May 27, 2025

This Privacy Statement (the “Privacy Statement”) sets forth how Kingland Systems LLC (formerly known as Kingland Systems Corporation and hereinafter referred to as "Kingland") acts as a Data Processor, receiving and processing data under contracts with various organizations serving as controllers (as defined in the European Union Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, each a “Controller”).

Kingland collects and manages this data solely as stipulated in our contracts with Controllers and for purposes agreed upon in those contracts. These contracts may include Standard Contractual Clauses and adhere to established frameworks such as the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) (collectively, the “Data Privacy Framework”).

This Privacy Statement outlines Kingland’s practices for collecting, processing, and protecting personal information on systems operated by Kingland. As used in this Privacy Statement, “your Controller” means the Controller by whom you are employed or that is otherwise requiring you to provide personal information to Kingland.

This Privacy Statement is structured into seven key sections based on the seven core principles on which the Data Privacy Framework is predicated: Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; Recourse, Enforcement, and Liability.

 

DATA PRIVACY FRAMEWORK

Kingland has certified to the U.S. Department of Commerce its compliance with the EU-U.S. Data Privacy Framework Principles (the “EU-U.S. DPF Principles”) with regard to the processing of personal information received from the European Economic Area (the “EAA”) and the United Kingdom (the “UK”) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and to the Swiss-U.S. Data Privacy Framework Principles (the “Swiss-U.S. DPF Principles”, collectively with the EU-U.S. DPF Principles, the “Principles”) with regard to the processing of personal information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is a conflict between the terms in this Privacy Statement and the applicable Principles, the Principles will govern. For more information or to view our certification, visit https://www.dataprivacyframework.gov/.

 

NOTICE

Information We Collect

The personal data Kingland processes depends on your Controller's policies and the specific services we provide. Data collected typically includes:

• Personal Identification Information, such as your name and unique identifiers necessary for system access and user authentication.
• Employment-related Information, including details necessary for regulatory compliance required by global audit firms.
• Financial Disclosures, limited specifically to the identification of individual financial interests or relationships (without disclosing the value of such interests), if/when required by the Controller.
• Registration Information, when applicable, such as details submitted during the process of obtaining a Legal Entity Identifier (“LEI”), per guidelines set by Business Entity Data B.V.
• Technical identifiers, (e.g., cookies, IP addresses), used to support platform functionality, performance, and security.

For questions about the necessity or scope of data collection, please contact your Controller.

Use of Your Information

Kingland uses the personal data it collects solely for the following purposes and as specified in contractual agreements with the Controllers:

• To fulfill contractual obligations with Controllers.
  
  
• To support compliance-related review, analysis, and reporting functions.
  
  
• To facilitate registration and management of LEIs.
  
  
• To enable communication to you by Controllers, such as sending reminders or notifications about data updates or modifications required by their policies.

Kingland does not, and will not without your explicit consent, use, share, or otherwise disclose your personal data for purposes not specified in this Privacy Statement, including for advertising or marketing activities.

SHARING YOUR INFORMATION

Kingland may disclose personal information to the following categories of third parties, for the purposes outlined:

• Service Providers and Outsourced Contractors: To facilitate technical support, data storage, security audits, and compliance activities.
  
  
• Authorized Representatives of Global Audit Firms: To ensure regulatory compliance and proper data management.
  
  
• Security and Compliance Auditors: For conducting audits and assessments.
  
  
• Regulatory and Law Enforcement Authorities: For legal compliance, security purposes, fraud investigations, or in response to government requests, always notifying your Controller within legal limitations.
  
  
• Business Entity Data B.V.: For LEI registration and compliance purposes.
  
  
• Mergers, Sales, or Corporate Changes: In the event of fundamental corporate changes such as mergers, acquisitions, or asset transfers, ensuring continuity of service and compliance.

Kingland does not sell, lease, rent, or share your personal information with credit reporting agencies or unrelated third parties for marketing purposes.

Disclosure to Public Authorities

Kingland may disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

CHOICE

Personal information collected by Kingland is managed according to the instructions provided by your Controller. Your Controller administers all opt-out opportunities and choices regarding the collection, use, or disclosure of your personal data. If you encounter any difficulty exercising these choices or have questions about your options, please contact your Controller directly.

Kingland will not use or disclose your personal information in any way other than as explicitly described in this Privacy Statement without or your Controller first clearly informing you and obtaining your explicit consent. Specifically, you will be provided with an opportunity to opt-out if your personal information is:

• To be shared with a non-agent third party.
• To be used for purposes different from those initially disclosed or subsequently authorized by you.

ACCOUNTABILITY FOR ONWARD TRANSFER

Kingland maintains contracts with Controllers defining how personal data may be used, transferred, and secured. All transfers of personal information are carried out in a manner consistent with these contractual obligations and may involve transferring data across state or national borders.

Kingland may transfer your personal data within its own controlled facilities or computing environments used for data management, storage, security, and other purposes. Additionally, we may host data and applications on leased virtual or physical computer systems, provided these systems remain under Kingland’s control.

Kingland also engages third-party agents to process personal data. Kingland conducts these transfers under contractual agreements requiring these agents to uphold our privacy standards and obligations as outlined in this Privacy Statement.

In the context of onward transfers, Kingland is accountable for the processing of personal data it receives, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. Kingland remains liable under the Principles if the Kingland’s agent processes personal information in a manner inconsistent with the Principles, unless the Kingland proves that it is not responsible for the event giving rise to damage.

For further details about the Data Privacy Framework, please visit the Data Privacy Framework website.

SECURITY

Kingland is dedicated to protecting your personal information and maintaining its confidentiality, integrity, and availability. To prevent unauthorized access, disclosure, or misuse, we employ reasonable physical, technical, and administrative security measures. Our practices are regularly reviewed through security audits conducted by Controllers and independent certified auditors.

In the event of a security incident involving your personal information, Kingland has procedures to promptly notify the affected Controller and relevant civil authorities if required by law. We will also take prompt and reasonably appropriate steps to mitigate any potential harm from the incident, including providing written notice to impacted individuals when required by law.

DATA INTEGRITY AND PURPOSE LIMITATION

Kingland maintains your personal data according to the specific purposes defined in our agreements with your Controller. We agree to abide by those requirements for as long as Kingland maintains the data and will ensure that the disposition of the data is in accordance with the terms specified in those agreements.

If you have questions or concerns regarding the accuracy or specific use of your personal information, please contact your Controller directly through the support channels provided within your application or as instructed by your Controller.

ACCESS TO YOUR INFORMATION

Kingland recognizes the importance of keeping your personal information accurate and up to date. Our software applications and services provide you with online access to review, correct, update, or supplement the personal information we maintain about you. You can also contact Kingland directly at Privacy@kingland.com for assistance.

If you encounter difficulties accessing or updating your personal information, please reach out directly to your Controller through the designated support mechanisms indicated within your application or according to your Controller's instructions.

RECOURSE, ENFORCEMENT, AND LIABILITY

Kingland is committed to ensuring compliance with applicable data privacy requirements. Our privacy practices and obligations are governed by formal agreements with Controllers and supported by our Information Assurance Program. This program incorporates privacy and security principles aligned with the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Kingland commits to resolve Data Privacy Framework-related complaints about our collection and use of your personal information in accordance with the DPF Principles. If you believe your personal information has been improperly accessed or used, or if Kingland has failed to meet its obligations as a Processor acting on behalf of the Data Controller, under this Privacy Statement, please notify your Controller's privacy officer (or equivalent). Our agreements with Controllers include a dispute resolution process, in which Kingland participates.

If you are unable to contact your Controller’s privacy officer or your local or national data protection authority, please contact Kingland directly at Privacy@kingland.com for assistance.

The Federal Trade Commission (FTC) has jurisdiction over Kingland’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Dispute Resolution

Kingland commits to refer unresolved complaints concerning our handling of personal data received in reliance on EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to our U.S.-based third-party dispute resolution provider (free of charge), TRUSTe. If you do not receive timely acknowledgment of your Data Privacy Framework-related complaint from us, or if we have not addressed your Data Privacy Framework-related complaint to your satisfaction, please visit at https://feedback-form.trustarc.com/watchdog/request for more information or to file a complaint. The services of TRUSTe are provided at no cost to you.

If a privacy complaint remains unresolved after utilizing all other available channels described in this Privacy Statement, under limited circumstances you may have the option to pursue binding arbitration through the Data Privacy Framework Panel. This arbitration panel is established jointly by the U.S. Department of Commerce and the European Commission to address unresolved complaints under the Data Privacy Framework. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

CHANGES IN THIS PRIVACY STATEMENT

This Privacy Statement may be periodically updated to reflect changes in applicable laws, regulations, or requirements of our agreements with Controllers. Kingland will communicate any updates by publishing notices of changes directly within this Privacy Statement.

 

Recent updates include:

• Minor wording revisions for enhanced clarity.
• Alignment updates from the previous Privacy Shield Framework to the current Data Privacy Framework Principles.
  
  

CONTACT INFORMATION

For questions or comments regarding privacy practices or this Privacy Statement, please first contact your Controller’s data privacy officer (or equivalent).

 

If you are unable to reach your Controller’s privacy officer or your local or national data protection authority, you may directly contact Kingland for further assistance:

 

Kingland Systems LLC

Attention: Data Protection Officer / Chief Security Officer

1401 Sixth Avenue South

Clear Lake, IA 50428, USA

Email: Privacy@kingland.com