Privacy Policy
KORA MANAGEMENT LP
Last Updated: March 21, 2024
Privacy Policy; Consent. This Privacy Policy sets forth the privacy practices of Kora Management LP ("Kora", "Manager", "we", "our", or "us") with respect to the collection, use, sharing and disclosure of Personal Information, including, but not limited to, Personal Information collected through this website (the "Site"), how it is used, and the circumstances under which it may be shared and disclosed. This Privacy Policy constitutes a legally binding agreement between you and Manager that conditions your use of the Site, where and as permitted by applicable law. This Privacy Policy is being provided in accordance with the requirements of data privacy laws applicable to the Manager (“Data Protection Law”). All capitalized terms not defined in this Privacy Policy shall have the meaning assigned to them in the Terms of Use.
We reserve the right to amend this Privacy Policy at any time and from time to time. You should check this Privacy Policy each time you use the Site to determine if any changes have been made. If you use the Site after the amended Privacy Policy has been posted, you will be deemed to have agreed to the amended Privacy Policy.
1. Personal Information We Collect. Kora may collect certain nonpublic personal information (“Personal Information”) in order to help us manage our relationship with you and serve your investment needs. We do not actively collect personally identifiable information such as your name, email address, or mailing address on the Site.
2. Sources of Personal Information. We may collect Personal Information from:
From Your Activity. IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Site you visit, etc.
From Cookies. Information that we collect using "cookie" technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will "remember" information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect information and to enhance your experience using the Site. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. You can disable cookies from your computer system by following the instructions on your browser or at http://www.allaboutcookies.org/. However, if you decide not to accept cookies from us, the website may not function properly.
Third-Party Analytics. We use third-party analytics services (such as Google Analytics) to evaluate your use of the Site, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Site usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Site, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Site.
Below is a list of analytics providers that we use; however, such list may be subject to change based on how we wish to understand the user experience. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their analytics collection.
Click here for more information on Squarespace Analytics or Google Analytics.
3. How we may Use Personal Information.
We use Personal Information for the following business purposes:
To provide our products and services;
To process your requests and inquires;
To offer new products and services;
To process transactions;
For account maintenance;
To confirm your identity;
To communicate with you;
To improve the Site;
To customize the Site to your preferences;
To protect the security and integrity of the Site;
To prevent or investigate fraud or other unlawful activity, and detect security incidents; and
To comply with and enforce applicable legal requirements.
4. How we Share Personal Information. Your privacy is important to us. Kora does not disclose any Personal Information to nonaffiliated third parties, except to service or manage a client’s account or as permitted by Data Protection Law. We do not sell any Personal Information.
You may contact us at any time to limit our sharing of your Personal Information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.
5. Retention Periods and Security Measures. Kora seeks to carefully safeguard Personal Information. We will use commercially reasonable efforts to ensure that Personal Information is kept secure and safe from any loss or unauthorized disclosure or use. We restrict access to our client’s Personal Information to employees requiring that Personal Information to provide our products or services.
We will not retain Personal Information for longer than is necessary in relation to the purpose for which it is collected, subject to applicable Data Protection Law. If you are an investor in a fund or funds managed by Manager, Personal Information will be retained for the duration of your investment in the Manager and for a minimum period of five to seven years after a redemption or withdrawal, as applicable, of your investment or liquidation of the Manager. We may retain Personal Information for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which Personal Information has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.
Additional Information for Residents of the European Economic Area and United Kingdom.
Processing and International Transfers. Due to the international nature of our business, your Personal Information will be processed in the United States, and other countries outside the European Economic Area and the United Kingdom (“Third Countries”), that may not offer the same level of data protection as that afforded by the European Union’s General Data Protection Regulation, and the same as forms part of the law in the United Kingdom (the “GDPR”). We will process personal data (or ensure that it is processed) in such Third Countries subject to appropriate safeguards and in accordance with the requirements of applicable law, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries. We may also be required to transfer your Personal Information to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.
Legal basis for processing. We will use one of the permitted grounds under the GDPR to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your Personal Information.
The legitimate interests to collect your Personal Information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your Personal Information for such purpose.
Consequences of failing to provide personal information. As a regulated financial services firm, we are subject to legal and regulatory obligations that may require us to collect and store your Personal Information. We may also need to collect and use your Personal Information for the purposes of entering into or performance of a contractual arrangement between us.
A refusal to provide us with Personal Information may, depending on the purpose for which your Personal Information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.
Your rights. You may have certain rights under the GDPR in respect of the personal data we hold and which you may exercise. These rights are:
to request access to your personal data;
to request rectification of inaccurate or incomplete personal data;
to request erasure of your personal data (a “right to be forgotten”);
to restrict the processing of your personal data in certain circumstances;
to object to our use of your personal data, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of certain types of direct marketing activities);
where relevant, to request the portability of your personal data;
where you have given consent to the processing of your data, to withdraw your consent by contacting us on the e-mail below; and
to lodge a complaint with a data protection authority.
7. Contact Us. If you have any questions, comments, or concerns about this Privacy Policy or the information practices of the Site, please contact us at info@korcap.com.