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PRIVACY POLICY

Kaltura Privacy Notices

These privacy notices provide important information about how Kaltura, Inc.
(“Kaltura”) collects, uses, processes, protects, and discloses information when
you use the Kaltura Websites and the Kaltura Platform.

Our Privacy Notice for the Kaltura Websites details the kinds of Personal
Information we collect when you visit the various websites that we operate and
how we manage and use that information.

Our Privacy Notice for the Kaltura Platform details the kinds of Personal
Information that are collected when you use or interact with the Kaltura
Platform through an Account Owner’s account.

These notices include legal information about your privacy rights, how you can
exercise your legal rights, and how to contact Kaltura.

Kaltura may update these Privacy Notices at any time without prior notice. Any
such changes will become effective prospectively from the date of publication.
These Privacy Notices were last updated on January 1, 2024. We encourage you to
check this page frequently for any changes to our Privacy Notices.

Any inquiries, concerns, or requests regarding the use or disclosure of your
Personal Information should be directed to Kaltura’s data protection officer
at: DPO@kaltura.com.

 

Privacy Notice for the Kaltura Websites

This privacy notice contains important information about how Kaltura, Inc.
(“Kaltura”) collects, uses, processes, protects, and discloses information when
you use the Kaltura Websites.

Please visit the Terms of Use for further conditions governing your use of the
Kaltura Websites.

1. What this Privacy Notice covers

This policy describes how Kaltura treats Personal Information that we collect,
receive, process, store, distribute, and display via the Kaltura Websites,
including email, text, and other electronic communications between you and
Kaltura.

For our privacy notice on information collected on the Kaltura Platform
visit: Privacy Notice for the Kaltura Platform.

In this policy, “you” means any person or organization that is authorized to use
the Kaltura Platform or Website; “we” or “us” means Kaltura, including our
subsidiaries and affiliates.

The “Kaltura Websites” or “Websites” are websites and apps belonging to Kaltura.

“Marketing Partners” are trusted third parties providing us with services and
data for marketing purposes or conducting joint marketing activities with us.

“Personal Information” is information about you that is personally identifiable
by name or can be linked to you through a personal identifier like your address,
e-mail address, phone number, or location. This definition is given here for the
purpose of this notice only, and some laws may use a different definition. If
you are asserting your rights under law, the applicable legal definition governs
your rights.

2. When does Kaltura collect Personal Information?

In general, Kaltura collects Personal Information about you in the following
situations:

 * * * When you visit the Kaltura Websites
     * When you interact with us on the Kaltura Websites (e.g. via webforms, our
       website chat feature, etc.)
     * When you register through one of the Kaltura Websites for online or
       in-person events organized by Kaltura and/or our business partners
     * When you sign up to receive Kaltura’s email newsletter, blog updates, or
       other communications from Kaltura
     * When you participate in a Kaltura survey
     * When you communicate with Kaltura, post information to a blog or
       community forum, or upload user submitted media.
     * When you enter promotions and contests offered by Kaltura
     * When you submit your resume or other Personal Information through the
       Kaltura Websites in connection with a job application

Provision of this information to Kaltura is not mandatory. However, you will not
be able to access and use the Kaltura Websites and communicate with Kaltura
without disclosing some Personal Information to Kaltura.

3. What categories of Personal Information we collect?

Through the Kaltura Websites, we may collect Personal Information that you
voluntarily provide, such as your name, email address, location, professional
title and affiliation, and interests. We also record your communications
preferences when you sign up to receive email communications from Kaltura.

In addition, like most other websites, when you visit any of the Kaltura
Websites, Kaltura automatically receives and records information from a variety
of sources, such as information from your browser, device, Kaltura and
third-party cookie information, web beacons, VAST tags, pixel tags, social media
buttons, URL links, and other methods. Information collected automatically
through these sources include your activity on the Kaltura Websites and unique
identifiers such as your IP address and device ID.

We collect Personal Information about potential business customers and partners
from our Marketing Partners and public sources.

Although some information collected automatically is not personally
identifiable, we or our Marketing Partners may, to the extent permitted by
applicable law, aggregate or combine this information with information from
other sources, both public and non-public (such as data brokers and organizers
of conferences you attended who have your permission to transfer information to
us, and information available publicly on the Internet). Combining information
from various sources could make anonymous information identifiable as Personal
Information or add to the Personal Information we already have about you.

 

4. The purposes for which we use your Personal Information

We use your Personal Information from the Kaltura Websites solely for certain
legitimate business purposes, which include some or all of the following:

 * * * Contacting you and sending you communications that we think will be of
       interest to you.
     * Providing you the information you request through our Websites.
     * Remembering information you previously entered on our Websites to
       enhance, modify, personalize, or otherwise improve your experience on our
       Websites.
     * Improving our Websites, services, and products.
     * Customizing the advertising and content you see.
     * Conducting research and providing statistical reporting to understand how
       individuals interact with our Websites and determine the effectiveness of
       promotional campaigns and advertising.

5. Children

The Kaltura Websites are not intended for children and we do not permit children
to register on Kaltura Websites.

If we become aware that we have inadvertently received or collected Personal
Information pertaining to a child under the age of consent in the jurisdiction
where the child is located without valid consent, we will delete such
information from our records.

6. Cookies and other activity tracking technologies

We use cookies and other technologies such as web beacons, tags and other
technologies to collect information about usage of Kaltura Websites and
interaction with emails that we have sent.

When you visit Kaltura Websites, our servers or an authorized third party may
place a cookie on your browser. The cookie can collect information, including
Personal Information, about your online activities. Cookies allow us to track
usage of the Kaltura Websites and provide you with a better browsing experience.

We also use web beacons on the Kaltura Websites. For example, web beacons may be
placed in marketing emails to notify us when you click on a link in the email
and are directed to a Kaltura Website. Web beacons are used to improve the
Kaltura Websites, enhance our email communications, and track the success of our
promotional campaigns.

Please see below for details about how we use different categories of cookies
and other tracking technologies, as well as how you can manage cookie settings:

 * * * Functional cookies – We use functional cookies to retain information you
       entered (such as your language or your geographic region) and collect
       information about how the Kaltura Websites are used. We may use
       third-party technology to track and analyze usage information to improve
       how the Kaltura Websites function, improve your browsing experience,
       provide more relevant communications, and track the performance of our
       advertisements. To manage the use of functional cookies on the Kaltura
       Websites, consult your individual browser settings for cookies. You can
       also visit https://www.aboutcookies.org/ for more information on managing
       cookies. Note that disabling these cookies may impact functionality when
       using the Kaltura Websites.
     * Advertising cookies – We or authorized third parties may use cookies to
       show you ads for our products that we think may interest you on any
       devices you may use. You may see advertisements for Kaltura’s products on
       other websites or mobile applications on any of your devices. These
       cookies also help us manage and track the effectiveness of our marketing
       efforts. To manage the use of advertising cookies on the Kaltura
       Websites, consult your individual browser settings for cookies. In
       addition, many ad networks have joined the Digital Advertising Alliance’s
       self-regulatory program to provide a single opt-out tool
       at: https://www.aboutads.info and at the European Interactive Digital
       Advertising Alliance (EDAA) website: https://youronlinechoices.eu.
       However, Kaltura does not guarantee that using these tools will prevent
       online behavioral tracking using cookies through our Websites. At
       present, Kaltura and our third-party Marketing Partners do not honor Do
       Not Track signals set by some browsers. If you wish to avoid behavioral
       tracking by ad networks, please choose from the available methods for
       doing so or refrain from using the Kaltura Websites.
     * Social media buttons – The Kaltura Websites use social media buttons,
       such as the Facebook “like” button, the “Tweet” button and other sharing
       functions (collectively, “Social Media Buttons”). Through the Social
       Media Buttons, you may have the option to post information about your
       activities on the Kaltura Websites to your profile page on a third-party
       social media network and share with others within your network. Cookies
       may be set by the respective social media networks to track your online
       activity. Kaltura has no direct control over the information that is
       collected by these third parties. Your interactions with Social Media
       Buttons are governed by the privacy policies of the respective social
       media networks.

7. Editing and deleting your Personal Information and preferences and opting out
of communications and direct marketing.

You can review, correct, edit, or delete the information that you provided to us
by sending us an e-mail request at DPO@kaltura.com. Please note that we may need
to verify your identity before processing your request. You may elect to “opt
out” of receiving direct marketing or being included in market research
information. You can opt out of receiving email communications by following the
instructions through the unsubscribe option in Kaltura’s emails. You may also
opt out at any time, edit your account information, or delete your account
entirely by sending an e-mail request to DPO@kaltura.com (please indicate “Opt
Out” in the subject line).

New categories of communication and notification might be added to the
Preferences page of the Kaltura Community Forum from time to time. You can opt
out of receiving future communications from these new categories or you can
unsubscribe and block future messages by following instructions through the
unsubscribe option in those messages.

If you are a Kaltura Platform Account Owner, you will continue to receive
certain communications pertaining to your Kaltura Platform account such as
service announcements and administrative messages even if you opt out of
marketing communications from Kaltura.

While we will try to comply with any request pertaining to your Personal
Information in accordance with applicable law, please be aware that we may not
be able to fulfill requests pertaining to information already shared with third
parties. Some information may be retained on our systems for record-keeping
purposes, and some residual digital information cannot be removed or changed.

8. Disclosure of Personal Information to third parties

We do not sell, disclose, or share Personal Information about you with third
parties except under the following circumstances and for the following purposes:

 * * * When we have your permission to provide you with services you requested
       and to carry out your instructions.
     * When required by law to respond to subpoenas, court orders, or legal
       process by public authorities, including disclosures required by national
       security or law enforcement agencies.
     * When we need to establish or exercise our legal rights, or to defend
       against legal claims, or when we believe it is necessary to share
       information in order to investigate, prevent, or take action regarding
       illegal activities, data breaches, suspected fraud, situations involving
       potential threats to the physical safety of any person, violations of
       Kaltura’s Terms of Use, or as otherwise required by law.
     * We may transfer your Personal Information if Kaltura is acquired by or
       merged with another company, to ensure the continuity of our business and
       services. In such an event, Kaltura will make a public announcement
       before information about you becomes subject to a different privacy
       policy.
     * When we conduct joint webinars or marketing events with business
       partners, we may share participant contact information with such business
       partners for their marketing use.
     * We may share your Personal Information with third-party service providers
       or vendors that we engage to support Kaltura’s business and/or the
       Kaltura Websites. Examples include providers of website hosting services,
       website analytics services, website chat services, and marketing and
       communication services. These third parties are authorized to process
       your Personal Information solely for the purposes of providing the
       relevant services to Kaltura.

Kaltura and its affiliates are located in different regions around the world,
and Kaltura works with strategic partners across different industries,
categories of business, and in different jurisdictions. By accessing the Kaltura
Websites, your information may be transferred outside of your local
jurisdiction.

9. Retention of information

We may retain your information (including Personal Information) for any lawfully
permitted period of time, and as necessary to comply with our legal and
contractual obligations, enforce our agreements, and enable us to investigate
events and resolve disputes.

10. Kaltura blogs and discussion forums

If you participate in a Kaltura blog, discussion forum, or other parts of our
Websites that allow you to post your comments, you should be aware that the
information you provide there may be made broadly available to others,
potentially inside and outside Kaltura, who have access to that blog or
discussion forum. Blogs and discussion forums are monitored by Kaltura, and we
reserve the right to remove your content at our discretion. Each participant’s
opinion on a blog or discussion forum is his or her own.

11. Third-party sites

The Kaltura Websites include links to other websites owned or operated by third
parties, such as our channel partners who provide products and services that can
be used together with Kaltura’s products and services. Kaltura is not
responsible for the privacy or security practices of any third-party websites,
which are governed by their own privacy policies.

12. Confidentiality, security, and data integrity

We take great precautions to protect the integrity of your Personal Information.
However, no data transmission over the Internet or any other network can be
guaranteed to be 100% secure. While we strive to protect information transmitted
on or through our Websites, we cannot and do not guarantee the security of any
information you transmit.

To learn more about security, including the security measures we have taken and
steps you can take to enhance the security of your information when using the
Kaltura Websites, please contact us at DPO@kaltura.com.

13. Rights of California Residents under the California Consumer Privacy Act of
2018 (CCPA)

If you are a resident of the State of California in the United States, you are
entitled to certain rights under the California Consumer Privacy Act of 2018
(CCPA). The categories of Personal Information we collect about or from you are
described in section 3 above, and the business purposes for which we collect
such Personal Information are described in section 4 above.

As a business subject to the CCPA, Kaltura does not sell Personal Information.
Kaltura may share Personal Information with third-party service providers or
business partners for our own business purposes as described in section 8 above.
However, we disclose your Personal Information to these third parties only where
you have consented to disclosure of Personal Information to such third parties
or where such third parties have agreed to contractual limitations around their
use, retention, and disclosure of Personal Information.

As a resident of the State of California, you have the following rights under
the CCPA:

 * * * You have the right to request access to the Personal Information we
       collect from or about you.
     * You have the right to request details about how we process or disclose
       your Personal Information.
     * You have the right to request that we delete the Personal Information we
       have collected about you, subject to certain exceptions.
     * You have the right to not be denied any goods or services for exercising
       your rights under the CCPA.

To exercise any of these rights, you may contact Kaltura by following the
instructions in section 16 below. We may need to verify your identity before we
are able to process your requests.

14. Rights of European Data Subjects under the EU and UK General Data Protection
Regulation (GDPR)

If you are in one of the European Union (EU) or European Economic Area (EEA)
countries, United Kingdom (UK) or Switzerland, you are entitled to certain
rights under applicable laws including the General Data Protection Regulation
(GDPR) EU Regulation 2016/679, and applicable national data protection
regulations.

By visiting the Kaltura Websites or communicating with Kaltura, you acknowledge
that we may process your Personal Information for the purposes described above,
either on the basis of your consent or if we have other lawful grounds to do so.
Under the GDPR and applicable local data protection regulations, you have the
following rights with respect to your Personal Information:

 * * * You have the right to withdraw consent to processing, where consent is
       the basis of processing. For the Personal Information we collect on the
       Kaltura Websites, this means you may withdraw your consent to processing
       by leaving the Kaltura Websites, suspending your account if you have
       registered on our Websites, and requesting that we delete your Personal
       Information by contacting us at DPO@kaltura.com.
     * You have the right to access your Personal Information that we hold and
       request further details about how we process it, under certain
       conditions.
     * You have the right to demand rectification of inaccurate Personal
       Information about you. We will promptly correct any information found to
       be incorrect.
     * You have the right to object to unlawful data processing under certain
       conditions.
     * You have the right to erasure of past data about you (your “right to be
       forgotten”) under certain conditions.
     * You have the right to demand that we restrict processing of your Personal
       Information, under certain conditions, if you believe we have exceeded
       the legitimate basis for processing, processing is no longer necessary,
       or if you believe your Personal Information is inaccurate.
     * You have the right to data portability of Personal Information concerning
       you that you provided us in a structured, commonly used, and
       machine-readable format, subject to certain conditions.
     * The Personal Information we collect on the Kaltura Websites is not used
       for automated decision making and profiling, except for automated
       processes in the context of marketing. As stated above, you can opt-out
       of direct marketing by Kaltura by contacting Kaltura directly or by
       following the instructions through the unsubscribe options in our email
       messages.
     * You have a right to complain to a data protection supervisory authority
       in your country if you believe that Kaltura is processing your Personal
       Information in violation of applicable laws.

To exercise any of these rights, you may contact Kaltura by following the
instructions in section 16 below. We may need to verify your identity before we
are able to process your requests.

Kaltura’s representative in the EU for the purposes of compliance with the GDPR
is Kaltura Germany GmbH, Kaltura’s Germany-based subsidiary, which may be
contacted at:

Kaltura Germany GmbH

c/o Mazars GmbH & Co. KG

Theodor-Stern-Kai 1

60596 Frankfurt am Main

Deutschland

Tel:      +1 800 871 5224

Email:  DPO@kaltura.com

To learn more about your rights under the GDPR you can visit the European
Commission’s page on Protection of Personal Data,
at: https://ec.europa.eu/justice/data-protection/index_en.htm

15. Cross-border Personal Information transfers

Kaltura is a global organization headquartered in the United States (US) and has
legal entities, business functions, and systems in countries around the world.

We may share your Personal Information within Kaltura and transfer it to
countries in the world where we do business, including to the US. Therefore,
your Personal Information may be processed in countries with privacy laws that
are different from privacy laws in your country or in countries that are not
subject to an adequacy decision by the European Commission. Regardless of
location, Kaltura handles Personal Information as described here, and we take
care to ensure that our employees, agents and strategic partners in other
countries act in a manner consistent with this privacy notice. Kaltura ensures
that the recipient of your Personal Information provides appropriate safeguards,
including by entering into data processing agreements incorporating, where
required, standard contractual clauses or an alternative mechanism for the
transfer of personal data as approved by the European Commission or other
applicable regulator.

Kaltura Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the
UK Extension to the EU-U.S DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce,  and where
appropriate, primarily relies on such certification for accepting transfers of
data from the EEA, UK and Switzerland to the US (as applicable).

Kaltura Inc. has certified to the U.S. Department of Commerce that it adheres to
the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with
regard to the processing of Personal Information received from the EU in
reliance on the EU-U.S. DPF, and from the UK (and Gibraltar) in reliance on the
UK Extension to the EU-U.S. DPF. We furthermore certify that Kaltura Inc.
adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF
Principles) with regard to the processing of Personal Information received from
Switzerland in reliance on the Swiss-US DPF. We will remain liable for onward
transfers of your Personal Information to third parties in accordance with
applicable data transfer mechanisms. If there is any conflict between the terms
in this policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern for Personal Information transferred
under the DPF. To learn more about the Data Privacy Framework (DPF) program, and
to view our certification, please visit https://www.dataprivacyframework.gov/.

Complaints about transfers of data from EU, UK or Switzerland to the US &
dispute resolution: In compliance with the DPF Principles, we commit to resolve
complaints about our collection or use of your Personal Information. EU, UK and
Swiss individuals with inquiries or complaints regarding our DPF compliance
should submit such inquiries to DPO@kaltura.com.

Kaltura is further committed to refer unresolved privacy complaints under the
EU-U.S. DPF, the UK Extensions to the EU-U.S. DPF, and the Swiss-U.S. DPF to
JAMS, a non-profit alternative dispute resolution provider located in the US. If
you do not receive timely acknowledgment of your DPF Principles-related
complaint, or if we have not addressed your DPF Principles-related complaint to
your satisfaction, please visit
https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to
file a complaint. The services of JAMS are provided at no cost to you.

Furthermore, subject to certain conditions (as described under the EU-U.S. DPF
Principles that Kaltura Inc. adheres to), you may invoke binding arbitration by
delivering a notice to us via DPO@kaltura.com. Kaltura Inc. is also subject to
the investigatory and enforcement powers of the Federal Trade Commission.

16. Contacting Kaltura about this Privacy Notice

Any inquiries, concerns, or requests regarding the use or disclosure of your
Personal Information should be directed to Kaltura’s data protection officer
at: DPO@kaltura.com.

You may also send inquiries to the following address:

Kaltura, Inc.

860 Broadway, 3rd Floor

New York, NY 10003

Attention: Legal Counsel

17. Changes to this Privacy Notice

Kaltura may update this Privacy Notice at any time without prior notice. Any
such changes will become effective prospectively from the date of publication.
This Privacy Notice was last updated on January 1, 2024. We encourage you to
check this page frequently for any changes to our Privacy Policy.

Privacy Notice for the Kaltura Platform

This privacy notice explains how Kaltura, Inc. (“Kaltura”) collects, uses,
processes, protects, and discloses information on the Kaltura Platform.

Please visit the Terms of Use for further conditions governing your use of the
Kaltura Websites.

1. What this Privacy Notice covers

This policy describes how Kaltura handles Personal Information on the Kaltura
Platform.

For our privacy notice on information related to the Kaltura Websites and other
communications with Kaltura go to: Privacy Notice for the Kaltura Websites.

In this policy, “you” means any User that is authorized to use the Kaltura
Platform through an Account Owner’s account; “we” or “us” means Kaltura,
including our subsidiaries and affiliates.

“Account Owner” means the individual(s) or organization(s) that have permission
to use the Kaltura Platform to provide services and distribute media from their
account.

“Kaltura Platform” means the cloud-based hosted services, APIs, plug-ins,
applications, media players, custom websites, and storage provided by Kaltura to
Account Owners.

“Partner” means trusted third parties and business associates that provide us
with some of the services that we provide to you. For example, our Partners
include content distribution networks (CDNs), third-party platforms that are
integrated with the Kaltura Platform via APIs or plug-ins, and third-party
services you can access through the Kaltura Platform.

“Personal Information” is information about you that is personally identifiable
by name or can be linked to you through a personal identifier like your address,
e-mail address, phone number, or location, and which is not otherwise publicly
available. This definition is given here for the purpose of this notice only,
and some laws may use a different definition. If you are asserting your rights
under law, the applicable legal definition governs your rights.

“Users” are those individuals (such as, customers, subscribers, viewers,
employees, staff, faculty, student, members, or other persons) who are
authorized by an Account Owner to access video, audio, and/or other content from
their account.

2. Kaltura is a Data Processor

The Kaltura Platform is a set of online hosted software (“SaaS”) tools for
hosting, managing and distributing video content over the Internet. We make
accounts on the Kaltura Platform available to Account Owners that are paying
customers, free trial users, and business partners. Information uploaded and
stored on the Kaltura platform is associated with a given account. In each case,
the Account Owner is the Data Controller of the Personal Information of its
Users on that account. Kaltura is the Data Processor carrying out data
processing activities and instructions on behalf of each Data Controller.

3. Disclosures of information under Account Owner control

Account Owners use the Kaltura Platform to store, process, and distribute videos
and other information belonging to them or their Users through their websites,
apps, or other comparable means. Depending on the configuration of the Kaltura
Platform selected by the Account Owner, media and other information on the
Account Owner’s account may be viewable to the general public or to limited
audiences. As the controller of Personal Information on the Kaltura Platform,
Account Owners are responsible for maintaining the privacy of Personal
Information pertaining to their Users.  Kaltura is not responsible for
disclosures of information made by Account Owners and their Users through such
Account Owners’ respective accounts. When we process your Personal Information
on behalf of an Account Owner, it is that Account Owner’s responsibility to
protect your privacy.

If you are concerned about your privacy while interacting with services provided
by a Kaltura Account Owner, you should address requests and inquiries relating
to your Personal Information directly to that Account Owner. If you contact us
regarding information associated with an Account Owner’s account, we may forward
your requests or inquiries to the relevant Account Owner.

4. When is your Personal Information collected on the Kaltura Platform?

When you interact with the Kaltura Platform through an Account Owner’s account,
Kaltura collects your Personal Information. Examples of activities where you
might interact with the Kaltura Platform include:

 * * * Viewing videos on the Internet provided from a Kaltura Platform account.
     * Uploading content to the Kaltura Platform.
     * Appearing on videos hosted on the Kaltura Platform.
     * Using applications connected to the Kaltura Platform, logging in to
       applications connected to the Kaltura Platform, or downloading a Kaltura
       mobile application.
     * Interacting with the Kaltura APIs.
     * Opening a free trial account or other partner account for the Kaltura
       Platform.
     * Downloading a Kaltura application from sites like the Apple App Store and
       Google Play.
     * Interacting with Kaltura on behalf of an Account Owner (for example, if
       you are an Account Owner’s account or business administrator or a
       technical contact you may provide your contact information to Kaltura for
       service or billing purposes).

5. What Personal Information do we collect about you on Kaltura Platform
accounts?

When you use the Kaltura Platform as a User through an Account Owner’s account,
the following categories of Personal Information may be collected and processed:

 * * * Information you upload – If you are authorized to upload videos to a
       Kaltura account, the video content and metadata that you upload may
       potentially include Personal Information about you and/or other third
       parties.
     * Information provided by the Account Owner – The Account Owner may enter
       or create Personal Information about you on its account. For example,
       your information may be included in the Account Owner’s authorized User
       lists, access permissions, or in audio or video content and/or metadata.
     * Traffic information, instructions, and activity on the Kaltura Platform –
       When you interact with the Kaltura Platform, the system collects the
       traffic information needed to deliver your actions and instructions over
       the Internet. Personal Information about you may include IP addresses,
       and URLs used to deliver content to you, and the Kaltura Platform may
       collect other system information such as MAC addresses to allow the
       system to recognize your devices. The Kaltura Platform uses cookies to
       remember your preferences and/or support the use of digital rights
       management systems.
     * Passwords and login credentials – When you log in to the Kaltura
       Platform, we collect the user IDs and passwords used in order to access
       the Kaltura Platform. When you log in to other Account Owner systems that
       are connected to the Kaltura Platform (such as single sign-on systems or
       third-party portals), depending on the configuration of those systems,
       the Kaltura Platform may receive user login credentials or an anonymous
       identifier or token.

Contact and billing information – If you are a Kaltura Account Owner, we collect
your contact and billing information.

6. How we use your Personal Information

We use your information solely for the following purposes:

 * * * Provide the services and functions you requested from the Account Owner
       and performing your actions and instructions on the Kaltura Platform
       through the Account Owner’s account.
     * Providing support, service notices, billing, and other account-relevant
       information to Account Owners.
     * We use the Account Owner’s contact and billing address to send Account
       Owners offers and promotional information.
     * Creating aggregate statistics and analytics information for Kaltura’s own
       use and our Account Owners’ respective use.
     * We may use content on an Account Owner’s account to troubleshoot and
       resolve service issues on that Account Owner’s account.
     * We use traffic information and aggregated user information to better
       monitor the performance of the Kaltura Platform, track account usage, and
       test and improve the Kaltura Platform.

7. Audit logs

The activity on the Kaltura Platform production servers is logged within the
system for the purpose of providing Kaltura Account Owners and Partners with
statistical analysis of use, and to enable us to monitor the system, perform
security audits, track errors, report activity via the system, and to comply
with data retention rules and internal policies.

We use commercially reasonable methods to keep production logs secure and do not
use them for any other purpose or share them with third parties except for
permitted disclosures to third parties as detailed below.

8. Sharing information with Partners

We rely on certain trusted third-party Partners to provide part of the services
and functions that make up the Kaltura Platform. For example, we transmit video
content via third party content delivery networks (CDNs).

Kaltura does not share your information, including Personal Information, with
any third parties other than our Partners except in the limited circumstances
detailed below. Our Partners do not have permission to use your Personal
Information for any purpose other than to provide to Kaltura the services we
require to serve our Account Owners.

The Kaltura Platform is designed to interoperate with different systems.  Our
Account Owners may choose to integrate the Kaltura Platform with their own
systems or with other third-party services of their designation. Kaltura is not
responsible for systems connected to the Kaltura Platform that are not under our
control.

9. Cookies and other activity tracking technologies

The Kaltura Platform uses certain persistent first-party cookies to provide the
best user experience and remember your preferences on the Kaltura Platform.

The Kaltura Platform does not place third-party cookies on your devices.
However, elements of the Kaltura Platform, such as the Kaltura player may send
information about your activities on the Kaltura Platform to cookies placed by
others (such as ad networks) on your devices through web beacons, VAST tags, and
other technologies. Other parties’ cookies are subject to their own privacy
policies.

Most Internet browsers have options for controlling, disabling, and deleting
cookies on your computer. To learn how to control cookies using your browser
settings, visit https://www.aboutcookies.org/. In addition, many ad networks
have joined the Digital Advertising Alliance’s self-regulatory program to
provide a single opt-out tool at: https://www.aboutads.info and at the European
Interactive Digital Advertising Alliance (EDAA)
website: https://youronlinechoices.eu. However, Kaltura does not guarantee that
using these tools will prevent online behavioral tracking using cookies through
the Kaltura Platform.

10. Disclosure of Personal Information to third parties

Your Personal Information on a Kaltura Platform account is controlled by the
Account Owner. We do not disclose your Personal Information to third parties
except under the following circumstances and for the following purposes:

 * * * When we have the Account Owner’s permission, in order to provide the
       Account Owner with services it requests.
     * When required by law to respond to subpoenas, court orders, or legal
       process by public authorities, including disclosures required by national
       security or law enforcement agencies.
     * When we need to establish or exercise our legal rights, or to defend
       against legal claims, or when we believe it is necessary to share
       information in order to investigate, prevent, or take action regarding
       illegal activities, data breaches, suspected fraud, situations involving
       potential threats to the physical safety of any person, violations of
       Kaltura’s Terms of Use, or as otherwise required by law.
     * If Kaltura is acquired by or merged with another company, the Kaltura
       Platform (including the information stored on Account Owner’s respective
       accounts) may be transferred to another entity.
     * With our Partners, as described above.

11. Receipt of information from third parties

Kaltura integrates with third-party services (e.g., Zoom, Webex, YouTube) to
automate ingestion of media assets from the third-party service to the Kaltura
Platform. Media assets ingested from third-party services and associated with an
Account Owner’s account are processed according to the same guidelines that
apply to the Account Owner’s other media assets and data stored on the Kaltura
Platform. Retention of media assets ingested from third-party services is
controlled by the Account Owner, who may choose to retain such media assets even
after ending its relationship with the third-party service.

Processing and retention of data from third-party services may also be subject
to the privacy policies and terms of use of those third-party services. In
particular, Kaltura’s YouTube integration uses the YouTube API Services. Account
Owners using Kaltura’s YouTube integration agree to be bound by the YouTube
Terms of Service (https://www.youtube.com/t/terms) and are subject to Google’s
Privacy Policy (https://www.google.com/policies/privacy). In addition to
Kaltura’s normal procedures for managing and deleting the media assets, Account
Owners can manage and revoke the Kaltura YouTube integration’s access to data
via the Google security settings page
at https://security.google.com/settings/security/permissions.

12. Retention of information

We may retain your information (including Personal Information) on the Kaltura
Platform for any lawfully permitted period of time, and as necessary to comply
with our legal and contractual obligations, enforce our agreements, and enable
us to investigate events and resolve disputes.

13. Confidentiality, security, and data integrity

We take great precautions to protect the integrity of your Personal Information.
However, no data transmission over the Internet or any other network can be
guaranteed to be 100% secure. While we strive to protect information on the
Kaltura Platform, we cannot and do not guarantee the security of any information
you transmit.

To learn more about security, including the security measures we have taken and
steps you can take to enhance the security of your information when using the
Kaltura Platform, please contact us at DPO@kaltura.com.

14. Rights of California Residents under the California Consumer Privacy Act of
2018 (CCPA)

If you are a resident of the State of California in the United States, Kaltura
has certain obligations as a service provider towards Account Owners regarding
your Personal Information under the California Consumer Privacy Act of 2018
(CCPA). As a service provider, Kaltura processes Personal Information solely for
the purpose of providing the services specified in the contracts between Kaltura
and the Account Owners. Kaltura does not process Personal Information collected
through an Account Owner’s account for any other purpose.

If you are concerned about your privacy while interacting with services provided
by a Kaltura Account Owner, you should address requests and inquiries relating
to your Personal Information directly to that Account Owner. If you contact us
regarding information associated with an Account Owner’s account, we may forward
your requests or inquiries to the relevant Account Owner.

To learn more about your rights under the CCPA, you can visit the California
Office of the Attorney General’s page on the CCPA at:
https://oag.ca.gov/privacy/ccpa.

15. Rights of European Data Subjects under the EU and UK General Data Protection
Regulation (GDPR)

If you are in one of the European Union (EU)/ European Economic Area (EEA)
countries, the United Kingdom (UK) or Switzerland, Kaltura has certain
obligations as a data processor towards Account Owners regarding your Personal
Information under applicable laws, including the General Data Protection
Regulation (GDPR).

The Account Owners, as data controllers, will be responsible for protecting your
rights under applicable laws, including the GDPR.

If you are concerned about your privacy while using services provided by a
Kaltura Account Owner, you should address requests and inquiries relating to
your Personal Information directly to that Account Owner. If you contact us
regarding information on an Account Owner’s account, we may forward your
requests or inquiries to the relevant Account Owner.

To learn more about your rights under the GDPR you can visit the European
Commission’s page on Protection of Personal Data,
at: https://ec.europa.eu/justice/data-protection/index_en.htm.

16. Cross-border Personal Information transfers

The Kaltura Platform hosts and processes information in the United States (US)
and in other countries around the world. In addition, Kaltura staff may remotely
access the Kaltura Platform from other countries where we conduct business
operations.

In providing the Kaltura Platform and processing your Personal Information on
behalf of an Account Owner, your Personal Information may be transferred to the
US or to other countries. Therefore, your Personal Information may be processed
in countries with privacy laws that are different from privacy laws in your
country or in countries that are not subject to an adequacy decision by the
European Commission. Regardless of location, Kaltura handles Personal
Information as described here, and we take care to ensure that our employees,
agents and Partners in other countries act in a manner consistent with this
privacy notice. Kaltura ensures that the recipient of your Personal Information
provides appropriate safeguards, including by entering into data processing
agreements incorporating, where required, standard contractual clauses or an
alternative mechanism for the transfer of personal data as approved by the
European Commission or other applicable regulator.

Kaltura Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the
UK Extension to the EU-U.S DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce, and where
appropriate, primarily relies on such certification for accepting transfers of
data from the EEA, UK and Switzerland to the US (as applicable).

Kaltura Inc. has certified to the U.S. Department of Commerce that it adheres to
the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with
regard to the processing of Personal Information received from the EU in
reliance on the EU-U.S. DPF, and from the UK (and Gibraltar) in reliance on the
UK Extension to the EU-U.S. DPF. We furthermore certify that Kaltura Inc.
adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF
Principles) with regard to the processing of Personal Information received from
Switzerland in reliance on the Swiss-US DPF. We will remain liable for onward
transfers of your Personal Information to third parties in accordance with
applicable data transfer mechanisms. If there is any conflict between the terms
in this policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern for Personal Information transferred
under the DPF. To learn more about the Data Privacy Framework (DPF) program, and
to view our certification, please visit https://www.dataprivacyframework.gov/.

Complaints about transfers of data from EU, UK or Switzerland to the US &
dispute resolution: In compliance with the DPF Principles, we commit to resolve
complaints about our collection or use of your Personal Information. EU, UK and
Swiss individuals with inquiries or complaints regarding our DPF compliance
should submit such inquiries to DPO@kaltura.com.

Kaltura is further committed to refer unresolved privacy complaints under the
EU-U.S. DPF, the UK Extensions to the EU-U.S. DPF, and the Swiss-U.S. DPF to
JAMS, a non-profit alternative dispute resolution provider located in the US. If
you do not receive timely acknowledgment of your DPF Principles-related
complaint, or if we have not addressed your DPF Principles-related complaint to
your satisfaction, please visit
https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to
file a complaint. The services of JAMS are provided at no cost to you.

Furthermore, subject to certain conditions (as described under the EU-U.S. DPF
Principles that Kaltura Inc. adheres to), you may invoke binding arbitration by
delivering a notice to us via DPO@kaltura.com. Kaltura Inc. is also subject to
the investigatory and enforcement powers of the Federal Trade Commission.

17. Contacting Kaltura about this Privacy Notice

Any inquiries, concerns, or requests regarding the use or disclosure of your
Personal Information should be directed to Kaltura’s data protection officer at:
DPO@kaltura.com.

You may also send inquiries to the following address:

Kaltura, Inc.

860 Broadway, 3rd Floor

New York, NY 10003

Attention: Legal Counsel

18. Changes to this Privacy Notice

Kaltura may update this Privacy Notice at any time without prior notice. Any
such changes will become effective prospectively from the date of publication.
This Privacy Notice was last updated on January 1, 2024. We encourage you to
check this page frequently for any changes to our Privacy Policy.



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solutions are deployed globally across thousands of enterprises, media
companies, service providers, and educational institutions, leveraging video to
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