This privacy policy (“Policy”) will help you understand how Akuna Capital LLC on behalf of itself and its affiliates (collectively, “Akuna”, “we”, or the “Company”) uses and protects the personal data you provide to us through our website and virtual reality tool that post a link to this Policy.

By accessing our website and/or virtual reality tool, you consent to the collection of your data, to be used pursuant to this Policy.

Please note that Akuna is not engaged in the business of selling any products to consumers and your data is used solely for Akuna’s recruiting purposes or as a result of your independent contractor relationship with Akuna. Akuna will NOT lease or sell your personal data to any third parties. Your personal data will be used only in accordance with the guidelines provided in this Policy.
Akuna reserves the right to change this policy at any given time by updating this Privacy Policy page. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.

What User Data We Collect

When you visit the website, depending on your use case, we may collect the following data:

• Your IP address;
• Your name;
• Your age and gender;
• Your contact information, including email and phone number; Your University and graduation year;
• Your employment preference- full time vs. intern etc.; and
• Your simulation activity: percentage of course completed, overall scores, completion times, etc.
• Other information we collect from you in connection with your status as an Akuna job applicant or independent contractor.

Why We Collect Your Data

We are collecting your data for recruiting purposes:

• To better understand your employment preferences.
• To send you ongoing and future recruiting information: open positions that suit your profile and recruiting event invitations.
• Recruiting analytics.
• Basic identification- to connect testing results to your profile.

To the extent applicable, we are also collecting your data for purposes of administration of your independent contractor relationship with Akuna.

Safeguarding and Securing the Data

We have taken reasonable steps to help secure and safeguard the personal data we collect. However, no data security measures can guarantee security.

Disclosure of Personal Data to Third Parties

Where Akuna is permitted to do so under applicable law, Akuna may share your personal data with its affiliates, employees, contractors, consultants, and other third parties who assist Akuna in connection with your job application or independent contractor status with Akuna, without limitation, third parties that provide information technology and data processing services to Akuna with respect to the operation of its businesses.

Akuna has centralized aspects of its processing of personal data. Accordingly, where Akuna is permitted to do so under applicable law, Akuna (including, without limitation, its international affiliates) may transfer or provide your personal data to Akuna affiliates or third-party service providers both in and outside of the nation where you reside and/or work.

Additionally, your personal data may be disclosed in connection with a significant corporate change (e.g., merger or acquisition), as required by applicable law, to comply with a court order, subpoena, warrant or other legal process, or where the personal data is publicly available (unless otherwise restricted by applicable law).

Cookies and Similar Technologies

We use cookies and similar technologies, including technologies designed for mobile applications, to track user activity and collect usage data about our website. We may combine this data with the personal data we have collected from you.

Cookies. Cookies allow a web server to transfer data to a computer for record keeping and other purposes. We and our service providers use “cookies” on our website, to, among other things, better serve you with tailored information and facilitate your ongoing access to and use of our website.

Analytics. We work with service providers (including Google Analytics) who conduct analytics to help us track and understand how visitors use our website. Google Analytics is a web analytics service provided by Google that uses cookies to help us analyze how users use our website. The information generated by the cookies about your use of the services will be transmitted to and stored by Google on servers in the United States. If you access our website through different devices, Google may associate your devices with one another. Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js).

You can prevent Google’s collection and use of the data it collects as defined in its policy by downloading this browser plug-in: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

For more information about Google Analytics cookies, please see Google’s help pages (https://support.google.com/analytics/answer/6004245) and privacy policy (https://www.google.com/intl/en/policies/privacy/).

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Do Not Track

Your browser or device may include “Do Not Track” settings or functionality. Currently, our systems do not recognize browser “Do Not Track” requests. For more information about Do Not Track signals, please visit: https://allaboutdnt.com/.

Restricting the Collection of your Personal Data

You may have the right to restrict the use and collection of your personal data, or to request that the personal data Akuna has collected be deleted. These rights vary dependent on the jurisdiction in which you reside. Please contact privacypolicy@akunacapital.com if you have any questions or requests regarding this Policy.

Information for California Residents

The following section of this Policy only applies to California residents.

Collection

Akuna collects certain personal data pertaining to individuals who reside in California (“CA Personal Data”). In the prior 12 months, Akuna collected the following CA Personal Data, which Akuna will continue to collect:

• Identifiers: including but not limited to name, telephone number, address, age, email address, or date of birth;
• Characteristics of protected classifications under California or federal law: including but not limited to sex, gender, or age;
• Commercial information: including but not limited to financial account information, health information, medical information, or health insurance information;
• Internet or other electronic network activity information: including but not limited to computer and connection information;
• Audio, visual, or similar information: including but not limited to photographs, security camera video, audio, or recordings; andInferences drawn from the above categories of CA Personal Data.

Sources

Akuna collects certain categories of CA Personal Data directly from individuals and, in some circumstances, third parties. The categories of sources that Akuna collected CA Personal Data from in the prior 12 months includes the following:

• Akuna’s internal and external websites;
• Akuna’s third-party service providers; and
• Data subject communication with Akuna.

Disclosures to Third Parties

We do not sell CA Personal Data.

The categories of third parties that Akuna has disclosed CA Personal Data to in the prior 12 months includes the following:

• Third party service providers; and
• Akuna affiliates.

California Privacy Rights

The California Consumer Privacy Act (the “CCPA”) grants individuals, that are California residents, certain rights with respect to our collection of personal data. These rights include:

• The right to request the disclosures of (1) what personal data has been collected; (2) the categories of sources from which the personal data was collected; (3) the business or commercial purpose for collection or selling personal data; (4) the categories of third parties with whom Akuna shares personal data; and (5) the specific pieces of personal data Akuna has collected;
• The right to request the deletion of their personal data that has been collected;
• The right to request the correction of their personal data that has been collected;
• The right to opt-out of the sharing of their personal data that is shared for cross-contextual behavioral advertising purposes;
• The right to opt-out of the sale of their personal data;
• The right to limit Akuna’s processing of sensitive data to what is necessary; and
• The right to not be discriminated against due to their exercise of their rights under the CCPA. Akuna does not discriminate against individuals for exercising the rights granted to them under the CCPA.

Under the CCPA, a data subject can only make a request for disclosure twice in a 12-month period. Akuna will respond to such requests within 45 days of receiving the request.

Exercising Your Rights

To exercise your rights as described herein, you may submit a verifiable request by contacting us at privacypolicy@akunacapital.com. We will respond to requests within the applicable timeframe required by the CCPA. Akuna reserves the right to decline data subject requests to the extent permitted by law, for example with respect to Akuna’s legitimate business purposes as defined by the CCPA.