knnct Privacy Policy

Last Updated: January 15, 2023

This Privacy Policy (“Policy”) is incorporated by reference into, and considered a part of, the knnct Terms and Conditions (“Terms and Conditions”). The term “knnct,” “knnct App,” “knnct Platform”, “knnct.com Platform”, “we,” and “us” includes knnct Markets Corp., a Canadian corporation, and our partners, affiliates, subsidiaries and 3rd party contractors and service providers. This Privacy Policy discloses how knnct, knnct Platform, knnct.com Platform or knnct App collects, uses and shares information about you, when you use our website, knnct App, knnct Platform and any other online products and services (collectively, the “Services“) or when you otherwise interact with us.  A Member of the knnct Platform is hereinafter referred to in this Privacy Policy as a “User,” or collectively, the “Users”. In this Privacy Policy, “you” and “your” refer to an individual User of the knnct Platform whether through a website or through the knnct App. All other terms not defined herein will have the meanings set forth in the Terms and Conditions.

We may change this Policy from time to time. If we make changes to this Policy, we will notify you by revising the date at the top of the Policy. If we make material changes, we may provide you with additional notice (such as by adding a statement to the Services or sending you a notification). We encourage you to review this Policy regularly to stay informed about our information practices and the choices available to you.

INTRODUCTION.

knnct respects and upholds individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of your personal information.

“Personal Information” means information about an identifiable individual, including, for example, an individual’s name, address, telephone number(s), whether you are acting as a Broker and/or Lender, license to operate as a Broker or Lender including the Broker or Lender’s registration or license number, Broker’s or Lender’s email address and business name and address, that alone or when in combination with other information may be used to readily identify, contact, or locate you. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third-party to easily identify a specific individual.

COLLECTION AND USE OF PERSONAL AND NON-PERSONAL INFORMATION.

We collect information, including Personal Information, when you:

• Register or log in to use the Service;
• Log in with social networking credentials (if available);
• Use the Service and communicate with us.

When you visit knnct Platform, you provide us with two types of information: personal information you knowingly choose to disclose that is collected by us and non-personal information collected by us as you interact with our Services.

The types of information we collect depend on the nature of your interaction with us:

Personal Information Generally.

We may collect personal information such as:

• Account Information: To create an account with knnct, you may be required to provide some information about yourself, including but not limited to your email address, your license or registration number (if applicable), name, whether you are a Broker and/or a Lender, business name, address, telephone number, password, and other information. You will be providing this information directly to us.
• Other Information: You may provide other information directly to us. For example, we collect information when you fill out a form or mortgage application, fill in your lending criteria, fill in a the information regarding mortgages for sale, filter results of Mortgage Deals or Mortgage Assets, complete a survey or review, participate in a contest or promotion, communicate with us via third-party social media sites, request customer support or otherwise communicate with us. Providing this information is voluntary and not required to use the Services.

You may choose not to provide us with your Personal Information. However, if you make this choice, we may not be able to provide you with the Service, or information that you requested. For example, we require your email address in order to verify your account, which is necessary so that notifications may be sent to you electronically. In addition, we require your license number to verify that you are authorized to operate as either Lender and/or Broker and to confirm your entitlement to use the knnct Platform and Services.  Should you no longer wish to receive notifications from knnct when you receive a message from another knnct Member, you may notify knnct by email that you wish to opt out of receiving these types of messages or turn these notifications off through the Application Settings. knnct will not send you notifications after your account is deleted.

The categories of personal information we collect and the sources from which we collect it depend on your interactions with us and are described in more detail below.

PERSONAL INFORMATION YOU PROVIDE DIRECTLY TO US

We collect personal information directly from you, including when you engage in any of the activities listed below:

• Post a mortgage deal, review a mortgage deal or make an offer to a broker subscriber using knnct or the Services;
• Inquire about our products or services;
• Contact us to request assistance or provide feedback, including correspondence with customer services;
• Create an online account and profile;
• Subscribe to receive our emails;
• Enter a contest or sweepstakes;
• Submit a company or product review;
• Participate in a marketing survey, promotion, or event; and
• Interact with us on social media, including by posting content and tagging us.

The types of personal information we collect directly from you may include your name, email address, postal address, phone number, name of the brokerage or lender that you work for, birthday, marketing preferences, product preferences, lending criteria, account information (such as account password and promo award cards), information provided in your company or product reviews (such as user name, photos, city, state or province, country and zip or postal code), and any other information you choose to provide.

If you are obligated to make a payment to us, we work with a third-party payment processor to collect and process your payment information.

PERSONAL INFORMATION WE COLLECT AUTOMATICALLY

We automatically collect personal information when you access and use our Services, or shop in our stores, or dine in our restaurants, including:

• Device and Usage Information: We collect information about how you access and use our Services, including device information, such as your browser type, hardware model, operating system version, IP address, unique device identifiers, and language settings. We also collect information about your activity on our Services, such as items placed in your shopping cart, your access times, pages viewed, the routes by which you access our Services, and your use of any hyperlinks available within our Services.
• Transaction Information: When you make a purchase of a service or services, we collect information about your transaction, including services you purchased, or are considering purchasing from us, the transaction price, and the date and location of the transaction.
• Information collected via cookies, web beacons, and other tracking technologies: We (and those that perform work for us) use cookies, web beacons, and other tracking technologies to collect information about your browsing behavior, deal posting or loan offer behavior, purchase behavior, and other engagement with our Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. See the “Targeted Advertising and Analytics” and “Your Privacy Rights and Choices” sections below for further information).
• Video, Images, and Audio: We collect video recordings and photographs in our stores for security, fraud, and loss prevention purposes, and we may record calls you place to customer service.

PERSONAL INFORMATION WE COLLECT FROM OTHER SOURCES

We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you (or Mortgage Deal owners or the consummation of Mortgage Asset transactions) from third parties, including but not limited to identity or license verification services, mailing list providers and publicly available sources.

We also combine data and information we collect from other users with information (including publicly sourced data and information) we have collected about you. For example, if another user imports his or her address book or contacts from another site or service, we may merge that information with information we have collected about you.

For example, we may collect personal information about you from:

• Other companies when we offer joint promotions and marketing campaigns;
• Other customers who provide information about you, such as to communications or questions regarding mortgage deals or loans;
• Providers of rewards programs;
• Order processing partners, such as fraud prevention partners or other partners that provide services to subscribers; and
• Marketing and advertising companies, data co-ops and mailing list providers, and market research companies.

The types of personal information we collect from other sources may include name, email address, mailing address, demographic information, product preferences, and product purchases.

PERSONAL INFORMATION WE DERIVE

We may derive information or draw inferences about you based on the information we collect. For example, we may infer your approximate location based on your IP address or that you are interested in certain lending opportunities based on your browsing behavior on our Services.

USE OF PERSONAL INFORMATION

We use the personal information we collect to provide, maintain, and improve our products and services. We also use personal information to:

• Communicate with you about products, services, contests, promotions, and other information offered by knnct and others that we think will interest you, unless you have opted out of such communications (see “Opting Out of Marketing Communications” for more information);
• Administer and fulfill our contests, sweepstakes, and other promotions and deliver rewards;
• Identify, report, and repair errors that impair the functionality of our Services;
• Analyze trends and statistics, learn more about your preferences and your interaction with our Services, and improve your experience in using the knnct app;
• Detect, investigate, and prevent security incidents and protect against malicious, deceptive, fraudulent, or illegal activity;
• Respond to your comments, questions, and requests and provide customer service;
• Personalize and improve the Services and provide content or features that match your profile and interests;
• Target advertisements to you on third-party platforms and websites unless you have opted out (see “Opting Out of Targeted Advertising, Sharing, and Sales” for more information);
• To operate, maintain and make available the knnct Platform and improve our Services.
• To connect Lenders and Brokers to facilitate mortgage transactions either by way of a Lender entering into a mortgage agreement with a Client (or client of a Client) or Lender purchasing or acquiring all or a portion of an existing Mortgage Assets from another Lender.
• To verify that a Lender and/or Broker is properly authorized to act as Lender and/or Broker in the jurisdiction where the Lender and/or Broker is operating or where the mortgage assets are located;
• To develop a deeper understanding and insights as to current and long-term mortgage market trends about Brokers, Lenders and other using the knnct Platform;
• For billing, identification and authentication, and fraud prevention.
• To analyze Services and improve features and functionalities of the knnct Platform, our products and the knnct Platform generally.
• To contact you and deliver administrative and technical notices, updates, security alerts, marketing notifications and offers and communications relevant to your use of our products and Knnct Platform via email, SMS, and push notifications.
• To provide you with customer support.
• For internal market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity.
• To enforce our Terms and Conditions and Service Agreement.
• As required by law or to comply with legal obligations such as law enforcement, courts orders, subpoena, or other situation where the law in a jurisdiction we operate in requires such.
• As otherwise set forth in the Policy; and
• To comply with our legal and financial obligations.

Mortgage Resources. Access to third-party mortgage service providers (and advertising by those third-party mortgage service providers) are a standard part of user experience on the Internet, and knnct believes that targeted advertising relating to the mortgage and real estate sector enhances this experience. knnct also provides a mechanism on the knnct Platform that allows third-party service providers in the Mortgage Deal and mortgage ecosystem to advertise the services that they provide in a specific geographic area and knnct believes that this type of targeted advertising enhances your experience on the knnct Platform.  We may use Cookies and other technologies and Personal Information to place ads where we believe interested parties will see them. In addition to banner ads, we may advertise products, companies and events that we think might interest you through the email address you provide. Your choice regarding third party ads are set forth in the “Opt Out” section below.

Email or Cell Phone Numbers. knnct may use your email or cell phone number to contact you or call or text you in order to provide you notifications about notifications that you have received correspondence from another member about a Posting, tasks, for marketing purposes and to administer the knnct Platform. You can opt out of receiving certain promotional communications from knnct sent via text message at any time by following the instructions provided in text messages from knnct to text the word, “STOP“. Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, knnct may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or knnct’s ongoing business relations.

Financial Information. We use Financial Information solely as authorized by you in accordance with the knnct Platform. To keep your financial data secure, we do not store full credit card information on our servers. We may contract with a third party to process your payment card information.  We also verify as to whether transactions involving Mortgage Assets have been consummated and the value of the Mortgage Assets that have been sold and purchased.

TARGETED ADVERTISING AND ANALYTICS

We engage others to provide analytics services, serve advertisements, and perform related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address and other identifiers, web browser and mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information is used to deliver advertising targeted to your interests on other companies’ sites or mobile apps and to analyze and track data, determine the popularity of certain content, and better understand your online activity. In addition, some of our advertising partners enable us to translate your email address or phone number into an identifier that can’t be used to identify you personally. Our advertising partners then use that unique identifier to show ads that are more relevant to you across the web and in mobile apps. Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under some laws. See “Opting Out of Targeted Advertising, Sharing, and Sales” below to learn how to opt-out of these activities.

You can also learn more about interest-based ads and opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance by visiting www.aboutads.info/choices, or, if you reside in the European Union, by visiting www.youronlinechoices.eu.

DISCLOSURES OF PERSONAL INFORMATION

In certain circumstances, we may disclose the personal information we collect about you. We disclose the categories of personal information described in “Collection of Personal Information” above in the following ways:

• Corporate Affiliates. We may disclose personal information to our holding company, subsidiaries, and corporate affiliates for the purposes described in the “Use of Personal Information” section above.
• Vendors and Service Providers. We make personal information available to our vendors, service providers, and contractors who perform services on our behalf, such as companies that assist us with web hosting, additional relevant financial services, fraud prevention, customer service, surveys, payment processing, analytics, and marketing and advertising.
• For Marketing Purposes. We may share your personal information with third parties for their own marketing purposes or to expand the reach and effectiveness of our own marketing campaigns. Depending on where you live, these activities may constitute “sales” and you may opt out of these disclosures.
• Corporate Transactions. Personal information may be disclosed or transferred as part of, or during negotiations of any purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization, or financing involving knnct.
• Professional Advisors. We disclose personal information to our legal, financial, insurance, and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of knnct’s business or operations.
• Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We may disclose personal information about you, if necessary, in our good faith judgment, to comply with laws or regulations or in response to a valid subpoena, order, or government request, or to protect the rights, property, or safety of knnct or others. In particular, in response to a request for information in legal obligations (including, without limitation, regulators and legislators that govern the mortgage and financial sectors and the parties that operate in those sectors). knnct may disclose Personal Information, including location data, communication data or data analyzing the number of views of a Mortgage Deal or Posting, to a third party if required to do so by law or pursuant to a warrant or subpoena or as otherwise required by any applicable foreign or domestic law, rule or regulation;
• We make personal information available to third parties when we have your consent or you intentionally direct us to do so. For example, if you decide to submit a product review, you direct us to post the personal information you provide publicly.
• With vendors, venues, consultants and other service providers who need access to such information to carry out work on our behalf;
• Third Parties. With third parties such as venues and event planners that we partner with for their own services and marketing purposes;
• Actions Inconsistent. If we believe your actions are inconsistent with our user agreements or policies, or to protect our rights, or the rights of Members, and safety of knnct or others;
• Between Business Affiliates. Between Business Affiliates in specific circumstances. knnct reserves the right to transfer, sell and/or distribute all information collected through Services to an affiliate, subsidiary, or third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or stock. We will use our best efforts to ensure that the new entity follows this Privacy Policy with respect to your Personal Information, as and to the extent required by applicable law.
• With your consent or at your direction.

knnct does not share or sell Personal Information to third party vendors.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. knnct processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

Non-Personal information.

Non-personal information does not identify you as an individual. When you visit and use the Services, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Service may not work properly or as well as it might otherwise.

• We may collect non-personal information such as:
• Usage Information: We collect information about your use of the Services, including Mortgage Deals, Mortgage Assets, Posting, successful transactions and Mortgage Deals and/or Mortgage Assets viewed, Member interactions and other information about your interactions with us, other Members, the Services and other users.
• Device Information: We collect information about the computer or mobile device you use to access our services, which may include the hardware model, operating system and version, browser type and language, IP address, unique device identifiers and mobile network information.
• Location Information: We may collect information about the location of your device each time you post or view a Mortgage Deal or Posting through knnct Platform, access or use one of our mobile applications including the knnct App, or otherwise consent to the collection of this information.
• Non-Specific Mortgage Deal Information: We may collect general information about the Mortgage Deals posted on the knnct Platform relating to location, amount of mortgage loan sought, type of mortgage sought, applicant’s beacon score, loan-to-value percentage and any other data or information or Mortgage Assets posted on the knnct Platform relating to location, number of mortgages to be sold, currency of any proposed transaction, type of mortgages being sold, average beacon score, average loan-to-value percentage and any other data or information that allow us to gain a better understand of the mortgage marketplace (both mortgage origination as well as mortgage sales) operating in the jurisdiction where you operate.
• Non-Specific Lender and Lending Criteria Information: We may collect general information about the Lenders or lending criteria of such Lender using, or accessing Mortgage Deals, on the knnct Platform relating to location, amount of mortgage loan willing to provide, types of mortgage willing to fund, successful applicant’s beacon score, loan-to-value percentage information about the Lenders posting Mortgage Assets for sale or criteria of Lender using, or accessing Mortgage Assets, location, number of mortgages to be sold, currency of any proposed transaction, type of mortgages being sold, average beacon score, average loan-to-value percentage and any other data or information that allow us to gain a better understand of the mortgage marketplace (both mortgage origination as well as mortgage sales) operating in the jurisdiction where you operate.

WHERE INFORMATION IS STORED AND PROCESSED.

knnct is based in the Canada but the information we collect is governed by laws of the country where such Data and information is created, and that Data and information is stored in that country in accordance with the rules and regulations of that country. By accessing or using the Services or otherwise providing information to us, all non-Canadian users consent to the processing and transfer of information in and to Canada.

DELETION OF ANNONYMOUS OR AGGREGATED DATA.

knnct collects, stores, analyzes, reviews for trends and shares certain data about the use of Services on an aggregate and/or anonymous basis. knnct does not link this information to anything personally identifiable to you if shared with third parties.

DELETION OF PERSONAL INFORMATION

knnct recognizes the importance of each Client’s personal information and data of personal data and knnct will erase and to prevent processing in following specific circumstances:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed – for example, after a reasonable period of time following either a Broker accepting an offer from a Lender or the expected closing date of any proposed transaction;
• When the individual withdraws consent;
• When the individual objects to the processing and there is no other legal ground for the relevant processing activity;
• When the personal data was unlawfully processed;
• Where the personal data has to be erased in order to comply with a legal obligation.

What information does knnct retain?

The knnct platform stores data about Brokers and Lenders that are subscribers to the knnct platform. We store the name, e-mail address, gender, organisation/department (if provided) and transactions (in the case of Brokers, mortgage deals posted or Lender offers accepted or declined and, in the case of Lenders, any deals considered or offers made to Brokers whether such offer is accepted or declined) in order to create a report, which is stored on our secure servers in country where the Brokers and/or Lenders reside for a period of 90 days. This data is stored and used in accordance with our Terms and Conditions which can be found at: www.knnct.com/termsofservice.

If consent is provided, personal data (including the above, plus address, telephone number and notes) may be stored in our CRM system for the purposes of contacting you regarding knnct updates, news, products and promotions.

How can data be deleted?

If you are a Broker or Lender using the knnct platform, knnct acts as data controller. In this case, we will delete personal information about you upon request (via email to info@knnct.com), upon the closure of your account, or after three years.

Data may still remain in the systems back-up files, which will be deleted periodically.

Information may be deleted from our CRM upon request to info@knnct.com. We undertake to perform the deletion within one month (30 calendar days) and will send you a confirmation once the information has been deleted. Wherever possible, we will aim to complete the request in advance of the deadline.

SOCIAL SHARING FEATURES.

The Services may offer social following or sharing features and other integrated tools (such as the Facebook “Follow” or “Like” button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

CHOICE/OPT-OUT/OPTING OUT OF MARKETING COMMUNICATIONS.

You may opt-out of receiving communications from us and our partners by unsubscribing to email notifications or simply changing your settings for the knnct Platform. You can also remove your information from our database and choose to not receive future communications related to the knnct Platform by cancelling your account. If you wish to deactivate your account, please contact us at deactivate@knnct.com .

If you would like to stop receiving promotional communications from us, please contact us and specify from which list(s) you would like to be unsubscribed (“Do Not Email,” “Do Not Mail,” or “Do Not Call”). Please note that requests by email or phone may take up to ten business days to process. You can also unsubscribe from our promotional emails by clicking the unsubscribe link provided at the bottom of any knnct promotional email. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.

YOUR PRIVACY RIGHTS AND CHOICES

Access, Correction, and Deletion

Depending on where you reside, you may have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. To request access, deletion, or correction of your personal information, please fill out our webform. You may also call 1.866.986.8282 to submit a request. Once we receive the request, we will validate the information that you provide and send a message to the email address you provided in the request. Please follow the instructions in that email to verify your email address and/or provide any additional information that may be needed to process your request. If we deny your request, you may have the right to appeal our decision by contacting us at privacy@tommybahama.com. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

You can also review and modify your online account information at any time. To access your online account, simply click “My Account” at the top of any web page and sign in when prompted. You can also update your account information by calling guest services at 1.888.272.3707.

Opting Out of Targeted Advertising, Sharing, and Sales

As described in the “Targeted Advertising and Analytics” section above, we process personal information to serve you advertisements on third-party properties. Some of these activities may be considered “sales” or “sharing” of your personal information or “targeted advertising” under the law that applies to you. You may opt out of these activities by following the prompts here.

In addition, we disclose your information to other entities for marketing purposes as described in Disclosures of Personal Information above. Such disclosures may constitute “sales” of your personal information in California and Virginia and Connecticut, Colorado, and Utah. If you live in one of these states, you may opt out of such activities.

Cookies and Similar Tracking Technologies

We use cookies and similar tracking technologies to analyze visits to our websites and interactions with our communications to help us improve our website, services, and marketing campaigns. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. You can exercise certain choices related to cookies on our website here.

REGULATORY BODIES.

The mortgage industry, regardless of location, is highly regulated and there are a significant number of rules and regulations that govern the industry and actions and activities of Brokers and Lenders.  knnct collects, retains, and use information regarding its Members, the Mortgage Deals and Postings and all data, information and documents created by Brokers (including any amendments) and accessed and uploaded by a Client to the knnct cloud server.  Knnct makes all such information available to regulatory bodies that govern the mortgage industry as and when properly requested to the extent that the location of the Mortgage Deal, Posting, Mortgage Assets or Member is relevant to such regulatory body.  In addition, knnct maintains and retains in secure storage all such information specifically as a record for its own purposes and so that is able to comply if it is properly requested to provide such documents to relevant regulatory bodies.

SECURITY.

Your knnct Platform account is password-protected so that only you and authorized knnct staff have access to your account information. In order to maintain this protection, do not give your password to anyone. Also, if you share a computer or phone, you should sign out of your knnct Platform account before someone else logs on. This will help protect your information entered on public terminals from disclosure to third parties. knnct takes steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, knnct cannot ensure or warrant the security of any information you transmit to us or to any third parties, and you do so at your own risk. While knnct will use commercially reasonable efforts to ensure the security of all credit card and all other Personal Information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all Personal Information and/or Financial Information stored therein, and you agree to hold knnct and knnct`s affiliates and assignees harmless for any damages that may result therefrom. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an e-mail or text message to you. knnct expressly disclaims any liability that may arise should any other individuals obtain the information you submit through Services.

PRIVACY OF MINORS.

Members are obligated under the Terms and Conditions to be at least 18 years of age.  We do not knowingly collect, maintain, or use Personal Information from minors under 18 years of age, and no part of the Service is directed to minors under the age of 18. If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@knnct.com. If we learn that we have collected any Personal Information from individuals under 18 years of age, we will promptly take steps to delete such information and terminate the minor’s account.

CALIFORNIA PRIVACY INFORMATION.

CALIFORNIA PRIVACY INFORMATION

The California Consumer Privacy Act (“CCPA”) requires us to explain some information using definitions and categories set out under the CCPA. If you are a California resident, this section applies to you.

Additional Disclosures

We collect, and in the preceding 12 months we have collected, the following categories of personal information: Identifiers (such as your name, email address, or IP address), characteristics of protected classifications under California or U.S. law (such as your age), commercial information (such as records of products or services purchased), Internet and electronic network activity information (such as browsing history, search history, information about your activities on our Services), geolocation data (such as your city of residence), audio and visual information (such as phone recordings when you call customer service), inferences drawn about your preferences, and other categories of personal information that relate to or are reasonably capable of being associated with you (for example, certain information you submit in connection with a product review or in response to a survey such as your height and clothing size). For more information about the precise data points we collect, please see “Collection of Personal Information” above. We collect personal information directly from you (for example, when you place an order from our website or make a purchase at one of our stores), automatically when you access or use our Services or shop in our stores, and from third-party sources such as joint marketing partners, each described in more detail in the “Collection of Personal Information” section above.

We collect personal information for the business and commercial purposes described in the “Use of Personal Information” section above.

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.

We retain personal information for as long as necessary to carry out the purposes for which we originally collected it and for other purposes described in this Policy.

We may “share” and “sell” personal information with third parties for the purpose of engaging in advertising and marketing activities, including to expand the reach and effectiveness of our own marketing campaigns and for the third parties’ own marketing purposes. We may share and sell the following categories of personal information to the following categories of third parties:

Categories of Personal Information

• Categories of Third Parties
• Identifiers

Commercial information

• Advertising and marketing networks
• Internet and electronic network activity information
• Advertising and marketing networks

We do not knowingly sell or share personal information about consumers under the age of 16.

YOUR CANADIAN PRIVACY RIGHTS

If you are a Canadian resident, this section applies to you.

You may exercise your rights to access and correct the personal information we hold about you by following the instructions set forth in the “Your Privacy Rights and Choices” section above.

By submitting personal information to us, or to our service providers and agents, you consent to the collection use, disclosure, and transfer of your personal information in accordance with this Policy and as permitted or required by law. You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your personal information time by contacting us at privacy@tommybahama.com. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may not be able to provide you, or continue to provide you, with certain products, services, or information that may be of value to you.

We do not share your shopping history or account information with third parties for marketing purposes. However, we do share your postal address as a knnct Canadian customer with marketing partners to use for direct mail marketing purposes. If you would like to opt out of the provision of your information for this purpose, please contact us. To opt-out of interest-based online advertising, and to find information about how to block or limit cookies, visit AdChoices, the Canadian self-regulatory program for online interest-based advertising, administered by the Digital Advertising Alliance of Canada (“DAAC”).

We will retain the personal information that you provide in accordance with applicable laws, and we will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for the purposes for which it was collected. Your personal information may be stored and accessed by us in Canada and the United States, and we may use third party service providers which may be located in or may have servers in the United States or another country. We transfer your information to these third-party service providers only to the extent necessary for them to perform the services on our behalf. We do not authorize our service providers to make any other use or disclosure of your information, but your information may be accessible to governmental and law enforcement organizations in those countries.

We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message. If you opt out, we may still send you non-promotional messages, such as those about your account or our ongoing business relations.

SUBSCRIBERS OUTSIDE OF NORTH AMERICA

Subscribers outside of North America are not authorized to use the Services.

CHANGING, REMOVING AND UPDATING YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION.

Access and control over most personal information on knnct is readily available through the profile editing tools. Our Members may modify or delete any of their profile information at any time by logging into their account. Information will be updated immediately. If you wish to deactivate your account may do so by emailing us at deactivate@knnct.com. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to other Members. If you would like to update or correct any information that you have provided to us through your use of the Service or otherwise and you cannot access such information through your account, or if you have suggestions for improving this Privacy Policy, please send an e-mail to customerservice@knnct.com.

NOTIFICATION OF CHANGES.

knnct’s security and Privacy Policy are periodically reviewed and enhanced as necessary. This policy might change as knnct Policy updates and expands Services. We will endeavor to notify you of any material changes by email, but will not be liable for any failure to do so. We also encourage you to review this Privacy Policy periodically whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. If you have any questions about this Privacy Policy, please contact us at privacypolicy@knnct.com.

CONTACT US.

If you have any questions about this privacy statement, the practices of Services, or your dealings with the knnct Platform, you may contact us at customerservice@knnct.com.

Last Updated: January 15, 2023