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  Privacy Policy Effective January 1, 2023






















Kynex Inc. (“Kynex,” “us,” “we,” “our”) is committed to protecting the privacy of our users, and strives to provide a safe, secure user experience. This Privacy Statement sets forth the online data collection and usage policies and practices that apply to the Kynex Tool (including the website located at (the “Site”)). This privacy policy does not apply to any third-party websites, service or applications, even if they are accessible through the Kynex Tool. By using the Kynex Tool, you agree to the processing activities set forth in this Privacy Policy with respect to your Personal Information.

1. Revisions to this Privacy Policy
Any information that is collected via our Site is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. When we do so, we will update the “Last Update” above to indicate when those changes will become effective.

2. Collection and Use of Information
Information Collected or Received from You
Our primary goals in collecting information are to provide and improve the Kynex Tool, to administer your use of the Kynex Tool, to enable you to enjoy and easily navigate the Kynex Tool, and to respond to your inquiries submitted via the Kynex Tool. To achieve these goals, we may collect information that can reasonably be used to directly or indirectly identify a person (hereinafter “Personal Information” or “PI”). We use this information for the purposes of providing our services, responding to any queries you may have, operating and improving the web site, fostering a positive user experience and delivering the products and services that we offer. This information may include:

   Contact Information: Depending on how you choose to use the Kynex Tool, you may provide us with contact information such as your: name, email address, or telephone number.

   Device Information: Depending on how you access the site, we may collect information regarding the type of device on which the Kynex Tool is used or downloaded, the operating system name and version of the device used to access the Kynex Tool, device manufacturer, application version accessed on your device, device ID, IP address, and geolocation data.

   Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies to collect certain information.
   “Cookies” are small text files that are placed on your hard drive by a Web server when you access our Site. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Site and to tell us how and when you interact with our Site. We may also use Cookies to monitor aggregate usage and web traffic routing on our Site and to customize and improve our Site. Unlike persistent Cookies, session Cookies are deleted when you log off from the Site and close your browser. If you configure your browser options to stop accepting Cookies, you may not be able to access all portions or features of the Site..

3. How Information Is Used
Once you provide us with your Personal Information, we may use it in the following ways:
   (a) To present our website and its contents to you;
   (b) To provide you with access to and use of the Kynex Tool;
   (c) To fulfill the purposes for which you provide the information;
   (d) To provide you with notices about your account/subscription, including expiration and renewal notices;
   (e) To carry out our obligations and enforce our rights arising from the Terms of Use or any contracts with you, including for billing and collection or to comply with legal requirements;
   (f) To notify you about changes to the Kynex Tool or any products or services we offer or provide though it;
   (g) To improve the Kynex Tool, our products or services, or our client relationships and experiences;
   (h) In any other way we may describe when you provide the information;
   (i) For any other purpose with your consent.

4. Information that We May Share with Third Parties
We will not share any PI that we have collected from or about you with any third party except as described in this Privacy Policy.

Information Shared with Our Service Providers
We may engage third-party services providers to work with us to administer and support our business. These third-party services providers have access to your PI only for the purpose of performing services on our behalf. Examples include hosting our web servers, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. These companies and individuals may be located in a country whose data protection legislation is different from your country, and they will have access to your Personal Information only as necessary to perform their functions, but they may not share that PI with any other third party or use that data for any other purpose.

Information Disclosed in Connection with Business Transactions
We may disclose PI to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any of our business, assets, or stock, including in connection with bankruptcy or similar proceedings.

Information Disclosed for Our Protection and the Protection of Others
We may disclose your PI if legally required to do so, pursuant to a request from a governmental entity, or if we believe in good faith – after considering your privacy interests and other factors – that such action is necessary to:
   (a) Conform to legal requirements or comply with legal processes (including subpoenas);
   (b) Enforce or apply our terms of use and other agreements, including for billing and collections purposes;
   (c) Protect our property rights, rights and safety or property, rights and safety of a third party, our affiliated companies, or the public in general; or
   (d) Stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed to Others in Accordance with Your Preferences
We may disclose such PI to third parties if you consent to such disclosure.

5. International Transfer
Your PI may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your PI to us, we may transfer your PI to the United States and process it there.
In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy legislation.

6. Your Choices About Your Information
Information Collected by Us
We respect the choices that you make with respect to your privacy and therefore provide you with the following options with respect to your PI. You may request:
   • Access to your PI to know what information we have collected about you;
   • That we correct your PI if such data is out of date or incorrect; or
In the event you decide to exercise these rights, we will do our best to honor your request.

7. The Security of Your Information
Kynex takes reasonable administrative, physical and electronic measures to safeguard your Personal Information from unauthorized access or inappropriate use by third parties. Please be aware, however, that no method of transmitting and storing information over the internet is completely secure. Accordingly, we cannot guarantee the absolute security of any information and you should ensure that you do not post sensitive information, including personality profiles, to the Kynex Tool.

8. Data Retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

9. Our Policy Toward Children
Our Site is not directed to children under 16 and we do not knowingly collect PI from children under 16. If we learn that we have collected PI of a child under 16 without verification of parental consent, we will take steps to delete such information from our files as soon as possible.

10. Contact Us
If you have any questions regarding this policy or would like to exercise your rights, please contact us at

11. Additional Matters Relating to Residents of the European Economic Area

Privacy Policy Until December 31, 2022

We collect information from you during the registration process and, occasionally, at other times. This information, which ranges from limited personal data such as name and address to facts about your profession and investment style, is then securely stored on separate servers. We are strongly committed to protecting your privacy online and will not release the information you share with us to any outside organization. We do use third-party service providers to facilitate some aspects of our service, and these service providers may be supplied limited amounts of data solely for the purposes of providing our service. (You may wish to select a Login Name that is not personally identifiable.) To help us protect your privacy, you should maintain the secrecy of the login name and password.

We use registration information to process, validate and verify your identity. This information also enables us to provide you with customized services, content and features. We will use this information to notify you of new service features and reserve the right to contact you regarding any service-related activities such as collecting membership fees or any problem or question with, or the expiration of, such services.

We employ "cookie technology" to help you move faster through our various service offerings. (A "cookie" is a string of information that is sent by us and stored on your hard drive or temporarily in your computer’s memory.) When you log on to our service and take advantage of several key features such as Convertibles, we pass several cookies to your computer. This avoids the potentially time-consuming task of checking our registration database each time a service feature is requested.

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