Effective Date: October 2020
Financial companies choose how they share nonpublic personal information, and federal law gives consumers the right to limit some but not all sharing. To facilitate the protection of confidential nonpublic personal information obtained from investors for purposes of providing financial products or services, Kainos Capital LP and its affiliates (together, “Kainos”) have developed the following internal policies and procedures with respect to the treatment of such nonpublic personal information.
- Nonpublic personal information is gathered from investors through subscription documents, questionnaires, certificates, tax forms, notices, and other forms of documentation provided by investors. Such information may include, without limitation: name; mail and email addresses; phone, fax, and other numbers; social security number; driver’s license, passport or other identification numbers; account numbers; wire transfer instructions; financial information; investment information; and other personal information. This information may be received in any manner, including through in-person discussions, telephone conversations, and electronic or other written communications.
- Kainos will not disclose nonpublic personal information about investors, including the categories of information listed above, to anyone other than affiliates and “Service Providers” without first obtaining your permission, except as required or permitted by law (including, without limitation, as required pursuant to applicable United States and foreign open records laws and anti-money laundering laws). Affiliates are companies related by common ownership or control, such as the affiliated general partners of the funds advised by Kainos and other affiliated investment-related entities. Service Providers include third parties that assist in providing services to investors, such as broker-dealers, bankers, lenders, transfer agents, custodians, accountants, auditors, attorneys, investment advisors, fund administrators and other professional service providers or consultants. Kainos does not disclose nonpublic personal information to third parties for joint marketing purposes.
- Access to nonpublic personal information about investors is provided to those employees, agents, and Service Providers of Kainos who need to know such information to provide services to the investors or Kainos. Commercially reasonable physical, electronic, and procedural safeguards are maintained consistent with applicable standards. In addition, nonpublic personal information may be rendered unreadable or undecipherable by shredding or other means, including contracting with providers of such services.
- Notwithstanding the foregoing, Kainos reserves the right to disclose nonpublic personal information about investors to any person or entity, including without limitation any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over Kainos or its affiliates, if (i) Kainos determines in its discretion that such disclosure is necessary or advisable pursuant to or in connection with any United States federal, state or local, or non-U.S., law, rule, regulation, executive order or policy, including without limitation any anti-money laundering law and the PATRIOT Act and (ii) such disclosure is not otherwise prohibited by law, rule, regulation, executive order or policy.
- The policies and procedures described in this privacy notice with respect to nonpublic personal information obtained from investors continue to apply if services are no longer provided to such investors. Kainos reserves the right to change these policies and procedures at any time and will provide investors with a notice describing any material changes.
If you have any questions about the above privacy policies, please email firstname.lastname@example.org or call Jerry Neisel at 214-740-7300. To the extent Kainos collects personal information from you for any purpose other than providing financial products or services, please refer to the privacy notice available at www.kainoscapital.com/privacy-policy for information on how we collect it.