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Privacy

Effective and last updated: February 26, 2023

This Privacy Policy (the “Policy”) explains how A.B. Closing Corporation DBA Kavaliro collect, use, and disclose your personal information. Unless otherwise expressly indicated in this Policy, this Policy describes our collection, use, and disclosure of personal information through Kavaliro.com and any other websites and online services that we operate and that include a link to this Policy (collectively, the “Websites”), and does not apply to information that we collect offline or through other channels or methods, except as specified in the Additional Information for Residents of California section.

California Notice at Collection

If you are a California resident, the Additional Information for Residents of California section below includes additional information that we provide pursuant to the California Consumer Privacy Act of 2018 as amended from time to time (“CCPA”). That section includes information regarding the categories of information to be collected, the purposes for which the categories of information are collected or used, whether the information is sold or shared, and how long the information is retained.

The Information We Collect and How We Collect It

We generally collect and receive personal information about you through the Websites in three ways: (1) when you voluntarily provide personal information to us directly, such as when you fill out a contact form on the Websites; (2) through automated processes that collect information about your use of the Websites; and (3) when we receive information about you from third-party sources, such as individuals who participate in our Referral Programs and use the Websites to provide your personal information to us. These methods, and the personal information we collect, are described in more detail below.

Information You Provide Directly

When you use or access the Websites, we may collect personal information that you choose to provide directly, such as your name, email address and other contact information, and any other information that you choose to provide as part of a request or inquiry. Examples of this collection are described below.

If you represent a current or prospective client and seek to contact us through the Websites about how Kavaliro can help your business or organization, we may collect information that includes:

  • your location and contact information, such as your name, email address, phone number, and job title;
  • information about your business or organization, including the name and location of your business or organization, the location of the project or position for which you are seeking our assistance, and information regarding your organization’s projects and hiring needs; and
  • any other information you submit when you use or contact us through the Websites, including any information you provide in a submission through “Comments” fields in our contact forms.

If you are a career seeker and use the Websites to contact us about working with Kavaliro, we may collect information that includes professional and employment-related information, such as your resume, cover letter, location, and any other information you choose to provide in employment inquiries or applications.

If you use the Websites to participate in our Referral Programs, we will collect your name, email address, and phone number, and any information about the referral that you choose to provide, including contact information for the individual or the company that is the subject of your referral.

Information We Collect Automatically

We also may collect certain other information automatically when you visit the Websites, such as the following:

  • Browser and device information, such as device identifiers like IP addresses or MAC addresses, operating system information, browser information, usage information including the pages you visited and how long you viewed them, searches, links you click on, and other information about your interaction with the Websites and other online services.
  • Information stored in web-based technologies like cookies, pixel tags, log files, or web beacons, including browser type, portions of the online services visited, time spent on the online services, pages visited, referring URLs, links you click on, and other traffic and usage data.
  • Information collected in connection with analytics technologies, such as Google Analytics and other similar technologies, that permit us to learn more about how visitors use our online services. For more information about how Google Analytics uses and processes data, please visit https://www.google.com/policies/privacy/partners/.
  • Information that indicates your general location, including your IP address.

When you visit our Websites, third parties with whom we work may use cookies and other similar technologies to collect this information and other information about your online activities over time and across third-party websites or online services.

Information We Receive from Third Parties

We may also receive information about you from third parties who use the Websites to submit your information to us, such as in connection with our Referral Programs. That information may include any information that the party making the referral chooses to provide to us, which may include, without limitation, your field of expertise, your current role, your preferred role, and your contact information.

How We Use Your Information

We may use personal information that we collect for purposes that include the following:

  • providing the Websites and our services to you and others, including our clients;
  • for our internal business operations, such as evaluating, updating, and modifying our operations, including our services, Websites, applications, and marketing efforts, conducting research and analysis, developing new services, and performing other internal business operations, including as described elsewhere in this privacy policy;
  • communicating with you, our clients, our business partners, our service providers, and others, including responding to your requests and sending you promotional information;
  • for our and our clients’ recruitment and hiring purposes, including evaluating and processing your resume and employment application;
  • understanding how you and other users use the Websites and our services and to determine what features and services may interest our users and clients;
  • debugging, identifying and repairing errors, effectuating similar functional enhancements, and improving our Websites or other services;
  • storing information about your preferences, recognizing you when you use the Websites, and customizing your experience;
  • creating aggregate or deidentified data;
  • maintaining the safety, security, and integrity of our Websites, applications, technology assets, services, and our business;
  • protecting against malicious, deceptive, fraudulent, illegal, or other unauthorized activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity;
  • protecting the legal rights, property, safety, and security of our organization, workforce, users, clients, and others;
  • complying with applicable law, other legal requirements, and industry standards;
  • enforcing our policies, terms of use, or rights arising from contracts;
  • evaluating or participating in an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings; and
  • for such other purposes as you may authorize.

How We Share Your Information

To accomplish the purposes set out above, we may disclose personal information we collect about you:

  • to our clients;
  • to our affiliates and subsidiaries;
  • to our business partners, such as organizations that provide services to our clients;
  • to our contractors, service providers, and other third parties we use to support our organization, which may include support of any of the data uses described above;
  • to maintain the safety, security, and integrity of our Websites, applications, technology assets, services, and our business;
  • as necessary to comply with applicable law, other legal requirements, and industry standards;
  • to enforce our policies, terms of use, contracts, or other legal rights.
  • to protect against malicious, deceptive, fraudulent, illegal, or other unauthorized activity, and to participate in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity;
  • to debug, identify and repair errors, effectuate similar functional enhancements, and improve our Websites or other services;
  • to protect the legal rights, property, safety, and security of our organization, workforce, users, clients, and others;
  • to an actual or potential buyer, successor, or other organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceedings; and
  • to such other parties as you may authorize.

Your Choices

We provide you with choices with regard to your information.

You may choose not to provide the personal information we request through the Websites. However, in some cases, if you decide not to provide information we request, you may not be able to use certain features of the Websites, and we may not be able to provide the service or information you requested.

You may opt out of receiving our commercial email messages at any time by using the opt-out mechanism provided in the message.

You may be able to restrict the automatic collection of some information by the Websites through your device’s operating system or browser, or take other steps to block, manage, or delete cookies. Doing so, however,  may prevent you from using the functionality of the Websites. Some Internet browsers have a “do-not-track” feature that let you tell websites that you do not want to have your online activities tracked. At this time, the Websites do not respond to browser “do-not-track” signals.

Third Party Websites and Services

The Websites may include links to websites, applications, and services operated by third parties, either on our behalf or on their own behalf, that are subject to their own privacy policies. We encourage you to review those privacy policies, which apply to the information collected by those websites, applications, and services.

Additional Information for Residents of California

This section of the Policy applies only to consumers who reside in California (as used in this section, “consumers” or “you”) and to our processing of particular consumers’ or consumer households’ personal information (“California Personal Information”) that we collect through any means, including the Websites and other online and offline methods. California Personal Information does not include, and this section of the Policy does not apply to, information that is subject to exceptions from the California Consumer Privacy Act of 2018 (“CCPA”), such as deidentified information.

This section also does not address our processing of personal information of job applicants, employees, and contractors for human resources, employment, benefits administration, health and safety, and other similar business-related and legal compliance purposes.  If you are a California resident and are a job applicant, employee, or contractor, of Kavaliro, or an emergency contact or beneficiary of benefits provided to one of our applicants, employees, or contractors, please refer to our Human Resources Privacy Policy for California Residents available at https://www.kavaliro.com/human-resources-privacy-policy-for-california-residents/  for information regarding our collection, use, disclosure, and other processing of California Personal Information for human resources, employment, benefits administration, health and safety, and other similar business-related and legal compliance purposes.

Additionally, this section of the Policy applies only to the extent we direct the purposes and means of California Personal Information processing and otherwise qualify as a “business” under the CCPA.  It does not apply to our activities as a “service provider” to our clients, as that term is defined under the CCPA, or to California Personal Information that we process in that capacity.

A.                 California Personal Information We Collect and Process and the Purposes for which We Collect, Disclose, and Process It

We may collect, and may have collected in the preceding 12 months, the categories of California Personal Information described above in the “Information We Collect and How We Collect It” section of this Policy, which include:

  • Identifiers, including online identifiers.
  • Commercial information.
  • Internet and other electronic activity information.
  • Inferences drawn from your activity.
  • Geolocation data.
  • Sensory data, including audio information.
  • Other categories of personal information described in California law.

We may use, disclose, and otherwise process these categories of California Personal Information for the purposes set out in the “How We Use Your Information” section of this Policy.

We will retain the California Personal Information we collect and process for as long as required to satisfy the purpose for which it is collected and used (for example, for the time necessary for us to fulfill orders, provide you with customer service, answer queries, or resolve technical problems), unless a longer period is required or permitted by law, such as to fulfill our legal obligations or to establish, protect or defend legal claims.

B.            Sources of California Personal Information We Collect

We may collect California Personal Information:

  • directly from consumers;
  • automatically and indirectly from consumers, such as through logging and analytics tools, cookies, pixel tags, and other similar technologies; and
  • from third parties, such as individuals that participate in our referral programs; our service providers and business partners; our clients; and services that make user-generated content available to others, such as social media networks and similar online services.

C.            Sharing of California Personal Information for a Business Purpose

In the preceding 12 months, we may have disclosed the categories of California Personal Information listed below to the categories of third parties identified below for a business purpose:

  •  Identifiers, including online identifiers—with our affiliates and service providers.
  • Internet and other electronic activity information—with our affiliates and service providers.
  • Inferences drawn from your activity—with our affiliates and service providers.
  • Geolocation data—with our affiliates and service providers.
  • Sensory data, including audio information—with our affiliates and service providers.
  • Other categories of personal information described in California law—with our affiliates and service providers.

D.            Sales of California Personal Information and Sharing of California Personal Information for Cross-context Behavioral Advertising Purposes

We do not sell California Personal Information in exchange for monetary consideration. However, the CCPA defines “sale” very broadly in a manner that includes disclosing California Personal Information in exchange for any other valuable consideration, and also regulates the “sharing” of California Personal Information with third parties for cross-context behavioral advertising purposes, which means displaying advertising to you based on California Personal Information obtained or inferred from your activities over time across different websites, applications, and other online services we do not operate. Under the CCPA, we may “sell” or “share,” and we may in the preceding 12 months have “sold” or “shared,” the following categories of California Personal Information:

  • Identifiers, including online identifiers.
  • Internet and other electronic activity information.
  • Inferences drawn from your activity.

We may have sold or shared each of these categories of California Personal Information with third parties such as advertising networks that enable or participate in targeted and cross-context behavioral advertising, and analytics providers that provide online tracking technologies that we use to analyze use of the Websites.

We do not have actual knowledge that we sell California Personal Information of consumers under 16 years of age or share the California Personal Information of consumers under the age of 16 for cross-context behavioral advertising purposes.

E.            California Personal Information Rights and Choices

The CCPA provides consumers with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise them.

  • Right to Data Portability. You may request obtain a copy of your California Personal Information in a portable and, if technically feasible, readily-usable format that allows you to transmit the California Personal Information to another person or entity without hindrance.
  • Right to Deletion. You may request that we delete your California Personal Information, subject to certain exceptions.
  • Right to Correction. You may request that we correct California Personal Information about you that is inaccurate. We will take into account the nature of the California Personal Information and the purposes of our processing when we address your request.
  • Right to Opt out of Sales of California Personal Information and Sharing of California Personal Information for Cross-context Behavioral Advertising. You may request that we not sell your California Personal Information or share your California Personal Information for cross-context behavioral advertising. You may make this request by visiting our Preference Center.

We have also configured our Websites to process opt-out preference signals that may allow you to inform us of your desire to opt out of sales or sharing as described in the above paragraph. Opt-out preference signals must be in a format commonly used and recognized by businesses and be delivered by a platform, technology, or mechanism that makes clear to consumers that the use of the signal is meant to have the effect of opting the consumer out of sales and sharing of California Personal Information as described above. If you do not have an account with us or are not logged into your account, your opt-out preference signal will be linked to your browser identifier only and may not be linked to other California Personal Information, such as account information, about you that we process that is not associated with your browser identifier.

If we receive an opt-out preference signal from you, we may offer you the option to provide additional information to help facilitate your opt-out request. We may also notify you if an opt-out preference signal we receive from you conflicts with your privacy settings or participation in certain programs we offer, and request your consent to sales or sharing of California Personal Information or to affirm your intent to withdraw from any relevant programs.

Even if you opt out of sales or sharing of your California Personal Information for cross-context behavioral advertising, you may still see our ads online at other sites and apps, and we may still base aspects of ads on your interactions with us and the Websites.

  • Right to Access to Specific Information.  You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your California Personal Information during the applicable time period for your request. If we receive a request from you pursuant to the “Exercising Your Rights” section below and confirm the request, we will disclose to you, depending on the scope of the request:
    • The categories of California Personal Information we collected about you.
    • The categories of sources for the California Personal Information we collected about you.
    • Our business or commercial purpose for collecting California Personal Information about you, selling California Personal Information about you, or sharing California Personal Information about you for targeted or cross-context behavioral advertising.
    • The categories of third parties to whom we disclose your California Personal Information.
    • The specific pieces of California Personal Information we collected about you.
    • If we disclosed your California Personal Information for a business purpose, sell your California Personal Information, or share your California Personal Information for cross-context behavioral advertising purposes, a list of the categories of third parties to whom we disclosed your California Personal Information for a business purpose, sold your California Personal Information, and shared your California Personal Information for cross-context behavioral advertising purposes identifying the categories of California Personal Information disclosed to those parties during the applicable time period for your request.
  • Exercising Your Rights. To exercise the rights described above you may submit a verifiable consumer request by either:
    • Calling us at (407.243.6006); or
    • Emailing us at contactus@kavaliro.com.

Only you, or an agent that you authorize to act on your behalf in accordance with applicable law, may make a verifiable consumer request related to your California Personal Information. You may also make a verifiable consumer request on behalf of your minor child

Your request must provide information sufficient to verify you are the person about whom we collected California Personal Information. In order to verify your request, we may ask you to provide information such as your first and last name, address, email address, phone number, and any other information necessary to verify your identity. Your request must also include sufficient detail for us to properly understand, evaluate, and respond to it.

You may designate an authorized agent to submit requests on your behalf through a valid power of attorney in certain circumstances or through signed written permission that authorizes the agent to act on your behalf. We may require additional information when requests are submitted through an authorized agent, such as requiring the submission of signed written permission for the agent to act on your behalf and requiring you to verify your identity directly with us or to confirm the authorized agent’s permission to act on your behalf directly.

We cannot respond to a request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.

If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision. We reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.

  • Non-Discrimination. Subject to certain exceptions, you have a right to not receive discriminatory treatment for exercising your rights as described above.

Changes to this Policy

We may update this Policy to reflect changes in our privacy practices at any time and without prior notice to you. When we do so, we will update the effective and last updated date above. We encourage you to periodically review this Policy for the latest information on our privacy practices.

Contacting Us

If you have any questions or comments about this Policy or our privacy practices, please contact us by email at contactus@kavaliro.com

CONTACT US

Mailing Address:

Kavaliro. Attn: Terms of Use / Privacy Policy

12612 Challenger Parkway Suite 400 Orlando, FL 32826

Email Address: contactus@kavaliro.com

Please note that e-mail communications will not necessarily be secure; accordingly, you should not include credit card information or other sensitive information in your e-mail correspondence with us.