Privacy Policy

‍KATMAI U.S. PRIVACY POLICY

Last Updated: October 31, 2023

At Katmai Tech Inc. (referred to in this policy as “Katmai,” “we,” “us” or “our”), your privacy and the security of your information is very important to us. We have prepared this Privacy Policy to describe the type of Personal Information (as defined below) that we collect about individuals located in the U.S., including individual users of our conferencing software and services, representatives of our potential and current customers, such as businesses or other organizations that sign up for and grant privileges to licensed users on their account (such businesses or organizations, the “Account Owner”) and visitors to our website at www.katmaitech.com (the “Site”) (the foregoing individuals referred to in this policy as “you” or “user”), and contains disclosures with respect to how we collect, process, use and share such information and the rights and choices available to control such use.

This Privacy Policy is effective as of the date that this Privacy Policy is posted. Any links that we provide to third-party websites or services are provided for your convenience and information. We do not own, operate or control such third party properties and this Privacy Policy does not apply to unaffiliated sites or services. If you visit any linked third party sites or services, please review any applicable privacy policies. We are not responsible for the content of unaffiliated sites, any use of such sites or services or the privacy practices of any third parties.

For the purposes of this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, as well as any other information related to a particular individual that constitutes “personal information” or “personal data” under applicable U.S. privacy or data protection laws. [“Sensitive Personal Information” is a subset of Personal Information and includes Personal Information that reveals your social security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; your precise geolocation; your racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless we are the intended recipient of the communication; your genetic data; the processing of your biometric information for the purpose of uniquely identifying you; and Personal Information collected and analyzing your health, sex life or sexual orientation.] Data that is either publicly available, has been aggregated or been de-identified is not Personal Information [or Sensitive Personal Information].

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

Katmai collects and processes Personal Information [and Sensitive Personal Information] when you interact with us via our Site or through any of our mobile applications, and when you use the Katmai conferencing software and services (collectively, the “Services”), whether on behalf of yourself or in a commercial capacity when you act on behalf of your employer or organization.

In the previous twelve (12) months we have collected and/or processed and, going forward, we may collect and/or process the following categories of Personal Information [and Sensitive Personal Information] from you for the following purposes and disclose it to the following persons:

CATEGORIES OF PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION] COLLECTED

Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers

BUSINESS OR COMMERCIAL PURPOSE FOR PROCESSING

To perform the Services and other internal operations necessary to run our business and provide services to you, including undertaking internal research to provide, develop, maintain and improve the Site and Services
To communicate with you about our Site or Services, including to update you on changes to your account or to respond to you when you contact us
[To facilitate and process payments]
To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal
To satisfy legal and compliance obligations

CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION] MAY BE DISCLOSED

The Account Owner, if applicable, in connection with account activation, management and servicing
Third-party service providers, such as information technology consultants, data analytics providers, cloud storage providers, [payment processors,] etc.
External advisors, such as lawyers, accountants and auditors
Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations

CATEGORIES OF PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION] COLLECTED

Professional or employment-related information, such as your name, business name and job title, business or personal email address and business or personal mobile or other telephone number

BUSINESS OR COMMERCIAL PURPOSE FOR PROCESSING

To perform the Services and other internal operations necessary to run our business and provide services to you, including undertaking internal research to provide, develop, maintain and improve the Site and Services
To communicate with you about our Site or Services, including to update you on changes to your account or to respond to you when you contact us
[To facilitate and process payments]
To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal
To satisfy legal and compliance obligations

CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION] MAY BE DISCLOSED

The Account Owner, if applicable, in connection with account activation, management and servicing
Third-party service providers, such as information technology consultants, data analytics providers, cloud storage providers, [payment processors,] etc.
External advisors, such as lawyers, accountants and auditors
Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations

CATEGORIES OF PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION] COLLECTED

[Commercial information, such as records of services purchased and obtained and other transaction/purchase history]

Device information, such as information collected about the computer, phone or other device used to access and interact with our Services, including device identifiers, the name of the mobile device operator or Internet service provider, browser type, language and time zone, etc.

BUSINESS OR COMMERCIAL PURPOSE FOR PROCESSING

[To perform the Services and other internal operations necessary to run our business and provide services to you, including undertaking internal research to provide, develop, maintain and improve the Site and Services
To communicate with you about our Site or Services, including to update you on changes to your account or to respond to you when you contact us
[To facilitate and process payments]
To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal
To satisfy legal and compliance obligations]

To perform the Services and other internal operations necessary to run our business and provide services to you, including undertaking internal research to provide, develop, maintain and improve the Site and Services
To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal
To satisfy legal and compliance obligations

CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION] MAY BE DISCLOSED

[The Account Owner, if applicable, in connection with account activation, management and servicing
Third-party service providers, such as information technology consultants, data analytics providers, cloud storage providers, [payment processors,] etc.
External advisors, such as lawyers, accountants and auditors
Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations]
Third-party service providers, such as third party developers, information technology consultants, data analytics providers, etc.
External advisors, such as lawyers, accountants and auditors
Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations

CATEGORIES OF PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION] COLLECTED

Internet or other electronic network activity information, such as audio and video settings, screen sharing settings and other settings and configuration information, browsing history, search history, and information regarding a consumer’s interaction with the Site or Services (including the number of users logged into a certain Katmai workspace and located within the Katmai workspace or in a specific sound zone, the frequency of clicks on a screen share, etc.), or other general activity and diagnostic information

[Sensitive Personal Information, such as your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account]

BUSINESS OR COMMERCIAL PURPOSE FOR PROCESSING

To perform the Services and other internal operations necessary to run our business and provide services to you, including undertaking internal research to provide, develop, maintain and improve the Site and Services
To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal
To satisfy legal and compliance obligations

[To perform the Services and other internal operations necessary to run our business and provide excellent services to you, including undertaking internal research to provide, develop, maintain and improve the Site and Services
[To facilitate and process payments]
To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal
To satisfy legal and compliance obligations]

CATEGORIES OF THIRD PARTIES TO WHOM PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION] MAY BE DISCLOSED

The Account Owner, if applicable, in connection with account activation, management and servicing
Third-party service providers, such as third party developers, information technology consultants, data analytics providers, cloud storage providers, etc.
External advisors, such as lawyers, accountants and auditors
Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations
[Third-party service providers, such as information technology consultants, data analytics providers, cloud storage providers, [payment processors,] etc.
External advisors, such as lawyers, accountants and auditors
Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations]

If you can’t or choose not to provide us with the Personal Information we reasonably require and as set forth in the chart above, we may be unable to display the Site to you in a manner that you require or to otherwise provide you with the information or Services you have requested.

We do not use or otherwise process your Personal Information [or Sensitive Personal Information] for the purposes of inferring characteristics about you nor do we use such information for any other purpose other than as noted above or as expressly permitted by applicable U.S. privacy and data protection laws, including the CPRA and its implementing regulations.

De-Identified Information. With respect to our use of de-identified information, we commit to maintain and use such information in de-identified form and to refrain from attempting to re-identify such information, except for the sole purpose of determining whether our de-identification processes and procedures satisfy applicable legal requirements.

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‍FURTHER INFORMATION ABOUT HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION]

We do not sell Personal Information [or Sensitive Personal Information] for monetary or other valuable consideration, nor do we share such information for purposes of cross-context behavioral advertising, and have not done so within the past twelve (12) months.

In addition to the purposes indicated in the table above, we may disclose Personal Information [or Sensitive Personal Information] about you (a) if we are required or permitted to do so by law or legal process, for example, for the exercise of legal proceedings, a request from a law enforcement agency or if we believe in good faith that such disclosure is necessary to comply with a legal obligation or request or to enforce our terms and conditions, (b) when we believe disclosure is necessary or appropriate to protect the rights, property or safety of Katmai, our users or customers, a third party or the public, (c) in conjunction with business continuity purposes or (d) to a third party that acquires, or is interested in acquiring, all or part of our business in connection with a corporate sale, merger, reorganization, dissolution or similar event. We may also disclose Personal Information [or Sensitive Personal Information] about you in other circumstances where we have your consent.

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FROM WHAT SOURCES DO WE COLLECT YOUR PERSONAL INFORMATION [OR SENSITIVE PERSONAL INFORMATION]

In the past twelve (12) months we have collected and/or processed and, going forward, we may collect and/or process Personal Information [or Sensitive Personal Information] from the following sources:

From you directly (e.g., when you (i) create an account with us via the Site, (ii) access our Services, (iii) request technical support, (iv) subscribe to learn more about our Services or (v) contact and/or contract with us in connection with your role as an employee, director, officer or other representative of a prospective or current Account Owner);
From the Account Owner (e.g., when you access the Site or Services via an account to which you have been granted access by the Account Owner or via a guest pass provided by an Account Owner or another authorized user);
From your device (e.g., when you visit our Site or access our Services, depending on the permissions you or the Account Owner has set);
Automatically through online tracking technologies such as browser and flash cookies, web pixels or other online tracking technologies, as further described below;
From third party service providers (e.g., payment processors, IT service providers, cloud storage providers, data analytics providers, etc.)

Cookies. Your Internet browser has a feature called cookies, which store small amounts of data on your computer or device about your visit to our Site or your access to and use of the Services. As noted above, we and our service providers may use browser and flash cookies and other common online tracking technologies, including electronic images known as “web bugs” (sometimes called transparent GIFs, clear GIFs, or beacons). We generally refer to such other tracking technologies as “cookies.”

Cookies allow us and our service providers to automatically collect information regarding general user-traffic patterns and your interactions with our Site and Services. In using such technology, we collect such automatically transmitted data as the domain, page served, time of visit (including the initial timestamp, last timestamp, current timestamp and session number), the type of browser making the request, the preceding page view and other such information to understand how the Site and Services are performing or how to improve the Site or Services for you. [Unless you or the Account Owner has signed up for an account with us, the information we gather through the use of tracking technologies cannot be matched with any personally identifiable information about you.] You do not need to have cookies turned on to visit our Site, although active participation in certain areas of our Site may require cookies. You can set your browser to refuse or delete cookies. Please consult the corresponding instructions of the hardware manufacturer for more detailed information on the actual procedure. If you configure your computer or device to block all cookies, you may disrupt certain features of our Site or Services and limit the functionality we can provide when you visit our Site or use our Services. If you block or delete cookies, not all of the tracking that we have described in this Privacy Policy will stop.

[Additionally, we use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of our Site and to report on activities and trends. This service may also collect information regarding your use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.]

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MINORS AND CHILDREN UNDER 13

Our Site is not intended for or directed at minors and therefore we do not knowingly collect any Personal Information [or Sensitive Personal Information] from any individual under the age of 18 or knowingly track the use of our Site by minors. To the extent we have any Personal Information [or Sensitive Personal Information] related to individuals under the age of 18, we have no actual knowledge that we “sell” or “share” such individuals’ Personal Information [or Sensitive Personal Information].

If you believe we might have any information (including Personal Information [or Sensitive Personal Information]) from or about an individual under the age of 18, please contact us by phone at (917) 300-8267, by email at privacy@katmaitech.com or by mail at the following address:

Katmai Tech Inc.

99 Madison Avenue, 8th Floor

New York, New York 10016

HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION [AND SENSITIVE PERSONAL INFORMATION]?

We retain your Personal Information [or Sensitive Personal Information] for no longer than reasonably necessary to fulfill the purpose(s) set forth for such information, as described in this Privacy Notice, unless a longer retention period is required under applicable law. We consider the following criteria to determine our data retention periods:

The type of information collected and the purposes for which it was collected;
Whether you or the Account Owner have requested retention or deletion of such data;
Whether we have a legal obligations to retain such data (e.g., for backups, archiving and prevention of fraud or abuse) or where such retention is required by law; and
Whether it is advisable in light of our legal position or where we have a reasonable belief that we have a legitimate reason to do so.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

The security and confidentiality of your Personal Information [and Sensitive Personal Information] is important to us. That’s why we have technical, administrative and physical controls in place that are designed to protect your Personal Information from unauthorized access, use and disclosure. Even so, despite our reasonable efforts, no security measure is ever completely sufficient, perfect or impenetrable.

You are also responsible for keeping your Personal Information [and Sensitive Personal Information] secure. We strongly recommend that you keep passwords unique from other identifiers such as your login information or account ID to help protect your privacy. In addition, you should make sure you only use trusted wireless connections in transmitting any Personal Information [or Sensitive Personal Information].

YOUR PRIVACY RIGHTS

In connection with our collection and/or processing of your Personal Information [or Sensitive Personal Information] you have the following privacy rights:

Right to Know: Know what Personal Information we collect about you, including the categories of Personal Information collected, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you;

Right to Request Deletion: Request deletion of your Personal Information that we have collected or maintained, subject to certain exceptions;

Right to Correct: Request that we correct inaccurate Personal Information that we maintain about you; and

Right to be Free from Discrimination and Retaliation: Not receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CPRA or any other applicable U.S. data privacy law, including your right not to be retaliated against for the exercise of these rights.

EXERCISING YOUR PRIVACY RIGHTS

Responding to Do Not Track Signals. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.

Method to Submit Your Requests. If you wish to exercise any of the rights listed above or if you consider that we have processed your Personal Information [or Sensitive Personal Information] in violation of applicable law, please email us at privacy@katmaitech.com or call us at (917) 300-8267. You can also submit requests via [INCLUDE LINK TO ONLINE REQUEST FORM OR PORTAL].

Verification Procedures. To respond to your requests, we may ask you for at least two pieces of Personal Information and, for requests for specific pieces of Personal Information, we may ask you for at least three pieces of Personal Information, that we will match with data points we already have, in order to verify your identity to the degree of certainly required by applicable law. The information we require may vary depending on your relationship to us, and may include your full legal name, residential address, email, phone, as well information we may have on file about you or other information that may be necessary to verify your identity. If we are unable to verify your identity to the degree of certainty required by applicable law through any reasonable method, we will state in a written response to you that we are unable to verify it, along with a reason as to why there is no reasonable method by which we can verify your identity.

If you are making a request on behalf of another individual, such as a member of your household, we may also request additional information from you and/or such individual to verify their identity. If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf as described above. If you designate an authorized agent, (a) we may require you to provide your authorized agent with written permission to do so, and (b) for access, correction and deletion requests, we may require you to verify your own identity with us directly.

CALIFORNIA’S SHINE THE LIGHT LAW

In addition, under California Civil Code Section 1798.83 (California’s “Shine the Light Law”), if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of Personal Information to third parties for the third parties’ direct marketing purposes. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”

HOW TO CONTACT US:

If you have any questions or complaints, or you wish to send us comments about this Privacy Notice, please contact us: by phone at (917) 300-8267, by email at privacy@katmaitech.com or by mail at the following address:

Katmai Tech Inc.

99 Madison Avenue, 8th Floor

New York, New York 10016

HOW WILL YOU KNOW IF WE AMEND THIS PRIVACY POLICY?

We may amend this Privacy Policy at any time. If we make any material change to this Privacy Policy, we will prominently post the updated Privacy Policy and indicate at the top of the Privacy Policy when it was updated. If you disagree with our Privacy Policy changes, you may choose not to use or access our Site or Services, or request that we delete your account.