Effective Date: Thursday, May 28, 2026.
This Privacy Policy describes how Kinds Capital (the "Fund, " "we, " "us, " or "our"), a private investment fund focused on manual trading and capital preservation, collects, uses, discloses, and protects your personal information when you interact with our services, websites, and platforms. By accessing or using our services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.
1. Information We Collect
1.1 Personal Information
We collect the following types of personal information from investors and prospective
investors:
Identification Information: Full name, date of birth, government-issued ID numbers,
passport information, nationality
Contact Information: Email address, phone number, physical mailing address
Financial Information: Bank account details, wire transfer information, investment portfolio data, trading history, capital commitments, redemption requests
Investment Profile: Accredited investor status, investment experience, risk tolerance, investment objectives, net worth, income information
Compliance Documents: Proof of identity, proof of address, source of funds documentation, KYC (Know Your Customer) materials, AML (Anti-Money Laundering) certifications
1.2 Automatically Collected Information
When you access our investor portal or website, we may automatically collect:
Device Information: IP address, browser type, operating system, device identifiers
Usage Data: Pages visited, time spent, login times, document downloads, access patterns
Cookies and Tracking: Session cookies, persistent cookies, analytics tools
1.3 Third-Party Information
We may receive information from third party sources including background check providers,
credit bureaus, regulatory databases, identity verification services, and public records to
comply with our legal and regulatory obligations.
How We Use Your Information
We use your personal information for the following purposes:
Processing and managing investment subscriptions, capital calls, distributions, and redemptions
Conducting due diligence, compliance checks, and KYC/AML verification
Providing performance reports, quarterly statements, tax documents, and investment updates Managing investor accounts and maintaining accurate records
Communicating with investors regarding fund operations, notices, and administrative matters
Complying with securities laws, tax regulations, and other legal obligations
Preventing fraud, money laundering, and unauthorized access Improving our services and operational efficiency
Improving our services and operational efficiency
Legal Basis for Processing (GDPR)
For investors in the European Economic Area (EEA) and the United Kingdom, we process
your personal data based on:
Contractual Necessity: To fulfill our obligations under subscription agreements and fund documentation
Legal Obligations: To comply with securities regulations, tax laws, and AML/KYC requirements
Legitimate Interests: To operate the Fund, manage risk, and protect against fraud
Consent: Where you have provided explicit consent for specific processing activities
How we share your information
We may share your personal information with:
4.1 Service Providers
We collect the following types of personal information from investors and prospective
investors:
Fund administrators and accounting firms
Custodians and prime brokers
Banking institutions and payment processors
Compliance and KYC/AML verification providers
Legal advisors, auditors, and tax professionals
Technology providers and cloud storage services
4.2 Regulatory and Legal Authorities
We may disclose your information to securities regulators, tax authorities, law enforcement agencies, or governmental bodies when required by law, in response to legal processes, or to comply with regulatory obligations.
4.3 Business Transfers
In the event of a fund restructuring, merger, acquisition, or transfer of management, your information may be transferred to the successor entity or acquiring party.
Data Retention
We retain your personal information for as long as you remain an investor in the Fund and for such additional period as required by applicable securities laws, tax regulations, and record-keeping obligations. Retention periods typically range from 7 to 10 years after your investment terminates, or longer if required by law.
Data Security
We implement industry-standard technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encryption, secure servers, access controls, and regular security audits. However, no security system is completely impenetrable, and we cannot guarantee absolute security.
International Data Transfers
Your personal information may be transferred to, stored, and processed in jurisdictions outside your country of residence, including countries that may not provide the same level of data protection. By investing in the Fund, you consent to such transfers. We implement appropriate safeguards, including standard contractual clauses, to protect your data in accordance with this Privacy Policy and applicable laws.
Your Rights and Choices
Depending on your jurisdiction, you may have the following rights:
Access: Request access to the personal information we hold about you
Correction: Request correction of inaccurate or incomplete information
Deletion: Request deletion of your information, subject to legal retention requirements
Restriction: Request restriction of processing in certain circumstances
Portability: Request a copy of your data in a structured format
Objection: Object to processing based on legitimate interests
To exercise these rights, please contact us using the information in Section 11. We may
require verification of your identity before processing requests. Note that certain rights may
be limited by legal or regulatory obligations.
Cookies and Tracking Technologies
We use cookies and similar technologies to enhance your experience on our investor portal, analyze usage patterns, and maintain security. You may manage cookie preferences through your browser settings. Disabling cookies may affect the functionality of our platforms.
Updates to this Policy
We may update this Privacy Policy from time to time. Material changes will be communicated to investors via email or through our investor portal. The updated policy will be posted with a revised "Last Updated" date. Your continued participation in the Fund after such changes constitutes acceptance of the updated Privacy Policy.
Contact Us
For questions, concerns, or requests regarding this Privacy Policy, please contact us at:
Kinds Capital
Email: Wes.kinds@kindscapital.com
