Privacy Policy
Last updated: August 28, 2023
This document includes important information about your personal data and we want to encourage you to read it in its literary entirety.
Welcome
We provide business consulting for businesses and individuals. People use our services to further their knowledge and ability to further business endeavors. Kynein wants to be clear about our use of the Personal Data entrusted to us.
This Privacy Policy (“Policy”) describes the “Personal Data” that we collect about you, how we use it, how we share it, your rights and choices, and how you can contact us about our privacy practices. This Policy also outlines your data subject rights, including the right to object to some uses of your Personal Data by us.
“Kynein”, “we”, “our” or “us” means Kynein Consulting and Acquisition, the entity responsible for the collection and use of Personal Data under this Privacy Policy.
“Personal Data” means any information that relates to an identified or identifiable individual, and can include information that you provide and that we collect about you, such as when you engage with our Services (e.g. device information, IP address).
“Services” means the products and services that Kynein indicates are covered by this Policy. Our “Business Services” are Services provided by Kynein to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. Our “End User Services” are those Kynein provides directly to people (rather than entities) for their own use.
“Sites” means kynein.com and the other websites, apps and online services that Kynein indicates are covered by this Policy. Collectively, we refer to Sites, Business Services, and End User Services as “Services”.
Depending on the context, “you” means End Customer, End User, Representative, or Visitor:
When you directly use an End User Service for your personal use (such as when you sign up for a course or make a payment to Kynein in your personal capacity), we refer to you as an “End User.”
When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, administer an account for a business/entity who is a Business User), we refer to you as a “Representative.”
When you visit a Site without being logged into a Kynein account or otherwise communicate with Kynein, we refer to you as a “Visitor.” (e.g. you send Kynein a message asking for more information because you are considering being a user of our products and/or services).
Depending on the activity, Kynein acts as a “data controller” and/or “data processor (or service provider)”.
1. Personal Data that we collect and how we use and share it
Our collection and use of Personal Data changes depending on whether you are acting as End User, End Customer, Representative or Visitor and our different Services. For example, if you are the sole owner of a business (i.e., sole proprietorship), we may collect Personal Data to onboard your business, but you may also be an End Customer that purchased goods from another Business User that uses Stripe’s Services for payment processing and you may also be an End User who uses Link to make those purchases.
1.1 End Users
We provide End User Services where we do not act as a service provider or processor to Businesses but instead provide the Services directly to you for your personal use (e.g. Lab Link). The legal bases for the collection of Transaction Data are listed by our processor, Stripe,
here.
a. Personal Data that we collect about End Users
Using Stripe or Connecting your Bank Account. Kynein offers you the opportunity to store your payment methods with Stripe so that you can conveniently use them across our platform. When you opt into Link by Stripe, you agree to let us store your Personal Data via Stripe such as your payment method so that you can more readily make purchases through Link with Business Users of our payment processing Business Services (e.g. name, contact information, payment method details (e.g. card number, CVC, and expiration date)). When you choose to make purchases, we will also collect Transaction Data related to your transactions.
Learn more at Stripe.
b. How we use and share Personal Data of End Users
Services. We use your Personal Data to provide the End User Service to you, including security, sanctions screening, delivery, support, personalization (e.g. language preferences and settings choices), and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). For example, we will use Personal Data to assess whether your use of Lab Link to make a payment with a merchant is authorized by you (and not a bad actor) and likely to be successfully authorized by the payment method you choose to use when you choose to make purchases with Lab Link.
Our Business Users. When you choose to connect your financial account with Stripe you may also choose to share account information with Business Users that you do business with. These Business Users will have their own privacy policies which describe how they use that information.
Transactions. For payment transactions with Link, End User Personal Data is shared with others to enable or “process” the transaction. For example, when you choose to use a payment method for the transaction with Stripe or with Link (e.g. credit card, debit card, buy now pay later, or direct debit), the third party provider of your payment method will receive Transaction Data that includes your Personal Data. When you use Link, the merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and, with your separate consent, your bank account information. Please review the privacy policies of your payment method and the merchants who you choose to learn more about their processing of your Personal Data.
Fraud Detection and Loss Prevention. We use your Personal Data collected across our Services (e.g. Stripe Radar) to detect fraud and prevent financial losses for you, us, and our Business Users and financial partners, including to detect unauthorized purchases.
Learn More. We may provide Business Users and financial partners (including card issuers, payment methods and others involved in payment processing activities) that use our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud or loss risk with a transaction. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction and what information we share with Business Users
here.
Advertising. We may use your Personal Data to assess your eligibility for, and offer you, other End User Services or promote existing End User Services. Where allowed by law (including with your opt-in consent where required), we use and share End User Personal Data with others so that we may market our End User Services to you, including through interest-based advertising. See our
Cookie Policy. We do not sell or share End User Personal Data with third parties for marketing or advertising their products without your separate consent.
1.2 Representatives
To provide Business Services, we collect, use and share Personal Information from Representatives of Business Users (e.g. a business owner). We provide more information about our collection, use and sharing of Personal Data in our
Privacy Center, including the
legal bases which we rely on for using (processing) your Personal Data.
a. Personal Data that we collect about Representatives
Registration and Contact Information. If you register for a Stripe account for a Business User (including incorporation of a Business), we collect your name and account log-in credentials. If you register for an event that Stripe organizes or attends or if you sign up for Stripe communications, we collect your registration and profile information. If you are a Representative or Representative of a potential Business User, we receive your Personal Data from third parties (including data providers) in order to advertise to, market and communicate with you as described further below and in Section 2. We may also associate a location with you in order to assess which Services or information may be useful to you.
Learn More.
Identification Information. If you are an owner of a Business User or you are expected to be a shareholder, officer or director of a Business User, we require that you provide your contact details, such as name, postal address, telephone number, and email address to fulfill our financial partner and regulatory requirements. We will directly (and through others) collect Personal Data about you, such as your ownership interest in the Business User, your date of birth and government identifiers associated with you and your Business User (such as your social security number, tax number, or Employer Identification Number). You may also choose to provide bank account information.
b. How we use and share Representatives Personal Data
Business Services. We use and share the Personal Data of Representatives with Business Users to provide the Services you (or the Business User you are associated with) have requested. If you are a Business User and have chosen a name that includes Personal Data (e.g. a sole proprietorship or family name in a company name), we will share and use that information as any company name in connection with the provision of our Services (e.g. including it on receipts and other descriptions identifying financial transactions).
Advertising. Where allowed by applicable law, we use and share Representative Personal Data with others so that we may advertise and market our Services to you. Subject to applicable law (including any consent requirements), we may advertise to you through interest-based advertising and emails and seek to measure the effectiveness of our ads. See our
Cookie Policy. We do not sell or share Representative Personal Data to others for their advertising purposes.
1.3 Visitors
We collect, use and share Personal Data of Visitors (who are not End Users, End Customers or Representatives). We provide more information about our collection, use and sharing of Personal Data in our
Privacy Center, including the
legal bases which we rely on for using (processing) your Personal Data.
a. Personal Data that we collect about Visitors
Forms. When you choose to fill in a form on the Site or on third party websites featuring our advertising (e.g. LinkedIn or Facebook), we will collect the information included in the form (e.g. your contact information and other information about your question related to our Services). We may also associate a location with your visit.
Learn More.
b. How we use and share Visitor Personal Data
Personalization. We use information about you that we gather from cookies and similar technologies to measure engagement with the content on the Sites, to improve relevancy and navigation, to personalize your experience (e.g. language and relevant geography) and to tailor content about Stripe and our Services to you. For example, because not all of our Services are available in all regions, so we may tailor our answers for your region.
Advertising. As allowed by law, we use and share Visitor Personal Data with others so that we may advertise and market our Services to you. Subject to applicable law (including any consent requirements), we may advertise our Services to you through interest-based advertising and emails, and seek to measure the effectiveness of our ads. See also our
Cookie Policy. We do not sell or share Visitor Personal Data to others for their advertising purposes.
Engagement. When visitors engage with our stripe.com site, we will use information we collect about and through your devices in order to provide the opportunity to engage in conversations or with chatbots to address your questions.
2. Other ways we collect, user, and share Personal Data
In addition to the ways we collect, use and share Personal Data that are described above, we also process your Personal Data as follows:
a. Person Data Collection
Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about:
Communication and Engagement Information. We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Stripe emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Stripe, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Stripe events and other interaction with Stripe personnel.
Forums and Discussion Groups. Where our Sites allow you to post content, we will collect Personal Data that you provide in connection with the post.
b. Personal Data Usage
In addition to the Personal Data usage described above, we use Personal Data in the following ways:
Improving and Developing our Services. We use analytics on our Sites to help us analyze your use of our Sites and Services and diagnose technical issues. To learn more about the cookies that may be served through our Sites and how you can control our use of cookies and third-party analytics, please see our
Cookie Policy. We also collect and process Personal Data through our different Services, whether you are an End User, End Customer, Representative or Visitor, to improve our Services, develop new Services and support our efforts to make our Services more relevant and more useful to you.
Learn More. Communications. We will use the contact information we have about you to perform the Services, which may include sending codes via SMS to authenticate you.
Learn More. If you are an End User, Representative or Visitor, we may communicate with you using the contact information we have about you (e.g. using email, phone, text message or videoconference) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and include you on our marketing information campaigns.
Social Media and Promotions. If you choose to submit Personal Data to us to participate in an offer, program or promotion, we will use the Personal Data you submit to administer the offer, program or promotion. We will also use that Personal Data and Personal Data you make available on social media to market to you unless we are not permitted to do so.
Fraud Prevention and Security. We collect and use Personal Data to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection Business Services, and to otherwise seek to secure our Services and transactions against unauthorized access, use, modification or misappropriation of Personal Data, information and funds. In connection with fraud and security monitoring, prevention, detection, and compliance activities for Stripe and its Business Users, we receive information from service providers (including credit bureaus), third parties, and the Services we provide. We may collect information from you, and about you, from Business Users, financial parties and in some cases third parties. For example, to protect our Services, we may receive information from third parties about IP addresses that malicious actors have compromised.
Learn More. This Personal Data (e.g. name, address, phone number, country) helps us to confirm identities, run credit checks subject to applicable law and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by an End Customer or End User with a Business User or financial partner.
Compliance with Legal Obligations. We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas and other legal obligations.
Learn More. We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is critical to this effort. For example, we may monitor patterns of payment transactions and other online signals and use those insights to reduce the risk of fraud, money laundering and other activity that is harmful to Stripe, our End Users and their End Customers.
Minors. The Services are not directed to minors, including children under the age of 13, and we request that they not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law.
c. Personal Data Sharing
In addition to the ways described above, we share Personal Data in the following ways:
Stripe Affiliates. We share Personal Data with other Stripe affiliated entities. When we share with these entities, it is for purposes identified in this Policy.
Service Providers or Processors. In order to provide Services to our Business Users and End Users and to communicate, market and advertise to Visitors, Representatives and End Users regarding our Services, we will rely on others to provide us services. Service providers provide a variety of critical services, such as hosting (storing and delivering), analytics to assess the speed, accuracy and/or security of our Services, identity verification, customer service, email and auditing. We authorize such service providers to use or disclose the Personal Data that we make available to perform services on our behalf and to comply with applicable legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union, the United States of America and India.
Learn More.
Financial Partners. “Financial Partners” are financial institutions that we partner with to offer the Services (including payment method acquirers, banks and payout providers). We share Personal Data with certain Financial Partners to provide the Services to the associated Business Users and to offer certain Services in partnership with our Financial Partners. For example, we share certain Personal Data of Representatives (e.g. loan repayment data and contact information) with institutional investors who purchase or provide credit secured by the Capital loans that we have made to the associated Business Users.
Others with Consent. In some cases we may not provide a service, but instead refer you to, or enable you to engage with, others to get services (e.g. professional services firms that we partner with to deliver Atlas). In these cases, we will disclose the identity of the third party and the information that will be shared with them and seek your consent to share the information.
Corporate Transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy.
Compliance and Harm Prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) to comply with rules imposed by a payment method in connection with use of that payment method (e.g. network rules for Visa); (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Stripe, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
3. Your rights and choices
You may have choices regarding our collection, use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us
If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails or as described
here. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, (i) we retain the right to communicate to you regarding the services you receive (e.g. support and important legal notices) and (ii) our Business Users may still send you messages and/or direct us to send you messages on their behalf.
b. Your data protection rights
Depending on your location and subject to applicable law, you may have the following rights described
here with regard to the Personal Data we control about you:
The right to request confirmation of whether Stripe processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
The right to request that Stripe rectify or update your Personal Data that is inaccurate, incomplete or outdated;
The right to request that Stripe erase your Personal Data in certain circumstances provided by law.
Learn More;
The right to request that Stripe restrict the use of your Personal Data in certain circumstances, such as while Stripe considers another request that you have submitted (including a request that Stripe make an update to your Personal Data);
The right to request that we export your Personal Data that we hold to another company, where technically feasible;
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time;
Where we process your information based on our legitimate interests, you may also have the right to object to the processing of your Personal Data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
Learn More.The right not to be discriminated against for exercising these rights; and/or
The right to appeal any decision by Stripe relating to these rights.
c. Process for exercising your data protection rights
To exercise your data protection rights please also see the
Stripe Privacy Center or contact us as described below.
4. Security and retention
We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
To help us protect Personal Data, where you have an account with Stripe, we encourage you to use a strong password, protect that password from unauthorized use and not use the same log-in credentials (e.g. password) for your Stripe accounts as you do with other services or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your Stripe account has been compromised), please contact us immediately.
Learn More.
We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your Stripe account or complete a transaction with a Business User, we may retain your Personal Data:
to comply with our legal and regulatory obligations.
to enable fraud monitoring, detection and loss prevention activities.
to comply with our tax, accounting, and financial reporting obligations
where required by our contractual commitments to our financial partners (and where data retention is mandated by the payment methods you used).
5. Updates and notifications
We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective the latter of when we post the revised Policy on the Services or otherwise provide notice of the update as required by law.
We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Representative, by contacting you through your Stripe Dashboard, email address and/or the physical address listed in your Stripe account.
