We at Akala Inc. respect the privacy of your personal information and, as such, make every effort to ensure
your information is protected and remains private. As the owner and operator of www.GoAKALA.com (the
and any mobile application that we may make available to you now or in the future (the "App"), hereafter
explain how we collect, use, share and protect information about the users of our Website and mobile App
(hereafter referred to as “user”, “you” or "your"). For the purposes of this Agreement and our Terms of
Service, any use of the terms "AKALA", "us", "our" or "we" includes Akala Inc., without limitation. We will
the data, the ways in which the data is handled and your rights with regard to your personal data.
Regulation 2016/679 ("GDPR") and the laws implementing GDPR.
or legal person who (either alone or jointly or in common with other persons) determines the purposes for
and the manner in which any personal information are, or are to be, processed.
may be of a confidential or sensitive nature and may include personally identifiable information ("PII")
financial information. PII means individually identifiable information that would allow us to determine the
actual identity of a specific living person, while sensitive data may include information, comments,
and other information that you voluntarily provide.
AKALA collects information about you when you use our Website or App to access our services, and other
online products and services (collectively, the “Services”) and through other interactions and
have with us. The term Services includes, collectively, various applications, software, websites, widgets,
and other methods of communication, notifications and other mediums, or portions of such mediums, through
on our privacy practices.
CONSENT AT THE TIME OF YOUR REGISTRATION FOR YOUR ACCOUNT, AND BY ACCESSING OR USING OUR SERVICES, YOU
TO THE COLLECTION, TRANSFER, MANIPULATION, STORAGE, DISCLOSURE AND OTHER USES OF YOUR INFORMATION
MAY BE ACCESSED HERE (INSERT LINK TO TERMS OF SERVICE PAGE HERE). IF YOU DO NOT, OR NO LONGER, AGREE WITH
FOR USERS OF OUR SERVICES PROVIDING INFORMATION FROM THE EUROPEAN UNION, WE RELY UPON THE LEGAL GROUNDS
IN THE SECTION ENTITLED "THE LEGAL BASIS AND REASONS FOR COLLECTION AND PROCESSING YOUR PERSONAL
1. Childrens privacy
Our Website and our Services are intended for individuals who are 13 years of age or older. If you are
the age of majority (18 years of age or older in most jurisdictions), you represent and warrant that you
years of age or older and possess parental or legal guardian consent to use our Services.
b. Furthermore, we do not knowingly collect personally identifiable information (PII) from persons under
age of 13 in the United States ("U.S."), or under 16 in the European Union ("EU"), the "Protected Age". If
are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have
reason to believe that we may have accidentally received information from a child under the Protected Age,
please contact us immediately. If we become aware that we have inadvertently received Personal Information
a person under the Protected Age, we will delete such information from our records.
2. Information Provided Directly By You
We collect information you provide directly to us, such as when you request information, create or modify
personal account, request Services, order a subscription to our Services, complete a AKALA form, survey,
or application, contact customer support, make a purchase, join or enroll for an event or otherwise
with us in any manner. This information may include, without limitation: name, date of birth, e-mail
physical address, phone number, school name, graduation date, photograph, credit card or other method of
payment information, or any other personal information you choose to provide.
3. Information Collected Through Your Use of Our Services
We collect information about your activity on our services, for instance how you use them (e.g., date and
you logged in, features you’ve been using, searches, clicks and pages which have been shown to you,
webpage address, advertising that you click on) and how you interact with other users and us. The following
situations in which you may provide Your Information to us:
- When you register for an account with our Service
- When you create a subscription for our Services
- When you fill out forms or fields through our Services including, but not limited to, school name(s),
graduation date, grade point average, courses taken, test scores received and career choices
- When you provide responses to a survey
- When you answer questions on a quiz
- When you join or enroll in an event through our Services
- When you order services or products from, or through our Service
- When you sign up for any newsletters or other materials through our Services
- When you provide information to us through a third-party application, service or Website
- When you communicate with us or request information about us or our products or Services, whether via
or other means
- When you participate in any of our marketing initiatives, including, contests, events, or promotions
- When you participate in forums, reviews or provide or post user generated content or other submissions.
We also automatically collect information via the Website or App through the use of various
including, but not limited to Cookies and Web Beacons (explained below). We may collect your IP
browsing behavior and device IDs. This information is used by us in order to enable us to better
our Services are being used by visitors and allows us to administer and customize the Services to
4. Information Collected From Other Sources
We may also receive information from other sources and combine that with information we collect through our
Services. For example if you choose to link, create, or log in to your AKALA account with a social media
service, e.g. LinkedIn, Facebook or Twitter, or a payment provider, e.g. Apple Pay or Google Wallet, or if
engage with a separate App or Website that uses our API, or whose API we use, we may receive information
you or your connections from that Site or App. This includes, without limitation, profile information,
picture, gender, user name, user ID associated with your social media account, age range, language,
friends list, your contact names, e-mail addresses, phone numbers, and other identifiers and any other
information you permit the social network to share with third parties. The data we receive is solely
upon your privacy settings with the social network.
5. Aggregated Data
We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data is de-identified or anonymized and does not constitute Personal Data for the purposes of
GDPR as this data does not directly or indirectly reveal your identity. If we ever combine Aggregated Data
your Personal Data so that it can directly or indirectly identify you, we treat the combined data as PII
6. Information Third Parties Provide
We may collect information about you from sources other than you, such as from social media websites (i.e.,
Facebook, LinkedIn, Twitter or others), blogs, analytics providers, business affiliates and partners and
users. This includes, without limitation, identity data, contact data, marketing and communications data,
behavioral data, technical data and content data.
7. Device Information
When you use our Services through your computer, mobile phone or other device, we may collect information
regarding and related to your device, such as hardware models and IDs, device type, operating system
the request type, the content of your request and basic usage information about your use of our Services,
as date and time. In addition, we may collect information regarding application-level events and associate
with your account to provide customer service. We may also collect and store information locally on your
using mechanisms such as browser web storage and application data caches.
8. Cookies, Log Files and Anonymous Identifiers
- When you visit our Services, we may send one or more Cookies – small data files – to your computer to
uniquely identify your browser and let us help you log in faster and enhance your navigation through
“Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or
website browsing equipment for record keeping purposes. A Cookie may convey anonymous information about
browse the Services to us so we can provide you with a more personalized experience, but does not
personal information about you. Cookies allow the Sites to remember important information that will
use of the site more convenient. A Cookie will typically contain the name of the domain from which the
has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain
may be used on the Sites regardless of whether you are logged in to your account or not.
- Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave
Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will
the lifetime of the specific Cookie).
- When we use session Cookies to track the total number of visitors to our Site, this is done on an
aggregate basis (as Cookies do not in themselves carry any personal data).
- We may also employ Cookies so that we remember your computer when it is used to return to the Site to
customize your AKALA web experience. We may associate personal information with a Cookie file in those
understand when you are interacting with our Services, and compile other information regarding use of
- Third parties with whom we partner to provide certain features on our Site or to display advertising
- Our Website may use remarketing services, to serve ads on our behalf across the internet on third
websites to previous visitors to our Sites. It could mean that we advertise to previous visitors who
completed a task on our site. This could be in the form of an advertisement on the Google search
on your past visits to our Website. Any data collected will be used in accordance with our own privacy
as well as Google's privacy policies. To learn more, or to opt-out of receiving advertisements tailored
interests by our third parties, visit the Network Advertising Initiative at www.networkadvertising.org/choices.
- AKALA may use third-party services such as Google Analytics to help understand use of the Services.
services typically collect the information sent by your browser as part of a web page request,
Cookies and your IP address. They receive this information and their use of it is governed by their
privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and
customized Google Display Network ads by visiting the Google Ads Preferences Manager here
To provide website visitors more choice on how
is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by
visiting Google Analytics Opt-out Browser Add-on here https://tools.google.com/dlpage/gaoptout.
information on how Google uses data when you use Google partners’ sites or apps, go here:
you do not wish to receive a Cookie or if you wish to set your browser to notify you when you receive a
You can easily delete and manage any Cookies that have been installed in the Cookie folder of your
following the instructions provided by your particular browser manufacturer. Consult the documentation
your particular browser manufacturer provides. You may also consult your mobile device documentation
information on how to disable Cookies on your mobile device. If you reject Cookies, you may still use
Website or App, but your ability to use some features or areas of our Service may be limited.
party Cookies is not covered by this policy.
- We automatically collect information about how you interact with our Services, preferences expressed,
settings chosen and store it in Log Files. This information may include internet protocol (IP)
browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp,
clickstream data. We may combine this automatically collected log information with other information we
about you. We do this to improve services we offer you, to improve marketing, analytics, or App/Site
functionality, and to document your consent to receiving products, services or communications from us
partners. If we link such information with personally identifiable information in a manner that
particular individual, then we will treat all such information as PII for purposes of this Privacy
m. When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels)
anonymously track online usage patterns. No Personally Identifiable Information from your account is
using these Web Beacons.
9. Table of Cookies
Our Cookie table below lists some of the Cookies on our sites. Please note that the names of Cookies and
technologies may change over time.
||Prevents cross-site request forgery (CSRF).
|LinkedIn ad tracking
||Measuring conversion from ads on LinkedIn
||Managing and tracking user activity
10. Location Information
When you use the Services we may collect your precise location data. We may also derive your approximate
location from your IP address.
11. Call and SMS Data
In connection with providing Service, we may receive call data, including the date and time of the call or
message, the parties phone numbers, and the content of the SMS message. You consent to the receipt,
and storage of this information.
12. Protective Measures We Use
We protect your information using commercially reasonable technical and administrative security measures to
reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we
are firewalls and data encryption, physical access controls to our data centers, and information access
authorization controls. Although we take measures to secure your information, we do not promise, and you
not expect, that your personal information, or searches, or other information will always remain secure. We
cannot guarantee the security of our information storage, nor can we guarantee that the information you
will not be intercepted while being transmitted to and from us over the Internet including, without
email and text transmissions. The GDPR and certain jurisdictional laws may not allow the exclusion or
limitation of certain liability for data security. If these laws apply to you, some or all of the above
limitations may not apply to you. In the event that any information under our control is compromised as a
result of a breach of security, we will take reasonable steps to investigate the situation and where
appropriate, notify those individuals whose information may have been compromised and take other steps, in
accordance with any applicable laws and regulations.
13. Payment Information
AKALA uses a third party payment processing gateway to collect, store and process payment information. AKALA
does not store this information on our Website or servers.
14. The Legal Basis and Reasons For Collection and Processing Your Personal Information
The legal basis upon which we rely for the collection and processing of your
Personal Information under the
GDPR are the following:
- When signing up to use our Services, you have given us explicit consent allowing AKALA to provide you
transfer of your personal data to other jurisdictions including, without limitation, the United States;
- It is necessary for entering into, or performing, the obligations of a contract between you and AKALA,
including, without limitation, the Terms of Service agreement which may be accessed by you here (insert
the Terms of Service page here) and any subscription for our Services that you order;
- It is necessary registering you as a user, managing your account and profile, and authenticating you
you log in.
- It is necessary for our legitimate interests in the proper administration of our website and business;
analyzing the use of the website and our Services; assuring the security of our website and Services;
maintaining back-ups of our databases; and communicating with you;
- To resolve technical issues you encounter, to respond to your requests for assistance, comments and
questions, to analyze crash information, to repair and improve the Services and provide other customer
- To send communications via email and within the Services, including, for example, responding to your
comments, questions and requests, providing customer support, and sending you technical notices,
updates, security alerts, and administrative, billing and account management related messages.
- To send promotional communications that you have consented to receive or have expressed a
interest in receiving.
It is necessary for our legitimate interests in the protection and assertion of our legal rights, and
legal rights of others, including you
- It is necessary for our compliance with certain legal provisions which may require us to process your
personal data. By way of example, and without limitation, we may be required by law to disclose your
data to law enforcement or a regulatory agency.
15. How We Use Information We Collect
Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate
business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not
rent, sell, lease or barter your information to anyone unless you grant us explicit permission for this
information to be shared.
We will use this information in order to:
- Provide users with our Services and customer support including, but not limited to, confirming emails
related to our services, reminders, confirmations, requests for information and transactions.
- Contact you and provide you with our Services, including one-on-one counseling and guidance and other
- Analyze, improve and manage our Services and operations.
- Resolve problems and disputes, and engage in other legal and security matters.
- Enforce our Terms of Service and any terms and conditions of any subscription for our Services.
Additionally, we may use the information we collect about you to:
Send you communications we think will be of interest to you, including information about
promotions, news, and events of AKALA and other companies, where permissible and according to
Display advertising, including advertising that is targeted to you or other users based on your
interests, as well as your activities on our Services.
Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity
without limitation, infringement of intellectual property rights of third parties.
it in, the United
States and other countries, some of which may have less protective data protection laws than
the region in
which you reside. Where this is the case, we will take appropriate measures to protect your
16. How We Share Information We Collect
time of collection or sharing, including as follows:
- With our staff of consultants and employees in order to provide you with the one-on-one
counseling and guidance services;
- With parents or legal guardians of minors (under 18 years of age in most jurisdictions);
- With third party Service Providers to enable them to provide technical (non-counseling)
- With the general public if you submit content in a public forum, such as your comments,
features of our Services that are viewable by the general public;
- With third parties with whom you choose to let us share information, for example other websites
integrate with our API or Services, or those with an API or Service with which we integrate.
With AKALA subsidiaries and affiliated entities that provide services or conduct data
processing on our
behalf, or for data verification, data centralization and/or logistics purposes;
vii) With affiliated entities that provide payment processing services on our behalf;
viii) With vendors, consultants, marketing partners, and other service providers who need
access to such
information to carry out work on our behalf;
In response to a request for information by a competent authority if we believe disclosure is
with, or is otherwise required by, any applicable law, regulation, or legal process;
With law enforcement officials, government authorities, or other third parties if we believe
are inconsistent with our user agreements, Terms of Service, or policies, or to protect the
or safety of AKALA or others;
In connection with, or during negotiations of, any merger, sale of company assets,
restructuring, financing, or acquisition of all or a portion of our business by or into another
If we otherwise notify you and you consent to the sharing; and
In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We
such data in the aggregate form and our analytical services do not record any personal
- We may disclose Your Information:
To any person who, in our reasonable judgment, is authorized to receive Your Information as
including as a result of your business dealings with that person (for example, your attorney);
To our third-party vendors and service providers so that they may provide support for our
business operations, including for the processing of payments, handling of data processing,
data storage, surveys, research, internal marketing, delivery of promotional, marketing and
materials, and our Services maintenance and security. These companies are authorized to use
only as necessary to provide these services to us and are contractually obligated to keep Your
To third parties when you engage in certain activities through our Services that are sponsored
such as purchasing products or services offered by a third party, electing to receive
communications from a third party, or electing to participate in contests, sweepstakes, games
sponsored, in whole or in part, by a third party. When we disclose Your Information to these
Your Information will become subject to the information use and sharing practices of the third
As required by law or ordered by a court, regulatory, or administrative agency;
As we deem necessary, in our sole discretion, if we believe that you are violating any
or regulation, or are otherwise interfering with another's rights or property, including,
our rights or property;
If requested by authorities in the event of any act of terrorism or instance of local, regional
To enforce or protect our legal rights.
17. Sharing Information With Law Enforcement
AKALA is committed to cooperating with law enforcement while respecting each individual’s right to
If AKALA receives a request for user account information from a government agency investigating
activity, we will review the request to be certain that it satisfies all legal requirements before
information to the requesting agency.
Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer
or Records), AKALA may disclose user account information to law enforcement, without a subpoena, court
or search warrant, in response to a valid emergency when we believe that doing so is necessary to
or serious physical harm to someone. AKALA will not release more information than it prudently believes
necessary to prevent harm in an emergency situation.
18. Social Media Sharing
Our Services may now or in the future integrate with social sharing features and other related tools
let you share actions you take on our Services with other Apps, sites, or media, and vice versa. Your
such features enables the sharing of information with your friends or the public, depending on the
establish with the social sharing service. Please refer to the privacy policies of those social sharing
services for more information about how they handle the data you provide to or share through them.
Any information or content that you voluntarily disclose for posting publicly to a social sharing
becomes available to the public, as controlled by any applicable privacy settings that you set with the
sharing service. Once you have shared User Content or made it public, that User Content may be
others. If you remove information that you posted to the social sharing service, copies may still
viewable in cached and archived pages, or if other users or third parties, using the social sharing
have re-shared, copied or saved that User Content.
19. User Content and Public Sharing
If you share User Content or post a comment or message that contains personally identifiable information to
page on our Services that is accessible to the public, third parties may use that information, or share it
other parties. As a result, you may receive unsolicited messages from other parties. Such User Content,
will need to contact AKALA in the event that you wish to have this personally identifiable information
from our Service
20. Analytic Services Provided By Others
We may allow others to provide audience measurement and analytics services for us, to serve advertisements
our behalf across the Internet, and to track and report on the performance of those advertisements. These
your device when you visit our Site and use our Services, as well as when you visit other online sites and
21. Links to Third-Party Websites
Our Services, as well as the email messages sent with respect to our Services, may contain links or
to websites operated by third parties that are beyond our control. Links or access to third parties
Services are not an endorsement by us of such third parties, or their websites, applications, products,
content of such third parties. These third-parties may send their own Cookies to you and independently
If you visit or access a third-party Website, application or other property that is linked or accessed
our Services, we encourage you to read any privacy policies and terms and conditions of that third
providing any personally identifiable information. If you have a question about the terms and
22. Do Not Track Settings
Some web browsers may give you the ability to enable a "do not track" feature that sends signals to the
websites you visit, indicating that you do not want your online activities tracked. This is different than
blocking or deleting Cookies, as browsers with a "do not track" feature enabled may still accept Cookies.
currently is no accepted standard for how to respond to this signal, and we do not take any action in
to this signal.
23. International Privacy Practices
In order to provide our products and services to you, we may send and store your personal information
of the country where you reside or are located, including to the United States. Accordingly, if you reside
are located outside of the United States, your personal information may be transferred outside of the
where you reside or are located, including countries that may not, or do not, provide the same level of
protection for your personal information.
We are committed to protecting the privacy and confidentiality of personal information when it is
If you reside or are located within the European Union ("EU") or European Economic Area ("EEA") and such
transfers occur, we take appropriate steps to provide the same level of protection for the processing
out in any such countries as you would have within the EU and EEA to the extent feasible under applicable
consent at the time of your registration for your account, users who reside or are located in countries
of the United States agree and consent to the transfer to and processing of personal information on servers
located outside of the country where they reside, and assume the risk that the protection of such
may be different and may be less protective than those required under the laws of their residence or
24. Account Information
You may correct your account information at any time by logging into your online account. If you wish to
your account, please email us at support@GoAKALA.com Please note that in some cases we may retain certain
information about you as required by law, or for legitimate business purposes to the extent permitted by
For instance, if you have a standing credit or debit on your account, or if we believe you have committed
or violated our Terms of Service, we may seek to resolve the issue before deleting your information.
25. Promotional Information Opt Out
You may opt out of receiving promotional messages from us at any time by following the instructions in
messages sent to you or by contacting us at any time using the Contact Us information at the end of this
account, about Services you have requested, or our ongoing business relations.
26. Your Access and Rights to Your Personal Information
You have certain rights in relation to Personal Information we hold about you. You can exercise any of the
following rights by contacting us using any of the methods in the Contact section below. We may need to
specific information from you to help us confirm your identity and ensure your right to access your
Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is
disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within
month. Occasionally it may take us longer than a month if your request is particularly complex or you have
a number of requests. In this case, we will notify you and keep you updated.
Right to Access Your Personal Data. You have the right to access information held about you for the
of viewing and in certain cases updating or deleting such information. Furthermore, if you prefer that
information. We will comply with an individual’s requests regarding access, correction, sharing and/or
of the personal data we store in accordance with applicable law. To make changes to your account affecting
personal information contact us at the email address in our Contact section below. For any deletion,
non-sharing or update request, we will make the changes as soon as practicable, however this information
stay in our backup files. If we cannot make the changes you want, we will let you know and explain why.
Right of Correction or Completion of Your Personal Data. If personal information we hold about you is
accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make
corrections to your account please contact us at the email address in our Contact section below.
Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to
that personal information we hold about you is deleted. If we cannot delete the information you want, we
let you know and explain why. To request information deletion please contact us at the email address in our
Contact section below.
Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the
right to object to our processing of your personal information. For example, you have the right to object
use of your personal information for direct marketing purposes. Similarly, you have the right to object to
of your personal information if we are processing your information on the basis of our legitimate interests
there are no compelling legitimate grounds for our processing which supersede your rights and interests.
may also have the right to restrict our use of your personal information, such as in circumstances where
have challenged the accuracy of the information and during the period where we are verifying its accuracy.
object to or restrict processing please contact us at the email address in our Contact section below.
Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a
of the information we maintain about you in a structured, machine-readable and commonly used format. To
a copy of the information we maintain about you please contact us at the email address in our Contact
Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal
Information after we have requested it, you have the right to withdraw your consent at any time. To
your consent please contact us at the email address in our Contact section below.
Right to Complain. If you’re based in the EU, you can file a complaint with the supervisory authority in
your Member State. By way of example, if you reside in the United Kingdom you can file a complaint with the
Information Commissioner’s Office here https://ico.org.uk/.
27. Your California Privacy Rights
California Civil Code Section 1798.83 entitles California residents to request information concerning
whether a business has disclosed Personal Information to any third parties for their direct marketing
California residents may request and obtain from us once a year, free of charge, information about the
information, if any, we disclosed to third parties for direct marketing purposes within the immediately
preceding calendar year. If applicable, this information would include a list of the categories of personal
information that was shared and the names and addresses of all third parties with which we shared
within the immediately preceding calendar year.
If you are a California resident and would like to make such a request, please submit your request in
writing to: support@GoAKALA.com
28. Our Information Retention Policy
Unless you request that we delete certain information, we retain the information we collect for as long as
account is active or as needed to provide you services. Following termination or deactivation of your
we will retain information for at least 3 years and may retain the information for as long as needed for
business and legal purposes. We will only retain your Personal Data for so long as we reasonably need to
a longer retention period is required by law (for example for regulatory purposes).
29. Contact Us
If you have any questions or if you would like to contact us about our processing of your personal
including exercising your rights as outlined above, please contact us by any of the methods below. When you
contact us, we will ask you to verify your identity.
Contact name: Data Protection Officer
Last updated: September 1, 2018
Our office address:
9950 Durant Dr. #309