Last modified: May 31, 2023 

Introduction 

Kinikin, LLC (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. 

This policy describes the types of information we may collect from you or that you may provide when you visit the website kompasskapital.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information. 

This policy applies to information we collect: 

• On this Website. 
• In email, text, and other electronic messages between you and this Website. 

It does not apply to information collected by: 

• Us offline or through any other means, including on any other website operated by Company or any third party; or 
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

Children Under the Age of 18 

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us you can contact us at the Contact Information section in this Website Privacy Policy. 

Information We Collect About You and How We Collect It 

We collect several types of information from and about users of our Website, including information: 

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information“); 
• That is about you but individually does not identify you; and/or 

• About your internet connection, the equipment you use to access our Website, and usage details. 

We collect this information: 

• Directly from you when you provide it to us. 
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. 

Information You Provide to Us.   

The information we collect on or through our Website may include: 

• Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services. We may also ask you for information when you report a problem with our Website. 
• Records and copies of your correspondence (including email addresses) if you contact us. 

Information We Collect Through Automatic Data Collection Technologies. 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: 

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. 
• Information about your computer and internet connection, including your IP address, operating system, and browser type. 

The information we collect automatically may include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: 

• Estimate our audience size and usage patterns. 
• Store information about your preferences, allowing us to customize our Website according to your individual interests. 

• Speed up your searches. 
• Recognize you when you return to our Website. 

The technologies we use for this automatic data collection may include: 

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 

• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

Third-Party Use of Cookies and Other Tracking Technologies 

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

How We Use Your Information 

We use information that we collect about you or that you provide to us, including any personal information: 

• To present our Website and its contents to you. 
• To provide you with information, products, or services that you request from us. 
• To fulfill any other purpose for which you provide it. 
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. 

• To notify you about changes to our Website or any products or services we offer or provide though it. 
• In any other way we may describe when you provide the information. 
• For any other purpose with your consent. 

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please do not fill out our contact form.  

Disclosure of Your Information 

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 

We may disclose personal information that we collect or you provide as described in this privacy policy: 

• To our subsidiaries and affiliates. 
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. 
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred. 

• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.  
• To fulfill the purpose for which you provide it. 
• For any other purpose disclosed by us when you provide the information. 
• With your consent. 

We may also disclose your personal information: 

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request. 
•  and other agreements, including for billing and collection purposes. 
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. 

Choices About How We Use and Disclose Your Information 

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:  

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website. 

Changes to Our Privacy Policy 

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. 

Contact Information 

To ask questions or comment about this privacy policy and our privacy practices, contact us at: 

1032 6450 Rd 
Montrose, CO 

970-240-4329 

CALIFORNIA & OTHER STATES RIGHTS SUPPLEMENT  

Last Updated: 5/31/2023 

Some US states, such as California, Virginia, Colorado, Connecticut, Utah, Iowa, Indiana, Tennessee, Texas, Montana, Florida, and others require us to inform their residents about additional privacy information and rights. This supplement (“US State Supplement”) to our Privacy Policy provides this additional privacy information and explains those additional US state rights. This US State Supplement applies to our online and offline practices.  

Categories of Personal Information We Collect and Share 

Here are the categories of personal information that we may collect and process: 

• Identifiers – such as name, phone number, postal address, zip code, email address, account name or number, or other similar identifiers 
• Legally Protected Characteristics – such as age or gender 
• Unique and other online identifiers – such as IP address, device IDs, or other similar identifiers that relate to your device and its operating system 
• Customer records and other commercial information – such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies 

• Internet or other electronic network activity information – such as browsing history, search history, and information regarding your interactions with our websites, a “Site” or collectively, the “Sites”)  
• Geolocation information – such as your device’s general location  
• Inferences or audience segmentation – such as individual profiles, preferences, characteristics, and behaviors 

We may collect, share, sell, or otherwise process these categories of personal information, including Sensitive Personal Information, for the following business or commercial purposes: 

• Providing products or services you request and performing services on behalf of the business, such as customer service, processing or fulfilling orders, providing content recommendations, and processing payments  

• Maintaining or servicing accounts 
• Auditing customer transactions and other internal risk management or compliance purposes  
• Prevention of fraud, crime, and other harms, providing security, and protecting the integrity of our Sites, products, or business  
• Debugging or repairing or debugging systems or Sites, including to deliver intended functionality  
• Marketing and advertising, including targeted advertising  

• Internal research, analytics and development – e.g., user-preference analytics 
• Developing, maintaining, provisioning or upgrading networks, products, services, or devices 

We may obtain personal information from a variety of sources, including: 

• Directly from you – such as information you provide when you register or sign-up for our Sites or services and technical and usage information when you use our or our affiliates’ Sites or services 
• Our joint ventures and promotional and strategic partners 

• Information suppliers and other unaffiliated third parties, such as linked sites, third-party platforms, Social Media Sites and marketing mailing lists  
• Distributors and other vendors 
• Other users who submit information about you – such as to invite you to participate in an offering, make recommendations, or share content 
• Publicly available sources 

Retention of personal information:  

We retain personal information only for so long as reasonably needed to fulfill the purposes for which we collected or obtained it. We use reasonable business criteria to establish retention periods for personal information. For example, if you register on our Sites, we will store your personal information for as long as needed to maintain your account, fulfill your requests, enforce any applicable terms that govern your use of the Sites, maintain appropriate records of the above, or as otherwise required by law. 

Disclosures of personal information, including sales or sharing of personal information to third parties 

We may disclose, for a business purpose, the following categories of personal information to third parties: 

• Identifiers  
• Characteristics of protected classifications  

• Unique and other online identifiers  
• Customer records and commercial information  
• Internet or other electronic network activity information  
• Biometric information 
• Audio, electronic, visual, thermal, olfactory, or similar information  

• Geolocation data   
• Government identifiers 
• Health information 
• Inferences or audience segmentation 
• Sensitive Personal Information 

We may disclose, for a business purpose, each of those categories of personal information to the following categories of third parties: 

• Affiliates – These entities are associated with us through common ownership   
• Service Providers – These entities process information on our behalf for business purposes, helping us provide products or services to you 
• Social Media Platforms – These entities maintain networks connecting individuals and organizations – such as Facebook, LinkedIn, or Twitter 
• Advertising Partners – These entities help us advertise our products or services , as well as connect us with others who want to place advertisements on some of our products or services 

• Analytics Partners – These entities help us collect data on how our products or services are used, so that we can improve them and better understand our consumers 
• Promotional Partners – We partner with these entities to jointly promote our products, for example by running sweepstakes, contests or other promotional campaigns 
• Government Entities – These entities include law enforcement authorities, regulatory agencies, and courts 

Categories of personal information shared with or sold to third parties 

We do not disclose personal information to third parties in exchange for monetary consideration (e.g., cash payment). However, as an example, California law, defines ‘sale’ very broadly. It includes the disclosure of personal information in exchange for anything of value. California law also defines “sharing” to mean disclosure of personal information for targeted advertising. 

In the year before this section was last updated, we do not believe we have sold or shared personal information to third parties for targeted advertising according to above definitions. 

How We Keep Your Personal Information Secure 

We implement and maintain reasonable security measures appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process.  Those measures include administrative, physical and technical safeguards, although such safeguards may not always be adequate to prevent all breaches of security. 

Data Minimization 

We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary in connection with the purposes set out in this Policy. 

YOUR STATE SPECIFIC RIGHTS 

This section describes some of the state-specific privacy rights that are available to residents of the states that were mentioned at the beginning of this US State Supplement. When you make a request, we may provide more detailed information regarding whether your request is subject to applicable law, and whether any exception or limitation applies.  

YOUR RIGHT TO ASK US TO DELETE YOUR PERSONAL INFORMATION 

Upon your request, we will delete the personal information we have collected about you, subject to certain legally permissible exceptions.  

To make a request, please contact at the Contact Information section on the main Website Privacy Policy. 

YOUR RIGHT TO ASK US TO ACCESS YOUR PERSONAL INFORMATION 

You have the right to ask us to confirm that we process your personal information, or to ask us for a copy of the specific personal information we have collected about you.  

To make a request, please use the contact information found at the Contact Information section on the main Website Privacy Policy. 

In addition, if you are a California resident, you have the right to request certain information about our practices in the prior 12 months with respect to personal information. In particular, you can request the following: 

• The categories of personal information that we’ve collected 

• The categories of sources from which we collected personal information 
• The business or commercial purposes for which we collected or sold personal information 

You can submit a request to us for the following additional information: 

• The categories of third parties to which we’ve shared or sold personal information, and the category or categories of personal information shared or sold to each 
• The categories of third parties to which we’ve disclosed personal information, and the category or categories of personal information disclosed to each 

YOUR RIGHT TO ASK US NOT TO SELL OR SHARE YOUR PERSONAL INFORMATION  

You can tell us not to sell or share (defined by California law and others to mean that we have disclosed personal information to a third party in exchange for anything of value or for targeted online advertising based on your activities over time across other websites and applications), your personal information according to applicable law, by contacting us at the contact information found at the Contact Information section on the main Website Privacy Policy. 

This option is limited to residents whose laws provide for such option.  

California has specific rules regarding the use of California information from consumers under 16 years of age.  In particular, if we knowingly collect the California Information of a consumer under the age of 16, we will not share or sell the information unless we receive affirmative permission to do so.  If the consumer is between the ages of 13 and 16 years of age, the consumer may provide that permission; if the consumer is under the age of 13, the consumer’s parent or guardian must provide the permission. 

YOUR RIGHT TO LIMIT OUR USE OF YOUR PERSONAL INFORMATION FOR TARGETED ADVERTISING 

You can ask us not to use your personal information for targeted online advertising, which means we will not use personal information collected by third parties from your activities over time across websites and applications we do not operate to present ads that we think will interest you. Even if you opt out of targeted ads, we will continue to collect and use data for purposes that are not related to targeted advertising, including research, analytics, and internal operations, and to serve you ads based on information we gain from your direct engagement with our content and products. To opt-out of targeted advertising, please use the contact information found at the Contact Information section on the main Website Privacy Policy. 

YOUR RIGHT TO ASK US TO CORRECT YOUR PERSONAL INFORMATION 

You can ask us to correct information about you that is inaccurate. We will take into account the nature of the personal information, where we obtained the personal information, and the purposes of our processing when we address your request. We may deny your request to correct if we determine that these circumstances make it more likely than not that the personal information we have is accurate.  

If would like to correct information that you believe is inaccurate, please use the contact information found at the Contact Information section on the main Website Privacy Policy. 

YOUR RIGHT TO LIMIT OUR USE OF YOUR SENSITIVE PERSONAL INFORMATION 

We may use Sensitive Personal Information about you for the business or commercial purposes described above.  Subject to a few exceptions, you may limit our use of this Sensitive Personal Information to only uses that are reasonably necessary to perform services or provide goods. Depending on your state, you may have the right to limit our processing of certain Sensitive Personal Information (or to withdraw consent for such processing if you previously gave it). 

YOUR RIGHT TO LIMIT OUR USE OF YOUR PERSONAL INFORMATION FOR PROFILING/AUTOMATED PROCESSING 

Under applicable law, you may have the right to opt-out of certain automated processing performed on personal information to evaluate, analyze, or predict personal aspects of a person’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. At this point we are not aware of any such processing that could produce legal or similarly significant effects concerning you. However, if you have questions or concerns, please contact use the contact information found at the Contact Information section on the main Website Privacy Policy. 

HOW TO EXERCISE YOUR STATE SPECIFIC RIGHTS 

You may exercise any of the rights described in this US State Supplement, by visiting our use the contact information found at the Contact Information section on the main Website Privacy Policy. When you submit a request, we will usually ask you to provide an email address which we will contact to confirm the request was not fraudulently submitted. 

If you are the parent or guardian of a minor child, you may also submit a request on behalf of your child.  In that event, we will ask you to provide your child’s email address and to submit a signed form authorizing us to proceed with the request regarding your child’s personal information. 

You may also designate an authorized agent to submit a request on your behalf.  Depending on the nature of the request, we may authenticate the request, such as by requiring a signed written permission from you that authorizes the agent to act on your behalf. A valid power of attorney will constitute signed written permission, but you are not required to obtain a power of attorney to use an authorized agent.   

YOUR RIGHT TO APPEAL 

In certain situations, if we deny/cannot fulfill your request, you may appeal the denial by contacting us use the contact information found at the Contact Information section on the main Website Privacy Policy to ask us to review your request again.  

OUR SUPPORT FOR THE EXERCISE OF YOUR DATA RIGHTS 

We are committed to providing you control over your personal information. You have the right not to receive discriminatory treatment if you exercise any of the rights explained in this US State Supplement of the Privacy Policy.  

YOUR CALIFORNIA PRIVACY RIGHTS TO REQUEST INFORMATION ABOUT OUR PRACTICES WITH RESPECT TO PERSONAL INFORMATION WE COLLECT AND SHARE ABOUT YOU 

California Consumers under 18 Years Old  

As of the most recent date of this State Supplement, we do not have actual knowledge that we share or sell personal information of consumers under 18 years of age. 

California Consumers Under 18 Years Old 

California Consumers who are registered users of the Sites and under 18 years of age may request removal of content or information they posted on the Sites. We will remove such content or information when we are required to do so by law. To request removal of content or information you posted on the Sites, you may contact us at the contact information found at the Contact Information section on the main Website Privacy Policy. 

NOTIFICATION REGARDING UPDATES 

From time to time, we may update this US State Supplement. We will notify you about any material changes by placing a notice on our sites. We encourage you to periodically check back and review this Supplement so that you are up to date. 

HOW TO CONTACT US 

If you have any questions about this US State Supplement, you can contact us at the Contact Information section on the main Website Privacy Policy.