Privacy Policy

Website kohorta.co and its related services are owned and operated by Roman Kozak, Individual Entrepreneur, and Olga Gozha, Individual Entrepreneur. Kohorta Studio (“Kohorta Studio”, “our”, “us”, “we”) has adopted this Privacy Policy (“Privacy Policy”) to inform you that it collects Personal Information when you use the Website or other services and to explain how this information is used. You should contact Kohorta Studio directly with any questions or concerns. 

KOHORTA STUDIO MAY CHANGE, MODIFY, AMEND, SUSPEND, TERMINATE, OR REPLACE THIS PRIVACY POLICY FROM TIME TO TIME AND WITHIN ITS SOLE AND ABSOLUTE DISCRETION. IN THE EVENT KOHORTA STUDIO CHANGES, MODIFIES, AMENDS, OR REPLACES THIS PRIVACY POLICY, THE EFFECTIVE DATE, LOCATED ABOVE, WILL CHANGE.  YOUR CONTINUED USE OF THE WEBSITE AFTER A CHANGE IN THE EFFECTIVE DATE OF THIS PRIVACY POLICY CONSTITUTES YOUR MANIFESTATION OF ASSENT TO THE CHANGE, MODIFICATION, AMENDMENT, OR REPLACEMENT CONTAINED WITHIN.

Definitions.

• California Consumer Privacy Act (“CCPA”) means the California statute intended to enhance privacy rights and consumer protection for residents of California, United States.
• General Data Protection Regulation (“GDPR”) means the European Union (“EU”) law on data protection and privacy applicable to individuals within the EU.
• Personal Information under the GDPR means any information relating to an identified or identifiable natural person,  an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Personal Information under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  For purposes of this Privacy Policy, “Personal Information” is included within this definition.
• “Account(s)” means a Registered User’s or an Organization’s account that is required for access to and use of Kohorta Studio’s website.
• “Account Administrator(s)” means the individual(s) responsible for and in control of the Organization’s Account, including creation and payment. Account Administrators can either create their Organization’s Account or join Kohorta  independently and subsequently join their Organization.
• “Member(s)” means individuals who are part of an Organization and granted access to an Organization’s Account.
• “Organization(s)” means the business, company, entity, or group that the Account Administrator creates an Account for.
• “Guest(s)” means an individual who is not a Member of a particular Organization but is granted limited access to that Organization’s Account.
• “Registered User(s)” means Organizations, Account Administrators, Members, and/or Guests.
• “User(s)” means all individuals that visit and access the website, including Registered Users.
• “You / Your / You’re” means Users.

Types of Personal Information We Collect.

Kohorta collects the following Personal Information from Organizations:

• Business name;
• Business address;
• Billing address;
• Any other information that you upload or submit to the Website directly or indirectly

Kohorta collects the following Personal Information from Members:

• Full name;
• Business name;
• Email address;
• Phone number (optional);
• Any other information that you upload or submit to the Website directly or indirectly.

Kohorta collects the following Personal Information from all Users who contact Kohorta seeking more information:

• Full name;
• Email address;
• Phone number;
• Any other information that you upload or submit to the Website directly or indirectly.

In addition, Kohorta collects the following Personal Information from all Users who visit and use the Website:

• Your geolocation;
• Your IP address;
• Your browser and search engine information;
• Your device information;
• Your visitor history;
• Your usage of the Website, including, without limitation, any links or items clicked or pages viewed and statistics;
• Information stored in cookies, pixel tags, or web beacons;
• Analytical data from HubSpot, Google Analytics and/or Google AdSense; and
• Any other additional analytic data that you voluntarily submit to the Website.

Sources of Personal Information.

Kohorta may collect this Personal Information from you through various channels, including, but not limited to, through your voluntary submission of information to the Website, through requests initiated by you through the Website, through the collection and analysis of information concerning your computer and browsing activities, through the use of cookies, web beacons, pixel tags, Google Analytics, Google AdSense, and through other sources permitted by law.

Cookies & Similar Technologies.

The Website also utilizes Cookies.  Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the Cookie. We use Cookies and similar technologies to enable our systems to recognize your browser and to provide certain features.  We also use “web beacons” to help deliver Cookies and gather usage and performance data. The Website may also include Cookies, web beacons, and other similar technologies from third-party service providers.

You have a variety of tools available to control the data collected by Cookies, web beacons, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use Cookies and to withdraw your consent by clearing or blocking Cookies. You can also stop Kohorta from placing Cookies (other than those required for the Website to function) on your device by referencing the instructions below or opting out using the Cookie notification opt-out on your initial visit to the Website.

The table below sets out how we use different categories of cookies and similar technologies, as well as information on your options for managing the settings for the data collection by these technologies:

Lawful Basis for Processing Your Personal Information

The lawful basis for us processing your Personal Information for the uses described above will typically be because you have provided your consent; it is necessary for our contractual relationship; the processing is required for us to comply with legal obligations; and/or the processing is in our legitimate interest of providing you with the Kohorta Studio online website.

How Kohorta Studio Uses Your Personal Information.

We use your Personal Information based upon the legal basis of Users’ consent to provide you with the Website, process any requests made by you, communicate with you, identify and fix problems with the Website, and update you regarding changes to the Website and the Kohorta Studio and third-party services offered through the Website. 

By using the Website, you further authorize the following specific uses of your Personal Information:

• Enable your use of the Website and its associated services;
• Improve algorithms;
• Measure service usage;
• Develop new features;
• Contact and communicate with you, whether through email, telephone, text message, and/or messages within the Website;
• Customize and/or tailor the Website and your user experience, which may include targeted selection and display of third party advertisements within the Website;
• Aggregate certain information that does not include your personal information and disclose it for analysis, demographic profiling and/or targeted advertising;
• Advertise products and services of Kohorta Studio or its affiliates;
• Transmit and process your information and actions within the Website;
• Provide statistical information, and include you in the same, where applicable;
• Provide you with technical service and support, including updates;
• Provide you with information concerning Kohorta Studio’ benefits or services or those of its affiliates;
• Store, archive, retrieve, and make copies of your user generated content;
• Understand your needs and requests;
• Communicate promotions or other offers;
• Prevent and detect illegal activities or violations of your Terms of Use;
• Combine your personal and personally identifiable information with information from other Kohorta Studio applications and/or services; and
• Facilitate your use of the Website and upgrades/replacements to the Website.

Sharing of Your Personal Information.

Kohorta Studio Shares Your Personal Information with third parties in the following circumstances:

• Where Kohorta Studio has obtained your consent;
• Where sharing or disclosure of your Personal Information is necessary to provide you with the Website, and/or associated services (We may also share your personal or personally identifiable information with trusted third-parties who assist us in operating the Website, providing the associated services, and conducting our business);
• Where sharing or disclosure of your Personal Information is necessary pursuant to a campaign with Facebook and/or Instagram;
• Where sharing or disclosure of your Personal Information is necessary to share personal or personally identifiable information with Kohorta Studio’ parents, subsidiaries, successors, assigns, licensees, affiliates, or business partners;
• Where Kohorta Studio has been purchased by a third party;
• Where sharing or disclosure of your Personal Information is necessary to respond to requests by government authorities;
• Where your Personal Information is demanded by a court order or subpoena;
• Where sharing or disclosure of your Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or owners/shareholders of Kohorta Studio;
• Where sharing or disclosure of your Personal Information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty; and
• Where Kohorta Studio is otherwise legally obligated to share your personal or personally identifiable information.

Kohorta Studio Shares Your Personal Information With the Following Third-Parties:

• Google, including Google Analytics (privacy policy here);
• HubSpot (privacy policy here);
• Stripe (privacy policy here)

No Liability Third-Party Services and Third-Party Links.

The third-party service providers affiliated with Kohorta Studio have their own independent privacy policies governing the use of your Personal Information pursuant to the GDPR and CCPA (if applicable) and we encourage you to read those privacy policies carefully.  You understand that even if Kohorta Studio deletes your Personal Information that it may still be available in a third-party service provider’s database.  Kohorta Studio has no responsibility or liability for the Personal Information collection, use, or storage activities of the third-party services providers used by Kohorta Studio to provide you with the services associated with the Website.

Kohorta Studio may outsource or subcontract some of our technical support, tracking and reporting functions, database management functions, and other services to third parties. We may share information from or about you with them so that they can perform their services as long as they comply with this Privacy Policy, the GDPR, and the CCPA (if applicable).  You understand and agree that Kohorta Studio will not be held responsible for any third-party communications sent by entities that Kohorta Studio does not own or control.  You are encouraged to review any third-party privacy policies before utilizing any such third-party service.

Kohorta Studio may include or offer third-party products or services on the Website and provide third-party links to the same.  These third-party websites have separate and independent privacy policies.  Kohorta Studio has no responsibility or liability for the content and activities of such third parties or their websites.  We encourage you to read carefully the privacy policies of all such third-party websites.  We seek to protect the integrity of the Website and therefore welcome any feedback about any such third-party websites.

Personal Information Transfer and Storage.

Your Personal Information is stored and processed on computers and servers in the United States and through your use of the Website, you consent to the processing and storage of your Personal Information and personally identifiable information.  You understand that your Personal Information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction.  If you are located outside the United States and choose to provide Personal Information to us, please note that we transfer your Personal Information to the United States and process it here, and that we may store portions of your Personal Information in the United States.

Website Users understand and agree that if they provide Kohorta Studio with Personal Information that it is stored indefinitely, unless the User contacts Kohorta Studio to have their Personal Information removed from storage.  As specified above, even if Kohorta Studio deletes your Personal Information from its own serves, it may still be available in a third-party service provider’s database.  You should consult with those third-parties in the event you would like Personal Information deleted therefrom. 

Personal Information Security.

Kohorta Studio uses standard technology to store and help prevent against the unauthorized disclosure of your Personal Information. Though we undertake commercially reasonable efforts to protect your information, no website, software, or online service is completely safe. Accordingly, you provide all such information at your own risk.

In order to protect your Personal Information, Kohorta Studio uses specific security measures, such Secure Sockets Layer (SSL) protocol, which encrypts information you input at 128-bit strength. This is denoted in most web browsers by a small padlock appearing on the bottom bar of the window and the address of the window changing from http:// to https://, indicating a secure connection.

EU Users’ Rights Under the GDPR.

The GDPR provides Users located in the EU under its protection certain rights with respect to their Personal Data collected by us on the Website.  Accordingly, Kohorta Studio recognizes and will comply with the GDPR and those rights, except as limited by applicable law.  The rights under the GDPR include:

• Right of Access: This includes the right to obtain from us your Personal Information and whether it is being processed, along with the purposes of the processing; categories of Personal Information concerned; recipients to whom your Personal Information has been disclosed; the period for which your Personal Information is being stored; and the right to lodge a complaint.
• Right of Rectification: This includes the right to correct inaccurate Personal Information collected and/or stored by us.
• Right of Erasure (“Right to be Forgotten”): This includes the right to have your Personal Information deleted.  However, if applicable law requires us to comply with your request to delete information, fulfillment of your request may prevent you from using our services and may result in closing your account.
• Right to Restriction of Processing: This includes the right to request restriction of how and why your Personal Information is used or processed by us.
• Right to Data Portability: This includes the right to receive your Personal Information in a structure, readable format and the right to have your Personal Information transferred.
• Right to Object: This includes the right to object to us processing your Personal Information for reasons such as direct marketing purposes and for scientific or historical research or statistical purposes.
• Right to not be Subject to Automated Decision-Making: This includes the right to not be subject to a decision based solely on automated processing, including profiling, that could have a legal, or similarly significant, effect on you from being made solely based on automated processes.

California Users’ Rights.

Under the CCPA, California Users have the following rights:

• Right of Access to Personal Information: You have the right to request that Kohorta Studio disclose certain information to you about our collection and use of your Personal Information over the past 12 months, including the type of Personal Information collected about you, the sources of Personal Information, and the third parties with whom we share that Personal Information.
• Right to Have Personal Information Deleted:  You have the right to request that Kohorta Studio delete any of your Personal Information that we collected from you and retained.
• Right to Request that Personal Information not be Sold:  Kohorta Studio does not sell Personal Information, but still allows Users to request that their Personal Information not be sold.
• Right to Non-Discrimination:  Kohorta Studio shall not discriminate against California Users for exercising their rights under the CCPA.

To exercise your rights under the CCPA, you may submit a request to Kohorta Studio by contacting Kohorta Studio at info@kohorta.co.

Under California’s “Shine the Light Law,” California residents have the right to receive information that identifies any third-party companies or individuals that Kohorta Studio has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting Kohorta Studio at the address below.

Purchase or Sale of the Website or Other Assets.

Kohorta Studio may purchase other businesses or sell components of its business, including, but not limited to, the Website. In the event Kohorta Studio purchases another business or sells any component of its business, your Personal Information will continue to be used consistent with the terms of this Privacy Policy.

How To Stop Kohorta Studio from collecting your Personal Information.

You can stop Kohorta Studio from collecting your Personal Information by contacting Kohorta Studio at info@kohorta.co and requesting that Kohorta Studio stop collecting your Personal Information.  Additionally, you can adjust your web browser settings to limit or turn off Cookies or other tracking techniques, or you can cease use of the Website.  You may contact Kohorta Studio with any requests regarding your Personal Information. Kohorta Studio also honors Do Not Track requests and signals.

Your Obligations.

When using the Website, you are obligated to inform Kohorta Studio of any changes to your Personal Information.

Children’s Online Privacy Protection Policy.

The Website is not intended for or directed to users under the age of 18, and Kohorta Studio does not knowingly or intentionally collect Personal Information from children under the age of 13 or other minors. Where appropriate, Kohorta Studio takes reasonable measures to determine that users are adults of legal age and to inform minors not to submit such information to the Website or in response to advertisements. If you are concerned that Personal Information may have been inadvertently provided to or collected by Kohorta Studio, please contact us immediately so appropriate steps may be taken to remove such information from Kohorta Studio’ database.

Contact and Notices.

All questions and concerns regarding this Privacy Policy may be submitted to Kohorta Studio at:

info@kohorta.co