Privacy Policy

PRIVACY POLICY

EFFECTIVE DATE: May 25, 2018

INTRODUCTION
K1 Investment Management, LLC (”K1”, “we”, or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Privacy Policy”).

This Privacy Policy explains our online information practices for the publicly accessible portions of this web site at www.k1capital.com (the “Site”). We have established and implemented this Privacy Policy to inform you, the user of the Site, of the type of information collected by us and how we use and protect such information. This Privacy Policy is effective as of May 25, 2018.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS NOT TO USE OUR SITE. BY ACCESSING OR USING THIS SITE, YOU AGREE TO THIS PRIVACY POLICY. THIS POLICY MAY CHANGE FROM TIME TO TIME. YOUR CONTINUED USE OF THIS WEBSITE AFTER WE MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES, SO PLEASE CHECK THE POLICY PERIODICALLY FOR UPDATES.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “Storage and Transfer of Information” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.

WHEN THIS PRIVACY POLICY APPLIES
Our Privacy Policy applies to all of the services offered by K1, and services offered on our Site, but exclude services that have separate privacy policies that do not incorporate this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

THE INFORMATION WE COLLECT
The Site does not collect any personally identifiable information, also known as “PII”, such as names, home addresses or e-mail addresses. You can visit this Site without telling us who you are or revealing any PII about yourself.

1. Information We Obtain from Your Use of Our Services

We collect certain information automatically, such as your operating system version, browser type, and internet service provider. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; and cookies that uniquely identify your browser. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personally Identifiable Information, but we may maintain it or associate it with Personally Identifiable Information we collect in other ways or receive from third parties.

2. Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as analytics services. Our third party analytics partners include Google or similar analytics partners.

HOW WE USE INFORMATION WE COLLECT
We use your personal data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
1. To inform you about services available from K1;
2. To authorize access to our Sites and Services;
3. To provide you with Services and Products;
4. To administer content or other Site features;
5. To communicate about our Services and Products and to deliver pertinent emails;
6. To comply with all applicable legal requirements.
7. To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users.

We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our Company and our users.
We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. We may use your personal information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

THIRD-PARTY SITES
This Privacy Policy applies only to the Site. This Site may contain links to other websites not operated or controlled by K1 (the “Third-Party Sites”). The policies and procedures we describe here do not apply to the Third-Party Sites. The links from this Site do not imply that K1 endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

DO WE SHARE THE INFORMATION WE COLLECT?
We may disclose your personal information to third parties in order to comply with law, to law enforcement or other governmental agencies, to enforce or protect our rights in or otherwise with respect to, or the safety of, our Site, to protect the safety or rights of other users of our Site, or for potential employment opportunities.

We provide personal information to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include our employee recruitment partner(s) and other business-related service providers. It is our policy to only share personal information with contractors, service providers and other third parties who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites. We do not share personal information with third parties for their own marketing purposes.

If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, personal information about our users is often a transferred business asset. In the event that K1 itself or substantially all of our assets are acquired, personal information about our users may be one of the transferred assets.

We may share aggregate and anonymized personal information to third parties in order to promote or describe use of the Sites, for research, marketing, advertising, or similar purposes.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

This Site may place cookies on your computer or device. Cookies are small data files stored on your computer or device at the request of a website. A cookie assigns a unique numerical identifier to your web browser or device and may enable us to recognize you as the same user who was at our Site in the past, collect general Site usage information (such as pages visited and time spent on each page), and perform analytics on Site usage information so we can improve its design, features and content. Most browsers can be set to detect cookies and allows you an opportunity to reject them. However, refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features. We may also utilize Google Analytics for certain web analytics. You can opt out of your Site usage data being included in our Google Analytics reports by visiting https://tools.google.com/dlpage/gaoptout.

STORAGE AND TRANSFER OF INFORMATION
We may, directly or indirectly through third-party entities around the world, process, store, and transfer all of the information you provide, including your personal information, as described in this Privacy Policy. Specifically, the information and personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), including the United States. It may also be processed by staff operating outside the EEA who work for us or for one of the organizations outlined in this Privacy Policy for in connection with the activities outlined in this Privacy Policy. By submitting your information and personal information and using the Site, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and personal information we collect on the Site.

YOUR CONSENT
By using this Site, you consent to the terms of our Privacy Policy and processing of personal information for the purposes given above. Should the Privacy Policy change, we intend to take every reasonable step to ensure that these changes are brought to your attention by posting all changes prominently on our Site for a reasonable period of time.

YOUR EU AND OTHER PRIVACY RIGHTS
Where provided under applicable law, you may request a copy of the personal information about you that we hold, and you may ask about all recipients of the information, the purpose of the processing, request the correction of incorrect information, and request the blocking and deletion of such information by contacting us at compliance@k1capital.com, We may require you to prove your identity with approved identification if you request this information. Any access request may be subject to a fee to provide you with details of the personal information we hold about you.

You have the right, where provided under applicable law, to ask us not to process your personal information.

You have the right, where provided under applicable law, to ask us not to process your personal information for direct marketing purposes. You can also exercise the right at any time by contacting us at compliance@k1capital.com.

We will retain your personal information for as long as needed to provide you with any services which you request. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

SECURITY
We implement administrative, technical and physical safeguards designed to protect your personal and other information on our systems. Notwithstanding our efforts to protect your information, no security system is completely impenetrable, so we cannot guarantee the absolute security of our databases, nor can we guarantee that information you supply to us will not be intercepted while in transit to us over the Internet.

CHILDREN UNDER THE AGE OF 13
Our Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site or on or through any of its features/register on the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information 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 compliance@k1capital.com.

YOUR CALIFORNIA PRIVACY RIGHTS

California 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. To make such a request, please write to us at:

K1 Investment Management LLC
2101 Rosecrans Ave #6250
El Segundo, CA 90245

Please note that we do not currently share any personal information for direct marketing purposes.

NOTIFICATION OF CHANGES
It is our policy to post any changes we make to our Privacy Policy on this Site. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Site. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Site and this Privacy Policy to check for any changes.

QUESTIONS OR REQUESTS
If you have any questions about our Privacy Policy please contact us at compliance@k1capital.com or call us as 800-310-2870.