PROTECTION OF PERSONAL INFORMATION POLICY

 

Effective Date: [Date]

 

KAIROS CAPITAL MANAGEMENT L.P. (“Kairos Capital” “us” or “we”) is aware of the need to protect the information you provide while making use of the www.kairoscap.ca website (the "Site") and is committed to maintain the privacy and security of your personal information (the “Personal Information”), which is any information about an individual that can be used to identify said individual, including, but not limited to, names, addresses, email addresses and dates of birth.


This Protection of Personal Information Policy (the “Policy”) describes Kairos Capital’s practices with respect to the processing of your Personal Information, which includes the collection, use, processing, transfer, storage or disclosure of your Personal Information associated with your usage of the Site. The application of this policy remains subject to applicable laws including legislation, regulations and the orders of courts or other lawful authorities, other lawful requests or legal processes.


Kairos Capital is committed to respecting and protecting the privacy of all individuals with whom it interacts. Kairos Capital will process your Personal Information at all times in accordance with applicable laws and the following principles: 


  • Personal Information is only gathered with your consent when required by law;

 

  • Personal Information is kept strictly confidential and secure;

 

  • Personal Information is only used for the purposes stated; and

 

  • You may have access to your Personal Information upon request.

 

PERSONAL INFORMATION COLLECTED

 

We collect or process information about how you use of the Site and the devices you use to access them. Personal Information collected or processed could include your name, postal address, email address, telephone number and communications with Kairos Capital. 

 

Cookies. A “cookie” is a small text file or piece of data that is downloaded to and stored on your computer or device when you visit a website (“Cookies”). By using this Site, you consent to Kairos Capital using Cookies which enable Kairos Capital, among other things, to recognize you when you visit the Site so as to customize your browsing experience based on your preferences and provide a customized offering of services and products on our Site or any other website. Most browsers are initially set to accept Cookies, but you can usually change your browser settings to refuse Cookies or to indicate when a Cookie is being sent. You can typically remove or block browser Cookies changing its settings, but that may impact your ability to use the Site as it may not work well or at all with Cookies disabled.

 

General usage data: In some cases, Personal Information that includes technical properties and general usage information of software and hardware utilized in conjunction with the Site might be processed (e.g. types of web browser, referring or exit web pages, operating system version, hardware model of your device or personal computer platform, IP address), or when you use a Kairos Capital’s troubleshooting tool (e.g. basic usage statistics or information about your device including event logs, application configurations, battery life, radio or Wi-Fi signal levels, device reset and memory or system performance information).

 

We do not collect sensitive information, such as your political or religious beliefs, ethnic background, sexual preference, health or any other sensitive information. We do not actively seek to collect information about minors.  If you have any concerns about the protection of your child’s personal information in relation to the Site, or if you believe that your child may have shared Personal Information, please contact us.

 

 

HOW WE USE THIS INFORMATION

 

Except where required by law, we only use the Personal Information you provide to deliver the specific information or service you have requested, and we will not use them for any other purpose without your express consent. The processing of your Personal Information is based on either (i) our legitimate interests related to us providing you services you have requested or otherwise your customer relationship with us; or (ii) your consent was requested. 

 

 HOW WE STORE YOUR PERSONAL INFORMATION

 

We are committed to ensuring your Personal Information is kept secure and confidential and not kept for longer than is necessary for the purposes they were processed. When your Personal Information is no longer necessary, it will be deleted. 

 

From time to time, we may ask other members of our group, or third-party service providers, to help us manage the information technology systems that are used to process your Personal Information. Some of these systems may be outside of Canada. 

 

We will only transfer your Personal Information to a third-party service provider or overseas, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any Personal Information being processed and compliance with applicable privacy and data protection laws. These measures may include use of standard contractual clauses. You may request further information on the legal security measures used for such transfers via the contact details given in this Policy. 

 

 

HOW WE SECURE YOUR PERSONAL INFORMATION

 

We have appropriate security measures in place to prevent unlawful or unauthorized use, access or accidental loss of Personal Information. We also seek to ensure our service providers do the same. 

 

 INFORMATION SHARING AND DISCLOSURE

 

We do not sell or rent any Personal Information to any third party except as provided herein. We may have to disclose Personal Information in response to legal process, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law. 

 

YOUR RIGHTS REGARDING THE PERSONAL INFORMATION PROVIDED TO US

 

General rights applicable to all users

 

  • If you wish to stop receiving marketing communications from us then please click on the "unsubscribe" link at the bottom of the relevant mailing. If you wish to opt out completely, then please contact us at using the details provided below.

 

  • If you would like us to delete or correct your Personal Information from our records, please contact us using the contact details below and we will respond within a reasonable time. Please note that we may be required to retain certain information by law or for our own legitimate business purpose. 


If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity. 

 

OUR RESPONSIBILITY FOR EXTERNAL LINKS

 

This Policy is limited to the Personal Information which we collect and use via the Site. We may provide links to external elements or third-party websites, including, but not limited to social media sites such as Facebook, Twitter and LinkedIn. If you follow these links, you should use these sites in conjunction with their applicable user and privacy notices. Furthermore, we can have no responsibility for the information collected by any third party under those circumstances and we cannot be responsible for collection, usage and protection of any information which you may so provide.

 

CONTACT US

 

If you have any questions about our approach to privacy or you would like to exercise any of the rights mentioned in this Policy, you can contact our Data Protection Officer in any of the following ways:

 

 

KAIROS CAPITAL MANAGEMENT L.P.

Address: 11, rue de Servando,

Blainville (Québec) J7B 1R7


Attention: Privacy Officer

Email: privacy@kairoscap.ca