Karlin Ventures, LLC
If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA”), and any CCPA-specific information is identified in this Policy. An explanation of your rights under the CCPA can be found here.
Site visitors and other consumers who use our services from other states that have adopted privacy and data protection laws may also have rights similar to or in addition to the provisions of the CCPA. KV complies laws applicable to KV.
Click on one of the links below to jump to the listed section:
What Personal Information does the Company collect?
How does the Company use Personal Information?
Do we share your Personal Information with any third parties?
Where we store your Personal Information
How we protect your Personal Information
How long we store your Personal Information
Additional Policies in Compliance with the CCPA
Additional Policies in Compliance with the EEA Privacy Laws
Your rights with respect to your Personal Information
Access to your Personal Information
Protecting Children’s Privacy
Links to other websites
“Personal Information” means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). The table below describes the categories of Personal Information we may collect.
Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number or state identification card number, passport number, or other similar identifiers
Race, age, gender, religion, citizenship, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information
Records of personal property, purchasing or consuming histories or tendencies
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data
Browsing history, search history, IP address, website interactions
GPS coordinates, location history or movements
Audio, electronic, visual, thermal, olfactory, or similar information
Current or past job history or performance evaluations
Educational background, grades, scores
Financial information, medical information, health insurance information
Profiles drawn from other Personal Information reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
“Processing” is any activity that involves use of the Personal Information. It includes obtaining, recording or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Information to third parties.
We only collect Personal Information that is relevant for the purposes for which we request the data. We do not use your Personal Information in any way that is incompatible with the purposes for which it was collected or for which you have consented.
When you contact us through our Site, or by corresponding with us by phone, e-mail, or otherwise, we may collect Personal Information including:
2.1 Personal Information Collected about Customers and Vendors
In order to provide our clients with individualized services, we collect certain non-public, personal information about you from documents you provide to us. In addition to receiving personal information directly from you, we may also receive information from your attorney, consultants, advisers, and other sources. We will only obtain such information from third parties with your express consent, as permitted by law.
We may collect the following categories of Personal Information from our clients:
- Identifiers: name, address, email, phone, social security number, federal tax ID number, passport, driver’s license, or other relevant identifiers, as applicable.
- Protected Classes: gender, race, sexual orientation, and citizenship information, as necessary.
- Professional Data: we may collect professional data such as C.V., salary history, and education history, as necessary.
- Sensory Data: we employ video surveillance at certain of our facilities for security purposes.
- Other Data: Financial information such as credit card and account numbers; financial records, such as tax information, and securities filings.
2.2 Information we collect automatically about visitors to our Site
When you visit our Site, our web server automatically collects the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages on our Site you viewed; page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
- We may also determine the approximate location of your device from your IP address. We collect and use this information to determine statistics about our website, including how many people visit our website from certain geographic regions.
2.3 Information we receive from other sources
We receive about you if you use the other websites we operate or the other services we provide. We work closely with third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers. We will inform you when we collect data if we intend to share the data or combine it with data we collect directly. We also will tell you the purpose for sharing and combining your data. We will notify you when we receive information about you from other parties and the purposes for which we intend to use that information.
The cookies we may use on this Site are:
These cookies are used to collect information about how visitors use the Site. We use this information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
More detailed information on cookies can be found at www.allaboutcookies.org.
2.5 Business Information
We also collect Personal Information from our vendors and business partners. We collect that information in the course of our business dealings:
If you or the company you work for are a customer or supplier of ours.
If you or the company you work for use our Services.
If you are someone, or you work for someone, to whom we want to advertise or market our Services.
From your employer in connection with your role and its relation to our Services.
From third parties we work with closely, such as business partners, and introductions from other individuals or companies.
When you or the company you work for interact with us (for example, when providing technical services to us), we collect the following types of Personal Information:
Contact information, such as your email address, phone number and any other information you choose to provide, relating to your work or to you personally, depending on the nature of our relationship with you or the company that you work for (for example, your name, job title or other information in your email signature).
Information relating to our dealings with you or the person you work for: including but not limited to administrating your company account, verifying financial transactions in relation to payments, using details of goods or services that we have exchanged with you, information about events to which you are invited and preferences related to managing those events (for example dietary information) and information that you give us or we otherwise obtain when you visit us.
Other information: information about you that you give us by communicating with us by phone, e-mail, via our website, via social media or otherwise. It includes information you give us or that we obtain when you use our Services, or subscribe to communications from our Services, enter a competition, promotion or contact us to report a problem, or do any of these things on behalf of the person you work for.
We use information held about you in the following ways:
3.1 Information you give to us. We will use this information:
- To provide you with the information, products, and services that you request from us;
- To send you direct marketing and promotional materials, or other communications;
- To respond to requests for information, services, or email notifications, or to respond to other enquiries;
- For training purposes, quality assurance, and to record details about the products and services you order from us;
- To comply with applicable laws and regulations;
- To carry out our obligations arising from any contracts entered into between you and us, or between you and our vendors or distributors;
- To provide you with information about other goods and services we offer, or that are offered by our affiliates or third party vendors, that are similar to those that you have already purchased or enquired about;
- To notify you about changes to our service;
- To make inquiries about you for credit reference purposes;
- To perform data analyses (including anonymization and aggregation of Personal Information);
- For prospective employees, to respond to your job application.
3.2 Information we collect automatically. We will use this information:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- As part of our efforts to keep our site safe and secure.
3.3 Information we receive from other sources.
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
KV does not sell your Personal Information. We may share Personal Information with our affiliates, service providers, and contractors who perform services on our behalf. When we share information, we require our affiliates, service providers and contractors to agree to use your Personal Information only as we instruct them. You agree that we have the right to share your Personal Information with selected third parties, including:
- Business partners, distributors, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- Analytics and search engine providers that assist us in the improvement and optimization of our site.
We may disclose your personal information to third parties in the following circumstances:
- You request or authorize it;
- The information is provided to help complete a transaction for you;
- The disclosure is part of a purchase, transfer or sale of services or assets (for example, if another party acquires our business or assets;
- The information is provided to our agents, outside vendors, or service providers to perform functions on our behalf (e.g. analyzing data, providing marketing assistance, providing customer service, processing orders, etc.);
- Disclosing your Personal Information is necessary as part of actual or threatened legal proceeding or dispute resolution proceeding, in which case we disclose only the information necessary to file, pursue, or defend against the proceeding, and take reasonable precautions to ensure that the information disclosed does not become a matter of public record;
- If we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual espionage, cybersecurity events, or other fraudulent or illegal activity.
In such circumstances, only KV, and its authorized affiliates, contractors, suppliers, or service providers will have access to your Personal Information. These third parties are required to act in accordance with the instructions we give them and they must meet the requirements of the law. We require them to put in place adequate measures to safeguard your Personal Information, and they agree to limit the use any Personal Information to the intended purpose for which it was shared.
We may share your Personal Information with other companies so that they can contact you with details of other products or services you may be interested in. We will only do this if you have agreed to this and where such companies agree to use your personal information for that purpose only. You can ask us not to continue to provide your personal information to any third parties in future by contacting us at the address below.
KV uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect. We maintain physical, administrative and technological safeguards designed to protect your Personal Information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Site via the Internet. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We will keep your Personal Information for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint about a product or service) for as long as is necessary to respond to a legal claim. In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Unless this is the case, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.
Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
The CCPA affords California consumers the rights with respect to their Personal Information described in this section. These rights apply only to California residents, who are not otherwise exempt pursuant to the terms of the CCPA.
California consumers have the right to request that the Company disclose what personal information it has collected, used, or disclosed over the 12-month period preceding the Company’s receipt of such a request. To exercise this right, a California consumer must submit to the Company a verifiable request to know such information. This request can be submitted by following the procedures set forth in Section 8.4 below. KV does not sell your Personal Information.
7.2 Right to Correct of Personal Information
California consumers have the right to request that any inaccurate or incomplete Personal Information maintained by the Company be corrected or supplemented
California consumers have the right to request the deletion of their Personal Information collected or maintained by the Company. To exercise this right, a California consumer must submit to the Company a verifiable request to delete such information. This request can be submitted by following the procedures set forth in Section 8.5 below.
All of these rights are subject to certain conditions and exemptions. For example, KV is not required to delete your Personal Information if we need to retain it to respond to a legal claim or where we are required by law to retain the Personal Information.
7.4 Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California consumers have the right to not be discriminated against because the consumer exercised any of the consumer’s rights under the CCPA. That means that a company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA (unless the different rate or different level or quality is reasonably related to the value to the business of the consumer’s data). We will not deny you any services or charge you a different price, level or quality of services because you exercise any of your rights under the CCPA; however, we may not be able to provide the services if you refuse to provide us the Personal Information that is necessary for us to provide the Services, or if you ask us to delete your Personal Information.
To submit a request to KV, know about the Personal Information we collect about you as described in Section 8.1, a request for deletion of your Personal Information as described in Section 8.2, or to correct your Personal Information as described in Section 8.3, please contact firstname.lastname@example.org.
The Company is required to verify the identity of the individual requesting access to a consumer’s data or requesting deletion of a consumer’s data. To verify your identity, we will rely upon information we have previously collected about you, such as phone calls received from a known phone number or emails received from a known email. We will also rely upon our personal relationship with our customers or vendors to verify the identity of a requester. If a requests involves the disclosure of sensitive Personal Information, or deletion of Personal Information, we may ask you to provide more than one piece of information. We will not require you to provide any information that you have not previously provided to us.
If the California consumer submitting a request is not the Company’s client, such an individual who requested information through our website or a phone call to our “contact us” number, then we will verify identity by confirmation using the information we collected, such as phone number of email address.
7.6 Authorized Agent
California consumers may designate an authorized agent to exercise a CCPA right on the consumer’s behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer’s behalf will need to be provided:
Proof of written permission by the consumer for the authorized agent to act on his or her behalf and separate verification of the consumer; or
Proof that the authorized agent holds a power of attorney to act on the consumer’s behalf pursuant to Cal. Probate Code §§ 4000-4465.
Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and medical information under the Confidentiality of Medical Information Act (adopted under the Health Insurance Privacy Protection Act) are not subject to the CCPA.
8.1 GDPR Definitions
“Controller” means the company that is the organization that determines the purposes for which, and the manner in which, any Personal Information is Processed and used in its business.
“Processor” means any Person Processing Personal Information.
“Person” means a natural person, corporation, association, organization, partnership, or other legal entity.
“Processing” is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Information to third parties.
8.2 The legal basis for processing your Personal Information
In order to comply with the GDPR, we are required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for processing your Personal Information will typically be one of the following:
- Our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors, such as, for example, providing direct marketing to our customers of our products and services that we think would be of interest, permitting prospective employees to search and apply for job opportunities, handling inquiries from our promoters, affiliates, distributors, vendors, and customers, or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest;
- The performance of a contract that we have in place with you;
- Your consent where appropriate; or
- Compliance with our legal obligations, including to meet national security or law enforcement requirements.
8.3 Where we store your Personal Information
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
8.4 Addendum to how long we store your Personal Information
In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Except in those circumstances, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.
8.5 Your rights with respect to your Personal Information
Subject to certain exceptions, you have the following rights with respect to your Personal Information:
- To receive or access a copy of the Personal Information that we hold about you;
- To request that any inaccurate or incomplete Personal Information be corrected or supplemented;
- To have your Personal Information erased, unless we have a legitimate reason to retain the Personal Information (such as if we are required to do so for legal reasons); and
- To ask us not to process your Personal Information for a particular purpose, including for marketing.
All of these rights are subject to certain conditions and exemptions. For example, the Company will not be obligated to erase your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.
To exercise any of these rights, please submit a written request to us using the contact information set forth below. The Company reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations.
You have the right, at any time, to object to the use of your Personal Information for direct marketing purposes and/or the receipt or further receipt of specific or all types of marketing information, or to object to the use of your Personal Information for any processing activity. To do so, you can direct your request by post to the address listed below or by e-mail.
Our Site is not designed nor intended to be used by children (those under the age of 18, “Minors”). We do not knowingly collect Personal Information from Minors. If you are under the age of 18, please do not submit any information to us.
Karlin Ventures, LLC
11755 Wilshire Blvd., Ste. 1400
Los Angeles, CA 90025
Attn: Compliance Officer
or you can simply click on Contact Us to send us an email.
Effective Date: August 12, 2023