo, including traffic data, location data, logs, and othercommunication data and the resources that you access and use on Milgo.
  • Information about your computer and internet connection, including your InternetProtocol (“IP”), operating system, and browser type.

The information we collect automatically may include Personal Information, or we maymaintain it or associate it with Personal Information we collect in other ways or receivefrom third parties. The information we collect helps us to improve our Services and todeliver a better and more personalized experience, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize Milgoaccording to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to Milgo.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard driveof your computer. You may refuse to accept browser cookies by activating theappropriate setting on your browser. However, if you select this setting you maybe unable to access certain parts of Milgo. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies whenyou direct your browser to Milgo.
  • Analytics. We collect analytics information from the third-party tools listedbelow. This includes information such as how often users visit Milgo, what pagesthey visit when they do so, what other sites they used prior to coming to Milgo,and users’ IP addresses. We use the information we get from analytics toolsonly to improve Milgo and do not combine the information collected withpersonally identifiable information.

Please note that in many instances, the tools we use do not collect Personal Information. We use the following third-party tools in connection with Milgo:

  • HotJar. We use HotJar, Ltd.’s web analysis service (“Hotjar”) to analyze your use of Milgo. Hotjar’s services allow us to analyze how visitors use Milgo by revealing online behavior related to Milgo and collecting feedback from those visitors. We do not use Hotjar to collect Personal Information, nor do we transfer such information to Hotjar. We use Hotjar to record, on a non-personal basis, information such as mouse movements, mouse clicks, and scrolling activity. Information about the browser (type, version, screen size, etc.), basic information about the user (country, language, time zone), and data containing mouse movements, clicks, scroll events, and keystrokes are transferred to Hotjar’s services in Europe for analysis. Information that you enter into form fields and your IP address are masked with unreadable content before information is transmitted to Hotjar to protect your privacy. More information on HotJar Ltd.’s data practices is available at https://www.hotjar.com/legal/policies/privacy. For information on how to disable the Hotjar service, see Choices About How We Use and Disclose Your Information.
  • Mixpanel. We use Mixpanel Inc.’s tracking tool (“Mixpanel”) to gather information about how and to what extent you use the features of Milgo. This information includes the kinds of buttons you click, how the user flow changes when you navigate through Milgo, your anonymized IP address, the time and date of your visit, and the time spent on particular pages. We use such information to improve the usability and functionality of Milgo. Mixpanel stores the data it collects in the U.S., and is subject to the EU-US Privacy Shield. More information on Mixpanel Inc.’s data practices is available at https://mixpanel.com/legal/privacy-policy/. For information on how to prevent Mixpanel from collecting your data, see Choices About How We Use and Disclose Your Information.

These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use Milgo. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. While you have the right to refuse sharing of any personal or other information, we do not control these third parties’ tracking technologies or how they may be used. Please reach out to each service provider directly for more information.

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, including its collection, conservation, storage, modification, use, circulation, evaluation, blocking, destruction, processing and/or transfer to third parties, through the means previously stated:

  • To provide you with information, products, and services that you request, view, engage with, or purchase.
  • To communicate with you about your account or transactions with us and send you information or request feedback about features of our Service or changes to our policies.
  • To send you targeted offers and promotions for our products and services or third-party products and services, if you have not opted-out of such promotional correspondences (see Choices About How We Use and Disclose Your Information).
  • To personalize your content and experience with our Service.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to Milgo or any products or services we offer or provide though it.
  • To operate, understand, optimize, develop, or improve our Service, including by using survey research and analytics tools.
  • To detect, investigate, and prevent activities that may violate our policies, pose safety issues, or be fraudulent or illegal.
  • For archives, updating systems, and the protection and custody of the Company’s information and databases.
  • For processes within the Company for development or operational and/or system administration purposes.
  • To manage all the necessary information for the fulfillment of tax obligations and commercial, corporate and accounting records of the Company.
  • For any lawful purpose with your consent, determined by you, in order to comply with legal and regulatory obligations, as well as our policies and procedures.
5. Disclosure of Your Information

We may disclose Anonymous Information and Aggregate Information about our users without restriction. We will not share your Personal Information with a third party except that we may disclose Personal Information that we collect or you provide as described in this Policy:

  • To our affiliates, partners, parent or subsidiary organizations.

  • To contractors, service providers, and other third parties we use to support our business, including but not limited to our:

    • Email and marketing service providers.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about Milgo users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • For another lawful purpose, with your consent.

We may also disclose your Personal Information:

  • To comply with any court order, law, or legal process, including responding to government or regulatory requests.
  • To enforce another agreement with you, including for billing and collection purposes.
  • If permissible under applicable law, we may disclose Personal Information that we collect or you provide if we believe such disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
6. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of Milgo may then be inaccessible or not function properly. Other ways to opt-out of specific data collection technologies that we utilize include:

    • Hotjar.  You may deactivate tracking by Hotjar pursuant to the instructions available at https://www.hotjar.com/policies/do-not-track/.
    • Mixpanel. You may prevent Mixpanel from generating data through its cookies, and the processing of such data by Mixpanel, pursuant to the instructions available at http://www.mixpanel.com/optout.
    • Do Not Track Signals.  Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not been adopted, Milgo does not process or respond to browsers’ “Do Not Track” signals. To make such request, please contact us at
      ‍https://coda.io/form/milgo-Support_dDCRTuQ8mc3
  • Promotional Offers from the Company.  We do not engage in targeted advertising aimed at children.  If you do not wish to have your contact information used by us to promote our own and/or third parties’ products or services generally, you can opt-out by filling a form stating your request at
    https://coda.io/form/milgo-Support_dDCRTuQ8mc3.  This opt-out does not apply to information provided to us as a result of a purchase, service experience, or other transaction.

We do not control third parties’ collection or use of your information to serve interest-based advertising.  However, these third parties may provide you with ways to choose not to have your information collected or used in this way.  You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website at https://thenai.org/opt-out/.

    7. Accessing and Correcting Your Information

    You can review and change some of your Personal Information by logging into Milgo and visiting your account profile page.  You may also contact us at https://coda.io/form/milgo-Support_dDCRTuQ8mc3 to request access to, correct, complete, update, or delete any Personal Information that you have provided to us.  Please note that we cannot delete certain or all Personal Information except by also deleting your user account.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.  If you choose to withdraw your consent for Milgo to use your Personal Information, or if you delete your user account, we will cease processing your data within a reasonable time.If you delete your Uploads from Milgo, copies of your Uploads may remain viewable by us in cached and archived pages. Residents of certain U.S. states (e.g., California, Nevada, Colorado, Connecticut, Virginia, and Utah) and countries (e.g., India and Colombia) may have additional rights and choices regarding their Personal Information. Please see Your State-Specific Privacy Rights and Country Specific Privacy Rights for more information.

    8. Your U.S. State Privacy Rights

    If applicable, state consumer privacy laws may provide their residents with
    additional rights regarding our use of their Personal Information. Please know that we
    do not currently trigger most state-specific privacy rights. If you think a state-specificMILGO (KAYMA LABS, LTD.)
    PRIVACY POLICY - 9right applies, please send your rights request to https://coda.io/form/milgo-
    Support_dDCRTuQ8mc3    .

    9. Other Country-Specific Rights

    Colombia.  Please see our Privacy Notice for Colombia Users, which contains Colombia-specific privacy information.

    India.  Please see our Privacy Notice for India Users, which contains India-specific privacy information.

    Israel.      Please see our Terms and Conditions for Israel Users, which contains Israel-specific privacy information

    10. Data Security, Integrity, and Retention

    The security, integrity, and confidentiality of your information are important to us.  We have implemented reasonable technological and administrative security measures designed to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure.  However, the safety and security of your information also depends on you.  Where you have a password, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.  We urge you to be careful about displaying information in public areas, as it may be viewed by unauthorized persons.

    Unfortunately, the transmission of information via the internet is not completely secure.  Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to or from Milgo.  Any transmission of Personal Information is at your own risk and volition.  We are not responsible for circumvention of any privacy settings or security measures contained on Milgo, nor for computer attacks and in general any action that aims to violate the security measures established for the protection of Personal Information other than these contained in its computer equipment or those contracted with third parties.

    We will retain your Personal Information for the length of time needed to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

    11. Data Transfers, Storage, and Processing Globally

    We operate globally and may transfer your Personal Information to third parties in locations around the world for the purposes described in this Policy. Wherever your Personal Information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Information. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring Personal Information. We take appropriate steps to comply with specific local laws vis-à-vis processing of Personal Information. Milgo’s database is currently hosted by Digital Ocean LLC (“Digital Ocean”) in an ISO/IEC 27001-certified data center in Frankfurt am Main, Germany. More information about Digital Ocean’s data practices is available at https://www.digitalocean.com/trust/ and https://www.digitalocean.com/legal/

    12. Incorporation into Terms of Service

    Use of the Service, and any dispute over privacy or Personal Information, including Student Information under our Children’s Privacy Notice, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and resolution of disputes.

    13. Changes to Our Privacy Policy

    It is our policy to post any changes we make to this Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Milgo home page. The date this Policy was last revised is identified at the top of the page. Please ensure we have an up-to-date active and deliverable email address for you (if you have an account with us). We encourage you to periodically visiting Milgo and this Policy to check for any changes.

    14. Contact Information

    If you have any questions or concerns regarding this Policy, or need to access this Policy in an alternative format due to having a disability, please contact us at https://coda.io/form/milgo-Support_dDCRTuQ8mc3

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