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Privacy Policy

PREAMBLE

We understand that you care about your personal data and how it is used. You can trust Karam Investment & Management Services to treat your data with the utmost care. This Privacy Policy explains the types of personal data we collect, why we collect it, and how we use it.

Please note that this Privacy Policy applies specifically to Karam Investment & Management Services, as defined below.

Take a moment to familiarize yourself with our privacy practices, and feel free to contact us at contact@kims.com with any questions.

We’ve aimed to keep this Policy as clear as possible. If you’re unfamiliar with terms like Cookies, IP Addresses, Applications, and Browsers, we recommend reviewing these key concepts first.

You have the right to object to certain uses of your personal data, including for direct marketing. You can learn more about your rights and how to exercise them here.

1. WHO IS RESPONSIBLE FOR DATA COLLECTION?

All personal data provided to or collected by Karam Investment & Management Services is controlled by Karam Investment & Management Services SAS, 102 rue Montmartre, 75002 Paris, France (the data controllers).

This Privacy Policy applies to personal data collected by Karam Investment & Management Services SAS in connection with the services and products we offer.

It also applies to Karam Investment & Management Services marketing content, including offers and advertisements for our products and services, which we (or a service provider acting on our behalf) may send to you on third-party websites, platforms, and applications based on your site usage. These third-party sites usually have their own Privacy Policies and Terms & Conditions. We encourage you to review them before using those websites.

2. WHAT PERSONAL DATA DO WE COLLECT?

Personal data means any information that can be used to directly or indirectly identify an individual. This includes personal data collected offline via our Consumer Engagement Centers, direct marketing campaigns, sweepstakes and contests, as well as online through our websites, apps, brand pages on third-party platforms, and third-party-accessed applications.

We may collect personal information from different sources, including:

  • Personal data you give us directly;
  • Personal data we collect automatically;
  • Personal data we collect from other sources.

You may be asked to provide personal data when contacting us. The data controllers may share this data and use it according to this Privacy Policy. We may also combine it with other data to improve our products, services, content, and ads.

You are not required to provide the personal data we request, but if you choose not to, we may not be able to deliver our products or services or respond effectively. We use collected information to enhance Karam Investment & Management Services offerings.

2.1. How We Collect Your Personal Data

Personal data you give us directly. We collect information about your use of our services and products, such as content you view, your preferences, and usage frequency. We also collect data when you subscribe to newsletters, complete surveys, open accounts, or purchase products. This may include your name, gender, birth date, address, email, phone number, or payment details. Some Karam brands may collect special categories of data with your explicit consent.

Personal data we collect automatically. We also receive and store certain types of personal data when you interact with us online or through our apps. For example, we use cookies and tracking technologies to collect data when your browser accesses our websites or our content on third-party sites. Your data is also collected when you search, post, buy, or engage with customer service. This may include your IP address, device ID, location data, browser type/version, timezone settings, operating system, and purchase history. We may use analytics tools to measure session behavior such as page response times, download errors, and navigation patterns.

Personal data from other sources. We may collect data from trusted third-party partners and platforms, including interactions with our content (like using Facebook “likes” or Google +1s), and marketing analytics to assess ad performance. We may also receive enriched data from selected providers to enhance our records.

2.3. Children’s Privacy

We take additional precautions to protect children’s privacy and safety using Karam Investment & Management Services products and services.

Our sites and apps are intended for adult use. For example, we may ask for age confirmation before granting access to applications.

We sometimes use personal data to verify age and enforce age restrictions.

3. HOW DO WE USE YOUR DATA?

We collect, process, and disclose your personal data only for specific and limited purposes—for example, to process payments, manage claims, improve products and services, offer personalized communications and targeted advertising, and analyze consumer behavior.

We create profiles by analyzing your online activity and direct interactions with our communications, segmenting data to deliver relevant content and advertising.

Sometimes, we use automated decision-making for marketing purposes. If required, we will notify you and request your consent.

We use your data to:

  • Process payments and manage orders or requests;
  • Respond to inquiries and provide customer support;
  • Improve our digital platforms and user experience;
  • Manage contests, promotions, and newsletter subscriptions;
  • Authenticate identity;
  • Conduct internal training and quality assurance;
  • Understand and anticipate consumer needs;
  • Deliver personalized content, advice, and recommendations.

3.1. Profiling

We analyze online behavior, purchase history, and brand interactions to build user segments and provide personalized experiences across our sites, newsletters, and advertising platforms. Consent for profiling is requested (e.g., cookie consent, newsletter signup).

You may withdraw consent at any time, configure cookie preferences, or unsubscribe from communications.

3.2. Automated Decision-Making

We use automated systems (e.g., email campaign automation based on browsing or purchase behavior). We do not make legally impactful decisions based solely on automated processing. If we do, we’ll inform you and explain your rights, including:

  • Human intervention;
  • Expressing your viewpoint;
  • Receiving explanation and contesting decisions.

4. WHO DO WE SHARE YOUR DATA WITH?

We may share your data with:

  • Third-party service providers: For hosting, payments, analytics, support, delivery, etc.
  • Other third parties: For marketing, advertising, and enrichment purposes.
  • Business transfers: If Karam Investment & Management Services merges, sells assets, or undergoes restructuring.
  • Legal disclosures: To comply with laws, enforce policies, or protect rights and safety.

4.1. International Transfers

If we transfer data outside the EEA, we ensure the same level of protection by:

  • Sending data to countries with adequate privacy laws;
  • Signing data protection contracts with third parties;
  • Using frameworks like the EU-U.S. Privacy Shield.

5. HOW DO WE PROTECT YOUR DATA?

We protect your personal data with strict access controls, encryption, pseudonymization, and anonymization. Only authorized personnel and contractors with confidentiality obligations may access your data.

6. HOW LONG DO WE RETAIN YOUR DATA?

We retain your data only as long as necessary to fulfill its original purpose, comply with legal requirements, or resolve disputes. We regularly review and securely delete or anonymize unnecessary data.

7. WHAT ARE YOUR RIGHTS?

You have the right to:

  • Be informed clearly about how we use your data;
  • Access, correct, or update your data;
  • Request data portability;
  • Request erasure (‘right to be forgotten’);
  • Restrict processing;
  • Object to processing, especially for marketing;
  • Lodge a complaint with a data protection authority;
  • Withdraw consent at any time;
  • Avoid decisions based solely on automated processing.

8. HOW TO CONTACT US

For questions or concerns about this Privacy Policy or our data practices, email us at contact@kims.com. We have a dedicated privacy team to review and respond to serious concerns. If unsatisfied, you may contact your local Data Protection Authority.

9. UPDATES TO THIS POLICY

We regularly update this Privacy Policy to reflect customer feedback or changes in law, products, or services. Significant changes will be clearly communicated. Archived versions are available upon request.

We will never reduce your rights under this Policy without your consent.

10. ADDITIONAL PRIVACY TERMS

Specific campaigns or promotions may be governed by supplemental privacy conditions. These will be highlighted when applicable.

11. KEY TERMS DEFINED

  • IP Address: A unique number that identifies a device on the Internet or a local network.
  • Cookie: Small data files stored by your browser when visiting websites.
  • SMS: Short Message Service for sending text messages to mobile phones.
  • Push Notification: A message that appears on your device via apps you’ve installed.

Last updated: October 12, 2022.

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