Cayman Privacy Notice
This privacy notice (Cayman Privacy Notice) explains the manner in which KANJI CAPITAL GROUP G.C. LLC (“Kanji LLC”) collects, processes and maintains personal data about you pursuant to the Data Protection Act (2021 Revision) (the “DPA“) of the Cayman Islands, as amended from time to time and any regulations, codes of practice or orders promulgated pursuant thereto (DPA). Kanji LLC is committed to processing personal data in accordance with the DPA. In its use of personal data, Kanji LLC will be characterized under the DPA as a ‘data controller’, whilst certain of the Site’s service providers, affiliates and delegates may act as ‘data processors’ under the DPA. Interpretation For the purpose of this Cayman Privacy Notice you or your shall mean, you, the User of the Kanji LLC website (the “Site”) or potential User of the same and shall also include any individual connected to you which could include: any person owning or controlling the User, having a beneficial interest in the User, any person for whom the User is acting as agent or nominee, any trustee, settlor or protector of a trust, and the directors, managers, members, officers and employees of all such persons. We us or our means Kanji LLC acting in its capacity as data controller of the personal data.
Personal data By virtue of registering on the SIte, Kanji LLC and their respective affiliates and delegates (Authorised Entities) may collect, record, store, transfer and otherwise process personal data by which individuals may be directly or indirectly identified. Much of the personal data will be provided through completion of forms, questionnaires and other information provided by you in writing (including any anti-money laundering, identification, and verification documentation), in person, by telephone (which may be recorded), fax, electronically or by any other means.
We may combine personal data that you provide to us with personal data that we collect from, or about you. This may include personal data collected in an online or offline context including from credit reference agencies and other available public databases or data sources, such as news outlets, websites and other media sources and international sanctions lists.
If you are a nominee investor or a corporate entity, this Cayman Privacy Notice will be relevant for those individuals connected to you and you should transmit this document to such individuals for their awareness and consideration.
A. where the processing is necessary for the Site to perform a contract to which you are a party or for taking pre-contractual steps at your request, which may include the following circumstances:
to operate the Site, including managing and administering the Site on an on-going basis which enables the Site to satisfy their contractual duties and obligations;
to facilitate the continuation or termination of the contractual relationship between you, other investors and the Site; and/or
to administer and facilitate transactions between you and Kanji LLC
B. where the processing is necessary for compliance with any legal, tax or regulatory obligation to which the Site is subject, which may include the following circumstances:
to undertake due diligence and on-boarding checks;
to carry out know-your-client, client due diligence, anti-money laundering, counter-terrorist financing and proliferation financing checks of investors (and where applicable, their controllers and beneficial owners);
to comply with requests from regulatory, governmental, tax and law enforcement authorities;
to prevent and detect fraud;
surveillance and investigation activities;
to carry out audit checks and to instruct auditors;
to comply with FATCA, CRS and other comparable legislation;
to comply with applicable sanctions and embargo legislation; and/or
to maintain statutory registers;
C. where the processing is for the purposes of legitimate interests pursued by the Site or by an Authorised Entity to whom the data are disclosed, which may include the following circumstances:
to comply with a legal, tax, accounting or regulatory obligation to which the Site or such Authorised Entity is subject;
to assess and process requests you make;
to send updates, information and notices or otherwise corresponding with you in connection with your usage of the Site;
to verify the identity of the Site to third parties in connection with any actual or proposed transactions and/or for any purpose which the Site considers is necessary or desirable;
to assist the Site in the improvement and optimisation of our services, advertising and marketing;
to investigate any complaints, or pursue or defend any claims proceedings or disputes (where domestic or foreign);
to provide you with, and inform you about, our products and services;
for risk management and risk controlling purposes relating to the Site;
to ensure internal compliance with our policies and procedures;
to seek professional advice, including legal advice;
to facilitate business asset transactions involving Kanji LLC or related entities;
to monitor communications to/ from us (where permitted by law);
to protect the securities and integrity of our IT systems;
for direct marketing purposes;
to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity, and share this data with legal, compliance, risk and managerial staff to assess suspicious activities, and against fraud, breach of confidence or theft of proprietary materials; and/or
D. where you otherwise consent to the processing of personal data
for any other specific purpose. As a data controller, we will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will contact you. Automated decision-making: We do not envisage that any decisions will be taken about you using fully automated means, however we will notify you in writing if this position changes.
Disclosure of personal data: We anticipate that we will share your personal data with the Authorised Entities for the purposes set out in this Cayman Privacy Notice as well as advisers (e.g. auditors, legal counsel and tax advisers) to the Site relating to or in connection with subscriptions to the Site. We may also share relevant personal data where it is lawful to do so and necessary to comply with our contractual obligations or your instructions or where it is necessary or desirable to do so in connection with any regulatory reporting obligations. In exceptional circumstances, we will share your personal data with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened), in any country or territory including to any other person where we have a public or legal duty to do so (e.g. to assist with detecting and preventing fraud, tax evasion and financial crime or compliance with a court order). At times, it may also be necessary to share relevant personal data with (i) a prospective service provider of the Site including one which is replacing an existing service provider or (ii) to people or companies where required in connection with a potential or actual corporate restructuring, merger, acquisition or takeover of the Site.
We will not sell your personal data without removing any and all personal identifying information prior to sale. Any transfer of personal data outside of the Cayman Islands shall be in accordance with the requirements of the DPA. Where necessary, we will ensure that separate and appropriate legal agreements are put in place with the recipient of that data. For example, where data is to be transferred to a person in a country which does not provide an adequate level of data protection, the Site will ensure it puts in place appropriate safeguards, such as contracts which seek to ensure that any data processor is contractually bound to provide an adequate level of protection in respect of the personal data transferred to it and that any such transfer complies with the requirements of the DPA.
Your rights: You have certain rights under the DPA, including:
the right to be informed as to how we collect and use your personal data;
the right to obtain a copy of your personal data;
the right to require us to stop direct marketing;
the right to have inaccurate or incomplete personal data corrected;
the right to withdraw your consent and require us to stop processing or restrict the processing, or not begin the processing of your personal data;
the right to be notified of a data breach (unless the breach is unlikely to be prejudicial);
the right to obtain information as to any countries or territories outside the Cayman Islands to which we, whether directly or indirectly, transfer, intend to transfer or wish to transfer your personal data, general measures we take to ensure the security of personal data and any information available to us as to the source of your personal data;
the right to complain to the Office of the Ombudsman of the Cayman Islands. You can access their website here:
; and
the right to require us to delete your personal data in some limited circumstances.
Please note that if you do not wish to provide us with requested personal data or subsequently withdraw your consent, you may not be able to use the Site as it will affect our ability to provide our services to you.
Retention of Personal Data: The personal data shall not be held by the Site for longer than necessary with regard to the purposes of the data processing.
Changes to Cayman Privacy Notice: We encourage you to regularly review this and any updated Cayman Privacy Notice to ensure that you are always aware of how personal data is collected, used, stored and disclosed. This Cayman Privacy Notice may be updated at any time without notice.
Contact us: Please contact Kanji LLC using the Site if you have any questions about this Cayman Privacy Notice, the personal data we hold about you or to discuss your data protection rights.
