Privacy Policy

Calamu respects your privacy, and its protection is important to us. This privacy policy applies to the personal information we obtain as a result of your transactions and interactions with us, including through your use of our websites and any app (together, the “Site”) we might offer. It describes the types of personal information referenced below (together, the “Personal Information”) that we collect from users of the Site, how we use the information, with whom we share it, and the choices available to our customers and others regarding our use of their information. It also describes measures we take to protect the security of that information and how you may contact us to exercise your rights and options. Your use of the Site is conditioned upon your acceptance of all the terms, conditions, policies and notices stated here, which you accept by continuing to utilize the Site.

Contents of this Policy:

1. SCOPE AND UPDATES

2. INFORMATION COLLECTED

3. USE OF PERSONAL INFORMATION

4. SHARING PERSONA

5. SECURITY

6. OPT-OUT

7. CALIFORNIA PRIVACY RIGHTS

8. DISCLOSURE FOR LEGAL PURPOSES

9. ASSIGNMENT

10. EUROPEAN UNION GENERAL DATA PROTECTION REGULATION

11. DISPUTES

1. SCOPE

1.1 Calamu collects Personal Information from individuals when they register with us, log-in to their account, complete surveys, request information, purchase products or become employees. Although some areas of the Site may be accessed by you without having to disclose any personal information, you may be asked to provide certain kinds of Personal Information, such as your name, email address, mailing address, telephone number, title, tax information, company name, username and password, and other information that might identify you as an individual. The Personal Information may be combined or supplemented with information from other sources. It will be handled by us as provided in this privacy policy.

1.2 If there is anything you do not understand about this privacy policy or the terms of service, please contact us at admin@calamu.com. If at any time you do not agree to this privacy policy or the terms of service, please do not use the Site.

1.3 We reserve the right to update this privacy policy by posting updates on the Site. They will be effective when posted. Updates may make material changes, and we urge you to review them carefully whenever they are made. You can tell if updates have been made checking the last modified date that appears at the end of this privacy policy. Because your continued use of the Site following any posting will constitute your acceptance of the updated privacy policy, we urge you to check this privacy policy from time to time for updates.

2. INFORMATION COLLECTED

2.1 We collect information provided by you directly to us on the Site, such as when you create an account, order a product or request service or otherwise directly contact us. If you do not provide required information for a particular activity, you may not be able to complete what you are attempting to accomplish on the Site.

2.2 The Site uses cookies, which are small pieces of information delivered to your hard drive by your browser. Our website uses cookies to analyze trends, support website management, track visitor activity, and to gather demographic and device details. These cookies assist us to customize, personalize and maximize your site experience, including remembering your preferences and improving search results. The cookies also aid us to spot and stop malicious website visitor activity. By continuing to use our Site, you are agreeing that you are consenting to receive cookies. If you would like to turn off cookies, you can do so in your browser settings, but certain features of the Site may no longer be fully available to you. Some of our services use Google cookies including Google Analytics. To opt out of Google’s advertising, visit Google’s Ad Preference Manager.

2.3 Examples of Personal Information that may be collected include: your browser, type of device and its IP address, operating system, your Internet, service provider; pages you visit on the Site, and geographic location. Cookies may also collect information about your interactions with communications, such as whether emails were opened, if links in those emails were clicked, and server log information.

2.4 We collect email addresses and information related to marketing services. When you use the Site, you may, for example, be given the option to subscribe to an email list or request certain resource materials or to subscribe to any list or newsletter. Subscriptions to the email list can be cancelled at any time.

3. USE OF PERSONAL INFORMATION

We may use your Personal Information for various purposes, including to:

• Authenticate your identity when you come to the Site;

• Provide you with services;

• Enable you to participate in special activities and offers, and to communicate with you about them.

• Continually maintain the accuracy of information we hold about our customers.

• Conduct market research.

• Aggregate and analyze user data.

• Provide you with information that may be of interest to you.

• Send you administrative or relationship notices or notices required by law.

• Send electronic communications, including company announcements, alerts, notices and updates, if given prior authorization.

• Provide others with your Personal Information for the limited purposes described in this privacy policy.

4. SHARING PERSONAL INFORMATION WITH THIRD PARTIES

4.1 We may share Personal Information and information collected about you. We do not share your information with third parties except as set in this privacy policy.

4.2 We may also disclose your Personal Information to others who help us develop, market, and sell products and services and who help maintain and operate the Site. We may work with third parties to: (a) manage databases of customer information; (b) assist in distributing emails; (c) assist with marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service and other services; (h) administer mailings, messaging and deliveries; and (i) administer IT systems. We require any outside vendors to agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.

4.3 In order to determine your financial eligibility for a product or paid service ordered by you, we may disclose your Personal Information to third-party financial institutions, consumer reporting or credit agencies to determine your eligibility.

4.4 Your Personal Information may be shared if we seek investors or go through a business transition, such as a merger, acquisition by another company, or a sale of all or a portion of our assets. Our collection of Personal Information will likely be among the assets transferred in the event of a sale or partial sale of our assets or equity in our business.

4.5 We may disclose your Personal Information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect

against misuse or unauthorized use of the Site, to protect our rights, or to protect the rights, property or safety of other users of the Site.

5. SECURITY

We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access.

6. OPT- OUT

You may opt out of receiving email communications from us by clicking the “unsubscribe” button at the bottom of emails we have sent you or by emailing us at admin@calamu.com and including the word unsubscribe in the subject heading. Please allow up to ten (10) business days for changes to your preferences to take effect. During that time, you may continue to receive communications from us that were already in process.

7. CALIFORNIA PRIVACY RIGHTS

7.1 Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of Personal Information we

share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit an email request to the following email address: admin@calamu.com and include the words California privacy rights in the subject line; in the body of the request, give the domain name of our website with respect to which you are requesting the information, as well as your name, street address, city, state, and zip code.

7.2 In addition, please note the following:

(a) Users can visit the Site anonymously.

(b) Users will likely be notified by email of any changes on our privacy policy page but notification cannot be guaranteed.

(c) Some Internet browsers include the ability to transmit “Do Not Track” signals that give you control over the collection and use of web browsing information. Because uniform standards for “Do Not Track” signals have not yet been adopted, we may not process or respond to any such signals in users’ web browsers.

(d) We do not authorize the direct collection of Personal Information on the Site by third parties.

8. DISCLOSURE FOR LEGAL PURPOSES

You hereby authorize us to disclose any of your Personal Information pursuant to judicial and administrative proceedings and to law enforcement or government agencies. In the event of an investigation of improper or illegal conduct in connection with our Site, such as fraud, misrepresentation, intellectual property infringement, data breach, or other activity that may put us at risk for liability, you also authorize us to disclose Personal Information.

9. ASSIGNMENT

We may freely assign our rights under this privacy policy and delegate any of our obligations under it.

10. EUROPEAN UNION DATA PROTECTION REGULATION

10.1 If you are protected by the European Union General Data Protection Regulation (EU 2016/679) (“GDPR”) or English Data Protection Law, we shall process your Personal Information in accordance with our privacy notice. Your rights in relation to Personal Information processed under the GDPR are, without limitation:

10.1.1 The right to be informed about our processing of your personal data.

10.1.2 The right to request access to personal data that we hold about you at any time.

10.1.3 The right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you.

10.1.4 The right to object to processing of your personal data and to withdraw any consent you have given us and to opt out of any marketing communications that we

may send you.

10.1.5 The right to prevent processing that is likely to cause damage or distress to you or anyone else.

10.1.6 Certain rights in relation to automated decision-making processes, including the right to object to profiling.

10.1.7 The right to request that we erase or destroy your personal data in certain circumstances (the right to be forgotten) for example, when the data are no longer

necessary for the purpose for which we collected them;

10.1.8 The right to have your personal data provided to you by us in a structured, commonly used and machine-readable format and the right to have those data transmitted to another data controller. This is known as the right to data portability.

If you wish to exercise any of the above rights, you should email us at admin@calamu.com.

You have the right to lodge a complaint with your local European Union Member State Data Protection Authority.

11. DISPUTES

11.1 This privacy policy will be interpreted in accordance with the laws of the State of New York and the United States of America, without regard to their conflicts-of-law

provisions. By visiting the Site, you agree that, except as otherwise specified in this privacy policy, you agree to the foregoing. Disputes under this privacy policy will be resolved as set forth in the terms of service.

DATE LAST MODIFIED: February 26, 2021