Kinzie Capital Partners LP, located at 20 North Clark, 36th Floor, Chicago, IL 60602 (“Kinzie”), is committed to protecting your privacy. This Privacy Policy (“Privacy Policy”) describes and governs our use and disclosure of the information we collect through the Kinzie website at www.kinziecp.com (the “Site”), as well as information that we collect through other means about people who contact us, vendors, and prospective investors and employees.
For users of the Site, your use of the Site signifies acceptance of the terms of this Privacy Policy. Undefined capitalized terms used herein shall have the definitions as set forth in our Terms of Use or Regulatory Disclaimer, as applicable, each of which is hereby incorporated in this Privacy Policy.
If you are Kinzie investor or a representative of an investor, please see our standard subscription agreement as well as the investor privacy notice, which is available in our investor portal, for information about our collection, use, and sharing practices with respect to investor information. In addition, the policies of our third-party administrator, Standish Management, also apply to the information collected in the investor portal.
1. Information We Collect
We collect several types of information from and about users of our Website, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number, bank account or other financial account information, or credit/payment card information (“Personal Information”);
- That is about you but individually does not identify you,
- About your internet connection, the equipment you use to access our Site, time spent on our Site, pages viewed on our Site, IP addresses accessing our Site, and other usage details.
We may collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- Or from third parties, for example, our affiliates and business partners
a. Information You Provide Directly to Us
The information we collect on or through our Site may include:
- Information that you provide by filling in forms on our Site, including information provided at the time of registering to use our Site, requesting further services (including access to our investor portal or other investment-related services), reporting a problem with our Site, or use of our contact form located at kinziecp.com/contact;
- Records and copies of your correspondence (including email addresses), if you contact us;
- Details of transactions you carry out through our Site;
- Your responses to surveys that we might ask you to complete for research purposes; or
- Your search queries on the Website;
This Personal Information may include your name, contact information (including e-mail address, postal address, or telephone number) resume information, payment information or other information about yourself.
Except where we are required to screen individuals pursuant to Office of Foreign Assets Control (OFAC) laws, and similar laws and regulations, you do not have a statutory or contractual requirement to provide us or our vendors with your Personal Information. If you do not provide us with your Personal Information, however, we may not be able to provide certain information or services to you. For example, we will not be able to enter into a contract with a potential investor without certain information.
b. Information We Collect from Third Parties
We do not collect Personal Information from third parties directly through your use of the Site. However, we may collect certain Personal Information from third parties, including information collected in our third-party investor portal. We may also collect information from business partners and vendors to support our provision of investment services. The data we collect from such third parties is often in aggregate form, but it may occasionally include Personal Information. The disclosure of Personal Information from third parties is governed by the privacy policies of any such third parties.
c. Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Site, including traffic data, location data, source of accessing our Site, logs, and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include Personal Information, which we may maintain or associate with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Site according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Site.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email, clicked through, purchased from an email, or unsubscribed from an email list and for other related Website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We may tie this information to Personal Information about you that we collect from other sources or you provide to us.
d. Third-Party Use of Cookies and Other Tracking Technologies
We currently do not offer advertising on behalf of third parties on the Site. However, some content or applications on the Site may be served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
e. Online Analytics
We may use third-party web analytics services (such as Google Analytics) on our Site to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies and Other Tracking Technologies” section will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site, including by noting the third-party website from which you arrive, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
2. How We Use Your Information
We may use the information we collect from and about you for the following purposes:
- For the purposes for which you provided it to us;
- To provide the features and services available through the Site;
- To provide and improve our investment services, including evaluating potential investments and managing existing investments;
- To respond to your requests or inquiries, to request your feedback, or to send you other communications;
- To conduct surveys and analyze market trends and interests;
- For internal research and reporting;
- To notify you about changes to our Site or any products or services we offer or provide though it.
- To improve the content and features of the Site;
- For recruiting purposes;
- To enforce the legal terms that govern your use of the Site;
- To administer and troubleshoot the Site;
- In any other way we may describe when you provide the information; and
- For any other purpose with your consent.
Please note that we may combine information that we collect from you and about you (including information that was collected automatically) with information we obtain about you from our affiliates, vendors, and/or other non-affiliated third parties, and use such combined information in accordance with this Privacy Policy.
We may aggregate and/or de-identify information we collect. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties.
3. When We Disclose Your Information
We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:
- To our subsidiaries and affiliates;
- To contractors, service providers, and other third parties we use to support our business, including the Standish Investor Portal, our technology providers such as Lightserve, our professional and legal advisors;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Kinzie’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Kinzie about our Site users is among the assets transferred;
- To fulfill the purpose for which you provide it, including compliance with contracts with you, to provide you investment services, providing and maintaining the Site, or other legitimate business operations of Kinzie;
- For any other purpose disclosed by us when you provide the information; or
- With your consent.
We may also disclose your Personal Information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- To enforce or apply our terms of use and other agreements, including for billing and collection purposes; or
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Kinzie, our investors, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
4. Accessing and Controlling Your Information
You can review and change your Personal Information by logging into the Site and visiting your account profile page. You may also send us an email at www.kinziecp.com/contact to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
5. Your Nevada and Your California Privacy Rights
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit questions to this designated address: www.kinziecp.com/contact. However, we do not currently sell data triggering that statute’s opt-out requirements, so we do not have opt-out obligations under Nevada law.
If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information.
We do not meet the minimum requirements obligating us to abide by the provisions of the California Consumer Privacy Act (“CCPA”). However, we hereby notify you that we currently do not disclose any of your Personal Information to third parties except for the reasons set forth in this Privacy Policy. We do not sell any of your Personal Information to third parties.
If you wish to opt out of any such disclosure of your Personal Information, please contact us at www.kinziecp.com/contact. However, please note that any such opt out may prevent us from providing services to you.
California’s Online Privacy Protection Act (Cal. Bus. & Prof. C. §§22575-22579) (“CalOPPA”), requires website operators to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information of a consumer over time and across third party websites and apps, to the extent the operator engages in that collection. At this time, we do not respond to Do Not Track (DNT) signals. This law also requires website and app operators to disclose whether third parties may collect personally identifiable information about their users’ online activities over time and across different websites and apps when the users use the operator’s website or app. The nature of how third parties may collect or receive personally identifiable information is disclosed in this Privacy Policy. To learn more about how Do Not Track signals work, please visit http://allaboutdnt.com.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not currently disclose Personal Information to third parties for direct marketing purposes. Please email us at www.kinziecp.com/contact with any questions. Please allow us 30 days for a response.
6. Data Transfer
Our computer systems are currently based in the United States, and your personal data will be processed in the United States, which may not offer the same level of protection as the privacy laws of your jurisdiction.
7. Children’s Privacy
The Site is intended for general audiences and not for individuals under the age of 18. If we become aware that we have collected Personal Information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 18 without valid parental consent, we will take reasonable steps to delete it as soon as practicable.
8. Security
We have implemented security measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures vary based on the sensitivity of the information that we collect and store. We do not store Personal Information on any of our own servers.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Site. Any transmission of Personal Information is at your own risk; please do not share your account information, including passwords, if any, with others. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
9. Data Retention
We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.
10. Third-Party Links and Services
The Site may contain links to or “frame” third-party websites, applications, and other services, including our investor website, as described above. Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every site they visit that collects their information.
11. Changes to this Privacy Policy
It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will post them here and will otherwise provide notice as required by law. We will also update the “last updated” date on this Privacy Policy, which is identified at the top of this page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.
12. Contact Information and Questions About this Privacy Policy
If you have any questions about our Privacy Policy, please contact us at www.kinziecp.com/contact.