Privacy Policy
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1. INTRODUCTION
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KSE Capital Management LLC ("KSE," "we," "us," or "our") is committed to protecting the privacy and security of personal information collected through its website (the "Website"). This Privacy Policy describes how we collect, use, store, and protect information provided to us through the Website.
This Privacy Policy applies solely to information collected via the Website and does not apply to information collected offline or through separate advisory or contractual relationships. Clients and investors in funds managed by KSE Capital Management LLC receive separate privacy notices in accordance with applicable regulations, including Regulation S-P under the Securities Exchange Act where applicable.
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2. INFORMATION WE COLLECT
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2.1 Information You Provide Voluntarily
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We may collect personal information that you voluntarily provide to us, including:
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Name;
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Email address;
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Organization or affiliation;
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Contact information; and
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Any other information you choose to submit through contact forms or direct communications.
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You are not required to provide personal information to browse the Website.
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2.2 Automatically Collected Information
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When you access the Website, we may automatically collect limited technical information, such as:
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IP address;
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Browser type;
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Device type; and
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Pages viewed and access times.
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This information is used for basic website operation, security, and performance monitoring.
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2.3 Third-Party Analytics
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We may use third-party analytics services, such as Google Analytics, to help us understand how visitors interact with the Website. These services may collect information about your use of the Website, including pages visited and time spent on pages. Analytics providers may use cookies or similar technologies to collect this information. You can learn more about Google Analytics and opt out by visiting Google's privacy policy and opt-out tools.
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3. USE OF INFORMATION
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We may use collected information for the following purposes:
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Responding to inquiries or communications;
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Operating and maintaining the Website;
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Improving Website functionality and content;
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Monitoring security and preventing unauthorized access; and
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Complying with applicable legal and regulatory obligations.
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We do not use Website information to provide personalized investment advice or recommendations.
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4. COOKIES AND TRACKING TECHNOLOGIES
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The Website may use limited cookies or similar technologies that are necessary for basic functionality and security. We do not use cookies for behavioral advertising or tracking across third-party websites.
If cookies are used, they are limited to session management, essential website operation, and analytics as described in Section 2.3.
You may disable cookies through your browser settings, although doing so may affect Website functionality.
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5. SHARING OF INFORMATION
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We do not sell, rent, or trade personal information.
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We may share information only in the following circumstances:
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With service providers who assist in operating the Website, subject to confidentiality obligations;
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To comply with legal, regulatory, or law enforcement requirements; and
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To protect the rights, security, or integrity of KSE Capital Management LLC.
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We may use and disclose aggregated or de-identified information that does not identify any individual for analytical, research, or other business purposes.
6. DATA SECURITY
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We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, or misuse.
However, no system is entirely secure, and we cannot guarantee absolute security of information transmitted electronically. We encourage you to avoid submitting sensitive personal or financial information through unsecured Website channels. Prospective investors and clients requiring secure document submission will be provided with designated secure communication channels.
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7. DATA RETENTION
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We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy or to meet legal and regulatory requirements.
Information provided by prospective investors who do not establish a client or advisory relationship may be retained for a limited period to respond to inquiries and for recordkeeping purposes, after which it will be securely deleted unless retention is required by law.
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8. INTERNATIONAL VISITORS
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The Website is operated from the United States and is intended for users located in the United States. If you access the Website from outside the United States, you acknowledge that your information may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.
If you are located in the European Economic Area, United Kingdom, or Switzerland, please be aware that we may transfer your personal information to the United States for processing. By using the Website, you consent to such transfer. You may have additional rights under applicable data protection laws, including the right to access, correct, or delete your personal information, or to object to or restrict certain processing. To exercise these rights, please contact us using the information provided below.
9. YOUR RIGHTS
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Depending on your jurisdiction, you may have certain rights regarding your personal information, including the right to request access, correction, or deletion.
Requests may be submitted using the contact information below. We will respond in accordance with applicable law.
9.1 California Residents
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If you are a California resident, you may have certain rights under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale or sharing of personal information. As noted above, we do not sell or share personal information for cross-context behavioral advertising.
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Please note that certain exemptions under the CCPA and CPRA may apply to personal information collected, processed, or disclosed in connection with financial products or services, including information subject to the Gramm-Leach-Bliley Act. To the extent such exemptions apply, this Privacy Policy describes our data practices with respect to non-exempt Website information only.
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To submit a request or inquire about your rights, please contact us using the information provided below.
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10. CHANGES TO THIS PRIVACY POLICY
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We may update this Privacy Policy from time to time. Any changes will be effective upon posting the revised policy on the Website. The "Last Updated" date reflects the most recent revision.
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11. CONTACT INFORMATION
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For questions regarding this Privacy Policy or our data practices, please contact:
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KSE Capital Management LLC
919 N Market Street, Suite 725
County of New Castle
Wilmington, Delaware 19801
United States
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