Privacy Policy

Effective: November 19, 2020

Respecting and protecting investor privacy is vital to our business. This Privacy Policy describes how Kingswood Acquisition Corp. (together with its subsidiaries and affiliates, “Kingswood” “us”, “we” or “our”) gathers and uses personal information about you when you visit our website that links to this Privacy Policy (our “Website”); how we protect and share this information; and the rights you may have in relation to this information. Please read this Privacy Policy carefully, and consult our Terms of Use for more information about the general terms and conditions regarding your use of our Website.

A. The Types of Information We Collect

When you visit and browse our Website, you may provide us with information, and we will collect certain information automatically.

1. Information You Provide to Us

In order to access certain services provided via our Website or to request certain information from Kingswood via our Website, you will be required to provide certain personal information. This may include your

• Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
• Information You Submit. We may collect information when you send us a message through the “Contact Us” page or similar features on our Website.
• Social Media Information. We may collect information you post on our social media pages. We may also collect your social media profile information and information posted on your page.

2. Information We Collect Passively

We may also collect certain information from you passively when you visit or navigate our Website. This may include:

• Device Information. For example, we may collect the type of device you use to access our Platform. We may also collect your device identifier, IP address or mobile operating system.
• Other Information. If you use our Website, we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us.

3. Information We Receive From Third Parties

We may also collect information about you from third parties, or by combining information about you from multiple sources. This may include:

• Information From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from our business partners, including analytics vendors.
• By Combining Information. For example, we may combine information that we collect offline with information we collect through our Website. We may also combine information we collect about you from the different devices you use to access our Website.

B. How We Use the Information We Collect

We use information we collect about you primarily to: provide services to you in accordance with any contract with you, communicate with you, and manage and improve our services for you and our other investors, as permitted by applicable laws. We may use your personal information to:

• respond to your requests for forms, literature, or information, on the basis that it is in our business interests to respond to your requests, and you have requested that we do this;
• provide you with the services you have requested. In many cases we will provide these services to comply with contractual obligations to you, but if these services are not governed by any contract, we will use your information in this way to meet our business interests in providing the best service possible;
• prepare investor disclosure materials. This is necessary to comply with our legal obligations, to meet our interests in managing our business effectively, and for informing you and our other investors about how we are meeting your expectations;
• improve our Website and learn about how visitors use our Website. This is necessary for us to improve the services we offer through our Website, and benefits you as it helps us make our Website more usable and appealing;
• communicate with you about our products and services, including providing you with information about features on our Website and possible changes to our Privacy Policy or terms of use. If required by applicable law, we will only send these messages on the basis that you have consented, or otherwise it will be to meet our business interests in providing information to our investors about new products and features. You can opt out of receiving marketing communications at any time;
• comply with legal obligations; and
• protect our rights, your rights, and the rights of others, as this may be necessary to meet our own high standards of business practice.

We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with our Website for research about the use of our Website and how our Website could be improved, from which your interactions with our Website cannot be singled out.

C. How We Share the Information We Collect

1. Internally

We may share your information internally with our parent, subsidiary, and affiliate entities. This includes Kingswood Holdings Ltd.; Benchmark Investments, Inc., Benchmark Advisory Services, LLC, Kingswood Capital Partners LLC, and Kingswood Wealth Advisors LLC.

2. Service Providers

Sometimes we engage companies that act on our behalf in association with the operation of our Website. For example, such companies may deliver products or services, improve the functionality of our Website, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you.

We share personal information with service providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.

3. Analytics Providers

We engage third-party analytics providers to help us understand how users engage with our Website. These third-parties may use cookies and similar technologies to collect information about your use of our Website as well as information about your use of other websites over time.

We may share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.

4. Additional Sharing Practices

From time to time we share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above. We may also share your information for other reasons we may describe to you.

We may disclose information when we believe in good faith that such disclosures:

• are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency’s request;
• will help to protect our rights or enforce our Terms of Use;
• will support our detection, prevention, or response to fraud or intellectual property infringement;
• will help protect your safety or security, including the safety and security of property that belongs to you; and
• will protect the safety and security of our Website, databases, and/or third-parties, including the safety and security of tangible and/or intangible property that belongs to us or to third-parties.

We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.

The above-described disclosures are provided on the basis that they are either necessary to comply with our legal obligations or they are necessary to meet our legitimate interests in managing our business efficiently and for developing future business.

Additionally, we reserve the right to share with third parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.

D. Children Under 18

The Website where this Policy is located is meant for adults. We do not knowingly collect personal information from persons under the age of 18, and we strive to comply with the provisions of the Children’s Online Privacy Protection Act (COPPA). If you are a parent or legal guardian and think your child has provided us with information, please send us a message at

E. The Security Measures We Take to Safeguard Information

The security and confidentiality of the information we collect or receive is extremely important to us. However, the Internet is not 100% secure and we cannot promise that the Website will be completely safe. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. From time to time, we review and consider updates for our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

F. Updating Your Contact Information

You may update your contact information and/or modify your communication preferences by sending us an e-mail at [email protected]. Additionally, we may provide tools on our Website that facilitate such updates or modifications.

G. Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.

Third-parties, such as our analytics providers, may collect data that relates to you on our Website, across time, and over other websites. We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

H. California Privacy Rights

If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. If you wish to exercise those rights, please email us at [email protected]. Please include in your subject line “Shine the Light Request.”

I. Your Choices and Rights

If you no longer wish to receive marketing materials from us, you can let us know by contacting us at [email protected] or by clicking the ‘unsubscribe’ link or using other unsubscribe features that we provide in our marketing communications. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

Subject to local law, you may have certain additional rights regarding your personal information. These may include the following rights to:

• access your personal information;
• rectify the information we hold about you;
• erase your personal information; restrict our use of your personal information;
• object to our use of your personal information (as described above);
• receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability);
• and lodge a complaint with your local data protection authority, and withdraw any consent you have given to uses of your personal information.

If you would like to discuss or exercise the rights you may have, feel free to contact us at [email protected].

J. Where Is Information Processed?

Information we maintain may be stored in or outside of the United States (“U.S.”). Any information stored in the European Union (“EU”) is only retained for as long as they are needed. If you live outside of the U.S., you understand and agree that we may transfer your personal information to the U.S. or non-EU countries, in connection with the purposes set out in this Policy. This Website is intended for use in the U.S. and is subject to the laws of the U.S., which may not provide the same level of protections as those in your own country. For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your personal information collected in the EU to the U.S. or to another non-EU country, under circumstances that are within scope of General Data Protection Regulation (“GDPR”), which are not in adequate jurisdictions, we take steps as required by applicable law to protect the privacy and security of personal information.

K. How Long Is Information Retained?

We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended in accordance with applicable law.

When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.

L. Third-Party Links

Our Website may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third-party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third-party sites.

M. Amendments to This Privacy Policy

We may change this Privacy Policy from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Policy to review any changes. Your continued use of our Website after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.

N. How to Contact Us

If you have any questions regarding this policy or our privacy or data protection practices, please feel free to contact us at [email protected]