Your Privacy Is Important to KLAS
In the course of serving our clients, KLAS may obtain personal information about such clients. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.
This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “KLAS” refers to KLAS Investments, LLC and its affiliates.
The Sources of Information
The personal information we collect about you comes primarily from the forms and materials you submit to KLAS during the course of your relationship with us. We may also collect information about your transactions and experiences with KLAS relating to the services KLAS provides. In addition, depending on the services you require, KLAS may obtain additional information about you, such as your credit history, from consumer reporting agencies.
Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. email monitoring). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
The Information We Have About You
If you deal with KLAS the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis) your full name, phone number, email address, organization, and other contact details
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to assist you fully. While we make every effort to ensure that all information we hold about our clients is accurate, complete, and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.
Our Use of Your Personal Information
We may use your personal information to:
- Administer, operate, facilitate and manage your relationship with KLAS. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
- Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your KLAS relationship;
- Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by KLAS; and
- Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
If your relationship with KLAS ends, KLAS will continue to treat your personal information, to the extent we retain it, as described in this policy.
Disclosures of Your Personal Information within KLAS
In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within KLAS may be given, or given access to, your personal information. For example, one KLAS entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management, and advisory services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within KLAS is provided below, under Information Security: How We Protect Your Privacy.
Disclosures of Your Personal Information to Third Parties
KLAS does not disclose your personal information to third parties, except as described in this policy. Third-party disclosures may include sharing such information with investment partners (e.g. deal sponsors), other financial institutions (e.g. lenders requiring such information pursuant to regulatory requirements), and/or nonaffiliated companies that perform support services for your account or facilitate your transactions with KLAS, including those that provide professional, legal or accounting advice to KLAS. Each such third party is required to maintain the confidentiality of such information to the extent received and to use your personal information only in the course of providing the services, and only for the purposes, dictated by KLAS.
We may also disclose your personal information to fulfill your instructions, to protect our rights and interests, and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.
You should know that KLAS will not sell your personal information.
Information Security: How We Protect Your Privacy
KLAS is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized KLAS employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, third parties are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification, and unauthorized access or disclosure. Some of the other central features of our information security program are:
- The use of specialized technology such as firewalls;
- Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;
- Internal and external reviews of our Internet sites and services;
- Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
- Implementing controls to identify, authenticate and authorize access to various systems or sites; and
- Protecting information during transmission through various means including, where appropriate, encryption.
Privacy and the Internet
The following additional information will be of interest to you as a visitor to this site:
- klasinvestments.com is built upon a secure infrastructure with multiple layers of protection. KLAS uses industry standard encryption technologies to protect any information submitted from external compromise.
- We may collect certain aggregate and non-personal information when you visit klasinvestments.com. We may collect this information through “cookie” technology. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the klasinvestments.com features.
- “Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by KLAS itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Web site or when you view an advertisement we have placed on another Web site. Clickstream data and similar information may be shared internally within KLAS and used: for administrative purposes; to assess the usage, value, and performance of our online products and services; to improve your experience with our Web sites; and as otherwise permitted by applicable law or regulation. If you are a KLAS client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.
- KLAS may make available on this Web site third-party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies.
- Our Web sites are not currently configured to respond to “do not track” signals or similar mechanisms.
Information For EEA Users (EU plus Iceland, Norway and Liechtenstein)
What Rights Do I Have?
Where KLAS is a Controller of data under the EU’s new General Data Protection Regulation (GDPR), individuals located in the European Economic Area (EEA) will have additional rights with respect to their non-public personal information (NPI), including the right of access, rectification, restriction, opposition, erasure and data portability (each, as defined by the GDPR). Where possible, we obtain and rely on user consent as a lawful basis for processing personal data. In some cases, KLAS may process and retain NPI pursuant to a legal obligation or another legitimate interest under the GDPR to protect your vital interests, the interests of KLAS, or those of another person.
How May I Exercise My Individual Rights?
Users located within the EEA may contact KLAS with questions or requests regarding their NPI using the contact information below. Please note that KLAS may request additional information from you to verify your identity before we disclose any personal information. You may opt out of receiving promotional communications at any time by following the “unsubscribe” instructions found within KLAS email updates or changing your contact preferences.
Who Can I Contact at KLAS Regarding Data Protection Issues?
If you have any questions or issues with data privacy and data protection issues, please email firstname.lastname@example.org.
Other Privacy Policies or Statements; Changes to Policy; Contact
This policy provides a general statement of the ways in which KLAS protects your personal information. You may, however, in connection with specific products or services offered by KLAS, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective October 10, 2022. If you require further information regarding our privacy policies and practices please contact email@example.com.
Statement on Cookies
Cookies at KLAS and How We Use Them
- To improve site security by “authenticating” you (i.e., verify that you are who you say you are) when you sign in to our site.
- To keep track of your specified preferences such as language, time zone and timeouts after periods of inactivity.
- To allow you to navigate our sites more easily by “remembering” your identity so that you do not have to input your password multiple times as you move between pages or services.
- To conduct research and analytics to improve our Website and our products and services. This includes compiling statistical information concerning, among other things, the frequency of your use of our Website, the pages visited, and the length of each visit.
- To display KLAS advertisements when you visit websites of third parties with whom we have marketing relationships and to help us gauge the effectiveness of our advertising efforts. These parties may gather information concerning your use of other websites and provide us with de-identified information about you (such as demographic information or the names of sites where you have been shown ads) which we may use to provide you with more relevant and useful advertising.