Kingston Capital Privacy Notice

Last Updated: September 29, 2023

This Privacy Notice describes how we collect and use information about you when you use our website (kingstoncapital.com) (our “Website”), applications, services, tools and features, or otherwise interact with us (collectively, the “Services”).

We are a limited liability company established in the United States with our full name Kingston Infrastructure Partners, LLC a registered office at c/o The Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware 19801 and registered company number 7196052, and in the UK, our representative office is at 50 Sloane Ave, London SW3 3HW, UK. We are the data controller for the processing of your information.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.

Our Services are not intended for children, and we do not seek or knowingly collect information relating to children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

1. CHANGES TO THIS PRIVACY notice

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. We will indicate on our Website when our Privacy Notice has been updated, including by updating the date of this Privacy Notice. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not access or continue to use the Services.

2. Collection of your information

When you use or access the Services, we collect certain categories of information about you from a variety of sources.

Information You Provide to Us

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. You may provide some or all of the following information to us when you contact us via email:

• Applicant details, such as information included in your resume, CV or cover letter, references, and job history.
• Any other information you choose to include in communications with us, for example, when sending us an email

3. USE OF YOUR INFORMATION

We may use your information to:

• Communicate with you and be responsive to your requests.
• Provide the Services to you and to maintain our business relationship.
• Evaluate your candidacy and process your application for employment.
• Administer the Website and Services, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis.
• Maintain the safety and security of our users, the Website, our Services and business.
• Send you announcements in relation to security, privacy or administrative related communications.
• Personalize our Website and Services to ensure content is presented in the most effective manner for you and your device.

In addition, we will use some or all of the above information to comply with legal obligations (including compliance with employment legislation if you apply for a job with us), to enforce our contractual arrangements and our policies, and to protect or defend the Services, our rights, the rights of our users, or others.

4. DISCLOSURE OF YOUR INFORMATION

We disclose your information with third parties in certain circumstances, subject to this Privacy Notice, including:

• With service providers and vendors (including website hosting vendors, data analytics vendors and security vendors) that assist us to provide our Website and Services to you.
• With professional advisors (including auditors, law firms or accounting firms) in our legitimate interests or as required by law.
• For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law. We will share your information with regulators, law enforcement agencies, public authorities, or any other relevant organizations: to comply with applicable law or obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; to exercise or defend legal claims; and to enforce our terms and conditions or other agreements.
• With our affiliates or otherwise within our corporate group, in our legitimate interests.
• When you request us to share certain information with third parties (including through your use of social media widgets) with your consent or to perform a contract with you.
• With a prospective buyer, seller, new owner, or other relevant third party in connection with or anticipation of an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation (including while negotiating or in relation to a change of corporate control), in our legitimate interests.

5. WHERE WE STORE YOUR INFORMATION

The information that we collect from you will be accessed from, transferred to, and stored and used in countries outside the country in which you are located, by us and by our third party service providers or partners. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Notice.
Transfers of data outside the EEA or the UK will be governed by the European Commission’s standard contractual clauses for the transfer of personal data to third countries (specifically, module one (controller to controller transfer), as relevant) or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their information (including transfers to the United States). Please contact us at Privacy@kingstoncapital.com should you wish to examine a copy of the EU standard contractual clauses or UK international data transfer addendum.

6. DATA SECURITY

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

7. RETENTION OF YOUR INFORMATION

We will retain and use your information for periods of time to the extent necessary based on our consideration of various criteria, including the evaluation of your application for employment, whether we need the information to continue providing you the Services, comply with our legal obligations, resolve disputes, enforce our contractual agreements and our policies, prevent harm, promote safety, security and integrity, and to protect or defend the Services, our rights, the rights of our users, or others.

8. USER RIGHTS

Depending on where you live, you may have certain rights in relation to your personal data:

• Access. You have the right to request access to the information we hold about you, how we use it, and who we share it with.
• Portability. You have the right to request to receive a copy of certain information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Correction. You have the right to request to correct your information we hold that is inaccurate.
• Erasure. You have the right to request deletion of the information we hold about you.
• Restriction of processing to storage only. You have the right to request that we stop processing the information we hold about you, other than for storage purposes.
• Objection. You have the right to object to our processing of your information.

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, if fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, if there are overriding public interests or if we are required by law to retain your information.
To exercise any of these rights, you can contact Privacy@kingstoncapital.com.
If you are located in the EEA or UK and you think we have infringed data protection laws, you have the right to lodge a complaint with the data protection supervisory authority in the EEA country in which you are based or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you.

9. HOW TO CONTACT US

We welcome your questions and feedback about our privacy practices and this Privacy Notice. You can contact us at Privacy@kingstoncapital.com, including if you have complaints about how we process your information.

10. LANGUAGE

Except as otherwise prescribed by applicable law, in the event of any inconsistency between the English language version and local language version of this Privacy Notice, the English language version will prevail.