Privacy Policy


1.1. At Kinesis Cayman (“we, “us”, “our”, “Kinesis” or “Company”) are committed to keeping your
information safe and secure. Please read this privacy policy (“Privacy Policy”) so that you
understand your rights in relation to this information, including how your information will be
collected, used and processed.

1.2. Kinesis Cayman is a company incorporated in the Cayman Islands, of C/O Stuarts Corporate
Services, 36A Dr. Roy’s Drive, Grand Cayman, Cayman Islands, KY1-1104.

1.3. In providing you with our website ( (“Website”) including our related products, services such as participating in the sale by the Company of digital tokens (the “Kinesis Tokens”) subject to:

1.3.1. the Simple Agreement for Future Tokens (the “SAFT Agreement”) during the Pre-Sale phase of the Kinesis Tokens sale being prior to 10 September 2018; and

1.3.2. the Terms and Conditions of Token Sale and Use (the “Token Sale Agreement”) and Offering Memorandum (if applicable to you) during the Public Sale phase of the Kinesis Tokens sale bring as and from 10 September 2018,

the documents being contained on the Website, or communicating electronically with us (collectively the “Services”) we may collect, process or be provided with your personal data.

1.4. By visiting or continuing to use our Website you are accepting and consenting to the practices
described in this policy.

1.5. We may update this Privacy Policy from time to time so it should be reviewed regularly for updates
and changes.


2.1. In operating our Website and providing our Services we may collect and process the following
data about you:

2.1.1. Details of your visits to our Website and the resources that you access, including but
not limited to, traffic data, location data, web logs and other communication data.

2.1.2. Information that you provide by filling in forms on our Website, such as when you
register to access, apply to or receive our Services which includes (but is not limited to)
your name, email, phone number, residential address, place of birth, date of birth,
gender, official identification number, nationality, country of residence and source of

2.1.3. Information provided to us when you communicate with us for any reason.

2.1.4. Details contained in any request for support or assistance from us including resolving
disputes or troubleshooting problems.

2.2. We endeavor only to capture information that is necessary to provide our Services to you in
compliance with our legal and regulatory obligations.


3.1. Kinesis may collect and process your information because:

3.1.1. we have a contract with you;

3.1.2. you have given us permission to do so;

3.1.3. you have applied for a Service from us; or

3.1.4. to comply with the law


4.1. The information that we collect and store relating to you is primarily used to enable us to provide
our Services to you. In addition, we may use the information for the following purposes:

4.1.1. to provide you with information requested from us, relating to our Services and to
provide information on other Services which may be of interest to you, where you have
consented to receive such information;

4.1.2. to improve our Website and our Services;

4.1.3. to verify your status and confirm any information you have provided to us;

4.1.4. to distribute Kinesis Tokens to you;

4.1.5. to verify compliance with the terms and conditions in relation to the use of our Services;

4.1.6. to compare the personal data provided with third party databases in order to verify its
accuracy and confirm your identity to comply with relevant regulations that apply to our

4.1.7. to meet our regulatory, legal and compliance obligations in meeting our obligations to
you; or

4.1.8. to notify you about any changes to our Website or improvements and changes to our

4.2. We will only contact you when you have provided consent and only by those means you have
provided consent for.


5.1. We may disclose your personal data:

5.1.1. to a third party, if we are under a duty to disclose or share your personal data with them
in order to comply with any legal obligation, or in order to enforce or apply our terms
and conditions and other agreements, or to protect the rights, property, reputation,
security and safety of our Website, applicants for Kinesis Tokens or others including
exchanging information with or providing information to third parties; or

5.1.2. to any law enforcement or revenue authorities (when requested by them to do so) but
only to the extent necessary to adequately deal with the requests made.

5.2. We may retain the services of a third party for the purposes of obtaining or engaging their external
expertise. In such circumstances we may permit access to certain aspects of any applicant’s
personal information or your information, but only once they have agreed to treat such personal
information with the strictest levels of security and confidentiality.


6.1. At any time, you can make a written request to us to have access to all the personal information
that we hold about you.

6.2. You may inform us of any changes in your personal information or data in accordance with our
obligations to you by accessing our Website and communicating with us directly. It is your
responsibility to contact us when information that you have provided to us is out of date or
requires amendment.

6.3. We will confirm with you any amendments, updates or deletions of our personal data that you
make in your request.


7.1. On occasion we may gather information about your computer or the personal device that you
access the Website on to facilitate usage of our Services and to provide statistical information
regarding the use of our Website.

7.2. Such information will not contain personally identifiable data and will solely be used by us for
statistical purposes about our visitors and their use of our Website.

7.3. We may gather information about your general internet use by using a cookie file. These cookies
are downloaded to your computer or personal device automatically and stored on the hard drive
of your computer or personal device. It contains information that assists us in improving our
Website and the Services we provide to you.

7.4. All computers and personal devices have the ability to decline use of cookies. This can be done
by activating the appropriate setting in your browser. However if you choose to decline cookies,
you may be unable to access particular parts of our Website.


8.1. Data that is provided to us is stored on secured servers managed, controlled or exclusively
accessed by us. Details relating to any transactions entered on our Website will be encrypted to
ensure its safety.

8.2. We may store and process your information using cloud services in various jurisdictions. The
information we collect from you may also be transferred to or stored in jurisdictions outside of
your country of residence. The laws and regulations processing such information in these
locations may differ than in your country. It may also be processed by a party operating outside
of your country including a third-party service provider or business partner. By submitting your
information, you agree to this transfer, storing or processing of personal data. We will take all
steps reasonably necessary to ensure that your information is treated securely and in accordance
with this policy.

8.3. The transmission of information via the internet is not completely secure and therefore we cannot
guarantee the security of data sent to us electronically and transmission of such data is entirely
at your risk.

8.4. Where we have given you a password (or where you have chosen a password) to access certain
parts of our Website or usage of our Services, you are responsible for keeping this password

8.5. We take all appropriate security measures in line with market driven best practice to protect your
personal information.


9.1. Kinesis will not retain your personal information for longer than it is required.

9.2. We will keep your personal information:

9.2.1. for as long as required by law;

9.2.2. until we no longer have a valid reason for retaining it; or

9.2.3. until you request us to stop using it.

9.3. We may keep a sufficient amount of personal information from you to ensure that we comply with
your requests not to use your personal information or comply with your right to erasure. For
example, we must keep your request to be erased even if it includes your personal data until
such time as you are no longer our customer.


10.1. Below are the rights that you may have under law, and what Kinesis does to protect those rights:

Legal rightWhat Kinesis does to protect your rights
The right to be informedKinesis is publishing this Privacy Notice to keep you informed
as to what we do with your personal information. We strive to be
transparent about how we use your data.

In addition, if there is a data breach that includes your personal
information that results in a risk for your rights and freedomsas
an individual we will notify you within 72 hours of firstbecoming
aware of the breach.

The right to accessYou have the right to access your information. Please contact
us at if you wish to access the personal
information Kinesis holds about you.
The right to rectificationIf the information Kinesis holds about you is inaccurate or not
complete, you have the right to ask us to rectify it. If that data
has been passed to a third party with your consent or for legal
reasons, then we must also ask them to rectify the data. Please
contact us you need us to rectify your information:
The right to erasureThis is commonly known as ‘the right to be forgotten’. If you want
Kinesis to erase all your personal data and we do not have a
legal reason to continue to process and hold it, please contact
The right to restrict
You have the right to ask Kinesis to restrict how we process your
data. This means We are permitted to store the data but not
further process it. We keep just enough data to make sure we
respect your request in the future. If you want us to restrict
processing of your data, please contact us:
The right to data portabilityKinesis must allow you to obtain and reuse your personal data
for your own purposes across services in a safe and secure way
without this effecting the usability of your data. Please contact
us if you want information how to port your data elsewhere: This right only applies to personal data
that you have provided to us where we have determined the
purposes and means of processing your personal data. The
data must be held by us by consent or for the performance of a
The right to objectYou have the right to object to Kinesis processing your data
even if it is based on our legitimate interests, the exercise of
official authority, direct marketing (including data aggregation),
and processing for the purposeless of statistics. If you wish to
object please contact us:
The right to withdraw consentIf you have given us your consent to process your data but
change your mind later, you have the right to withdraw your
consent at any time, and Kinesis must stop processing your
data. If you want to withdraw your consent, please contact us:
The right to complain to a Supervisory AuthorityYou have the right to complain to the Information
Commissioner’s Office if you feel that Kinesis has not
responded to your requests to solve a problem. You can find
their contact details here:


11.1. You may find links to third party website on our Website. These websites may have their own
privacy policies which you should review.

11.2. We do not accept any responsibility or liability for their policies as we do not have control over


12.1. We welcome any queries, comments or request you may have regarding this Privacy Policy. Any
request by you must comply with the terms of this Privacy Policy.

12.2. Please direct any correspondence to us relating to our Privacy Policy to our Data Protection
Officer at


This document does not constitute legal advice and should not be relied on by any person. It is
designed for general information purposes only. Visitors to our Website should consult their own