Kaholo LTD. general Privacy Policy

Welcome to Kaholo.io Ltd. (“Kaholo”, or “we”). We care about your privacy and are committed to protecting our users’ right to privacy.

This Privacy Notice (“Privacy Notice”), is an integral part of our Terms of Use, which can be found at: /terms-of-service, and governs the use, processing and transfer of Personal Data collected via Kaholo’s website (“Website”) and/or the services available through the Website or otherwise provided by Kaholo (“Services”), to each person (“User” or “you”), accessing or using the Website and/or the Services.

If you choose to use the Services, interact with the Website, or otherwise provide data to us, you explicitly agree to the use of such data in accordance with this Privacy Notice. You may not use the Services or the Website or submit any data through them if you do not agree to any of the terms hereunder.

Please note, that the Website and/or Services may contain links to other websites, products or services offered by third parties, which are not governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by Kaholo.


  • You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.
  • Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to use the Services. If you are under such age you should cease to use the Services immediately.
  • You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled.
  • We do not sell, trade, or rent ‘Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Website and/or Services to our Users, or other limited circumstances as specified herein.
  • If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: info@kaholo.io

1. What is Personal Data, and what data is collected about me by Kaholo?

Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.

Non-Personal Data  We collect non-Personal Data regarding Users concerning their use of the Website and/or Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Website and/or Services, device identifiers, and other technical information regarding the device used to access the Website and/or Services, such as model, operating system, etc.

Personal Data

1.1 We collect Personal Data you submit to us actively via the Website, for example when you choose to fill details in the “Contact Us”feature on our Website, you will be requested to provide certain Personal Data, such as full name and e-mail address.

1.2 We log users Internet protocol (IP) address. Kaholo also collects certain data regarding your use of the Website, such as the frequency and the extent of your use.

1.3 We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Website or collected by us, please inform us immediately

2. How Do We Use Your Information?

2.1 Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our Website and/or Services, including among others, in order to measure and understand the level of engagement to our Website and/or Services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Website and/or Services and for developing new services and features.

2.2 Personal Data. Personal Data is used only for the following limited purposes:

2.2.1 To provide our Services to Users and respond to our Users, including contacting you when you fill your details in our Website or sending to us applying for work on our careers page.

2.2.2 To prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Website or the Service and to enforce our Terms of Use.

2.2.3 To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.

2.2.4 We may send you promotional material concerning our Service, which we believe might interest you. You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us. Please note that even if you unsubscribe, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us.

2.2.5 To improve the Services, and to develop new features, products and services.

2.2.6 To improve your experience on the Website and customize our Services to your interests, including by way of targeted advertising.

2.2.7 For the purposes of our legitimate interests, to the extent not overridden by the rights and freedoms of natural persons, as permitted under applicable law.

2.2.8 To provide updates with respect to material changes to this Privacy Notice or our Terms of Use.

3. Does Kaholo use cookies?

Yes, we use cookies (small text files stored in a user’s device) and other similar technologies, these technologies help us track how Users use the Website and our Services. learn more about how we use cookies in our Cookie Policy.

4. What are my rights in connection with My Personal Data under the GDPR?

4.1 Reviewing and amending your Personal Data.You may send us a request in connection with reviewing your Personal Data to: info@kaholo.io. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the Website, as applicable to you.

4.2 Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.   

4.3 Portability of Personal Data. To the extent relevant to you and to the Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.   

4.4 Retention of Data.We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.

4.5 You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.

5. Will Kaholo Share My Personal Data with Others?


5.1 Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients.

5.2 We share Personal Data only under the following limited circumstances:

5.2.1  With trusted partners and third parties who assist us in operating the Services and conducting our business, such as fraud prevention, marketing and technology services.

5.2.2 For personalizing your experience of the Services.

5.2.3 As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about products, services and communications.

5.2.4 To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

5.2.5 Other third parties with your consent or direction to do so.

6. What is the lawful basis under which Kaholo processes Personal Data?

6.1 Certain processing activities conducted by us are based on the necessity of such activities for the performance of our Website and/or Services and the contract between us and our Users.

6.2  Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data.

6.3  There may be certain processing activities based on your consent. In connection with such activities, you may rescind your consent, by sending us an email to: info@KAHOLO.io. Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.

7. Will Kaholo transfer my Personal Data internationally?

Our databases are currently located in Israel and the USA. Some of our processing activities are made in Israel as well. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.

Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights.

8. Will I receive promotional materials from Kaholo?

We currently do not send Users any commercial or promotion information via direct mailing such as emails messaging. We will not send any User such promotional mailing without obtaining the Users’ explicit prior consent.

9. Persons under 16

Our Website and/or Services are intended for a general audience, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.

10. Applicable Laws

The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.


This section, is intended for California Residents under the California Consumer Privacy Act of 2018 (“CCPA”), supplements the information contained in our general Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “you”), as defined under the CCPA. Any terms defined in the CCPA have the same meaning when used in this section. Further, this section is an integral part of our Privacy Notice and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Notice.

As required under the CCPA, we will update this section every 12 months. The last revision date will be reflected in the “Recently Updated” heading located at the top of the Privacy Notice.

types of PERSONAL information we COLLECT

Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and have collected within the last 12 months), are detailed in the table below.

Please note that, under the CCPA Personal Information does not include: publicly available information from government records and deidentified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).

A. Identifiers.
A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, address, telephone number, account name.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Signature, Social Security number, physical characteristics or description, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows: (i) directly from you, for example, if you contact us; (ii) indirectly from you, for example, from observing your actions on our website; (iii) from third-party business partners such as analytics providers.


We may use or disclose the Personal Information we collect for one or more of the business purposes described in our general Privacy Notice.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.


We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

We share your Personal Information with the following categories of third parties:

  1. Service providers
  2. Data aggregators
  3. Business Partners


In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.

Category F: Internet or other similar network activity.


In the preceding twelve (12) months, Company has not sold Personal Information.


The CCPA provides consumers with specific rights regarding their Personal Information. See below explanation as to the rights you are entitled to under the CCPA, in comparison with the rights granted to data subjects under the GDPR as specified in our general Privacy Notice.  

Right to be informed

The categories of personal information collected/sold/disclosed by us in the previous 12 months must be provided to you, including:

  • the categories of personal information collected;
  • the sources from which the information was collected;
  • the business or commercial purpose for collecting or selling the information;
  • categories of third parties with whom the business shares the information;
  • the specific pieces of personal information the business collected about the consumer.

Right of Access

The right applies only to personal information collected in the 12 months prior to the request and we are not required to provide access to personal information more than twice in 12 months.

Right to deletion

Under US Law, there are no specific situations of deletion and no justifications needed for a deletion request.

In addition to the exceptions enumerated under the EU Law, we are not required to comply with the right to deletion in the following circumstances:

  1. to perform a contract between you and us;
  2. detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
  3. debug to identify and repair errors that impair existing intended functionality;
  4. to enable solely internal uses that are reasonably aligned with your expectations based on our relationship with you;

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days. If we require more time, up to 90 days, we will inform you of the reason and extension period in writing. Under the US Law the data request only applies to the 12 months prior to the request and not more than 2 requests in a 12 month period.


You must not be discriminated for exercising any of your rights, including by:

  • denied goods or services;
  • charged different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • provided a different level or quality of goods or services;
  • suggested they will receive a different price or rate for goods or services.

Data Portability

The CCPA’s right is limited to allowing you receive personal information, and it does not extend to having us transfer the information to another business.

You may exercise any or all of your above rights in relation to your personal information by sending us your request to info@kaholo.io


If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:



Kaholo LTD, at Netanya REGUS Business Centre
Hazoran 4 b, entrance 10,  3rd Floor
Netanya, 4250604, Israel