Privacy Policy

Last updated: 2025 

Kodama Systems, Inc. (“Kodama,” “Company,” “we,” “us,” or “our”) respects the privacy of individuals whose Personal Information it collects and processes. This Privacy Policy (“Policy”) describes the categories of Personal Information we collect, the purposes for which such information is used, the circumstances under which it may be disclosed to third parties, and the measures we take to comply with applicable privacy and data protection laws. 

This Policy applies to all Personal Information collected by Kodama from: (i) visitors to our website; (ii) individuals who submit inquiries, forms, or other communications to us; and (iii) job applicants and employees in the course of the employment lifecycle, among others and their respective engagements with the Company. 

1. Categories of Personal Information Collected 

A. Customer Information 

Through voluntary form submissions on our website hosted by website servers, which are transmitted to and stored on internal Company servers, we may collect the following Personal Information: 

  • Name 

  • Telephone number 

  • Email address 

  • Physical address 

  • Company affiliation, or 

  • Other related information 

B. Employment and Human Resources Information 

In the context of recruitment, employment, and administration of payroll and benefits, Kodama may collect the following categories of Personal Information: 

  • Government-issued identification numbers and documents 

  • Financial Information 

  • Health and safety data 

  • Background and work authorization data subject to applicable law 

Such information is maintained within secure, third-party systems used for work related purposes. 

C. Automatically Collected Technical Data 

When users access our website, the Company we may collect technical web data, “cookies,” by automated means to improve your browsing experience and provide enhanced security, analytics, and customization.  

Information collected may include: 

  • Device identifiers and browser characteristics 

  • Internet Protocol (IP) address 

  • Preferences (e.g., language, layout, theme) 

  • Login/authentication tokens 

  • Tracking data (e.g., pages visited, time spent, clicks) 

  • Usage information collected via cookies and related technologies 

Users may control the use of cookies through browser settings; however, certain functionality may be limited if cookies are disabled. 

2. Purpose of Collection and Use of Personal Information 

Kodama processes Personal Information solely for legitimate business purposes, including but not limited to: 

  • Responding to customer inquiries and providing requested services 

  • Processing payroll, reimbursements, and administering employee benefits 

  • Evaluating job applicants and maintaining employment records 

  • Complying with workplace health and safety, tax, and legal obligations 

  • Protecting the security and integrity of our systems and preventing fraud 

Personal Information is not processed for purposes inconsistent with those stated in this Policy without providing notice or obtaining consent where legally required. 

3. Disclosure of Personal Information 

Kodama does not sell Personal Information and does not disclose Personal Information to third parties for purposes of advertising, marketing, or cross-context behavioral profiling. 

Personal Information may be disclosed under the following limited circumstances: 

  • Service Providers: To vendors and contractors engaged to support business operations subject to contractual obligations to safeguard such information and restrict use to the services provided 

  • Legal and Regulatory Requirements: Where disclosure is required by law, regulation, subpoena, or lawful request from governmental authorities 

  • Corporate Transactions: In the event of a merger, acquisition, or other corporate restructuring, subject to appropriate confidentiality and legal protections 

4. Data Security 

Kodama implements reasonable and appropriate technical, organizational, and administrative safeguards to protect Personal Information from unauthorized access, disclosure, alteration, or destruction. Access to Personal Information is limited to those employees or authorized personnel who have a legitimate business need to access such information. 

5. Data Retention 

Kodama retains Personal Information only for as long as is necessary to fulfill the business or legal purposes for which it was collected, including: 

  • Customer inquiries: Retained until the request has been resolved or the customer account is inactive 

  • Employment and payroll records: Retained for the duration of employment and thereafter for the legally required period under applicable employment, tax, and recordkeeping laws 

  • Applicant records: Retained for as long as reasonably necessary to evaluate candidacy and maintain recruitment compliance 

  • Extended retention: Maintained only where legally required or to establish, exercise, or defend legal claims 

6. Data Subject Rights 

Depending on jurisdiction, individuals may have certain rights with respect to their Personal Information, including the right to: 

  • Request access to and a copy of their Personal Information 

  • Request correction, deletion, or restriction of processing 

  • Object to certain processing activities 

  • Request portability of Personal Information 

  • Opt out of the use or disclosure of sensitive Personal Information for secondary purposes 

Requests to exercise these rights may be submitted to privacy@kodama.ai. Kodama will process such requests in accordance with applicable law, including but not limited to the California Consumer Privacy Act (CCPA/CPRA) and the EU/UK General Data Protection Regulation (GDPR). 

7. International Transfers 

Where Personal Information is transferred outside of the jurisdiction in which it was collected, Kodama ensures that such transfers are made pursuant to lawful transfer mechanisms, including Standard Contractual Clauses (SCCs) or other appropriate safeguards as required by applicable data protection laws. 

8. Children’s Privacy 

Kodama does not knowingly collect Personal Information from individuals under the age of 13 (or under 16 where applicable law requires parental consent). If it is discovered that Personal Information has been inadvertently collected from such individuals, Kodama will take reasonable steps to delete such information promptly. 

9. Changes to This Policy 

Kodama reserves the right to amend or update this Policy at any time. Material changes will be communicated by updating the effective date and, where required by law, by providing additional notice or obtaining consent. 

10. Contact Information 

For questions regarding this Policy or Kodama’s privacy practices, please contact: 

Kodama Systems, Inc. 
privacy@kodama.ai 

or submit inquiries by post:

1171 Sanguinetti Rd., #1016
Sonora, CA 95370