Privacy Policy

Loka Inc. (“Loka”, “we” or “us”) provides its website (“Site”) to each visitor to, or user of, the Site (“User”, “you” or “your”). This Privacy Policy explains the types of information we may collect, how we use and disclose such information and purposes for doing so. It also describes how we protect your Personal Information (see definition below). Please be advised that this Privacy Policy governs our collection, use and protection of information in connection with our Site; additional and/or different privacy policies may apply with regard to use of our applications, programs or other product or service offerings.

To the extent you access or use the Site in any manner, this Privacy Policy will apply to you, so please read it carefully. If you do not agree to any term or condition provided herein, please do not access or use the Site.

1. Information We Collect & How it is Collected

We collect both Non-Personal Information and Personal Information, as described below.

Non-Personal Information: “Non-Personal Information” refers to information which does not identify a User or any other natural person. We collect the following types of Non-Personal Information in the manner described below:

• Site usage data, such as web pages visited, content viewed on web pages, amount of time spent on particular pages, information about a User’s browser, traffic channel and operating system. We collect site usage data as you use and navigate the Site.
• Geolocation data that does not include specific addresses/locations or information that may be used to identify any User or individual. We collect this information as you use and navigate the Site.
• Cookies and information derived from our Site analytics tools. We collect this kind of information as you use and navigate the Site.

Personal Information: “Personal Information” refers to information which identifies a User or which could reasonably be used to identify a User. We collect the following types of Personal Information:

• Name. We collect your name when you provide it to us in a form on our Site to contact Loka (“Contact Us Form”).  We also collect your name if you include it on your curriculum vitae (CV) or otherwise provide it as part of a job application that you submit to us.
• Email addresses. We collect your email address when you provide it to us in a Contact Us Form.  We also collect your email address if you include it on your CV or otherwise provide it as part of a job application that you submit to us.
• Company/organization with which you are affiliated and your title with such company/organization. We collect information about the company or organization with which you are affiliated and your title with such company/organization when you provide such information to us in a Contact Us Form. We also collect such information if you include it on your CV or otherwise provide it as part of a job application that you submit to us.
• Phone number. We collect your phone number when you provide it to us in a Contact Us Form.  We also collect such information if you include it on your CV or otherwise provide it as part of a job application that you submit to us.
• Other Personal Information you include on your CV or otherwise provide as part of a job application that you submit to us, such as postal address, past employment information and education information.
• Recorded Interviews.  With your prior consent and as permitted by applicable law, we collect audio and/or video recordings of your virtual job interviews with us.  We collect such recordings through the use of third-party software programs. 
• Internet Protocol (IP) addresses. We collect IP addresses derived from our Site analytics tools. We collect this kind of information as you use and navigate the Site.

2. Our Uses and Disclosures of Information & Purposes of Using and Disclosing Information

Uses and Disclosures of Non-Personal Information: We use Non-Personal Information we collect for Site analytics purposes. For example, we use cookies and other information derived from our Site analytics tools to analyze trends and our Users' preferences in using the Site, which helps us improve the Site and Users’ experiences on the Site. We may also disclose such Non-Personal Information to third party service providers for such purposes and as described in this Privacy Policy.

Uses and Disclosures of Personal Information: We use the following Personal Information for the purposes described below:

• We use names, email addresses, company/organization affiliation, your title with such company/organization and phone numbers of Users to respond to questions and comments submitted to us through a Contact Us Form;
• We use names, email addresses, company/organization affiliation, your title with such company/organization, phone numbers, and other Personal Information you include on your CV or otherwise provide as part of a job application that you submit to us to contact you about job opening(s) and/or evaluate your candidacy for job opening(s).  We also disclose such Personal Information to third party service providers that assist us with data management functions. 
• We use Personal Information contained in recorded job interviews to evaluate job candidates for current and future positions at Loka.  We also disclose such Personal Information to third party service providers that assist us with data management functions.
• We use IP addresses for our Site analytics purposes. We may also disclose IP addresses to third party service providers for such purposes as described in this Privacy Policy; and
• We use and disclose any of the foregoing Personal Information to comply with applicable law, regulation, legal process, subpoena or governmental request, or to protect the rights or property of Loka or its Users, as needed.

3. Retention of Personal Information

We retain your Personal Information for as long as reasonably required for fulfilling the purposes of using such Personal Information described above, in each case as permitted under applicable laws and regulations and no longer than 2 years.  With respect to Personal Information collected from job applicants, we retain such Personal Information for as long as necessary to evaluate an applicant’s candidacy for current and/or future job openings or as otherwise required under applicable laws and regulations and no longer than 2 years.

4. Security

We use commercially reasonable and appropriate measures to protect the security and integrity of Non-Personal Information and Personal Information we collect or maintain as a part of our Site. Please note, however, that there are inherent risks in transmission of information over the Internet, and we cannot guarantee that unauthorized access or use of information will never occur.

5. Cookies and Tracking Technologies

We use certain tools and technologies, such as cookies and web analytics tools, to track details of Site usage, navigation and traffic. Use of these tools and technologies may involve storage of text files on the computer or device you use to access our Site. We use these technologies for web analytics purposes to enhance and improve our Site and our Users’ experience on our Site. You may disable these technologies by adjusting your browser settings, but if you do so, certain features on our Site may not function properly.

6. Third Party Service Providers

We use third party services, such as third party software, platforms, programs and other services, to process Non-Personal Information and Personal Information, as described in this Privacy Policy. We make commercially reasonable efforts to engage only with third parties that comply with applicable law and implement reasonable information privacy and security measures; however, please be aware we do not control such third parties.

7. Children Under 13

Our Site is not directed to or intended to be used by children under the age of 13 and we do not knowingly collect any Personal Information from children under 13. If you become aware that we have collected Personal Information from any child under the age 13, we ask that you contact us at legal@loka.com and we will seek to delete such Personal Information as soon as possible.

8. International Data Transfer

In the course of providing our Site services to you, we may transfer Personal Information about you across borders from the country in which you are located to other countries around the world, as permitted by applicable laws. Please note that we may transfer such information to a country that does not have the same privacy or data protection laws as your country. Accordingly, with respect to an international transfer, your Personal Information may be subject to different protections depending on the laws and regulations of the country to which your Personal Information is transferred. In all cases, we will seek to apply reasonable safeguards for the protection of any Personal Information transferred internationally.

9. EU Data Protection

In addition to all of the foregoing terms of this Privacy Policy, the following terms apply to the processing of Personal Information in the context of the activities of Loka’s establishment in Portugal (such establishment referred to herein as “Loka Portugal”):

With respect to Personal Information collected through the Site, Loka Portugal is a data controller (i.e., an entity that determines the purposes and means of processing your Personal Information).  You may contact Loka Portugal at legal@loka.com.

Loka Portugal processes your Personal Information for the purposes set forth above in this Privacy Policy.  When Loka Portugal processes your Personal Information on the Site, such processing has various legal bases, depending on the particular circumstances.  The legal bases for processing your Personal Information may include: 

• our legitimate interests in operating and providing our Site where such interests are not overridden by the interests or fundamental rights and freedoms of our Users;
• our legitimate interests in performing job recruitment functions, including recruitment for current and future positions at Loka, where such interests are not overridden by the interests or fundamental rights and freedoms of our Users;
• compliance with applicable legal obligations; and
• your consent. 

As a data subject, you have the right to request any of the following from Loka Portugal: 

• access to your Personal Information; 
• rectification of your Personal Information;
• erasure of your Personal Information;
• portability of your Personal Information; and
• restriction on the processing of your Personal Information.  

You also have the right to object to further processing of your Personal Information. To exercise any of these rights, please contact Loka Portugal at legal@loka.com.  We will respond to your request in accordance with applicable law.

In the event Loka Portugal processes your Personal Information based on your consent, you may withdraw your consent at any time (provided, however, such withdrawal will not affect the lawfulness of the processing of your Personal Information that occurred before Loka Portugal’s receipt of your withdrawal).  To withdraw consent for processing of your Personal Information, please contact us at legal@loka.com.

Loka Portugal may transfer Personal Information from the European Economic Area (EEA) to countries outside of the EEA in accordance with applicable laws and regulations, including without limitation, the General Data Protection Regulation.  Specifically, your Personal Information may be transferred from the EEA to the United States on the basis of your explicit consent.  Please be aware that the European Commission has not determined that the United States (outside of the EU-U.S. Data Privacy Framework) provides an adequate level of protection of Personal Information.  Therefore, your Personal Information may be at greater risk of being compromised due to the absence of such a determination of an adequate level of protection.  Nonetheless, Loka Portugal will use commercially reasonable efforts to ensure the protection of your Personal Information transferred to the United States.  Loka Portugal may also transfer Personal Information from the EEA to its service providers and other organizations with which it works in the United States on the basis of standard data protection clauses.  In circumstances where Loka Portugal transfers your Personal Information on the basis of standard data protection clauses, you may contact Loka Portugal at legal@loka.com to request a copy of such clauses.

You are not required to provide Loka Portugal with your Personal Information, however, if you choose not to provide your Personal Information, this means that you may not be able to use certain components of the Site or receive certain Site services.

If you have a concern with the processing of your Personal Information, you may lodge a complaint with the applicable data protection authority in the country in which you reside.  For a list of EU data protection authorities and their contact information, please visit: https://edpb.europa.eu/about-edpb/board/members_en.  If you have a concern, you may also contact Loka Portugal at legal@loka.com.

10. Changes to this Privacy Policy

We may change this Privacy Policy at any time without prior notice. Any updated Privacy Policy will include a date which indicates when the Privacy Policy was last revised. Please check back often to review the most current version of the Privacy Policy.

Questions?

‍If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us at legal@loka.com and we will attempt to respond as soon as possible.