WHO IS KAIIZEN, INC.?
Kaiizen, Inc. and its affiliated companies (together “Kaiizen,” “we,” and “us”) provides an online proprietary platform (‘Platform”) that enablescommercial real estate investors (“Partners,” “Buyers,” “Sellers,” and “Customers”) to submit and bid on single family residential properties aswell as to efficiently apply for and obtain funding for the purchase and the renovation of such qualified properties (each a “Property” and,collectively, “Properties”). Kaiizen assists with valuating the renovation and standards of each Property as well as general insights with regards to said Properties.
Kaiizen takes the private nature of the Personal Information (defined below) we collect seriously, and we are committed to protecting it.Therefore, we have in place controls and procedures designed to ensure that such information is managed responsibly and in accordance withapplicable data protection and privacy laws (collectively, “Privacy Laws”).
This Privacy Notice applies to Kaiizen’s practices where we function as a data controller (or equivalent role as described under the variousPrivacy Laws in our regions of operations). It describes the categories of Personal Information that we collect and the sources of suchinformation, how we use that Personal Information, to whom Personal Information is disclosed and sold and for what purposes, and the rightsdata subjects have with respect to their Personal Information.
SCOPE OF PRIVACY NOTICE
This Privacy Notice addresses our Personal Information processing practices as it relates to: (a) our corporate website (the “Website”); (b) operation of the Platform; (c) other direct interactions with individuals/corporate entities, and (d) any data that we collect from third parties.
PERSONAL INFORMATION
For purposes of this Privacy Notice, “Personal Information” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Information includes information referred to as “personal data,” “personal information,” “personally identifiable information” and such similar references as codified in applicable Privacy Laws.
Most of the information Kaiizen collects pertains to commercial entities and persons associated with such entities (e.g., an officer, employee, contractor, analyst, executive.) Under most U.S. Privacy Laws, such information is not considered “Personal Information.” However, certain jurisdictions (e.g., California) and jurisdictions outside the U.S. (e.g., the United Kingdom and the European Union), do consider such information to be “Personal Information,” with certain exceptions. As a result, we consider information about an individual, in their professional capacity, to be Personal Information for purposes of this Privacy Notice. Note, however, that the rights of a data subject with respect to Personal Information are determined by the Privacy Law of the jurisdiction in which the data subject resides.
HOW KAIIZEN COLLECTS AND USES PERSONAL INFORMATION
Kaiizen collects Personal Information in a number of ways: (1) from Customers in connection with the establishment of an account with Kaiizen and our interactions with such Customers; (2) from visitors to our Website; (3) from vendors, Partners, Customers and other individuals with whom we interact in person, over the telephone, via email and other means of communication, and; (4) from third party data sources. The list below sets forth the categories of Personal Information Kaiizen has collected in the preceding twelve (12) months, the sources of such information and the purpose or use for which Kaiizen collects Personal Information.
PERSONAL IDENTIFIERS
Category of Sources of Information:
Examples of Data Elements Collected: Business address, Drivers’ license number, IP address, Phone number, Email address, Password, and / or Bank account or other financial information.
Purpose for Collection:
None of this information is used to infer characteristics about the individual to whom it pertains:
Category of Sources of Information:
Examples of Data Elements Collected: Full name, Home and Work Address, Date of Birth, Photograph, Personal and Business email, Personal and Business telephone number, Personal email, Social security number Driver’s license number, Citizenship status, Residency and work permit status, Gender, Race, Veteran status, Signature, Passport number, LinkedIn URL, Twitter URL, GitHub URL, Portfolio URL, Contents of emails regarding job applicants, Bank account and other financial information, and / or any additional information provided in a cover letter and a resume/CV, including the company with which applicants are currently employed.
Purpose for Collection:
None of this information is used to infer characteristics about the individual to whom it pertains:
Category of Sources of Information:
Examples of Data Elements Collected: First and last name, Email address, Password, Phone number, and / or Company name.
Category of Sources of Information:
Examples of Data Elements Collected: First and last name, Email address, Phone number, and / or Company name.
ELECTRONIC NETWORK ACTIVITY
Category of Sources of Information:
Examples of Data Elements Collected: Unique device identification numbers; Operating system and version; Performance data and browsing history; Time spent per visit; Cumulative time spent across all usage; Frequency of usage; Features used; Buttons clicked; Actions taken and frequency of each; and / or Ad tracking codes.
COMMERCIAL INFORMATION
Category of Sources of Information:
Examples of Data Elements Collected: Records of loans requested and received from Kaiizen.
Examples of Data Elements Collected: Records of Properties purchased from Kaiizen.
Examples of Data Elements Collected: Real property ownership information; Mortgage information; Real property transaction information; Foreclosure information; and / or Records of Properties purchased from Kaiizen.
Professional or employment-related information
Category of Sources of Information:
Examples of Data Elements Collected: Tax ID Number; Name of the company with which individuals are employed; and / or Role with company.
Category of Sources of Information:
Examples of Data Elements Collected: Current and prior employment history; and /or any other information provided in a cover letter and a resume/CV.
Data Collection Through Cookies
When you visit our Website, including when using our Platform, our goal is to make the experience simple and effective. To that end, we use text files, known as cookies, to track information about your use of our Website. A cookie is a text file that a website stores on a visitor’s computer to enable recognition of that visitor’s computer each time he/she/they return. As you navigate through and interact with our Website, we will automatically collect certain information about your equipment, browsing actions and patterns using these cookies. This may include information about your connectivity, your IP address and browser information, location data, logs and other communication data, and the resources that you access and use on the Website. The information we collect helps us to improve our Website and deliver better and more personalized content and services, enables us to estimate our audience size and usage patterns and recognize when you return to our Website.
Most web browsers automatically accept cookies, but if you prefer, you can change your browser settings to prevent that or to notify you each time a cookie is set. Please note however that by blocking or deleting cookies, you may not be able to take full advantage of our Website or Platform. Please refer to our Cookie Policy for more information on the specific cookies we use, the purpose for such cookies and how you can indicate your choices regarding placement of cookies.
KAIIZEN’S DISCLOSURE, SALE AND SHARING OF PERSONAL INFORMATION
Personal Information Disclosed to Third Parties for a Business Purpose
Kaiizen does not sell to or share your Personal Information with third parties. There are, however, certain circumstances in which we may disclose your Personal Information with trusted third parties in order to improve, protect and support our business. For instance, Kaiizen may disclose Personal Information to: (i) our subsidiaries; (ii) affiliated companies; (iii) service providers (e.g., hosting providers, title companies, property inspectors, property preservation providers, payment processors, business advisors, auditors, etc.); and (iv) any potential purchasers or investors in the business. In addition, Kaiizen may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with a legal obligation; (ii) protect and defend our rights or property; or (iii) protect the rights, property, or safety of our Customers, visitors to our Website, or the public. With respect to disclosures of Personal Information to third parties that do not qualify as related entities or service providers, our practices are described below.
PERSONAL IDENTIFIERS
Is the Personal Information Disclosed to Third Parties for a Business Operations Purpose: yes
Category of Sources of Information:
For What Purpose:
electronic network activity
Is the Personal Information Disclosed to Third Parties for a Business Operations Purpose: yes
Category of Sources of Information:
For What Purpose:
characteristics of protected classification and other sensitive information
Is the Personal Information Disclosed to Third Parties for a Business Operations Purpose: no
commercial information
Is the Personal Information Disclosed to Third Parties for a Business Operations Purpose: yes
Category of Sources of Information:
For What Purpose:
professional or employment-related information
Is the Personal Information Disclosed to Third Parties for a Business Operations Purpose: yes
Category of Sources of Information:
For What Purpose:
Personal Information Sold to or Shared With Third Parties
Personal Identifiers
Is the Personal Information Sold to Third Parties: yes
Category of Third Parties to Whom Sold:
For What Purpose:
electronic network activity
Is the Personal Information Sold to Third Parties: yes
Category of Third Parties to Whom Sold:
For What Purpose:
characteristics of protected classification and other sensitive information
Is the Personal Information Disclosed to Third Parties for a Business Operations Purpose: no
Commercial Information
Is the Personal Information Sold to Third Parties: yes
Category of Third Parties to Whom Sold:
For What Purpose:
professional or employment-related information
Is the Personal Information Sold to Third Parties: yes
Category of Third Parties to Whom Sold:
For What Purpose:
Kaiizen does not share Personal Information with third parties for use by the third parties in their own marketing.
disclosure to service providers
Kaiizen requires third party service providers with whom we share Personal Information to process Personal Information only as allowed in our contract with such third party service providers. We ensure that any third party service provider with whom we share Personal Information is subject to privacy and security obligations consistent with this Privacy Notice and applicable laws.
HOW WE PROTECT PERSONAL INFORMATION
The security of your Personal Information is important to us. We maintain industry standard physical, technical and administrative safeguards designed to protect your Personal Information from unauthorized access, use, disclosure, and destruction. Although we take reasonable steps to safeguard Personal Information, we make no warranty, express, implied or otherwise, that we will prevent such.
We update and assess our security controls on a regular basis. We also train our personnel about the importance of confidentiality, security and consumer privacy and limit our personnel’s access to Personal Information to only those employees who require access based on their job duties.
Electronic Personal Information, including the Personal Information about visitors to our Website and Personal Information submitted by our Platform users regarding their account and log-in information, is stored on systems in an enterprise third party cloud provider in the United States.
HOW LONG DO WE RETAIN PERSONAL INFORMATION?
Information about Customers: Kaiizen retains Personal Information collected from Customers for upwards of fifteen (15) years.
Website Visitor Information: We retain Personal Information about those who visit the Website as long as necessary to fulfill the purpose(s) for
which it was collected, including legal, accounting, and reporting requirements or as otherwise set forth under applicable law.
Job Applicant Information: We retain Personal Information obtained from our vendors for as long as our company retains a relationship with such vendors and for a period of time afterwards in order to satisfy legal, accounting and policy obligations.
A NOTE ABOUT CHILDREN’S PERSONAL INFORMATION
Neither the Platform nor the Website is marketed to, and neither is intended for use by, children. Therefore, Kaiizen does not knowingly collect any Personal Information from children under the age of 17. If you know or believe that such information has been provided to us, please contact us at contact@kaiizen.com. If we become aware that we have collected Personal Information about a child under the age of 17, we will delete it.
YOUR RIGHTS TO ACCESS
We will comply with all reasonable requests from you to correct, amend, or delete the Personal Information we have about you, and will provide you access to your Personal Information. There may be limits to the amount of information we can practically provide. For example, we may limit an individual’s access to Personal Information where the burden or expense of providing access would be disproportionate to the risks to your privacy or where doing so would violate other’s rights. You may contact us at contact@kaiizen.com
IF YOU ARE A CALIFORNIA RESIDENT
Kaiizen does not currently loan funds for, or purchase, Properties located in California. However, it is possible that Customers with whom we interact are California residents. For those California residents, in addition to the rights discussed above, you have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively, the “Act”), as it relates to the Personal Information Kaiizen collects about you:
1. Right to Know Before Collection of Personal Information: At or before the point your Personal Information is collected, Kaiizen must inform you of the following:
Note that Kaiizen does not knowingly collect, sell or share the Personal Information of individuals under the age of 17.
2. Right to Know What Personal Information Is Being Collected and Right to Access: California residents have the right to request disclosure of the following information, up to twice in a twelve-month period, from Kaiizen:
Before providing such information to you, Kaiizen must verify your identity. We will utilize the information that you submit with your request in order to do so and to locate any information that we maintain about you and for no other purpose.
3. Right to Know About Personal Information Sold or Shared: Kaiizen does not sell or share Personal Information.
4. Right to Request Deletion: California residents have the right at any time to request that Kaiizen delete any Personal Information that we collected directly from them. Kaiizen collects Personal Information directly from consumers as described in the Section titled “How Kaiizen Collects and Uses Personal Information” above. The obligation to delete Personal information upon request is not absolute. The law allows businesses to retain Personal Information for certain purposes, such as the need to retain the information to service a transaction you have with us, even when a deletion request is received. In addition, before deleting information in response to a request, Kaiizen must verify the requesting resident’s identity.
5. Right to Correct Inaccurate Personal Information: California residents have the right to request at any time the correction of inaccurate Personal Information that Kaiizen maintains about the requesting resident. Before correcting Personal Information in response to a request, Kaiizen must verify the requesting resident’s identity.
6. Right to Opt-out of the Sale or Sharing of Personal Information: California residents have the right to direct a business that sells and/or shares Personal Information to third parties to stop doing so). Kaiizen does not sell or share Personal Information. As a result, Kaiizen is not required to post a Notice of Right to Opt-out nor a “Do Not Sell Or Share My Personal Information” link.
7. Right to Limit Use and Disclosure of Sensitive Personal Information: California residents have third right at any time to direct companies to limit the use of their sensitive Personal Information to that necessary to provide the services requested by such resident and to those purposes otherwise allowed by California law. Kaiizen only uses and discloses sensitive personal information for purposes permitted under California law. As a result, Kaiizen is not required to post a Notice of Right to Limit. Nor is Kaiizen required to comply with a request to limit.
Right Non-Discrimination: California law prohibits Kaiizen from discriminating or retaliating against a California resident based on such resident’s exercise of the privacy rights described herein. For example, Kaiizen cannot deny a loan or provide a different level or quality of service as a result of a California resident exercising their rights.
Method to Submit Requests:
If you are a California resident and wish to exercise any of the rights listed above, please provide your name, phone number, and any other identifiers that you think will help us to verify you using one of the methods reflected below. Upon receipt of a request to know, to delete, or to correct (collectively, “Data Request”), Kaiizen will use the information you provide in the request to verify your identity. Kaiizen may occasionally request additional information in certain circumstances to assist in facilitating verification. Any information received by Kaiizen in response to a request for additional information will be held strictly in confidence, used only for the purposes of processing your request and in accordance with applicable data privacy laws and regulations.
To submit a Data Request, you may call us at our toll-free number, 1-800-991-3591, or by clicking here.
California law allows you to designate an agent to submit a request to exercise any of the above rights on your behalf. To have an authorized agent submit a request on your behalf, the authorized agent must provide Kaiizen with proof that you gave the agent signed permission to submit the request. We may also require you to verify your identity or confirm that you provided the authorized agent with power of attorney under the Probate Code.
responses to data requests
We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by email.Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable. Upon verifying your identity and confirming there are no applicable exemptions to deny the request, we will delete your personal information from our records and direct any service providers to do the same.
IF YOU LIVE IN THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM OR SWITZERLAND (collectively, “Europe”)
Kaiizen complies with the EU General Data Protection Regulation 2016/679, the UK Data Protection Act of 2018 and the Swiss Data Protection Act of 2020 (collectively, “GDPR”) with respect to the protection of individuals when processing their Personal Information and the free movement of such Personal Information.
Under the GDPR, you have the following rights:
1. Right of Access: You have the right to ask us for copies of your Personal Information. The law provides for some exemptions, which means you may not always receive all the Personal Information we process.
2. Right to Rectification: You have the right to ask us to rectify Personal Information you think is inaccurate. You also have the right to ask us to complete Personal Information you think is incomplete.
3. Right to Restrict Processing: You have the right to ask us to restrict the processing of your Personal Information in certain circumstances.
4. Right to Withdraw Consent: You have the right to revoke your consent to our processing of your Personal Information at any time by contacting us at contacto@kaiizen.com. Withdrawing consent will not affect the lawfulness of the processing performed based on your consent before its withdrawal.
5. Right to Erasure: You have the right to ask us to erase your Personal Information in certain circumstances.
6. Right to Data Portability: This only applies to Personal Information you have given to us and that is held electronically. You have the right to ask that we transfer this information from Kaiizen to another organization or give it to you.
You may contact us at contact@kaiizen.com if you wish to make a request with respect to exercising your rights above. You are not required to pay any charge for exercising your rights. We have one month to respond to you. You may also contact the relevant supervisory authority to lodge a complaint related to our handling of your Personal Information. However, we invite you to give us a chance to resolve the situation directly with you. Your privacy is important to us, and we will do our best to address any concerns.
Kaiizen does not lend funds for Properties located outside of the continental United States. However, we do have Customers who are residents of other countries and our Website is available globally. Please note that our computer systems are based in the United States, which means Personal Information we collect will be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. For transfers to the United States, we will either rely on a derogation applicable to the specific situation (e.g. consent or if the transfer is necessary to perform our contract with the data subject) or implement the Standard Contractual Clauses adopted by the European Commission and/or an International Data Transfer Addendum with respect to transfers outside of the United Kingdom.
The legal bases for processing your Personal Information include one or more of the following depending on the circumstances:
If Kaiizen uses email prospecting, we first obtain the consent of the individual, unless the recipient is already a Customer and the email involves products similar to those we already provide to such Customer. In such instances, the legal basis of the processing is the legitimate interest of Kaiizen, namely to promote our products to our Customers. When Kaiizen sends commercial solicitations to Customers by email regarding products other than those already provided to such Customers, the legal basis of the processing is consent.
You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us at: contact@kaiizen.com.
HOW LONG DO WE RETAIN PERSONAL INFORMATION?
Information about Customers: Kaiizen retains Personal Information collected from Customers for upwards of fifteen (15) years.
Website Visitor Information: We retain Personal Information about those who visit the Website as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, and reporting requirements or as otherwise set forth under applicable law.Job
Applicant Information: We retain Personal Information obtained from our vendors for as long as our company retains a relationship with such vendors and for a period of time afterwards in order to satisfy legal, accounting and policy obligations.
CHANGES TO THIS PRIVACY NOTICE
As we evolve, we may update this Privacy Notice to align with changes in the Platform, our business and/or Privacy Laws. The Effective Date at the beginning of this Privacy Notice will reflect the last date on which the Privacy Notice was updated. We recommend that you periodically review the Privacy Notice to stay informed of changes. We will ask for your consent to such changes if required by Privacy Law. The same is true with respect to Personal Information that we collect via email, snail mail and other communication methods. If you disagree with the Privacy Notice, please email us at contact@kaiizen.com and stop using the Website.
HOW TO CONTACT US
If you have any questions about this Privacy Notice or wish to exercise your rights hereunder, please contact us at contact@kaiizen.com.
Written inquiries can be sent to:
Kaiizen, Inc.
contact@kaiizen.com
