Privacy

Privacy Policy

Khepera Capital Management, LLC (“KCM,” “we,” “our,” or “us”) respects your privacy and is committed to handling any information collected through this website responsibly. This Privacy Policy describes what information we may collect, how we use it, and your rights in connection with it. By accessing or using this site, you acknowledge that you have read and understand this Privacy Policy and agree to the collection and use of information as described herein. This Privacy Policy does not constitute a contract between you and KCM, and nothing herein creates any legally enforceable right or obligation beyond what is required by applicable law. KCM reserves the right to modify this policy at any time, with changes effective upon posting. Your continued use of this site following any modification constitutes your acceptance of the revised policy.

Scope of This Policy

This policy applies to the KCM website, and any pages or materials hosted under its domain. This Policy applies solely to information collected through this website and its hosted pages. It does not govern: (i) third-party websites or platforms linked from this site, whose privacy practices are outside KCM's control; (ii) information exchanged in connection with any private investment, capital management, financing, acquisition, or other business transaction with KCM, which is governed exclusively by the terms of the applicable executed agreements and applicable securities or financial regulations; or (iii) communications initiated outside of this website (including direct email, telephone, or in-person meetings). Nothing in this Policy shall be construed to modify, expand, or limit the terms of any confidentiality agreement, non-disclosure agreement, subscription agreement, loan document, or other executed agreement between KCM and any counterparty. In all cases of conflict between this Policy and an executed agreement, the executed agreement governs.

Information We Collect

We may collect two categories of information through this site:

Information you provide directly. If the site includes a contact form, inquiry submission, or similar feature, you may voluntarily provide your name, email address, company affiliation, and any message or inquiry you choose to submit. If the site uses a direct email link rather than a form, we receive only what you choose to include in that communication.

Information collected automatically. When you visit this site, our hosting infrastructure and any analytics tools in use may automatically collect certain technical data, including your IP address, browser type and version, operating system, referring URL, pages viewed, and the date and time of your visit. This technical data is generally collected and processed in aggregate form. KCM does not use this data to identify individual visitors except as may be necessary to: (a) investigate or prevent actual or suspected fraud, unauthorized access, or other security incidents; (b) comply with applicable law, regulation, or legal process; or (c) enforce the terms of this Policy or any other agreement between you and KCM.

Cookies and Tracking Technologies

This site may use cookies or similar tracking technologies (including pixel tags, web beacons, and session identifiers) to support basic site functionality and, where analytics tools are deployed, to understand aggregate visitor behavior. Cookies are small data files placed on your device by your browser when you visit a website. Most browsers allow you to refuse cookies or delete them at any time; doing so may affect the functionality of certain features of this site. This site does not currently respond to “Do Not Track” signals transmitted by browsers, as no uniform standard for such signals has been adopted. KCM does not sell, rent, license, or share visitor data with third parties for advertising or commercial purposes.

How We Use Information

  • To respond to inquiries. If you contact us through the site, we use the information you provide solely to respond to your message and follow up as appropriate.
  • To maintain and improve the site. Automatically collected technical data helps us understand how the site is being used, identify issues, and make improvements.
  • To comply with legal obligations. We may retain or disclose information where required by applicable law, regulation, legal process, or a request from a governmental or regulatory authority.

Data Retention

KCM retains information collected through this site for the period reasonably necessary to fulfill the purposes described in this Policy, or as required by applicable law, regulation, or legal hold. Contact and inquiry data submitted through this site is generally retained for no longer than twenty-four (24) months following the date of submission, unless a longer retention period is required by applicable law or KCM's internal records management policies.

Security

KCM implements commercially reasonable administrative, technical, and physical safeguards designed to protect information collected through this site from unauthorized access, use, disclosure, alteration, or destruction. However, no security system is impenetrable, and no method of data transmission over the internet or electronic storage can be guaranteed to be completely secure.

Rights of Residents

California Residents. If you are a California resident, you may have rights under the California Consumer Privacy Act (CCPA), including the right to know, request deletion, and non-discrimination. KCM does not sell personal information and does not engage in targeted advertising using visitor data.

Florida Residents. KCM's principal place of business is in the State of Florida. Florida residents may have rights under Florida's data privacy framework, including the Florida Digital Bill of Rights (Fla. Stat. § 501.701 et seq.) to the extent KCM meets applicable statutory thresholds.

International Visitors (GDPR). If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with applicable data protection laws, you may have additional rights regarding your personal data, including access, correction, and deletion.

Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Florida, without regard to its conflict of laws provisions. Any dispute arising out of or relating to this Privacy Policy, the collection or use of your information, or your use of this site shall be resolved exclusively in the state or federal courts of competent jurisdiction located in Miami-Dade County, Florida.

Changes to This Policy

KCM may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date at the top of this page. Your continued use of this site following any update constitutes your acceptance of the revised policy.