Privacy Policy

Who We Are

Kelly Manjula Koza (“I”, “my”, “we”, “our”) operates the website https://tramite.org and the website https://sardinianarts.com. 

Kelly Manjula Koza 

  • Mailing Address: 900 Pepper Tree Lane #614, Santa Clara, California 95051 USA
  • Email: kmk@kmkoza.com

What Key Terms We Use

  • Personal Data: Data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
  • Usage Data: Data collected automatically, either generated by the use of the website or from email service providers, or from the website infrastructure itself (for example, the duration of a page visit).
  • Cookies: Small pieces of data stored on your device (computer or mobile device).
  • Data Controller: The natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
  • Data Processors (or Service Providers): Any natural or legal person who processes the data on behalf of the Data Controller.  We may use the services of various Service Providers in order to process your data more effectively.
  • Data Subject (or User): Any living individual who is using our website and related services and offerings and is the subject of Personal Data.

What Personal Data We Collect and Why We Collect It

We collect several different types of information for various purposes to provide and improve our services to you.  The types of data we collect are noted below.

We’re committed to maintaining the trust and confidence of our clients and visitors, and do not sell, rent, or trade Personal Data.

Personal Data

While using our website, we may ask you to provide us with certain personally identifiable information (“PII”) that can be used to contact or identify you (“Personal Data”). Personal Data may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, City, State/Province, ZIP/Postal code, Country
  • Nicknames used on social networking and communications applications
  • Cookies and Usage Data

We may use your Personal Data to provide you requested information, and/or to send you newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our website and gather certain information.

Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies that may be used include beacons, tags, and scripts that collect and track information to improve and analyze our website and the services we offer you.

You can instruct your browser to disable all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

The easiest way to disable cookies is to use your browser. You can find information in your browser’s Help section or see information for Safari, Chrome, Firefox, Explorer, and Opera on their websites.

Examples of Cookies We Use

Cookie types we use include:

  • Session Cookies. We use Session Cookies to operate our website.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

How We Handle Do Not Track

We do not monitor or follow any Do Not Track browser requests. 

Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

How We Handle Children’s Privacy

Our website and related services and offerings do not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our system. 

Who We Share Your Data With (Do Not Sell My Data)

We do not sell, rent, or trade Personal Data. 

Related Websites

SardinianArts.com, a sister site to this website and an initiative wholly-owned by Kelly Manjula Koza, may email you regarding offerings possibly of interest to you. You may opt out of receiving any, or all, of these communications from SardinianArts.com by following the unsubscribe link or instructions provided in any email SardinianArts.com sends. 

Service Providers

We use third party companies (and occasionally, individuals) to help run our website and related services and offerings (“Service Providers”) and to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

The third parties we use are noted below.

Google for Tracking Usage Data

We use Google Analytics to collect information about how the website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (IP address), the location of the IP address, the browser type and version, the pages of our website that you visit, the time spent on those pages, the time and date of your visit, unique device identifiers, and other diagnostic data.

We do not store the information provided by Google Analytics; we merely look at it occasionally to see where visitors come from, how they navigate the website, and what pages of the are of most interest.

To learn about how Google uses Analytics data, see Google Analytics’ page Data Privacy and Security. See Google’s privacy policy at https://policies.google.com/privacy. 

Google DoubleClick also places a cookie to ascertain if your browser supports cookies.

MailChimp for our Email List

We use MailChimp to deliver newsletters and emails to our email list. Mailchimp tracks clicks and opens and we use this information to improve and tailor the information we send to you. 

You can read the MailChimp privacy policy here.

Payment Processors

We may provide paid products and/or services on the website, and we use third-party services for payment processing (payment processors).

We do not store or collect your payment account or payment card details. This information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by the Payment Card Industry Data Security Standard (PCI-DSS) as managed by the Payment Card Industry Security Standards Council.

The payment processors we work with are:

  • PayPal. See their privacy policy here.
  • Wise.com. See their privacy policy here.

Referrals

We provide links to service providers we use and recommend. Some of these links may contain referral cookies that let the service provider know you found and clicked the link to their service from this website. We may sometimes receive a small in-kind (free month of service) or financial payment for referring you. These links are:

  • Backblaze. See their referral program information here.

Various Plugins and Cookies for Website Functionality

Plug-ins are small applications that add functionality to a website. The plug-ins that make certain parts of this site function may or may not place cookies on the site.

The plugins used on this site are listed below. Click the name of each to go to the plugin’s website and learn more:

How We Use Your Data

Kelly Manjula Koza uses the collected data for various purposes:

  • To provide and maintain our website and related services and offerings
  • To notify you about changes to our website and related services and offerings
  • To allow you to participate in interactive features of our website when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our website and related services and offerings
  • To monitor the usage of our website
  • To detect, prevent and address technical issues
  • To provide you with news, general information, and special information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Kelly Manjula Koza’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Why Kelly Manjula Koza may process your Personal Data

  • We need to perform a contract with you
  • For payment processing purposes 
  • You have given us permission to do so
  • To comply with the law
  • The processing is in our legitimate interests and it’s not overridden by your rights

When We May Disclose Data for Legal Reasons

Under certain circumstances, Kelly Manjula Koza may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Kelly Manjula Koza may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect the personal safety of members of the public and/or users of website and related services and offerings
  • Prevent or investigate possible wrongdoing in connection with the website and related services and offerings
  • Protect and defend the rights or property of Kelly Manjula Koza
  • Protect against legal liability

How Long We Retain Your Data

Kelly Manjula Koza will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, generally 10 years for individual and businesses from whom we collect Personal Data. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. 

Kelly Manjula Koza may also retain Usage Data for internal analysis purposes. Usage Data, if retained, will be retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website and related services and offerings, or we are legally obligated to retain this data for longer time periods.

When We Transfer Your Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Kelly Manjula Koza will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place for the security of your data and other personal information.

How We Protect Your Data

All Personal Data is secured on computers and devices that are encrypted, secured with passwords and, when possible, use biometric and/or double-factor authentication. Computers and devices are stored in locked locations with restricted access. Computers and devices employ up-to-date software to protect against malware, hacking, and other security threats.

We maintain strict human security measures, including continual education regarding security threats, social engineering trends, and data protection best practices.

We select our service providers for backups and cloud-based services with trust and security in mind, and maintain updated software and processes to ensure data is transferred and stored securely.

We use these service providers to securely store and/or back up Personal Data: 

  • Backblaze; see their privacy policy here.
  • Apple iCloud; see their privacy policy here.
  • MailChimp; see their privacy policy here.

What Data Breach Procedures We Have in Place

In the event of a data breach, we will 

  • Confirm the breach internally
  • Contain the breach as much as possible
  • Assess the risk and affect of the breach
  • Notify all individuals and businesses affected or presumed to be affected by email, phone, and/or postal mail of the breach and the information that may have been compromised
  • Notify local law enforcement entities and other necessary law enforcement entities
  • Work with data security and other experts to secure the breach internally and provide any information possible to law and fraud security agencies and specialists
  • Review and update any polices and procedures, hardware/software issues, and training necessary to secure systems, data, and human error from future breaches
  • Comply with reasonable related requests to mitigate the effect of the data breach

What Rights You Have Over Your Data

You can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Kelly Manjula Koza aims to make reasonable steps that enable you to correct, amend, delete, or limit the use of your Personal Data.

If you want to know what Personal Data we hold about you and/or if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time Kelly Manjula Koza relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Links to Other Sites

Our website and related services and offerings may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. We advise you to review the Privacy Policy of every site you visit.

Embedded Content from Other Websites 

Our website and related services and offerings may contain embedded content, such as videos, images, and articles, from other websites. Embedded content behaves in the exact same way as if you have visited the other website.

Websites from which we embed content may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

What Third Parties We Receive Data From

We do not receive or use third-party data. 

What Automated Decision Making and/or Profiling We Do

We do not do any automated decision-making or profiling.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • By email: kmk@kmkoza.com
  • By visiting this page on our website: https://tramite.org/contact/

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. 

We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.

Effective Date

This Privacy Policy was updated May 29, 2023.

© Kelly Manjula Koza unless otherwise noted.