Kenn Capital

Privacy Policy

Introduction

This Privacy Policy sets out Kenn Capital’s policy regarding the collection, use, and disclosure of any information You will provide when You access and use this website (the Site) or any of Kenn Capital’s services and/or products, regardless of whether or not You create an account. It is intended to be read together with the Site’s Disclaimers, Exclusion of Liability and Terms of Service (collectively, “Conditions“). By accessing and using Kenn Capital’s website, You are deemed to have read, accepted, and agreed to be legally bound by the terms of this Privacy Policy and the Site’s Conditions as they change from time to time, regardless of whether You have registered for an account with Kenn Capital.

  1. Kenn Capital reserves the right to amend the Privacy Policy without prior notice. Any use of the Site after such amendment shall be deemed acceptance of the amended Privacy Policy in its entirety. If You do not agree to this Privacy Policy, please immediately discontinue Your access to, and use of, the Site.
  2. This Privacy Policy does not apply to third-party websites You may access through, or in the course of Your use of, the Site. Your rights in relation to those third parties will be governed entirely by the privacy statements and/or terms and conditions of those third-party websites.
  3. This Privacy Policy is governed by and shall be construed in accordance with the laws of the Republic of Singapore. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Republic of Singapore.

Collection of Information

When You access or use the Site or any part thereof, or communicate with Kenn Capital or any of its officers, employees or agents whether through written, published or electronic means, the telephone or otherwise, Kenn Capital or its third-party processors may collect or receive personal or non-personal information or data about, in connection with or from You, including, without limitation, through cookies, pixel tags, website and data analytics, and other technology, in accordance with the Personal Data Protection Act 2012 and Personal Data Protection Regulations 2014 (the “Singapore Personal Data Protection Laws“). Personal information or data may include without limitation: (a) personally identifiable information and data (e.g., Your name, e-mail address, mailing address, contact number, birth date, age, occupation, educational level, income level, gender, industry of work, payment details); (b) anonymous information about Your usage of and interaction with Our website (e.g., computer and connection information, device capability, bandwidth, statistics on page views, frequency of use and traffic to and from Our website); (c) electronic identification data (e.g., Internet Protocol (IP) address and cookies); and (d) Your user profile (e.g., identification key and password) (“Personal Data“). The provision of such Personal Data by You is not mandatory, but may be required in order to use or access certain web pages and/or sections of Our Site or Our services, or to purchase Our products or services. Non-personal information or data may include without limitation Your browser information, IP address, how You use the Site or any part thereof, and aggregated information. Kenn Capital will, as far as possible, inform You at each collection point as to what information is required and what information is optional.

Use of Information

Kenn Capital uses the collected information:

  1. for the specific purpose for which the information was provided;
  2. to confirm Your identity and ensure that You are eligible to access and use the various services provided on the Site;
  3. to process and, where necessary, respond to Your application(s), enquiry(s), or request(s);
  4. to conduct due diligence checks on You in accordance with all applicable laws and regulations, and Kenn Capital’s internal ‘know Your client’ and anti-money laundering/countering the financing of terrorism policies;
  5. to verify and approve the disclosures entrepreneurs seeking capital for their business through Kenn Capital’s platform make to potential investors;
  6. to enable Kenn Capital to comply with all of its’ legal and regulatory obligations;
  7. to inform or update You about products, or services that You request from Kenn Capital or that may interest You, where You have consented to be contacted for such purposes;
  8. to update You about changes to the Site or Kenn Capital’s operations;
  9. to monitor, improve, and administer the Site and the services provided through it, and conduct statistical or other forms of analysis for purposes of maintaining or improving the Site and Kenn Capital’s services in general; or
  10. to comply with all proceedings or inquiries from any state, regulatory, or enforcement agency.

Disclosure of Information

Kenn Capital will not sell or rent Your personal information to any third party. Information You provide to Kenn Capital will be disclosed to third parties where:

  1. You have expressly or implicitly consented to such disclosure, or may be deemed to have consented to such disclosure;
  2. such disclosure is a necessary part of the process of seeking funding, investors, or backers (including third party entities that would or are likely to be involved in the fund raising process);
  3. necessary to provide You with the products and/or services You have requested for, or to respond to Your queries;
  4. necessary for the operation of the Site or Kenn Capital’s internal processes;
  5. required by any government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority;
  6. Kenn Capital believes, in good faith, that doing so will be appropriate or necessary for it to investigate and defend against any third party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Site, Kenn Capital’s interests, or any Kenn Capital employee;
  7. Kenn Capital is the subject of a takeover or acquisition of any of its assets, and Your personal information forms part of Kenn Capital’s assets to be transferred to the acquiring entity;
  8. Kenn Capital acquires or is otherwise involved in any transactions involving any business interests or subsidiaries; or
  9. You disclose such information to third parties in the course of participating in any competitions or promotional programmes on the Site, regardless of whether such competitions or promotional programmes are initiated and run by the third party or Kenn Capital.
  10. Kenn Capital is not responsible for removing Your personal information from the possession or control of any third party who may have previously been provided with Your information in accordance with these conditions.

How We protect Your information

Kenn Capital is concerned with protecting your privacy and data and has implemented and will continue to maintain security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of Your information. Nevertheless, You acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to Kenn Capital is done so at Your own risk. Kenn Capital does not warrant or guarantee that the information You provide will not be accessed, copied, used, or disposed of in breach of Kenn Capital’s security measures, and You agree not to hold Kenn Capital liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, Kenn Capital will, as far as reasonably possible, promptly notify all affected persons. You accept that You and, where applicable, anyone else with whom You share the same, are responsible for keeping confidential Your username and password to Your account with Kenn Capital.

Web-related Information

  1. Kenn Capital may collect certain information from You without You actively providing the information when You navigate the Site via cookies. Cookies are small data text files stored in Your local browser cache that send information about Your previous visits to and activities on the Site. Cookies track information such as users’ profiles, the number of users, their frequency of use and their preferred websites. These cookies will not give Kenn Capital any of Your personal information. Kenn Capital reserves the right to use the cookies to recognize Your browser and thereby customise and optimize the Site to Your preferences.
  2. The majority of Internet browsers will allow You to configure the settings used for cookies, including the deletion of cookies. For security reasons, You may wish to deactivate the storing of cookies or adjust Your browser to inform You before the cookies are stored on Your computer. However, if You disable the use of cookies on Your web browser, or remove or block specific cookies from the Site, You may not be able to gain access to all of the information, materials, facilities, and services provided on the Site.
  3. Kenn Capital may also collect Your IP address. Your internet service provider allocates an IP address to Your computer in order for it to access the Internet. The IP address is considered to be non-personal information and it may be dynamic (changing every time You connect to the Internet) or it may be static (unique to Your computer). Kenn Capital collects Your IP address in order to facilitate its administration and improvement of the Site. The information derived from Your IP address can help Kenn Capital diagnose server problems, report aggregate information, and determine the fastest route from Your computer to the Site.

Notifications and Communications

Kenn Capital will send You email notifications from time to time. You may not opt out of receiving certain service-related notifications that are:

  1. necessary elements of Your transactions on the Site and any product or service of Kenn Capital’s, such as confirmations of particular actions You have taken;
  2. are required for legal or security purposes; or
  3. meant to inform You of changes to Site policies, the Conditions, or disclaimers, or Kenn Capital’s operations, products, or services.

You may opt out of other service-related notifications at any time, including:

  1. user surveys or other requests for user feedback; or
  2. marketing offers from Kenn Capital or that Kenn Capital sends on behalf of third parties or the companies/funds featured on the Site.

Transfer, Storage, and Retention of Information

  1. Information collected in accordance with this Privacy Policy and Our Conditions may be transferred, stored, or processed outside of Singapore (for instance, to the servers of Our service providers). Kenn Capital will comply with its obligations under the Singapore Data Protection Laws in relation to personal data transferred, stored, or processed outside Singapore for as long as the data remains in Kenn Capital’s possession or control during the transfer. Kenn Capital will take appropriate steps to ascertain whether, and to ensure that, the recipient of the personal data who is located outside Singapore is legally obliged to provide to the personal data a comparable standard of protection. However, if data needs to be transferred to or stored or processed in countries that have less stringent personal data protection laws than Singapore in order to provide You with the services You request, You are deemed to acknowledge and consent to such transfer, storage, or processing in providing Your personal data to Kenn Capital during Your use of the Site. You may at any time inform Kenn Capital that You wish to withdraw Your consent to such transfer, storage, or processing of Your personal data.
  2. While Kenn Capital will take reasonable care in preventing the loss, misuse or alteration of Your Personal Data, You acknowledge that data transmission over the Internet is insecure and that Kenn Capital cannot, and does not, guarantee the security of the data transmitted over the Internet in connection with Your use of and activities on this Site.
  3. Kenn Capital will retain all information collected for as long as You continue to use the Site or Kenn Capital’s services. If You are a member and terminate Your Kenn Capital account, Kenn Capital will retain the information, including personal data, collected during Your membership for as long as reasonably necessary for any business or legal purpose.

Communications

Kenn Capital may record, and/or monitor any communication(s) (including telephone calls or other electronic communications) between You and Kenn Capital for purposes of resolving queries in the future and/or for the purpose of ensuring security, staff training and complying with its legal and/or regulatory responsibilities.

Your Rights

  1. You have the right to ask Kenn Capital not to process Your personal data for marketing purposes. Kenn Capital will inform You (before collecting Your data) if it intends to use Your data for such purposes or if it intends to disclose Your information to any third party for such purposes. You can exercise Your right to prevent such processing by checking certain boxes on the forms Kenn Capital uses to collect Your data.
  2. The Site may, from time to time, contain links to and from other websites, including without limitation the websites of companies featured on the Site and Kenn Capital’s partner networks, advertisers, and affiliates. If You follow a link to any of these websites, please note that Kenn Capital does not accept any responsibility or liability for any personal data disclosed to and/or on those websites. Please also note that these websites have their own privacy policies and that Kenn Capital does not accept any responsibility or liability for these policies. Please check these policies before You submit any personal data to these websites.
  3. You may choose to stop receiving or change the frequency of email, direct mail, phone and mobile marketing communications.

Access to and Correction of Personal Data

  1. Upon request, We will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the Singapore Personal Data Protection Laws.
  2. Upon request, We will correct an error or omission in the individual’s personal data that is in Our possession or control in accordance with the requirements of the Singapore Personal Data Protection Laws.
  3. We may charge for a request for access in accordance with the requirements of the Singapore Personal Data Protection Laws.

Withdrawal of Consent

Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of Our collection, use or disclosure of his personal data, We will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of Our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.

Data Protection Office

If You believe that information We hold about You is incorrect or out of date, or if You have concerns or further queries about how We are handling Your personal data, or any problem or complaint about such matters, please contact Our Data Protection Officer at dpo@kenncapital.com.

Accuracy

When submitting personal data to Kenn Capital, the individual should ensure that such Personal Data are current, complete and accurate. Kenn Capital will also make reasonable efforts to ensure the accuracy of Personal Data is accurate and complete if the Personal Data is likely to be used by Kenn Capital to make a decision that affects the individual concerned or disclosed by Kenn Capital to another organisation. You may contact Our Data Protection Officer (see contact details above) if You believe that the Personal Data which is in Our possession is incorrect, outdated or incomplete.

Other Jurisdictions

If You are subject to the data protection and privacy policies, laws and regulations applicable in any other territory or jurisdiction (“Privacy Laws”) to which Your Personal Data relates, Kenn Capital shall: (i) comply with the relevant Privacy Laws regarding the collection, use, retention of Your Personal Data; (ii) comply with all standards set by the Privacy Laws in relation to the privacy and security of Personal Information; (iii) refrain from any action or inaction that could cause Kenn Capital to breach any applicable Privacy Laws; (iv) do and execute, or arrange to be done and executed, each act, document and thing as necessary to keep Kenn Capital in compliance with the applicable Privacy Laws; and (v) immediately report the theft or loss of Personal Information (including the Personal Information of your own officers, directors, shareholders, employees or service providers).