Effective date: September 17, 2018
Salanga Inc. (“us”, “we”, or “our”) operates the www.kinaki.ca website and related online and offline app – tool for monitoring, evaluation, accountability and learning (hereinafter referred to as the “Kinaki” or as a “Service”).
At Salanga, we take the privacy of your information very seriously and we are guided by our fundamental principles:
- We never knowingly nor intentionally sell, share or provide access to any private information nor any of your data to any third party, except unless to comply with specific law enforcement or a court order.
- We never collect any private information, unless we need to legally or to provide you requested services in Kinaki.
- All data you store within the use of Kinaki is owned and managed by you, or your organization, we do not own it, neither we have any rights to the data and its use.
- Kinaki Administrators can access your project’s data, unless you select in the Project Settings to keep the project private. This access is solely for the purpose of providing technical support and improvement of Kinaki services.
Kinaki is the www.kinaki.ca website operated by Salanga Inc.
- Personal Data
Personal Data means 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
Usage Data is data collected automatically either generated by the use of Kinaki or from the Kinaki infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
- Data Controller
Data Controller means 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 will be, processed.
- Data Processors (or Kinaki Provider – Salanga Inc.)
Data Processor (or Kinaki Provider) means Salanga Inc. or any natural or legal person who processes the data on behalf of the Data Controller.
- Data Subject (or User)
Data Subject is any living individual who is using Kinaki and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Services to you.
Types of Data Collected
While using Kinaki, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials strictly related to Kinaki or other services provided by Salanga Inc. You may opt out of receiving any, or all, of these communications from us by contacting at email@example.com.
While using Kinaki, you may enter, submit or import additional data to be processed by Kinaki. Salanga considers this data as confidential and will not disclose it to any third party without your written / in-app consent. (“Confidential Data”). Confidential Data may include, but is not limited to:
- Project Name; Budget; Donor; Countries of Operation; Organization Name, address and contact person.
- Third party data (data you collect and store within your project operation and that are being processed by Kinaki)
Only selected staff members, who undergo a security protocol from Salanga and Kinaki providers may access this data for the following reasons: provide training, provide technical support, implement improvements to Kinaki App and its usability. No other sub-processors, neither any other third-parties are granted access to the Client’s Data in stored Kinaki. Access to your data is solely for provision of technical support and improving Kinaki functionality and will never be used for other purposes.
We may also collect information on how Kinaki is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the Kinaki pages that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers; we also track user’s actions while using Kinaki and other diagnostic data. We record and store this usage data also for security purposes.
Tracking Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies may also be used such as beacons, tags and scripts to improve and analyze Kinaki.
You can instruct your browser to refuse 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 Kinaki.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate Kinaki.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Integration with Google and other Outside Services and systems
Kinaki involves the collection, use and processing of data, and Salanga Inc aims to make it easy to integrate its products with other cloud-based products. For example with Asana, WordPress, Zapier, Google, Google Fusion Tables, Microsoft BI or other outside systems. In addition, we may use Google Analytics on our publicly accessible sites. This requires that Kinaki, using open standards and explicit authorization from users, access outside systems and documents in these outside systems.
Use of Data
Salanga Inc. uses the collected data for various purposes:
- To provide, maintain and improve Kinaki
- To notify you about changes in Kinaki
- To allow you to participate in interactive features of Kinaki when you choose to do so
- To provide customer support
- To monitor the usage of Kinaki
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about Salanga’s other services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Salanga Inc. may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- For payment processing purposes
- To comply with the law
Retention of Data
Salanga Inc. will also retain Usage Data for internal analysis purposes.
Data Location and Transfer
Your information, including Personal Data and Confidential Data is stored in Canada and under special circumstances may be temporarily transferred to — and maintained on — computers located outside of Canada, but only to sustain access to the services while our servers in Canada are not accessible. For European Citizens, or European legal entities – we currently do not store data in the EU; however, we can provide this feature on request.
If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and store and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Salanga Inc. 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).
Salanga Inc. will never intentionally disclose any of your Private Data, neither Confidential Data to any other third party.
Salanga Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Salanga Inc.
- To prevent or investigate possible wrongdoing in connection with Kinaki
- To protect the personal safety of users of Kinaki or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially high-end means to protect your Personal Data, we cannot guarantee its absolute security. In case of any data leak, we will inform or affected or potentially affected users as soon as possible, without any delays.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Salanga Inc. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our system, you can request your account deletion directly through your account settings, or by contacting us by email: firstname.lastname@example.org .
In certain circumstances, you have the following data protection rights:
- The right to access, update or 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 with 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 where Salanga Inc. 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).
We may employ third party companies and individuals to facilitate Kinaki and related services (“Kinaki Providers”), perform Kinaki-related services such as development, testing and security auditing or assist us with analysis of Kinaki usage.
Salanga Inc engages the following data sub-processors to carry out specific processing activities on our behalf:
- Microsoft Azure Cloud Services (Sub-Processing Activity: Cloud Service Provider, location: Canada)
- GoSquared Ltd. (Sub-Processing Activity: User Activity Analytics and Email Sending, location: UK)
- Mailchimp: (Sub-Processing Activity: Email Sending, location: UK)
- MailMunch (Sub-Processing Activity: Email Sending, location: USA)
- Userpilot Inc. (Sub-Processing Activity: User Onboarding, location: USA)
These sub-processors may access and use this data Personal Data only for the activities described above. We do not trade or share Personal Data with any other third party not listed here.
We may provide paid products and/or services within Kinaki. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
- QuickBooks online payments
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites.
Kinaki does not address anyone under the age of 18 (“Youth and 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 servers.
- By email: email@example.com
- By visiting this page on our website: https://kinaki.ca/
- Salanga Inc. 123 Slater Street, Unit 6th Floor, Ottawa, Canada K1P 5H2