Last Updated: February 26, 2022
This Policy does not encompass the Personal Information we collect from our employees, job applicants, independent contractors, information that may be governed by the U.S. Gramm-Leach-Bliley Act or Personal Information of our commercial clients’ representatives when acting on behalf of those clients when doing business with us.
Personal Information We Collect and Have Collected in the Past 12 Months – Sources
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In the 12 months preceding the date of this Policy, we may have collected your Personal Information when you visited or browsed on the Site, responded to questions on the Site, engaged with us via email or telephone, requested information about our funds, or when you voluntarily provided information to us through our web portal, email or phone number.
We may have also collected your Personal Information from the following sources to the extent permitted under applicable laws: our affiliates; the administrator of a fund, placement agents, public websites, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies and other public sources and information received from the investor’s advisers or from intermediaries.
We will continue to collect Personal Information from the same sources.
Personal Information We Collect and Have Collected in the Past 12 Months – Categories
Below we categorize the types of Personal Information we may collect or may have collected in the 12 months prior to the data of this Policy. We anticipate continuing to collect the same categories of Personal Information.
- Identifiers, such as name, email address, address, telephone number, facsimile number, and Internet protocol (“IP”) address.
- Commercial and financial information, such as King Street products or services of interest to you, the nature of your organization, information on investments including size of assets under management and investment style, assets, and net worth.
- Internet or other electronic activity information, including device and browser type, your browsing and search history on our Site, and information regarding your interaction with our Site.
- Professional or employment-related information. including name and location of current or past employers, information on your resume or CV, areas of specialization.
- Education information, including information about your educational history, degrees, and credentials.
- Inferences drawn from any of the Personal Information identified above.
Purposes for Collection of Personal Information
We have collected, and will continue to collect Personal Information for the following purposes:
- For offering and marketing our products and services, connecting individuals with other products and services.
- For ongoing review and improvement of the information provided on the Site to ensure it meets the needs of users, and to conduct analysis required to detect malicious data and to prevent any potential disruptions or cyber-attacks.
- To personalize your visit to the Site and to assist you while you use the Site.
- To understand feedback relating to King Street’s services as a user of the Site or as a business contact.
- To communicate with you as a user of the Site or as a business contact to provide you with services or information about King Street and King Street’s products.
- For fraud prevention and detection and to comply with and to assess compliance with applicable laws, rules and internal policies and procedures including in respect of your personal data.
Disclosure of Personal Information for Business Purposes in the Past 12 Months
The following chart describes the categories of Personal Information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy:
Categories of Consumers’ Personal Information
- Personal identifiers: Name, email address, address, email address, telephone numbers, facsimile number, and IP address.
- Commercial and financial information: as King Street products or services of interest to you, the nature of your organization, information on investments including size of assets under management and investment style, assets, and net worth.
- Internet or other electronic network activity information: device and browser type, your browsing and search history on our Site, and information regarding your interaction with our Site.
- Educational information: Information about your educational history, degrees and credentials.
- Professional information: Name and location of current or past employers, information on your resume or CV, areas of specialization.
Categories of Third Parties with Which We Shared Personal Information for a Business Purpose
- Service providers that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; advertise or market our financial products and services; provide website hosting, webcast and teleconference services.
- Service providers that provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; advertise or market our financial products and services.
- Service providers that provide data security services and cloud-based data storage; host our Site and assist with other IT-related functions; provide analytics information; advertise or market our financial products and services.
- Service providers that provide customer relationship management (CRM) services; advertise or market our financial products and services.
- Service providers that provide customer relationship management (CRM) services; advertise or market our financial products and services.
We anticipate disclosing your Personal Information to the same categories of third parties as stated above for business purposes.
Additional Information About How We May Share Personal Information
We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may transfer your Personal Information to a third party in the event of an actual or contemplated sale, merger, reorganization of our entity or other restructuring.
We do not sell and have not sold your Personal Information.
Cookies and Other Tracking Technologies
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
We Do Not Knowingly Collect the Personal Information of Minors
The Site is not directed to minors under the age of 13 and we do not knowingly collect the Personal Information of minors under the age of 16. Additionally, we do not knowingly sell the Personal Information of any minors, including those under 16 years of age. If we learn that we have erroneously collected Personal Information of minors under the age of 16, we will take steps to delete such information from our files as soon as possible.
International Transfers of Personal Information
Personal Information collected from you, including via the Site, may be transferred to, and stored at, a destination outside of your region or home country (e.g., the United States) which may not provide a similar or adequate level of protection as compared to that provided by the region or country in which you are located. It may also be processed by staff operating outside your region or home country who work for our affiliates or for one of our third-party contractors or suppliers. Please do not use the Site if you do not agree to the transfer and processing of your Personal Information in the United States or if it is illegal to do so in your region or home country.
We aim to protect Personal Information by implementing and maintaining reasonable security, such as by using reasonable organizational, technological and physical safeguards appropriate to the sensitivity of the Personal Information we hold. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.
Please note that the Site may contain links to third-party websites. Please be aware that we are not responsible for the privacy practices of other websites. This Site offers no guarantees on the safety or suitability of websites featured on third-party links, and any user who chooses to follow such links does so at his or her own risk.
We are committed to ensuring our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at InvestorReports@kingstreet.com.
Your Rights Regarding the Personal Information We Hold About You
If you are located in other regions, countries or states and applicable law provides you with rights with respect to the Personal Information we collect, use or disclose about you, please contact us at InvestorReports@kingstreet.com to exercise those rights. We will respond to your request in accordance with applicable law.
Rights of California Residents
Right to Access Personal Information We Collect and Disclose About You
You can submit a request to us for any or all of the following:
- The categories of Personal Information we have collected about you;
- The categories of sources from which we collected your Personal Information;
- The categories of Personal Information that the business sold or disclosed for a business purpose about you;
- The categories of third parties to whom your Personal Information was sold or disclosed for a business purpose; and
- The specific pieces of your Personal Information we collected.
Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
Right to Request the Deletion of Personal Information We Have Collected from You
Upon request, we will delete the Personal Information we have collected about you, except for situations where applicable law authorizes us to retain specific information, including when it is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. We may also retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us.
Our Approach to Processing Requests
If you would like to make a request to access or delete your Personal Information, you may email us at InvestorReports@kingstreet.com or call us at (212) 812-3130. We will acknowledge receipt of your request within 10 business days of receipt of your request and aim to provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
When you make a request to access or delete your Personal Information, we will take steps to verify your identity. These steps may include asking you for Personal Information, such as your name, address, or other information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
We are committed to honoring your rights. If you exercise any of the rights explained in this Policy, we will continue to treat you fairly.
You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process. Specifically, if the agent submits requests to access, know or delete your Personal Information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
California Do Not Track Disclosure
“Do Not Track” signals are options available on your browser to tell operators of websites that you do not wish to have your online activity tracked. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.
Rights of Singapore Residents
You have the right to withdraw consent, request access to, and correction of personal data that we hold about you in accordance with applicable laws.
All requests for the withdrawal of consent, access to, or correction of personal data held by us shall be made by sending us an email to the following email address: InvestorReports@kingstreet.com.
Comments / Contact Us
If you have any questions, comments or concerns about our privacy practices, please contact us at: InvestorReports@kingstreet.com.