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Privacy Policy

Last updated: June 2026
Kynera Inc. is committed to responsible data handling in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the EU General Data Protection Regulation (GDPR). This Policy describes what information Kynera collects, how it is used, and the rights available to individuals.
1. Who this policy applies to

This Policy applies to individuals who visit the Kynera website, inquire about or engage Kynera's services, or whose personal data Kynera processes in the course of client engagements. It does not govern data processed on behalf of clients within client-owned systems, which is subject to the applicable engagement agreement.

2. Information we collect

Information you provide directly:

Name, email address, company name, role, and phone number submitted through website forms.
Business information shared during initial consultations or engagement scoping.
Communications conducted via email or other channels.

Information collected automatically:

Website usage data including pages visited, time spent, and navigation paths.
Technical data including IP address, browser type, device type, and operating system.
Analytics and tracking data collected via cookies and similar technologies, as described in the Kynera Cookie Policy.

Information received from third parties:

Business contact information from publicly available sources or professional networks in the context of outreach.
Information provided by referral partners or existing clients in connection with a potential engagement.

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3. How we use your information

Kynera uses personal information for the following purposes:

Responding to inquiries and communications.
Evaluating and scoping potential client engagements.
Delivering contracted services and managing active client relationships.
Sending service-related communications and updates relevant to active engagements.
Improving the Kynera website and understanding how visitors interact with it.
Complying with applicable legal obligations.

Kynera does not use personal information for automated decision-making that produces legal or similarly significant effects on individuals.

4. Legal basis for processing (GDPR)

For individuals located in the European Economic Area or United Kingdom, Kynera processes personal data on the following legal bases:

Contract performance — processing necessary to deliver services pursuant to an engagement agreement.
Legitimate interests — responding to inquiries, improving services, and conducting business development activities, where such interests are not overridden by individual rights.
Consent — where explicitly obtained, including for certain marketing communications and non-essential cookies.
Legal obligation — where processing is required to comply with applicable law.

5. Data sharing and subprocessors

Kynera does not sell personal data. Kynera may share personal data with:

Service providers and subprocessors — third-party tools used to operate the website and deliver services, including analytics platforms, CRM systems, and communication tools. These providers are contractually bound to process data only as directed by Kynera.
Implementation partners — where an engagement involves a third-party platform partner, relevant data may be shared with that partner pursuant to the applicable engagement terms and partner data agreements.
Legal and regulatory authorities — where required by applicable law, court order, or regulatory obligation.

Where personal data is transferred outside Canada or the EEA, Kynera implements appropriate safeguards consistent with PIPEDA and GDPR requirements.

6. Data retention

Kynera retains personal data for as long as necessary to fulfil the purposes described in this Policy, and in accordance with applicable legal requirements.

Contact and inquiry data is retained for up to three years following last contact.
Data associated with active or completed client engagements is retained for a minimum of seven years for legal and accounting purposes.
Website analytics data is retained in accordance with the terms of the applicable analytics platform.

7. Kynera platform products

Where Kynera operates a proprietary software platform on a subscription basis, client data processed within that platform is governed by a separate Data Processing Agreement. Kynera may use aggregated, anonymized usage data derived from platform operations to improve platform functionality and train associated models. No personally identifiable information is used for this purpose without explicit agreement.

8. Your rights

Subject to applicable law, individuals may have the right to:

Access personal data held about them.
Request correction of inaccurate or incomplete data.
Request deletion of personal data, subject to legal retention obligations.
Object to or restrict certain processing activities.
Withdraw consent where processing is based on consent.
Lodge a complaint with the applicable supervisory authority.

Requests may be submitted to info@kynera.com. Kynera will respond within the timeframe required by applicable law.

9. Security

Kynera implements appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures are reviewed and updated as appropriate given the nature of the data and the risks involved.

10. Changes to this policy

Kynera may update this Privacy Policy from time to time. Material changes will be communicated with reasonable notice via the Kynera website. The effective date at the top of this document reflects the most recent revision.

11. Contact

For privacy-related inquiries or to exercise your rights, contact Kynera at info@kynera.com or at the registered address of Kynera Inc., Ontario, Canada.

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