Privacy Policy

1. Introduction

KAIN Capital Management Inc. ("KAIN Capital," "Company," "we," "us," or "our") is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website at kaincapital.com (the "Website") or interact with us.

We are committed to complying with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and other applicable Canadian privacy legislation. By using our Website or providing us with your personal information, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.

2. Definitions

"Personal Information" means information about an identifiable individual, but does not include the name, title, business address, or telephone number of an employee of an organization.

"Consent" means voluntary agreement to the collection, use, and disclosure of personal information for defined purposes.

3. Information We Collect

3.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us, including when you:

• Complete a contact form on our Website
• Send us an email or other correspondence
• Communicate with us by telephone
• Meet with us in person
• Submit an investment opportunity or business proposal

This information may include:

• Your name
• Email address
• Telephone number
• Company or organization name
• Your role or title
• Details about your property, business, or investment opportunity
• Any other information you choose to provide

3.2 Information Collected Automatically

When you visit our Website, we automatically collect certain technical information, including:

• Device Information: Device type, operating system, browser type and version
• Log Information: IP address, access times, pages viewed, referring URL
• Location Information: General geographic location based on IP address

3.3 Cookies and Similar Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities on our Website. Cookies are small data files stored on your device.

Types of cookies we use:

• Essential Cookies: Required for the Website to function properly
• Analytics Cookies: Help us understand how visitors interact with our Website

You can control cookies through your browser settings. However, disabling certain cookies may affect your experience on our Website.

4. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to inquiries: To answer your questions and respond to your requests for information
• To evaluate opportunities: To assess investment opportunities, properties, or businesses you submit to us
• To communicate with you: To provide information about our services and discuss potential business relationships
• To improve our Website: To analyze how visitors use our Website and improve its functionality and content
• To comply with legal obligations: To meet our legal and regulatory requirements
• To protect our interests: To enforce our Terms of Service and protect against fraud or other illegal activities

We will not use your personal information for purposes other than those described in this Privacy Policy without your consent, unless required or permitted by law.

5. Disclosure of Your Information

We do not sell, rent, or trade your personal information to third parties.

We may disclose your personal information in the following circumstances:

5.1 Service Providers

We may share your information with trusted third-party service providers who assist us in operating our Website and conducting our business. These providers are contractually obligated to protect your information and may only use it to provide services to us.

Our current service providers include:

• Netlify: Website hosting and form processing (netlify.com/privacy)
• Google Analytics: Website analytics (policies.google.com/privacy)

5.2 Legal Requirements

We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

5.4 With Your Consent

We may disclose your personal information for other purposes with your express consent.

6. Google Analytics

We use Google Analytics 4, a web analytics service provided by Google LLC ("Google"), to help us understand how visitors use our Website.

What Google Analytics collects:

• Pages visited and time spent on each page
• Referring website or source
• Device and browser information
• General geographic location (city/region level)
• Interactions with Website features

How Google Analytics uses this information:

Google Analytics uses cookies to collect this information. The information is transmitted to and stored by Google on servers that may be located outside of Canada, including in the United States. Google uses this information to compile reports on website activity for us.

Your choices:

• You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, available at: tools.google.com/dlpage/gaoptout
• You can also control cookies through your browser settings

For more information about Google's privacy practices, please visit: policies.google.com/privacy

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

• Contact form submissions: Retained for the duration of our business relationship or inquiry, plus a reasonable period thereafter for legal and business purposes
• Analytics data: Retained in accordance with our Google Analytics settings (currently 14 months)

We may retain certain information for longer periods if required by law or for legitimate business purposes, such as to resolve disputes or enforce our agreements.

8. Security of Your Information

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Secure Socket Layer (SSL) encryption for data transmission
• Secure hosting infrastructure
• Limited access to personal information on a need-to-know basis

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

9. Your Rights Under Canadian Privacy Law

Under PIPEDA and applicable Canadian privacy legislation, you have the following rights:

9.1 Right to Access

You have the right to request access to the personal information we hold about you. We will respond to your request within 30 days, as required by law.

9.2 Right to Correction

You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

9.3 Right to Withdraw Consent

You have the right to withdraw your consent to our collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide certain services to you.

9.4 Right to Complain

If you have concerns about our handling of your personal information, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

10. International Data Transfers

Our Website is hosted on servers that may be located outside of Canada, including in the United States. Our service providers, including Google, may also process your information in countries outside of Canada.

When your information is transferred outside of Canada, it may be subject to the laws of those jurisdictions, which may differ from Canadian law. By using our Website and providing us with your information, you consent to this transfer.

We take steps to ensure that our service providers provide an adequate level of protection for your personal information in accordance with PIPEDA.

11. Third-Party Websites

Our Website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party websites you visit.

12. Children's Privacy

Our Website is not directed to children under the age of 18, and we do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information.

13. Canada's Anti-Spam Legislation (CASL)

We comply with Canada's Anti-Spam Legislation. We will not send you commercial electronic messages unless you have provided your express or implied consent, as defined under CASL.

You may withdraw your consent to receive commercial electronic messages from us at any time by:

• Clicking the "unsubscribe" link in any email we send you
• Contacting us using the information provided below

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post any changes on this page and update the "Last Updated" date at the top.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

15. Contact Our Privacy Officer

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how we handle your personal information, please contact us:

Privacy Inquiries: Use the contact form on our website and indicate that your inquiry relates to privacy. We will respond within 30 days.