This Privacy Policy was last updated on August 5, 2024.
CALIBO, INC. (collectively also referred to as “Calibo,” “we,” “our,” “us”) is in the business of providing a self-service, cloud based integrated digital Platform.
This Privacy Policy governs the collection, storage, and use of your personal data as a user of Calibo website (“Website”), Calibo platform, Calibo services, or attendees of Calibo events (collectively “Calibo Services”). This policy provides you with details about the personal data we collect from you, how we use it and your rights to control personal data we hold about you. This policy is addressed to users located both in the United States and European Union.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO USE THE CALIBO SERVICES, YOU AGREE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, DO NOT PROVIDE US WITH YOUR PERSONAL DATA.
When you use our Calibo Services we collect only the information and personal data you have agreed to provide us that is necessary to provide you with the services you have requested. Depending on the jurisdiction, information about you may be called “personal information,” “personally identifiable information,” or just “personal data.” In this Privacy Policy, we call it both personal data and personal information in an effort to match the jurisdictional preference.
Through your use of the Calibo Services, we may request some or all of the following information:
If you become a registered user or if you conduct transactions through Calibo Services, we will collect information about the transactions you engage and other activities in while using Calibo Services. This information may include, without limitation, locations where we offer our events that you visit; transaction types; content that you view, download, or submit; transaction amounts; payment and billing details, as well as the nature, quantity, and price of the goods or services you might exchange; and the individuals or entities with whom you communicate or transact business while engaging with Calibo Services.
Some of this personal data, including name, company, and contact information, will only be collected if you voluntarily provide it during the user registration process. We may also track information such as the domain name and the name of the web page from which you accessed our Calibo Services, and how much time you spend on each of our web pages. We collect information that is combined with other web visitors' information, such as how many times visitors click on each web page and the methods by which our Calibo Service was found.
We may collect IP addresses and Website usage information from you when you use our Calibo Services via the use of "cookies." An IP address is a number that is assigned to your computer when you are using your browser on the Internet. A cookie is a small file that is stored on your device that can facilitate easier future access when you return to our Website. We use cookies to deliver web content specific to you and to keep track of your online order activity. Cookies cannot pass viruses, harm your computer, or transmit private information such as an email address without the user's intervention. Cookies contain session identification numbers that allow our systems to recall previous sessions for authentication efforts and assemble information from our gathered data. You can configure your device's browser to alert you when a site is attempting to send you a cookie and to allow you to accept or refuse the cookie. Further information on how to prevent cookies from being stored on your device can be found on http://www.allaboutcookies.org under the ‘manage cookies’ section. Alternatively, you can access further information by going to the help menu within your internet browser. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
We use cookies to give you the best experience on our Website. If you continue without changing your cookie settings, we assume that you consent to our use of cookies on your device. You can change your cookie settings at any time, but if you do, you may lose some functionality when you visit our Website.
You will be asked to provide personal data in certain fields when browsing our Website that allow you to be able to use our Calibo Services. The personal data we collect is used only for the purpose we state at the time of collection or for purposes contained below. For example, our uses may include, but are not limited to, the following:
To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” the data, i.e., remove information that would confirm your identity. We will not use your personal data, however, to send commercial or marketing messages to you unless we have a legal basis for doing so, such as your consent or your contract with us when you purchase a product or service, in either case, you will have the ability to opt out of by sending an email to opt-out@calibo.com.
We do not collect personal data when you browse our Website and request pages from our servers unless you voluntarily and knowingly provide such information to us. This means that except for the IP address of your device that our Website’s session cookie will collect, we will not know your name, your email address, or just because you browse the Website unless you:
In these cases, we will know who you are based on the information you previously supplied to us. When you request a page from our Website, our servers log the information provided in the HTTP request header including the IP address, the time of the request, the URL of your request and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our Website function correctly and to provide you with the browsing experience that you expect. We also use this information to personalize content for you, better understand how visitors use our Website, and how we can better update our Calibo Services, and their content and functionality to meet your needs. We only use your personal information for those activities listed at the time you submit your information to us. For example, if you provide us with an email to inform you of special events, then that is what we will use your email address to do. If we would like to use your personal information for an unrelated activity, we will first request your consent to do so.
We may provide your personal data to third parties, or third parties may collect personal data from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested. Other than those who act on our behalf and except as explained in this Policy, personal data you provide to us through our Calibo Services will not be transferred to unrelated third parties, unless we have a legal basis to do so. However, please note that personal data provided to Calibo for our Calibo Services may be subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders. We will only provide this information after approximately two weeks following receipt of a valid subpoena or other legal process in a civil case.
Security of Personal Data
We are committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update them as necessary to meet our business needs, changes in technology, and regulatory requirements. We take our security obligations seriously and so should you. While we are responsible for maintaining the security of our Website, you must also access and use our Website in a manner that is both responsible and secure. We adhere to internationally recognized security standards. Our information security management system relating to client confidential data is described in the Calibo Services Security and Data Protection Addendum found on Calibo’s Website at www.calibo.com/legal. In addition, we have implemented a series of internal policies, procedures, and training to address data protection, confidentiality, and security, and we update and review the appropriateness of these measures on a regular basis.
Storage and Transfer of Personal Data
Personal data collected by Calibo may be stored and processed in your region, in the United States, or in any other country where Calibo, its affiliates, or contractors maintain facilities, including outside the European Union. We take steps to ensure that the data we collect under this Privacy Policy is processed pursuant to the regulations and requirements of the applicable laws where the data is located. For further details, see our Data Privacy Addendum on our Website at www.calibo.com/legal/. Calibo also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within Calibo or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to the laws applicable to those jurisdictions. If you would like to know more about our data transfer practices, please contact info@calibo.com.
Retention of Personal Data
Calibo retains personal data for as long as necessary to provide the Calibo Services you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (such as may be required by a statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will destroy or anonymize that information.
We respect your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Calibo Services, you may decline. However, if you choose not to provide data that is necessary to receive Calibo Services, you may not have access to certain features or services on our Website.
Access to personal data: You have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing your personal data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant personal data. We may also charge you a fee for providing you with a copy of your personal data (except where this is not permissible under applicable law).
Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information. Please note that such a request could be refused because your personal information is required to provide you with the products or services you requested, for example, to deliver a product or send an invoice to your email address, or because it is required by the applicable law. Please note: Iowa (effective Jan. 1, 2025) and Utah (effective December 31, 2023) do not provide individuals with the right to correct.
Opt-Out of certain data processing: In some jurisdictions, you have the right to restrict a business’s ability to process personal information about you. Residents of California have the right to opt out of certain data processing for sensitive data, which is defined in the paragraph below entitled “Right to Opt-Out”. Please note: Residents of Colorado, Connecticut, Utah, and Virginia have the right to opt out of processing for profiling/targeted advertising purposes.
Right to Opt-Out: There is a right to opt out of collecting sensitive personal information in California. Under the California Consumer Privacy Act (as amended by the California Privacy Rights Act) (“CCPA”) sensitive personal information (“SPI”) is defined as personal information that reveals the following: (1) a consumer’s social security, driver’s license, state identification card, or passport number; (2) a consumer’s 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; (3) a consumer’s precise geolocation; (4) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (5) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (6) a consumer’s genetic data; (7) the processing of biometric information for the purpose of uniquely identifying a consumer; (8) personal information collected and analyzed concerning a consumer’s health.; and (9) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation. SPI that is “publicly available” is not considered either sensitive personal information or personal information. Currently, Calibo processes SPI (as that term is defined under the CCPA) when collecting your account information, such as your login and password. Because Calibo limits its use of SPI to what is necessary to perform the services you reasonably expect, California residents would not have the right to limit this use. Importantly, Calibo does not process personal information for profiling or targeted advertising. Please note: Under other current U.S. state privacy laws (Virginia, Colorado, and Connecticut) account information (login and password) is not defined as SPI, thus, under these state privacy laws, Calibo does not process SPI.
Right to Opt-In: Unlike California, Iowa, and Utah, three U.S. states with current privacy laws (Virginia, Colorado, and Connecticut) require organizations to obtain affirmative opt-in consent to collect and use SPI.
Right to Opt-Out of Sales: The CCPA defines a "sale" as the disclosure of personal information for monetary or other valuable consideration. Calibo does not share, sell, rent, or trade your personal information with third parties for commercial purposes or for monetary or other gain. We do not share personal information for cross-context behavioral advertising within the scope of CCPA or sell or share personal information of California residents 16 years of age and younger.
If you are a California, Virginia, Utah, Connecticut, or Colorado resident and have an established business relationship with us and want to receive information about how to exercise your third-party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail). You may contact us in two ways.
Send us an email to: info@calibo.com.
Alternatively, you may send us a postcard or letter to:
CALIBO, INC.
1000 Town Center Drive, Suite 700
Southfield, MI 48075
Attn: Your California Privacy Rights
c/o Privacy Administrator
For requests sent via email you must put the statement “Your [insert your state of residence] Privacy Rights” in the subject field of your email. All requests sent via postal mail must be labeled “Your [insert your state of residence] Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code. (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile. We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.
If you are a California resident under the age of 18, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
In addition, if we process your personal information in reliance upon your consent, you can still contact us at any time to withdraw your consent.
We will respond to all legitimate requests within 30 days. If you exercise your right to: (1) opt out of the sale, (2) opt out of the sharing, or (3) to limit the use of SPI (assuming that Calibo even has your SPI), Calibo will cease using and disclosing the SPI as soon as feasibly possible. Requests that fall into these three categories will be fulfilled within 15 days of the request.
Opt-In for sensitive data processing: In some jurisdictions, applicable U.S. state privacy laws require organizations to obtain affirmative opt-in consent to collect and use SPI. Please note: Residents of California and Utah do not have this right.
Portability: You have the right to ask for a copy of your personal data and/or ask for it to be ported to another provider of your choice. You have the right to ask for a copy of your personal information and/or ask for it to be ported to another provider of your choice. Please note that such a request could be limited to only the personal information you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures. Please note: Residents of California, Colorado, Connecticut, Utah, and Virginia have the right to request personal information about the consumer to be disclosed in a common file format.
Automated decision making: In some jurisdictions, residents have the right to opt out of certain automated decision making. Residents of California have this right. Residents of Colorado, Connecticut, and Virginia only have the right to opt out of certain automated decision-making. Please note: Residents of Iowa and Utah do not have this right.
Private right of action: In some jurisdictions, residents may seek civil damages from a business for violations of a statute. Residents of California have a private right of action limited to certain violations only. Please note: Residents of Colorado, Connecticut, Utah, and Virginia do not have this right.
Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via email, postal mail, or telephone about Calibo Services that may be of interest to you, including newsletters. If you do not wish to receive our email marketing communications for promotional purposes, you may opt-out by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as telemarketing), please contact us using the contact details provided under the “Contact Information” section below.
Right to Non-Discrimination: Calibo will not discriminate against you for exercising your consumer rights under applicable privacy laws. Email communications you receive from Calibo will provide an unsubscribe link allowing you to opt-out of receiving future email or to change your contact preferences. Email communications may also include a link to directly update and manage your marketing preferences. See Section 7 for how to manage your contact preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important information related to your account.
Your European Union Privacy Rights
If you are in the European Union, under the General Data Protection Regulation (Regulation EU 2016/679) (also known as the GDPR), you may have certain rights as a data subject. A data subject is a person who can be identified by a name, identification number, location, online identifier, or other physical, physiological, genetic, mental, economic, cultural, or social identity of the person. Under the GDPR, personal data is information that relates to a data subject. There are six lawful bases under the GDPR by which we can process personal data., or in order to take steps at your request prior to entering into a contract. If the processing is based on your consent, you may at any time withdraw your consent by contacting us at privacy@calibo.com.
In order to enter into a contract to use our Calibo Services, you must provide us with the required personal data. If you do not provide us with all the required information, it will not be possible to deliver our Calibo Services.
To request information about or avail yourself of those rights, please send an email to privacy@calibo.com with "GDPR Request" in the subject line. In the email please describe, with specificity, the GDPR right you are requesting assistance with. Please note we may request additional information from you prior to responding to your request, and we reserve the right to charge a fee with respect to certain requests. Upon Calibo’s completion of our review of your request, we will notify you if your request has been granted, denied, or if exemptions apply.
The Purpose and Legal Basis for Collection
Under the GDPR, there must be a lawful basis for processing personal data. There are six lawful bases, and they are consent, contract, legal obligation, vital interests, public task, and legitimate interests. As part of our compliance with the GDPR, we intend to use your personal data for the purpose of providing you the services you have requested in your contract with us. Our lawful bases for collecting and processing your personal data is both contract and consent.
The Legitimate Interest
In adherence with the GDPR, we have a legitimate interest which allows us to process your personal data. This legitimate interest is to provide the services you have requested in your contract with us.
Recipients of Your Data and Categories of Data Collected
For more information, see Section 3 of our Privacy Policy above.
Data Protection Officer
Calibo is headquartered in Southfield. Michigan, USA. Calibo has appointed an internal Data Protection Officer for you to contact if you have any questions or concerns about the Company’s personal data policies or practices. Calibo’s Data Protection Officer’s name and contact information are as follows:
Tapan Sahoo
Calibo Inc.
1000 Town Center
Suite 700
Southfield
MI48075
USA
dpo@calibo.com
Phone: +91 8978781681
Transferring personal data from the EU to the US or other jurisdictions
Personal data we collect from you will be processed in either the United States or the location you have chosen in your contract with us.
The 8 Rights of Individuals
Under the GDPR, you benefit from the following rights:
1. The right to be informed
The right to be informed encompasses the obligation to provide you with “fair processing information.” It emphasizes the need for transparency over how your personal data is used.
2. The right of access
Under the GDPR, you will have the right to obtain confirmation that your data is being processed, access to your personal data, and other supplementary information.
3. The right to rectification
You are entitled to have your personal data rectified if it is inaccurate or incomplete.
4. The right to erasure
The right to erasure is also known as “the right to be forgotten.” You may request the deletion or removal of personal data where there is no compelling reason for its continued processing.
5. The right to restrict processing
We are permitted to store your personal data, but not to further process it without your consent.
6. The right to data portability
The right to data portability allows you to obtain and reuse your personal data for your own purposes across different services. You may move, copy, or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
7. The right to object
You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
8. Rights in relation to automated decision making and profiling
The GDPR provides safeguards for you against the risk that a potentially damaging decision is taken without human intervention.
We may use third party analytics vendors to evaluate and provide us with information about the use of our services and viewing of our content. Some of the information you see on our Website may be customized based on automated predictions about your interests, which predictions are generated from your visits over time and across different websites, using tools such as Google Analytics. This information allows us to create content of greater interest to you and can also be used to serve ads based on your past visits to our Website. Note that you can opt out of a third-party vendor's use of cookies, including use by Google, by visiting the Network Advertising Initiative opt-out page (http://www.networkadvertising.org/choices/).
For more information about how targeted Network Advertising works, please visit: http://www.youradchoices.com/ or http://www.networkadvertising.org/understanding-online-advertising.
You may opt out of third-party targeted advertising or analytics in two ways: (1) By directly notifying a Network Advertising service provider via its opt-out tools (Please see above), or (2) using your browser’s Do Not Track (DNT) settings to indicate that you do not wish to receive targeted advertising based on your overall internet usage. For more information about DNT and how it works, visit the Future of Privacy Forum’s website: http://www.allaboutdnt.com/.We will make a reasonable effort to honor your DNT browser settings for opting out of receiving targeted third-party advertising based on your overall Internet usage.
Please note that various browsers frequently update technology or change their settings and business practices without advance notice, and we may not have the latest information on how to honor your preferences. If you exercise either opt-out option – the cookie opt-out or the browser opt-out – you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases, or search history.
However, you cannot opt out of our contextual analytics and advertising, which is based on your usage of only our services. We will continue to serve you contextual advertising. We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our services, features, and activities are functioning and used. We will also share this information in an aggregated or anonymized form (meaning that no one individual person can be identified) within Calibo.
You can also opt out of our marketing emails at any time by contacting us at opt-out@calibo.com or by sending us a post card to:
“OPT OUT”
Calibo, Inc.
1000 Town Center Drive, Suite 700
Southfield, MI 48075.
We aim to keep all personal data that we hold accurate, complete, and up to date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete, or out-of-date, just send an email with your old information and your corrections to info@calibo.com with "Correction" in the subject line.
We understand the importance of protecting the privacy of all individuals, especially the very young. Our Calibo Services are intended for audiences over the age of 18. Our Calibo Services are not directed at children, and you may not use our Calibo Services if you are under the age of 13. You must also be old enough to consent to the processing of your personal data in your country (some countries may allow your parent or guardian to do so on your behalf). You must be at least 16 years of age to use any interactive forums on our Website. Subscribing to or using our Calibo Services is restricted to adults who are either 18 years of age or older or otherwise legally defined as an adult by the country of your residency.
If you click on a link and go to another site, you will be subject to that website’s privacy policy. We encourage you to read the posted privacy policy statement at any website before submitting any personal data.
We may on occasion update our Privacy Policy. Your acceptance of any minor changes to this Privacy Policy is indicated by your continued use of our Services. If we make any material changes to our Privacy Policy, we will post a notice about the change at a prominent location on our Site. We encourage you to periodically review our Site and this Privacy Policy for any changes.
If you have questions or concerns regarding this statement, you should first contact us via email at info@calibo.com .
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