KosaLa Platform Privacy Policy

1. Information We Collect

We collect several types of information from and about users of our Services, including information that may personally identify you ("Personal Information").

1.1 Information You Provide Directly

Account and Profile Data: Name, email address, password, date of birth, gender, and location when you register for an Account.
Health and Fitness Data (Sensitive): Information related to your physical condition, goals, weight, height, body metrics, dietary preferences, activity levels, and biometric data (if provided or synced from third-party devices).
User-Generated Content (UGC): All content you post, including workout plans, meal recipes, social posts, comments, reviews, and messages.
Transactional Data (E-commerce): Details related to purchases and sales, such as Seller Offerings purchased, subscription details, and payment information (processed via third-party providers, we do not store full card details).
Customer Support Data: Information you provide when you contact us for support or feedback.

1.2 Information Collected Automatically

Usage Data: Details of your access to and use of the Services, including traffic data, logs, feature usage (e.g., interaction with the Lisanga or Muvema features), and the resources that you access and use.
Technical and Device Information: Internet protocol (IP) address, device type, operating system, browser type, unique device identifiers, and mobile network information.
Tracking Data: We and our service providers use cookies, web beacons, and other tracking technologies to gather information about your activities over time and across third-party websites or other online services.

1.3 Information from Third Parties

We may receive information about you from third parties, such as fitness trackers (e.g., smartwatches), social media services, or payment processors, when you link these services to your KosaLa Account.

2. How We Use Your Information

We use the information we collect for various purposes, including:

To provide, operate, maintain, and improve the Services, including our core features like Lisanga and Muvema.
To process your transactions and manage your Account, including facilitating communication between Buyers and Sellers.
To personalize your experience and provide tailored content, workout routines, and dietary recommendations.
To communicate with you about your Account, Services, or changes to our policies.
To monitor and analyze trends, usage, and activities in connection with our Services.
To detect, prevent, and address technical issues, fraud, or other illegal activities.
To enforce our Terms and Conditions and protect the rights and safety of our Users and KosaLa.

2.1 Specific Use for AI Training and Development

You acknowledge and agree that KosaLa uses your collected data, including:

User-Generated Content (UGC) (e.g., posts, recipes, custom plans).
Aggregated and De-identified Health/Activity Data (e.g., workout completion, metrics, preferences).
Usage Data and Feedback (e.g., how you interact with AI Features).

to **develop, train, and improve our proprietary artificial intelligence models and features**, such as those powering personalized plans and recommendations. This process helps us refine the accuracy, relevance, and safety of our AI-driven features for all users. When used for training, efforts are made to aggregate or de-identify personal identifiers wherever feasible, consistent with applicable legal requirements.

3. How We Share Your Information

We share your information in the following circumstances. Please note that raw, personally identifiable Health and Fitness Data (as defined in Section 1.1) is kept confidential and is not sold or shared with third parties, except with your explicit consent or as necessary to provide core Service functionality (e.g., syncing data to a connected fitness device).

3.1 With Other Users (Publicly)

Your profile name, profile picture, and any **User-Generated Content** you choose to post publicly (e.g., community posts, shared workouts, reviews) will be visible to other Users of the Services.
In the context of e-commerce, Sellers will receive Buyer information (e.g., name, purchase details) necessary to fulfill the Offering.

3.2 With Service Providers

We share information with third-party vendors, consultants, and other service providers who perform services for us or on our behalf. These include payment processors, cloud hosting providers, customer support services, and analytics providers. These parties are contractually obligated to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

3.3 Corporate Transactions

We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

3.4 Legal Compliance and Protection

We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a legal obligation; (b) protect and defend the rights or property of KosaLa; (c) act in urgent circumstances to protect the personal safety of Users or the public; or (d) protect against legal liability.

3.5 Sale of Aggregated, De-identified Group Data (Your Right to Opt-Out)

KosaLa engages in the business practice of sharing or "selling" **Aggregated and De-identified Group Data** to third parties for research, business analysis, security, and commercial purposes (e.g., providing insights to partners about general wellness trends, platform usage, and demographic statistics). This data is strictly defined as information that:

Has been processed to remove all direct personal identifiers.
Cannot reasonably be used to identify an individual user.
Focuses on group trends rather than individual activity.

Crucial Protection: Raw, personally identifiable Health and Fitness Data collected via the Platform is not included in the "Aggregated, De-identified Group Data" sets that are shared or sold. We maintain strict separation and do not sell or freely share your personal health metrics, name, or email with outside parties for marketing or commercial profit.

Your Right to Opt-Out: As detailed in Section 4, you have the right to opt-out of the sharing of this Aggregated, De-identified Group Data. If you opt-out, your personal data will not be included in any such commercially shared datasets.

4. Your Rights and Choices

4.1 Access and Correction

You can review and change your Personal Information by logging into the Services and visiting your Account profile page. You may also contact us to request access to, correct, or delete any Personal Information that you have provided to us.

4.2 Marketing Communications

You may opt-out of receiving promotional emails from us by following the unsubscribe instructions within those emails.

4.3 Opt-Out of Aggregated Data Sharing/Sale

If you wish to opt-out of the sharing of Aggregated and De-identified Group Data as described in Section 3.5, you may exercise this right by:

Account Settings: Visiting the "Privacy Settings" section within your Account and toggling the relevant data sharing preference.
Email Request: Sending an email request to privacy@kosala.io with the subject line "Opt-Out of Data Sharing," including your full name and Account email address.

Please allow up to thirty (30) days for your opt-out request to be fully processed.

4.4 Data Retention

We retain your Personal Information only for as long as is necessary for the purposes set out in this Policy, including for the purpose of satisfying any legal, accounting, or reporting requirements, and for the development and training of our AI models, as permissible under data minimization principles.

5. Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

6. Children's Privacy

The Services are not intended for children under 16 years of age. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on the Services or through any of its features. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information.

7. Changes to Our Privacy Policy

KosaLa reserves the right to modify this Privacy Policy at any time. When we make material changes to this Policy, we will notify you by posting the updated Policy on this page and updating the "Last Updated" date. We encourage you to review this Policy periodically for any changes. Your continued use of the Services after the posting of a revised Privacy Policy means that you accept and agree to the changes.