Important information

Privacy Shield Policy

Kyloe Partners Inc has subscribed to the EU-US Privacy Shield framework and adheres to the Privacy Shield principles regarding the collection, use and retention of personal data received from entities in the European Union. If there is any conflict between the terms in this Privacy Shield policy and the Privacy Shield principles as concerns personal data, the Privacy Shield principles shall prevail. Kyloe’s Privacy Shield certification can be found at https://www.privacyshield.gov/list.

To learn more about the Privacy Shield framework and the Privacy Shield principles, please visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov.

Notice and choice

Our privacy policy and data protection and information security statement can be found at https://www.kyloepartners.com/data-protection-statement.

We sometimes collect personal data through our website and marketing communications. Our privacy policy for use of our website can be found here: https://www.kyloepartners.com/privacy-policy.

We may process personal information received from clients as part of our delivery of Services and this will be in accordance with the written agreements signed by both parties. Our clients are companies, and remain the owner and controller of any personal data processed by Kyloe. Kyloe shall not pass any personal data to a third party unless otherwise detailed in our written agreements with clients.

Our website privacy policy sets out that some information provided to us by users of the website may be processed using third party products in order to deal with certain processes necessary for the full operation of our website.

Kyloe may be required to provide information by law. Under the Privacy Shield framework, Kyloe is subject to the regulatory enforcement powers of the US Federal Trade Commission or other authorised statutory body.

An individual can opt out of receiving marketing communications from us at any time (an opt out is available on all communications), and can request for their data to be removed. Any sensitive personal information collected by Kyloe shall only be obtained with an individual’s explicit consent, and for the purpose collected.

Onward Transfer and Accountability

Should Kyloe transfer personal data to a third party, this shall (i) only be for limited and specified purposes consistent with why the data was collected (ii) be with the same level of privacy protection as required by the principles (iii) have appropriate steps in place to ensure the third party processes the personal information in a manner consistent with the Kyloe’s obligations under the principles (iv) require the third party to notify Kyloe if it can no longer provide the same level of protection as required by the principles (v) require Kyloe to take reasonable and appropriate steps to stop and remediate any unauthorised processing and (vi) require Kyloe to provide a summary or a representative copy of the relevant privacy provisions of its contract with the third party to the Department of Commerce on request.

Security

Kyloe takes reasonable and appropriate measures to protect all data from loss, misuse and unauthorised access, disclosure, alteration and destruction. Our data protection and information security statement outlines the measures we have in place.

Access

Kyloe will provide access free of charge to an individual’s personal data and allow them to correct, amend, or request deletion of personal data where such personal data is inaccurate, unless the cost of such access is prohibitive in relation to the risk of privacy or where the rights of another individual would be infringed. More information on access can be found in our privacy policy and data protection and information security statement.

Data Integrity and Purpose Limitation

Kyloe will take all reasonable steps to ensure that any personal data it processes (and, if applicable, any processing by a third party) is limited to the purpose the data was collected.

Recourse, Enforcement and Liability

Kyloe will attempt to reasonably resolve any concerns related to the processing of an individual’s personal data directly with the individual and in accordance with the Privacy Shield principles.

In the event an agreement cannot be reached, our selected Independent Recourse Mechanism is the EU DPAs and an individual may contact the panel to raise concerns. Kyloe shall commit to cooperate with the EU DPA panel during an investigation and comply with any advice and actions provided following the investigation of a complaint.

A binding arbitration option may be available to address complaints not resolved by any other means (more information can be found on the Privacy Shield website). Kyloe is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC) or other US authorised statutory body. Should Kyloe become subject to a court order, any relevant Privacy Shield related sections of any compliance or assessment report to the extent consistent with confidentiality requirements shall be made public.

Questions, enquiries or complaints should be directed to informationsecurity@kyloepartners.com.