Privacy Policy

Introduction

Chalk Inc. ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

The types of information we may collect or that you may provide when you download, install, register with, access, or use the “Kaura” application (the "App") or the website www.kaura.co (the “Website”, and together with the App, the “Products”), or when you interact with the Company by email, text, telephone, or other means.

Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy DOES NOT apply to information that you provide to or is collected by any third party (see Third-Party Information Collection).

Our other websites and apps not listed herein, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register, or use the Products. By downloading, registering with, or using the Products, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Products after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 13

The App is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@kaura.co.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Information We Collect and How We Collect It

We collect information from and about users of our Products:

• Directly from you when you provide it to us, including when you email support or otherwise interact with our service team.
• Automatically when you use the App.
• Automatically when you interact with the Website.

Information You Provide to Us

When you download, register with, or use the Products, we may ask you provide information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, any other identifier by which you may be contacted online or offline ("personal information").
• That is about you but individually does not identify you, such as time and duration of use, heart rate information, and feedback you choose to provide about the Products.

This information includes:

• Information that you provide by filling in forms in the App or the Website. This includes information provided at the time of registering to use the Products, subscribing to our service, and posting material. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Products.
• Information about your time spent in meditation, including (i) length of time spent meditating, (ii) heart rate while meditating, and (iii) feedback you choose to provide through the Products before, during, and after meditation.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the App or the Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App or the Website.
• Your search queries on the App and Website.

You may also provide information for publication or display ("Posted") on public areas of the App or Website (collectively, "User Contributions"). Your User Contributions are Posted and transmitted to others at your own risk. Please be aware that, while we use reasonable efforts to secure your information, no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking

When you download, access, or use the Products, we may use technology to automatically collect:

• Usage Details. When you access and use the Products, we may automatically collect certain details of your access to and use of the Products, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Products.
• Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
• Stored Information and Files. The Products also may access metadata and other information associated with other files stored on your devices. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location Information. The Products do not collect real-time information about the location of your devices.

If you do not want us to collect this information do not download the App or delete it from your device and do not visit the Website. For more information, see the “How We Use Your Information” section below.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). Email support@kaura.co for information on how you can opt out of behavioral tracking on or through the Products and how we respond to browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your mobile device or computer. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your mobile device or computer. However, if you select this setting you may be unable to access certain parts of our App.
• Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
• Amplitude Tracking. “Amplitude” tracking data containing a record of your activities within the App, including button presses, user flow within the Products, and basic analytics about your device.

Third-Party Information Collection

When you use the Products or associated content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your mobile device manufacturer.
• Your mobile service provider.
• Your internet provider.
• Other software or hardware providers.

These third parties may use tracking technologies to collect information about you when you use the Products. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the Products and their contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Give you notices about your account, including expiration and renewal notices.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
• Email you about your activity with the Products and for other purposes associated with your use of the Products or notify you of other services and products we may offer.

The usage information we collect helps us to improve our Products and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Products according to your individual interests.
• Speed up your searches.
• Recognize you when you use the Products.

We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please delete the App, do not visit the Website, and clear your browser cache and cookies. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

We may use the information we collect to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may sell or disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect, or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Chalk Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Chalk Inc. about our users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures.
• fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of the Products, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the End User License Agreement which governs your use of the products, found at https://kaura.co/terms-of-use/, and which is incorporated herein by this reference.
• For billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Chalk Inc., our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
• Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.
• Promotion by the Company. If you do not want us to use your contact information to promote our own or third parties' products or services, you can opt-out by deleting the App, avoiding the Website, and clearing your browser cache and cookies. You can also opt-out by sending us an email stating your request to support@kaura.co.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Residents in certain states, such as California, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Apple HealthKit

The App utilizes the Apple HealthKit API. The following guidelines apply specifically to data gathered using the HealthKit API:

• We will not use information gained through use of the HealthKit framework for advertising or similar services.
• We will not disclose any information gained through HealthKit to a third party without your express permission.
• We will not sell information gained through HealthKit to advertising platforms, data brokers, or information resellers.
• We will only share your HealthKit data with a third party for medical research with your consent.
• We will only use your HealthKit data for your personal display of health data while using the Products.

You may restrict the App’s access to the Apple Healthkit API by selecting the toggle in the App, or by restricting the App’s access to Apple Healthkit in your device’s settings.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page.

You may also send us an email at support@kaura.co to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access and use of information provided on the App is governed by our End User License Agreement found at https://kaura.co/terms-of-use/.

Residents in certain states, such as California, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents' privacy rights, visit https://oag.ca.gov/privacy/ccpa. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@kaura.co.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Products, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Products like message boards. The information you share in public areas may be viewed by any user of the Products.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Products. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by an alert the first time you use the Products after we make the change.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

support@kaura.co

or via our phone number:

(720) 663-0641

To register a complaint or concern, please contact us at support@kaura.co.