Privacy Policy

This Privacy Notice was last updated July 08, 2020

This Privacy Notice applies to personal data collected on our website kairoshq.com (“Website”). This Privacy Notice sets out the categories of personal data we collect from you, how we collect it, what we use it for and with whom we share it in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”). For the purposes of this Privacy Notice, “Kairos”, “we”, “us”, and “our” means Kairos Capital LLC and Kairos Thematic Trust.

By “personal data” we mean any information relating to you such as your name, contact details, taxpayer identification number, account number, account balance and transaction information or online identifiers such as your IP address. Personal data does not include data where you can no longer be identified from it such as anonymized aggregate data.

Kairos is a data controller. This means that we are responsible for deciding how we hold and use personal data about you. If you have any questions about this Privacy Notice or how we handle your personal data, please contact us at info@Kairoscap.com.

This Privacy Notice applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us as a user of the Website.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. Those supplemental notices should be read together with this Privacy Notice.

What personal data do we collect about you and what do we use it for?

The categories of personal data about you which we may collect, store and use are set out in the table below and in each case we have indicated what we use your personal data for and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ under which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data: Where we need to comply with a legal obligation;

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or

Where we have obtained your consent.

We may rely on your consent as a lawful basis for processing your personal data. You have the right to withdraw consent at any time by contacting us at the details given at the beginning of this notice.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data itself as it can no longer be used to identify you. For example, we may aggregate your browsing information data to calculate the percentage of our users interested in a specific product type. However, if we combine or connect aggregated data with your personal data so that it can be used to identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

How do we collect your personal data?

We may collect personal data about you:

• When you submit your information on our Website through our collection forms
• When you request literature or research information from us
• When you visit our Website
• When you attend our webinar presentations
• When you attend other Kairos-hosted events
• When we send you emails
• We may also automatically collect certain data when you interact with our Website, such as technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

In addition, we may receive personal data about you from third parties and public sources, such as:

• Companies contracted by us to provide services to you, such as our webinar service provider
• Companies contracted by us to offer or market our sales materials to you, such as our sales affiliates and external sales partners
• Our marketing service provider, who combines data you provide on our Website with other publicly available data about you, such as your social media account information

With whom do we share your personal data?

We may share your personal data with third parties where this is required by law, where you have consented, or where we have another legitimate interest in doing so.

We may share your personal data with:

• Our service providers, including our attorneys, our IT service providers, our webinar service provider and our marketing service provider
• Our sales affiliates and external sales partners
• Other entities in our group for advertising and marketing purposes, in the context of a business reorganization or group restructuring exercise, for system maintenance support and for hosting of data
• A regulator or government entity if we are required by law to do so or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process

What if you do not provide the personal data we request?

If you do not provide us with certain personal data when requested, we may not be able to provide you with the services or products you have requested.

Change of purpose

We will only use your personal data for the purposes for which we collected it (as identified above in the What we use this personal data for column), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose for which you provided it to us. If we need to use your personal data for a purpose that is unrelated to the original purpose for which you provided it to us, we will notify you and we will explain the legal basis which allows us to do so.

“Do Not Track” Signals

Some web browsers may transmit “do not track” signals to the Website and other online services with which the browser communicates. There is no standard that governs what, if anything, Website should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard for responding is established, we may revisit our policy on responding to these signals.

Processing of your personal data outside the EEA

Kairos Capital LLC and Kairos Thematic Trust are U.S. organizations that do not have affiliates or offices in the EU. Our marketing partners and sales affiliates are also U.S. organizations that do not have affiliates or offices in the EU.

The personal data we collect about you will be transferred directly by you to us, our service providers or our sales affiliates outside of the EEA. It is therefore necessary for us to process your personal data outside of the EEA for the performance of our contract with you. We have put in place physical, electronic and procedural safeguards that are reasonably designed to protect your personal data from unauthorized access and use in order to ensure that your personal data is treated in a manner that is consistent with and which respects the EU laws on data protection. If you require further information about the transfer of your personal data outside of the EEA, you can request it from info@Kairoscap.com.

How long will we retain your personal data?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

Once we no longer require your personal data for the purposes we collected it for, we will securely destroy your personal data in accordance with applicable laws and regulations.

Accuracy of personal data

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

Your rights in relation to your personal data

You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:

• Request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
• Request rectification of your personal data;
• Request the erasure of your personal data;
• Request the restriction of processing of your personal data;
• Object to the processing of your personal data;
• Request the transfer of your personal data to another party.
• If you want to exercise any of these rights please contact us at info@Kairoscap.com.

You also have the right to make a complaint at any time to an EU data protection authority (“DPA”). However, it is possible that we could resolve your concerns directly if you contact us first, so please consider doing so.

While we strive to protect all information we receive from you, we cannot guarantee the security of any information you transmit to us.

Fees

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Your right to withdraw your consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at info@Kairoscap.com or update your marketing profile by clicking the preference link in one of Kairos’s marketing emails. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to unless we otherwise have an alternative legal basis for doing so.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our Website and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

Additional Information

Data Security

We have implemented measures that are reasonably designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure.

Children Under the Age of 13

Our Website are not intended for children under 13 years of age. No one under age 13 may provide any personal data to or on the Website. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on the Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@Kairoscap.com.

California Privacy Rights

If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by us to third parties for the third parties’ direct marketing purposes. To make such a request, please write, call or send an email to the below contact information.

Contact Information

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. If you require any further information, please do not hesitate to contact us at info@kairoshq.com.

31 Bond Street, New York NY 10012