PRIVACY POLICY

Updated: November 23, 2018

Kooltra Ltd. (“Kooltra,” “we,” “us,” “our,” or the “Company”) is committed to respecting your privacy. This Privacy Statement describes Kooltra’s privacy practices in relation to the websites, products, services and programs owned and operated by Kooltra. In addition, this policy states how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Statement.

We urge you to read this Privacy Statement so that you understand our commitment to you and your privacy, and how you can participate in that commitment. When you visit our website, or provide personal information to us through other means, you consent to the use of your information as described in the following sections of this Privacy Statement:

  1. Web sites covered

  2. Personal information we collect

  3. How we use and disclose personal information

  4. Customer data

  5. How Kooltra protects your data

  6. Collection of information from children

  7. Access and Choice

  8. Conflicts with this Privacy Statement

  9. How to contact us

Kooltra may review and update this Privacy Statement periodically to reflect changes to our privacy practices. We will provide notification of material changes to this Privacy Statement through our website or via email prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

1. Web sites covered

This Privacy Statement covers information practices, including how the Company collects, uses, shares and secures the personal information you provide, of websites that link to this Privacy Statement.

Kooltra’s website may contain links to other websites. The information practices or the content of such other websites is governed by the privacy statements of such other websites. We encourage you to review the privacy policies of other websites to understand their information practices.

2. Personal information we collect


This Privacy Statement applies to personal information and other information collected by Kooltra or its service providers from or about:

  1. Visitors to, or users of, its website;

  2. Prospective and current customers using our products or services;

  3. Service providers and business partners;

  4. Job applicants; and

  5. Other third-parties that it interacts with.

The personal information Kooltra collects includes the following:

Web registration information. Kooltra may require you to provide personal contact information such as your name, company name, address, phone number, and email address when: (i) expressing an interest in obtaining additional information about our products or services, (ii) registering to use our websites or other services, or (iii) registering for an event.

Website navigational information. Kooltra may collect certain information about you from your web browser when you visit our websites. This information may include your Internet Protocol ("IP") address, browser type, browser language, and the date and time of your request. This information could indirectly identify you and gathering this information from you helps us ensure our websites and other services work correctly in support of our customer analytic efforts.

Website Analytics. We may collect information about your use of our website through technology such as Google Analytics.

Email communication. We may use tags or web beacons in our emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. We use these tools to determine potential interest in particular topics, as well as measure and improve the effectiveness of our communications with you.

Job applications. We may collect personal information such as your name, email address, physical address, LinkedIn profile, phone number, compensation expectations and work history when you apply for a position with Kooltra through the careers section of our website. You also have the option to upload your resume that may include additional personal information.

Kooltra also utilizes third party recruitment firms for certain recruiting activities. Such firms send us potential candidate information such as name, email address, physical address, compensation expectations and work history.

Employee information. When you join Kooltra as an employee, we collect personal information such as your name, legal eligibility to work, physical address, email address, phone number, gender, background check information, dependent information, benefit information and bank information for payroll purposes.


Third party sources. Kooltra may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our services to you, and prevent or detect fraud. We work closely with third parties (for example, business partners, service providers, subcontractors, analytics providers and search information providers) and may receive information about you from them.

3. How we use and disclose personal information

Kooltra may use your personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your personal information to support our business functions, such as sales, marketing, services, recruitment and legal functions. For example, we may use this information to:

  • Fulfill requests;

  • Send product and services updates;

  • Respond to customer service requests;

  • Send marketing communications;

  • Improve our websites and marketing efforts;

  • Conduct research and analysis;

  • Comply with legal and/or regulatory requirements;

  • Respond to questions and concerns; and

  • Process employment applications and background checks.

Apart from using your personal information to support our own business functions, we may disclose your personal information under the following conditions:

Disclosure of personal information to third parties. Kooltra will not trade, rent, sell, or otherwise transfer your personal information to others, but may disclose personal information with third-party vendors and service providers that work with us. We will only share personal information to these vendors and service providers to help us provide a product or service to you. Examples of third parties we work with are background check agencies, benefits providers, financial institutions and other service providers that provide corporate functions to us such as human resources and customer relationship management. These third parties only have access to personal information necessary for them to perform their services.

Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own purposes. Your personal information may be maintained and processed by our affiliates and other third party service providers in the U.S.

Disclosure of personal information for legal and safety reasons. Kooltra may be required to disclose personal information to regulatory authorities, law enforcement agencies or government agencies. We may disclose information to:

  • comply with valid legal process as authorized by law;

  • respond to lawful requests by public authorities, including to meet national security or law enforcement requirements;

  • in the event of an emergency that threatens an individual's life, health, or security; or

  • to the extent permitted by applicable law, in special cases in which we believe it is reasonably necessary to investigate, identify, or take preventive measures or bring legal action against someone who may commit or cause harm, fraud, abuse, or illegal conduct, such as a threat of harm to you or anyone else, interference with our rights or property, or interference public safety.

Disclosure of personal Information via links to third party services and applications. Using our website or services may link you to third party websites, services, and applications. Kooltra is not responsible for any personal information collected by such third parties, which use is governed through the third party's website's privacy policies. Any interactions you have with these websites, services, or applications are beyond our control. When you post information to or through such services, those websites' privacy policies apply. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.

Sale of Business. We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our operations or as part of a corporate reorganization or stock sale or other change in corporate control.

4. Customer data

Kooltra’s customers may electronically submit data or information to us for hosting and processing purposes (“Customer Data”). In accordance with the Kooltra policy, Kooltra will access Customer Data only for providing our products and services or for preventing or addressing service or technical problems (at a customer’s request in connection with customer support matters), or as may be required by law. Kooltra will not otherwise review, share, distribute, or reference any Customer Data except as authorized by the applicable customer.

Kooltra may transfer personal information to third party companies that help us provide our products and services. Transfers to subsequent third parties are covered by the provisions in this Privacy Statement regarding notice and choice and the subscription and service agreements with our customers.

Kooltra acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by a Kooltra customer and you wish to exercise any rights you may have to access, correct, amend, delete, or limit uses or disclosures of such data, please inquire with our customer directly. Because Kooltra personnel have limited ability to access data our customers submit to our products and services, if you wish to make your request directly to Kooltra, please provide the name of the Kooltra customer who submitted your data to our products and services. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

5. How Kooltra protects your data

Security of your information is of the utmost importance to us. Kooltra uses reasonable security practices, including technical and physical safeguards, to protect the security of your personal information from misuse and unauthorized access and disclosure. Nevertheless, such security measures cannot prevent all loss, misuse, alteration, or unauthorized access or disclosure of personal information, and we are not able to guarantee absolute security.

6. Collection of information from children


The Company recognizes the importance of protecting the privacy and safety of children. Our websites and services are directed towards the general audience and are not directed towards children. We do not knowingly collect information about children under the age of 13 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 13 has provided personal information through one of our websites, we will use reasonable efforts to remove that information from our databases.

7. Access and choice

Kooltra may retain your information for a period of time consistent with the original purpose of collection, legitimate business interests, to conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

We acknowledge that you have the right to access your personal information. Upon request, Kooltra will provide individuals with reasonable access to their personal information, and in doing so allow individuals the opportunity to, under certain circumstances, correct, amend, update, or delete that information or limit uses and disclosures of that information. A request may be denied under certain circumstances, such as where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question, or where the rights of persons other than the individual would be violated. For requests to access, correct, modify, delete, or limit uses or disclosures of your personal information, please contact us using the information in the “How to contact us” section below.

Requests will be addressed within a reasonable timeframe. If you are an employee of Kooltra, you may also wish to contact your team lead for assistance in correcting or updating your information. As noted above, if we are hosting or processing your personal information on behalf of a customer, requests to access, correct, modify, update, delete, or limit uses or disclosures of your personal information should be made through the customer.

8. Conflicts with this Privacy Statement

This Privacy Statement may not apply to the extent it conflicts with other controlling terms and conditions (such as, for example, an agreement for our products and services between Kooltra and you or your organization) or applicable law or regulation.

9. How to contact us

Any questions, inquiries, complaints, and requests related to this Privacy Statement can be directed to our Chief Information Security Officer by email at privacy@kooltra.com or by mail at:

Kooltra Ltd.
26 Soho, Suite 300, Toronto, ON, Canada
M5T 1Z7