Kona Equity and our affiliates (together, “our”, “we”, “company”, or “Kona”) are committed to respecting the privacy of all users of our website at konaequity.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. Please read this Privacy Policy carefully.

Except where EU laws apply to the processing of your personal information, by providing your personally identifiable information to us, you signify your acceptance of this Privacy Policy and agree that we may collect, use, and disclose your personally identifiable information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not provide your personal details to us.

This Privacy Policy is incorporated into, and part of, the Terms of Use, which govern your use of the Site in general.

Kona reserves the right to amend this Privacy Policy in its sole discretion from time to time. Kona will post any changes to this Privacy Policy on the Site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it, and such changes shall be effective immediately upon posting. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. Except where EU laws apply to the processing of your personal information, your provision of personally identifiable information after any such changes constitutes your acceptance of the new terms and conditions.

We will use information only in accordance with the Privacy Policy under which the information was collected.

For the purposes of applicable EU laws, Kona Equity will be a data controller of any personal data collected by us.

Information We Collect

Information you provide to us

In general, you can visit the Site without telling us who you are or revealing any information about yourself.

We collect your personal information when you decide to interact with us and which you submit using the contact options provided on this Site. You can also provide us with personal information via email, post, and telephone. This may include your name, email address, address, title, job title, position, telephone number, and IP address. We may collect additional personal information about you, including special categories of personal information, when you apply for a job with Kona or an affiliate or enter into an agreement with Kona. See below for further information on ‘How We Use Information Collected’.

Information provided by third parties or publicly available sources

We collect personal information about you from third parties including from our affiliates, our portfolio companies, job posting websites and recruiting firms, and companies that we are evaluating in connection with a potential investment or business opportunity.

Information provided under a legal obligation

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations). Failure to provide this information may mean that we cannot provide our services or products to you. In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.

How We Use Information Collected

To the extent that you provide us with any personal information, through or in connection with this Site (i.e., via telephone, email, or post), we may use such information for the following purposes:

Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal information.

Marketing

We will send you direct marketing communications where we have obtained your prior consent to keep you informed of our services in which you might be interested, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested.

With Whom Do We Share the Information We Collect?

Your personal information will be shared with and processed by:

We use our best efforts to ensure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.

We reserve the right to disclose your personal information to third parties in order to comply with law, to law enforcement or other governmental agencies, or when we believe that disclosure is necessary to enforce or protect our rights in or otherwise with respect to, or the safety of, our Site, or to protect the safety or rights of other users of our Site and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance, or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment, or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors.

CCPA Consumer Rights

California: Your Privacy Rights

If you are a California resident, you may have the right to (1) request access to certain personal information we have collected about you, (2) request that we delete certain personal information we have collected from you, and (3) opt-out of the sale of your personal information.

Transfers of Personal Information Outside the EEA

Your personal information will be hosted in the U.S. and will therefore be transferred and stored outside of the European Economic Area (“EEA”), where collected in the EU. For the purpose of applicable EU laws, such third countries (including the U.S.) may not offer the same level of data protection as your country of residence. Such transfers will be made in accordance with applicable EU data privacy laws.

Security

We are committed to protecting the personal information you entrust to us. We implement appropriate security measures and technologies to seek to ensure the security of your personal information on our systems and to ensure that it is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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. Any transmission of information or data by you to or through this Site is at your sole risk.

Capacity

This site is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this site who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent. If we learn we have collected or received personal information from an individual under the age of 13, we will delete that information.

Cookies

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Incapsula

Onetrust Cookie Consent

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.

All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Google Analytics: To learn more about Google Analytics, please visit: http://www.google.com/policies/privacy/partners.

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages.

If you do not allow these cookies then some or all of these services may not function properly.

Your EU Rights

To the extent that EU data protection laws apply to the processing of your personal information, or to the extent that you are a resident of the UK, the EU, or the EEA, you have certain rights with respect to your personal information, as outlined below.