KYUGA MANAGEMENT INC.

Privacy Policy

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Effective [Date]. This Privacy Policy may be modified to be kept up to date

At [Full Corporate Name], our website does not collect personal information and we only collect business contact information from our clients. Our clients using our solutions may input personal information on our systems, which we keep secure. 

All personal information at [Full Corporate Name] is collected with consent when individuals seek our services or through contracts when clients use our solutions as their information infrastructure. 

We do not sell any personal information.

How we protect personal information at [Full Corporate Name]

1. We do not collect any personal information from website visits. We do not need it so we do not collect it.

2. We collect personal information clients provide us when they contact us, including first and last name as well as the email address and phone number for us to respond to inquiries. With consent, we send promotional emails from [Full Corporate Name] to keep our clients informed of our developments and new products and services. Each email features the option to unsubscribe from receiving these emails at any time. 

Where and how long we keep personal information

We generally hold personal information on secure servers located in Canada. Exceptionally, personal information may be held in the U.S, under the protection of the Trans-Atlantic Data Privacy Framework. Where personal information is held in the US, it may come under the application of US law. 

We only keep personal information as long as the client account with us is active, unless we are required by law, for example, tax law, to keep it for longer. 

How we keep personal information secure 

The security of personal information is important to us.  Although we cannot guarantee 100% security, we use reasonable and appropriate security measures to protect personal information against unauthorized use, loss, access, modification, destruction or disclosure while it is in our custody or under our control. These measures include physical, organizational, and technological measures. Physical measures include secure work areas, and technological measures include encryption, firewalls, anti-virus, and system security monitoring.  Organizational measures include access controls to limit access to personal information to those employees, contractors and agents who have a business need to know.

We do not disclose personal information

We do not disclose any information in our custody to third parties unless it is with consent or required by law.

How we give access to personal information

Clients may request access to or ask to edit or remove their personal information that we collect and maintain by contacting us at [email]. We will respond within 30 days. If we cannot provide access, for example because it would disclose personal information of a third person, we will provide justification. 

Questions and contact information

For individual requests to access personal information or to express concerns about protection of personal information at [Full Corporate Name], please contact [email].

Complaint mechanisms also exists with national privacy authorities.

Why does Kyuga Effective [Date]. This Privacy Policy may be modified to be kept up to datepersonal information?

Kyuga collects personal information to provide and improve our Site, its features, and content and allow users to enjoy and easily navigate the Site.

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What types of personal information does Kyuga collect?

In order to facilitate introductions, Kyuga will collect information to establish your identity, such as your name, address, phone number, occupation, title, business phone number, and email address.

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Information pertaining to business clients will include your business name, address, phone number, email address, industry type, and may include detail(s) on the owner(s), operator(s), and director(s).

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How does Kyuga collect personal information?

Except as otherwise set out in this Privacy Policy, we collect personal information directly from you. If you are referred to Kyuga, we may collect your name, address, email address, and any other relevant information from the introducing referral only upon your consent.

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Safekeeping of personal information?

Kyuga takes the security of your Personal Information very seriously but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.

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Kyuga maintains reasonable administrative, technical, and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification, and disclosure of. We train our employees to keep clients’ personal information strictly private and confidential. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information.

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We have personal information retention processes designed to retain personal information of our clients and prospective clients for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal requirements.

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We will make any legally required disclosures of any breach of the security, confidentiality or integrity of your Personal Information in the most expedient time possible and without unreasonable delay taking into account the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and restore the reasonable integrity of our data system.

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Who is your personal information shared with?

We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out in this Privacy Policy.

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Under certain circumstances, your personal information may be shared among Kyuga employees, or other third parties, and only on a “need to know” basis in order to fulfill their job and/or service requirements.

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Our Employees

All employees of Kyuga are bound under the policies and procedures of Kyuga to maintain the confidentiality of your personal information and are available to address any questions or concerns you may have. Access to your information is restricted to authorized employees who have a legitimate business purpose for accessing it. Unauthorized access to and/or disclosure of client information by an employee of Kyuga is strictly prohibited. All employees are required to maintain the confidentiality of client information at all times.

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Outside Service Providers

Kyuga provides access to third parties engaged by Kyuga to assist Kyuga with various issues. These third party service providers may at times be responsible for reviewing, processing, or handling personal information and are provide only the information necessary to perform the services required of them. Kyuga ensures that all third party service providers have a comparable level of protection in place in respect of your personal information.

 

Other Third Parties

We will only share your information with other third parties under the following special circumstances:

• To respond to valid and authorized information requests from domestic and international authorities.

• As permitted or required by law, to comply with laws, regulations, subpoenas, or court order.

• To identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) Kyuga’s rights or property or anyone else that could be harmed by such activities.

• To protect the personal safety of employees, clients, or other third parties on Kyuga’s property.

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Use of personal information for communication purposes

If you contact customer service with a comment, question, or complaint by email, telephone, or video call, you may be asked for information that identifies you (such as your name, address, and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and, product and service offerings.

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From time to time, we may obtain your consent to send you emails, and other communications about Kyuga services or events that may be of interest to you. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained in each of our email communications.

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We collect and use information when you visit our website

When you use or visit the Site, our servers automatically record information that your browser sends whenever you visit a website.

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Use of cookies

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard drive for record-keeping purposes. Persistent cookies are used to save your login information for future logins to the service on our Site. Session ID cookies are used to enable certain features of our Site, to get a better understanding of how you interact with the Site, and to monitor aggregate usage by NPWI users and web traffic routing on the Site. Unlike persistent cookies, session ID cookies are deleted from your computer when you log off from the Site and then close your browser. By changing its options, you can instruct your browser to stop accepting cookies or to prompt you before accepting cookies from the website you visit. However, if you do not accept cookies, you may not be able to use all portions of the Site.

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Website Analytics

The data we monitor and collect may include information such as your computer’s Internet Protocol (“IP”) address, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times, and dates, and other statistical information.

We may use third parties to help us gather and analyze information about the areas visited on the Website in order to better understand, evaluate and improve the user experience and the convenience of the Website.

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Kyuga and links to third party websites

Our Site may contain links to other websites that we do not own or operate. Also, links to our Website may be featured on third party websites. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third-party websites as a convenience to you. These links are not intended as an endorsement of or referral to the linked websites. We do not have any control over such websites, and as such we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure, and otherwise treat your personal information.

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Our Privacy Officer

Kyuga has appointed Jessica Mann, our President, as Privacy Officer who is responsible for overall privacy governance. The Privacy Officer may be contacted at  jessica@kyugamanagement.com.