Kalnin Ventures Privacy Notice
Kalnin Ventures, LLC (“Kalnin Ventures”, “our”, “us” or “we”) takes user privacy seriously. This Privacy Notice (this “Privacy Notice”) provides an overview of what information Kalnin Ventures may collect from you, and how we may use it. We will take reasonable steps to ensure that your Personal Information (as defined herein) and Browsing Information (as defined herein) will only be used in ways that are in compliance with this Privacy Notice and applicable privacy-related laws. This Privacy Notice is in effect for any Personal Information and Browsing Information collected and/or owned by Kalnin Ventures, including, but not limited to, collection through any Kalnin Ventures website (www.kalninventures.com and all of the subdomains located thereon) and any online feature, service and/or program offered by Kalnin Ventures (collectively, the “Web Properties”).
Notwithstanding the foregoing, this Privacy Notice is not applicable to any other web pages, mobile applications, social media sites, email lists, generic information and Personal Information collected and/or owned by any entity other than Kalnin Ventures.
Types of Information Collected. Kalnin Ventures may collect two types of information from you: Personal Information and Browsing Information.
(1) Personal Information. The types of personal information Kalnin Ventures collects may include, among other things, the following categories of information (collectively, “Personal Information”):
- contact information (e.g., your name, mailing address, telephone number, email address);
- demographic information (e.g., date of birth, gender, marital status);
- resume information (e.g., education, work and military history, legal work eligibility status);
- sensitive personal information collected as part of our representation of you, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health, or data concerning a natural person’s sex life or sexual orientation; and
- other information specific to you.
(2) Browsing Information. The types of browsing information Kalnin Ventures collects may obtain non-individualized, generic information about you when you visit the Web Properties. This may include, among other things, the following categories of information (collectively, “Browsing Information”):
- Internet Protocol (or IP) address, or device ID/UDID, protocol and sequence information;
- browser language and type;
- domain name system requests;
- browsing history, such as time spent at a domain, time and date of your visit) and number of clicks;
- http headers, application client and server banners;
- operating system and fingerprinting data; and/or
- similar behavioral and usage information.
How Information is Collected. In the course of our business, we may collect Personal Information about you from the following sources:
- information we receive from you, or on your behalf, through forms you complete, at events such as conferences and seminars, or if you contact us, for example to raise a query;
- the correspondence you and others direct to us;
- information we receive from you through the Web Properties;
- information we receive from your computer or mobile device;
- information we receive from our subsidiaries, affiliates, directors, employees, contractors, and agents; and
- information we receive from other sources, as permitted by applicable laws, rules and regulations.
We may collect Browsing Information from you as follows:
Web Beacons: The Web Properties may also contain electronic images known as Web Beacons (sometimes referred to as “clear gifs”). Web Beacons collect only limited information that includes a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. We may also carry Web Beacons placed by third-party advertisers. These Web Beacons do not carry any personal information and are only used to track usage of the Web Properties and activities associated with the Web Properties.
Unique Identifier: Kalnin Ventures may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the Web Properties and some of the electronic communications you receive from us.
Use of Collected Information. Information collected by Kalnin Ventures is used for three main purposes:
- To provide products and services to you or any third party service provider who is obtaining services on your behalf or in connection with a transaction involving you.
- To improve our products and services that we perform for you; to determine how to best provide services to you; and to improve our websites and applications to make them easier to use.
- To communicate with you and to inform you about Kalnin Ventures’ and third parties’ products and services.
When Information is Disclosed. We might disclose Personal Information and/or Browsing Information when required by law or in the good-faith belief that such disclosure is necessary to: (1) comply with a legal process and applicable laws; (2) enforce this Privacy Notice; (3) respond to claims that any materials, document, image, graphic, logo, design, audio, video or other information provided by you violates the rights of a third party; or (4) protect the rights, property or personal safety of Kalnin Ventures, its users or the public.
We maintain appropriate technical and organizational measures and safeguards to keep the Personal Information and Browsing Information that is disclosed to us secure. We may provide Personal Information and/or Browsing Information to our affiliates and other businesses or persons for the purposes of (1) processing such information on our behalf, (2) providing services to you and on your behalf, and (3) promoting our services and the services of our affiliates and trusted business partners as permitted by applicable privacy law. We require that these parties agree to process such information in compliance with our Privacy Notice or in a similar, industry-standard manner that complies with applicable privacy laws, and we use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures. The use of your information by a trusted business partner may be subject to that party’s own Privacy Notice.
We may share Browsing Information with third parties to demonstrate the usage patterns for Kalnin Ventures’ advertisements, content, functionality promotions and/or services on the Web Properties and to provide us with analytics services in connection with the Web Properties.
We also reserve the right to disclose Personal Information and/or Browsing Information to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Web Properties, and to protect the rights, property or personal safety of Kalnin Ventures, our users or others. We reserve the right to transfer your Personal Information, Browsing Information, and any information about or from you, in connection with the merger, sale or other disposition of all or part of Kalnin Ventures’ business and/or assets. We cannot make any representations regarding the use or transfer of your Personal Information, Browsing Information or other information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above described proceedings. We cannot and will not be responsible for any breach of security by any third party or for any actions of any third party that receives any of the information that is disclosed to us.
How Long is Your Information Stored. To the extent permitted by applicable law and in accordance with the provisions of this Privacy Statement, we keep personal data for so long as (1) it is needed for the purpose for which we obtained it originally, or (2) we have another lawful basis for retaining it beyond the purpose for which it was originally obtained.
Choices with Your Information. Whether you submit Personal Information or Browsing Information to Kalnin Ventures is entirely up to you. If you decide not to submit Personal Information or Browsing Information, Kalnin Ventures may not be able to provide certain services to you.
Employment Opportunity Information. For individuals interested in job opportunities with Kalnin Ventures, the Web Properties may allow prospective employees to request additional job opportunity information or submit a response to a job opportunity. The Web Properties may be used to collect Personal Information from prospective employees for human resources recruitment purposes. By submitting any of the foregoing information, you consent to its dissemination to, and use by, us and our affiliates. The foregoing also applies to job application inquiries that you may transmit to us other than through the Web Properties.
Information From Children. The Web Properties are not intended or designed to attract children under the age of thirteen (13). We do not collect personal information from any person that we know to be under the age of thirteen (13) unless in the connection with legal services and always with the requisite permission of that individual’s parent or guardian. You affirm that you are either more than 18 years of age, or an emancipated minor, or possess legal parental or guardian consent, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Notice, and to abide by and comply with this Privacy Notice. In any case, you affirm that you are over the age of 13, as THE WEB PROPERTIES ARE NOT INTENDED FOR CHILDREN UNDER 13 WHO ARE UNACCOMPANIED BY HIS OR HER PARENT OR LEGAL GUARDIAN.
Parents and legal guardians should be aware that this Privacy Notice will govern our use of Personal Information, but also that information that is voluntarily given by children – or others – in email exchanges, bulletin boards, or the like may be used by other parties to generate unsolicited communications. We encourage all parents to instruct their children in the safe and responsible use of their Personal Information while using the Internet.
Privacy Outside the Web Properties. The Web Properties may contain various links to other websites, including links to various third-party service providers. Kalnin Ventures is not and cannot be responsible for the privacy practices or the content of any of those other websites. Please check with those websites in order to determine their privacy policies and your rights under them.
Information Security. We make every effort to ensure that information collected through the Web Properties is not lost, misused or altered inappropriately by administering security measures. However, all information transferred over the Internet can potentially be accessed by unauthorized parties; therefore, Kalnin Ventures cannot guarantee the security of your data transmitted to the Web Properties.
Your California Privacy Rights. Under California’s “Shine the Light” law, California residents who provide certain personal information in connection with obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.
To obtain this information on behalf of Kalnin Ventures, please send an email message to email@example.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response.
Access and Correction. Please contact us in the manner specified at the end of this Privacy Notice to access your Personal Information in our possession and correct inaccuracies of that information in our records. We ask individuals to identify themselves and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances as permitted by applicable privacy legislation.
Your Consent to this Privacy Notice. By submitting Personal Information and/or Browsing Information to Kalnin Ventures, you consent to the collection and use of information by us as specified above or as we otherwise see fit unless you inform us otherwise by means of the procedure identified below. If we decide to change this Privacy Notice, we will make an effort to post those changes on this web page. Each time you provide information to us, or we receive information from you, following any amendment of this Privacy Notice will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.
If you have additional questions or comments or would like to access your recorded Personal Information, or to exercise your rights herein, please let us know by email or by sending your comments or requests to:Kalnin Ventures, LLC
1200 17th Street, Suite 2100
Copyright © 2020. Kalnin Ventures, LLC.
All Rights Reserved.
LAST UPDATED: February 14, 2020