1. Introduction
LKS BROTHERS LLC, doing business as LKSB (“LKS BROTHERS LLC,” “LKSB,” “we,” “us,” or “our”), respects your privacy and is committed to protecting Personal Information. This Privacy and Cookies Policy (“Policy”) explains how LKS BROTHERS LLC collects, uses, discloses, retains, transfers, and protects Personal Information in connection with our website, business activities, market-entry services, partnership and investment-related activities (including Water Purification), communications, events, and other interactions that link to or reference this Policy. This Policy is intended to provide clear notice of our privacy practices, including the categories of Personal Information we collect, the purposes for which we use Personal Information, the categories of parties to whom we may disclose Personal Information, the choices and rights that may be available to you, and the ways in which cookies and similar technologies may be used on our website. This Policy does not create contractual rights beyond those required by applicable law. Where a more specific written agreement, notice, consent, or legally required disclosure applies to a particular product, service, transaction, or relationship, that more specific document will govern to the extent it conflicts with this Policy.
2. Important Terms
Throughout this Policy, the following terms have the meanings set out below:
- “LKS BROTHERS LLC,” “LKSB,” “we,” “us,” or “our” means LKS BROTHERS LLC, a Nevada limited liability company, and its affiliates.
- “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information does not include publicly available information, aggregated information, or de-identified information as defined under applicable law.
- “Sensitive Personal Information” means Personal Information that may be treated as sensitive under applicable privacy laws, such as government identification numbers, financial account credentials, precise geolocation, racial or ethnic origin, citizenship or immigration status, health information, biometric information, or other data that receives heightened legal protection.
- “Services” means our website, business activities, market-entry services, partnership and investment inquiry processes, communications, events, digital properties, and any other interaction that links to or references this Policy.
- “Investment Activities” means any activities related to the evaluation, structuring, fundraising, management, operation, or reporting of investment opportunities, including due diligence on investors and investment opportunities, investor relations, capital raising, capital calls, distributions, and related compliance matters.
- “Cookies” means small files or similar identifiers that may be stored on a browser, device, or application to recognize a user, remember preferences, understand site usage, improve performance, or support security and marketing functions.
3. Scope of this Policy
This Policy applies to Personal Information that we collect or process through our Services, including when you visit our website, submit a business inquiry, request information, participate in meetings or events, communicate with us by email or other channels, engage with our business development materials, or provide information in connection with a potential transaction, partnership, consulting engagement, investment-related discussion, or U.S. market entry matter. This Policy does not apply to third-party websites, platforms, products, or services that we do not control, even if they are linked from our website or communications. Those third parties are responsible for their own privacy practices. If you provide Personal Information about another person to us, you represent that you have the authority to do so and, where required by law, that you have provided that person with appropriate notice and obtained any required consent.
4. Sources of Personal Information
We may collect Personal Information from a variety of sources depending on how you interact with us and the nature of the relationship we have with you. The sources may include:
- Directly from you, such as when you submit a contact form, send an email, participate in a meeting, provide business cards, deliver project materials, sign up for updates, or request information about our services.
- From your company, employer, organization, advisor, authorized representative, or business partner, including where they provide your contact details or professional information in connection with a business inquiry, transaction, engagement, or project.
- From public and commercially available sources, such as corporate websites, public registries, professional directories, event attendee lists, business databases, and publicly available social or professional media profiles.
- Automatically through technology when you use our website or digital services, including through cookies, log files, analytics tools, pixels, local storage, and similar technologies.
- From service providers, advisors, counterparties, platforms, and other third parties that support our operations, security, analytics, communications, due diligence, compliance, or business development activities, including activities related to Investment Activities.
5. Personal Information We Collect
The categories and examples below describe the types of Personal Information that we may collect. Not every category will be collected from every person, and the information we collect may vary depending on your relationship with us, your jurisdiction, the Services you use, and the information you choose to provide.
- Identifiers, such as name, email address, phone number, mailing address, company name, job title, account name, online identifier, or other contact information.
- Professional and business information, such as employer, role, industry, business history, professional background, project role, business card information, partnership interests, investment-related inquiry details, and U.S. market entry objectives.
- Investment and Investor-Related Information, such as information provided in connection with investment inquiries, investor accreditation, investment objectives, risk tolerance, financial information, investment history, capital commitment details, and related documentation. This includes information collected during due diligence processes for Water Purification and other Investment Activities.
- Due Diligence and Compliance Information, such as information reasonably necessary to evaluate a business relationship, confirm authority, conduct know-your-investor (KYI) procedures, anti-money laundering (AML) and sanctions screening, assess conflicts, support legal compliance, or complete onboarding procedures. This includes information collected in connection with Investment Activities.
- Commercial and transaction-related information, such as records of inquiries, services requested, proposals, engagement details, meeting notes, project documents, service preferences, business needs, and communications related to transactions or potential transactions.
- Communications information, such as emails, messages, meeting records, attachments, feedback, questions, call notes, contact preferences, and records of interactions with LKSB personnel.
- Internet, device, and network activity information, such as IP address, browser type, device identifiers, operating system, referring URLs, pages viewed, links clicked, access times, approximate location inferred from IP address, and other usage data.
- Cookie and tracking information, such as cookie identifiers, analytics identifiers, advertising identifiers, pixel data, browser settings, session information, and information about how visitors interact with our website.
- Inferences and preferences, such as language preference, communication preference, areas of business interest, service preferences, or other observations derived from your interactions with us.
- Sensitive Personal Information, if voluntarily provided by you or required for a specific legal, compliance, security, or transaction-related purpose in connection with Investment Activities. LKS BROTHERS LLC does not generally require Sensitive Personal Information for ordinary website inquiries. We ask that you not provide Sensitive Personal Information unless it is necessary for a specific purpose and requested or permitted by us. If you provide unnecessary Sensitive Personal Information, we may delete, restrict, or decline to process it where appropriate.
6. How We Use Personal Information
We may use Personal Information for the following business, operational, legal, and commercial purposes:
- To respond to inquiries, communicate with you, schedule meetings, provide requested information, and manage business correspondence.
- To evaluate, structure, support, and facilitate U.S. market entry, partnership, investment-related, consulting, business development, or transaction discussions.
- To conduct due diligence, know-your-investor (KYI) procedures, anti-money laundering (AML) and sanctions screening, conflict checks, and other compliance activities where appropriate, including in connection with Investment Activities.
- To prepare and deliver investor reports, financial statements, tax documents, capital call notices, distribution information, and other required communications to current and prospective investors.
- To manage investor relations, including ongoing communication with investors regarding investment performance, opportunities, and related matters.
- To provide, administer, improve, and personalize our Services, including preparing proposals, conducting research, supporting project delivery, maintaining records, and managing client or partner relationships.
- To enter into, perform, administer, and enforce agreements, terms, policies, and other arrangements with clients, partners, vendors, advisors, or counterparties.
- To operate, secure, analyze, and improve our website, systems, data, networks, and business processes.
- To send administrative, operational, legal, regulatory, security, service, and business communications.
- To send marketing or informational communications where permitted by law and consistent with your communication preferences.
- To protect the rights, property, security, and safety of LKS BROTHERS LLC, our personnel, our clients, our partners, website users, and others.
- To comply with applicable laws, regulations, legal process, regulatory inquiries, court orders, contractual obligations, and internal policies.
- To establish, exercise, or defend legal claims, resolve disputes, manage risk, conduct audits, and maintain appropriate business records.
- For other purposes that are disclosed to you at the time of collection, that are compatible with the context in which the information was collected, or that are otherwise permitted by applicable law.
7. Legal Bases for Processing
Where the General Data Protection Regulation, the UK GDPR, or similar privacy laws apply, we process Personal Information on one or more of the following legal bases:
- Performance of a contract, including where processing is necessary to provide requested services, respond to pre-contractual inquiries, manage an engagement, or administer a business relationship.
- Legitimate interests, including our interests in operating our business, responding to inquiries, managing professional relationships, improving our website and services, maintaining security, preventing fraud, conducting appropriate due diligence, and communicating about relevant business matters.
- Compliance with legal obligations, including obligations relating to recordkeeping, tax, accounting, sanctions, anti-fraud, regulatory, litigation, or other legal requirements.
- Consent, where we rely on consent under applicable law, such as for certain cookies, marketing communications, or processing activities that require consent. You may withdraw consent at any time where processing is based on consent.
8. Disclosure of Personal Information
We may disclose Personal Information to the categories of recipients described below when appropriate for the purposes described in this Policy:
- Service providers and vendors that support website hosting, analytics, customer relationship management, communications, scheduling, document management, security, professional support, information technology, cloud storage, marketing, payment, or administrative functions.
- Professional advisors, including lawyers, accountants, auditors, consultants, insurers, banks, and other advisors who assist with business, legal, tax, compliance, risk, or transaction matters.
- Current and prospective investors, their advisors, and representatives, where disclosure is necessary or appropriate in connection with Investment Activities, due diligence processes, investor reporting, capital calls, distributions, or related matters.
- Fund administrators, custodians, transfer agents, auditors, and other service providers engaged to support the administration, compliance, and operation of Investment Activities.
- Business partners, counterparties, and project participants where disclosure is necessary or appropriate to evaluate, structure, negotiate, or perform a potential or existing business relationship, project, investment-related inquiry, market entry engagement, or transaction.
- Government authorities, courts, regulators, law enforcement agencies, or other parties where required or permitted by applicable law, regulation, subpoena, court order, legal process, or regulatory request.
- Successors or transaction parties in connection with a proposed or actual merger, acquisition, financing, investment, reorganization, restructuring, sale, transfer, bankruptcy, or other corporate transaction involving all or part of our business or assets.
- Other parties with your direction, authorization, or consent, or as otherwise disclosed at the time of collection. LKS BROTHERS LLC does not sell Personal Information for monetary consideration. We may use cookies or similar technologies that could be considered a “sale” or “sharing” under certain U.S. state privacy laws if they involve cross-context behavioral advertising or certain analytics and advertising activities. Where required, we provide applicable opt-out rights.
10. Analytics, Advertising, and Tracking Choices
We may use analytics and measurement tools provided by third parties to help us understand website traffic, site performance, visitor behavior, and the effectiveness of our communications. These tools may use cookies or similar technologies to collect usage information and generate reports. We may also use advertising or audience tools where permitted by law to support business communications and understand the effectiveness of marketing activities. These tools may process identifiers such as email address, cookie identifiers, device identifiers, or online activity information to help deliver, measure, or improve relevant content. Where legally required, we will provide appropriate consent mechanisms or opt-out options for non-essential cookies and targeted advertising activities. You may also use industry opt-out tools, browser privacy settings, cookie controls, or device-level settings to limit certain tracking activities. Some browsers transmit “Do Not Track” signals. There is currently no consistent industry standard for responding to such signals. Where legally required, we will honor legally recognized browser-based opt-out preference signals, such as Global Privacy Control, for applicable activities.
11. International Data Transfers
LKS BROTHERS LLC may process and transfer Personal Information outside the country, state, province, or region where it was collected, including to the United States and other jurisdictions that may not provide the same level of data protection as your home jurisdiction. When we transfer Personal Information internationally, we take steps designed to provide appropriate protection consistent with applicable law. These safeguards may include contractual protections, Standard Contractual Clauses, data processing agreements, transfer impact assessments, technical and organizational safeguards, or other lawful transfer mechanisms. By interacting with us or using our Services, you understand that your Personal Information may be processed in jurisdictions outside your place of residence, subject to applicable law and this Policy.
12. Data Security
We maintain reasonable administrative, technical, and organizational measures designed to protect Personal Information from unauthorized access, disclosure, alteration, misuse, loss, or destruction. These measures may include access controls, authentication procedures, data minimization practices, confidentiality obligations, vendor oversight, secure storage, network protections, and internal policies. No method of transmission or storage is completely secure. Although we take reasonable steps to protect Personal Information, we cannot guarantee that unauthorized access, disclosure, loss, or misuse will never occur. You should use caution when transmitting information to us and should not send sensitive information through unsecured channels unless instructed to do so.
13. Data Retention
We retain Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, to provide and improve our Services, to manage our relationship with you, to comply with legal and regulatory obligations, to resolve disputes, to enforce agreements, to maintain appropriate business records, and to protect our rights and interests. The retention period may vary depending on the type of information, the context in which it was collected, the nature of the relationship, applicable legal or regulatory requirements, limitation periods, the sensitivity of the information, and whether retention is necessary for security, fraud prevention, audit, tax, accounting, or legal purposes. Investor-related information and information processed in connection with Investment Activities may be retained for extended periods to satisfy ongoing regulatory, tax, reporting, and audit obligations. When Personal Information is no longer needed, we will take reasonable steps to delete, de-identify, aggregate, archive, or otherwise handle the information in accordance with applicable law and our record retention practices.
14. California Privacy Rights
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), may provide you with specific rights regarding Personal Information. This section is intended to supplement the rest of this Policy and applies only to California residents where the law applies. Depending on the circumstances and subject to applicable exceptions, California residents may have the right to:
- Know the categories and specific pieces of Personal Information we have collected about you.
- Know the categories of sources from which Personal Information is collected, the purposes for collection, use, disclosure, sale, or sharing, and the categories of third parties to whom Personal Information is disclosed.
- Request deletion of certain Personal Information we collected from you.
- Request correction of inaccurate Personal Information we maintain about you.
- Opt out of the sale or sharing of Personal Information, where applicable.
- Limit certain uses or disclosures of Sensitive Personal Information where the right applies.
- Not be discriminated or retaliated against for exercising applicable privacy rights. In the preceding 12 months, we may have collected the categories of Personal Information described in Section 5, used them for the purposes described in Section 6, and disclosed them to the categories of recipients described in Section 8. We do not knowingly sell or share Personal Information of minors under 16 years of age. To exercise California privacy rights, please contact us using the information in the Contact Us section. We may need to verify your identity or authority before fulfilling a request. You may also designate an authorized agent to submit a request on your behalf where permitted by law. We will respond to verified requests within the time required by applicable law. If we deny a request in whole or in part, we will provide an explanation where required by law and, where applicable, instructions for appeal.
15. EEA and UK Privacy Rights
If you are located in the European Economic Area or the United Kingdom, you may have rights under the General Data Protection Regulation (GDPR), the UK GDPR, or similar applicable data protection laws, subject to legal limitations and exceptions. These rights may include:
- The right to access Personal Information we hold about you.
- The right to request correction of inaccurate or incomplete Personal Information.
- The right to request deletion of Personal Information in certain circumstances.
- The right to request restriction of processing in certain circumstances.
- The right to object to processing based on legitimate interests or direct marketing.
- The right to data portability where processing is based on consent or contract and carried out by automated means.
- The right to withdraw consent at any time where processing is based on consent.
- The right to lodge a complaint with a competent supervisory authority. To exercise these rights, please contact us using the information in the Contact Us section. We may request additional information to verify your identity, confirm your jurisdiction, or evaluate your request. We will respond to verified requests within the time required by applicable law. If more time is needed, we may notify you and explain the reason for the extension. If we deny a request in whole or in part, we will provide an explanation where required by law and, where applicable, instructions for appeal.
16. Other U.S. State Privacy Rights
Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws. Depending on your state and the circumstances, these rights may include the right to access, correct, delete, obtain a copy of, or opt out of certain processing of Personal Information, including targeted advertising, sale of Personal Information, or profiling that produces legal or similarly significant effects. If a state privacy law applies to your request, we will respond in accordance with that law. You may submit a request by contacting us using the information in the Contact Us section. We may verify your identity and may deny or limit a request where an exception applies. If you have a right to appeal a decision under applicable law, we will provide instructions for submitting an appeal in our response.
17. Marketing Communications and Communication Preferences
We may send you business, service, administrative, legal, security, and transactional communications. These communications are not promotional and may be necessary for our relationship with you or for legal, operational, or security purposes. Where permitted by law, we may also send marketing, newsletter, event, or business development communications. You may opt out of marketing emails by following the unsubscribe instructions in the email or by contacting us. Even if you opt out of marketing communications, we may continue to send non-marketing communications where permitted or required by law. You may also manage certain communications through your browser, device, email client, or platform settings.
18. Use of Artificial Intelligence and Automated Tools
We may use artificial intelligence, machine learning, automation, and similar technologies to support our business operations and improve efficiency. These tools may assist with tasks such as search, translation, transcription, summarization, drafting, data organization, analytics, document review, risk review, and operational support. When Personal Information is processed through such tools, we use reasonable measures designed to protect confidentiality, limit unnecessary data use, and maintain human oversight where appropriate. Our use of these tools is generally intended to support or enhance human work and does not generally result in decisions that produce legal or similarly significant effects without appropriate review or notice where required by law. We may update our practices regarding artificial intelligence as technologies, laws, and business needs evolve.
19. Children and Minors
Our Services are intended for business and professional users and are not directed to children. We do not knowingly collect Personal Information from individuals under 18 years of age. If you believe that a child has provided Personal Information to us, please contact us so that we can take appropriate steps, which may include deletion of the information where required by law.
20. Third-Party Websites, Platforms, and Services
Our website or communications may contain links to third-party websites, platforms, social media pages, applications, plug-ins, tools, or services. LKS BROTHERS LLC does not control and is not responsible for the privacy practices, security, content, policies, or terms of those third parties. Your interactions with third-party websites and services are governed by the privacy notices and terms of those third parties. We encourage you to review those notices before providing Personal Information or using third-party services.
21. Your Responsibilities
You are responsible for ensuring that the Personal Information you provide to us is accurate, complete, and current. If your information changes, you may contact us to update it. You should not send confidential, sensitive, privileged, or regulated information to us unless it is necessary for a specific matter and we have provided an appropriate channel or instruction for submitting that information. If you send information through ordinary email or unsecured channels, you acknowledge that those channels may not provide heightened security.
22. De-Identified, Aggregated, and Anonymous Information
We may create or use de-identified, anonymized, or aggregated information for lawful business purposes, including analytics, service improvement, market research, operational reporting, benchmarking, security monitoring, and business planning. This type of information is designed so that it does not identify a specific individual and is not reasonably capable of being linked to a specific individual. Where we maintain de-identified information, we will take reasonable measures designed to prevent re-identification except where permitted by applicable law, such as for testing whether the de-identification measures remain effective. We may disclose aggregated or de-identified information to business partners, advisors, service providers, or other parties for lawful purposes.
24. Data Accuracy, Minimization, and Confidentiality
We seek to collect Personal Information that is reasonably necessary and proportionate to the purposes described in this Policy. We encourage you to provide only information that is relevant to the matter for which you are contacting us. If you believe that Personal Information we maintain about you is inaccurate or incomplete, you may contact us to request correction. Information provided to LKS BROTHERS LLC in a business context may include confidential business information, proprietary materials, or non-public transaction information. This Policy addresses Personal Information and does not replace any separate confidentiality agreement, nondisclosure agreement, engagement letter, or contractual confidentiality obligation that may apply to business information or project materials. We may restrict access to Personal Information and confidential materials to personnel, advisors, service providers, or other parties who have a legitimate need to access the information for the relevant business, legal, compliance, operational, or security purpose.
25. Business Contact Information
Because LKS BROTHERS LLC primarily operates in a business-to-business context, much of the information we collect may relate to individuals acting in a professional capacity. Business contact information may include name, company, title, business email address, business phone number, office address, professional background, and records of business communications. We may use business contact information to manage relationships, respond to inquiries, provide requested materials, schedule meetings, evaluate opportunities, deliver services, maintain records, and communicate about relevant business matters. Depending on your jurisdiction, some business contact information may still be treated as Personal Information and may be subject to privacy rights.
26. Accessibility and Alternative Formats
If you require this Policy or related privacy information in an alternative format due to a disability or accessibility need, please contact us using the information in the Contact Us section. We will make reasonable efforts to provide the information in an accessible format consistent with applicable law.
27. Changes to this Policy
We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, business operations, or Services. When we update this Policy, we will revise the Effective Date above and post the updated version on the applicable page or otherwise make it available as appropriate. Material changes will apply as required by applicable law. Your continued use of our Services after an updated Policy is posted or otherwise made available means that you acknowledge the updated Policy, subject to any consent requirements under applicable law.
28. Contact Us
If you have questions about this Policy, our privacy practices, or your privacy rights, you may contact us at:
LKS BROTHERS LLC
Email: info@lksbrothers.com