Privacy Policy

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:

PURPOSE
LEGAL BASIS
To provide you with the services or financial products you have requested, e.g., responding to any inquiry.
Contractual necessity
For our administration, research, database development, and business operation purposes.
Legitimate interest
To keep a record of your relationship with us.
Legitimate interest
To verify your identity.
Legal requirement and legitimate interest



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:

our affiliates;
certain service providers as necessary to fulfill the purposes set out in this Privacy Policy, including professional advisors, recruitment firms, consultants, and data hosting providers



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.

Access: You have the right to ask for a copy of the personal information that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.


Correction: You may notify us of changes to such your personal information if it is inaccurate or it needs to be updated.


Deletion: If you think that we shouldn’t be holding or processing your personal information anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.


Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.


Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.


Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.


Withdrawalof consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office. You can find details for your relevant EU national data protection authority here.