ECOSYSTEM PRIVACY POLICY
SHARED PREFACE
Applicability to All Three Companies
This Privacy Policy (“Policy”) applies collectively to Kune Reevolution Ltd, Sagacelo Ltd, and Cointelligent Ltd (the “Companies”) in the Ecosystem. Each entity offers distinct services but adheres to a unified approach to user data privacy and protection.
Independent Yet Unified
By interacting with the Ecosystem, you consent to the data practices described in this Policy. “We,” “us,” or “our” refers collectively to the Companies unless explicitly stated otherwise.
Scope
This Policy explains how we collect, store, process, share, and protect personal data in compliance with applicable data protection regulations, including the EU General Data Protection Regulation (GDPR) and Irish data protection laws.
1. DEFINITIONS
- Personal Data: Information that can identify you directly or indirectly, such as your name, email address, or IP address.
- Processing: Any operation performed on Personal Data, including collection, recording, organization, storage, adaptation, use, disclosure, and deletion.
- Controller: The entity deciding how and why Personal Data is processed. In this Ecosystem, each Company is jointly responsible for certain data processing activities, while others may be handled independently.
2. INFORMATION WE COLLECT
2.1 Information Provided by You
- Registration Data: Name, email address, date of birth (to confirm eligibility), user preferences, location, etc.
- Profile Information: Usernames, photographs, and any optional details you add to your profile.
- Communications: Messages or submissions you share on our platforms.
2.2 Information Collected Automatically
- Log Data: IP addresses, browser type, device identifiers, and access timestamps.
- Cookies and Tracking Technologies: We may use cookies and similar technologies to improve user experience, analytics, and for security purposes. Refer to our Cookies Policy (if separate) for details.
2.3 Information from Third Parties
- Partners: If you opt to connect with our Partners, additional data may be shared or integrated.
- Public Sources: We may supplement user data with publicly available information (e.g., social media profiles).
3. HOW WE USE YOUR INFORMATION
3.1 Service Provision and Personalization
- To create and manage your account(s) within the Ecosystem.
- To personalize content, features, and user experiences.
3.2 Communication
- To send you important notices or updates related to Ecosystem changes, security alerts, or new features.
- To respond to your inquiries, feedback, and support requests.
3.3 Analytics and Improvement
- To gather insights and usage statistics that help improve the Ecosystem’s offerings.
- To conduct research, surveys, or tests for new feature development.
3.4 Legal Compliance
- To comply with applicable laws, regulations, and legal processes.
- To enforce our Terms of Service and other legal agreements.
3.5 Marketing and Promotion
- With your consent or where permitted by law, to send promotional materials about events, services, or partner offers.
4. LEGAL BASES FOR PROCESSING
Where the GDPR applies, we rely on various legal bases to collect and process Personal Data, including:
- Consent: You have given clear consent for us to process your Personal Data for specific purposes.
- Contractual Necessity: Processing is required for the performance of a contract you enter with us (e.g., Terms of Service).
- Legitimate Interests: Where processing is in our legitimate interests and not overridden by your data-protection rights.
- Legal Obligation: Where we must comply with a legal or regulatory obligation.
5. DATA SHARING AND TRANSFERS
5.1 Within the Ecosystem
Data may be shared among the Companies to deliver unified services, improve integration, and maintain consistent user experiences. Each Company respects the shared commitment to data privacy and dignity.
5.2 With Partners
If you choose to interact with or join Partner services within the Ecosystem, specific data will be shared with your explicit consent.
5.3 Third-Party Service Providers
We may use third-party service providers (e.g., cloud hosting, payment processors) bound by contractual obligations to protect and use Personal Data only for authorized purposes.
5.4 International Data Transfers
If Personal Data is transferred outside the EU or EEA, we take measures to ensure adequate protections, such as Standard Contractual Clauses, in line with GDPR requirements.
6. DATA RETENTION
We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting obligations. Where possible, we will anonymize or securely delete data when it is no longer needed.
7. YOUR RIGHTS
Under the GDPR and other data protection laws, you may have the following rights (depending on your jurisdiction):
- Access: Request confirmation on whether your Personal Data is being processed and to obtain a copy.
- Rectification: Correct inaccuracies in your Personal Data.
- Erasure: Request deletion of your Personal Data, subject to legal limitations.
- Restriction: Limit how we process your Personal Data in certain circumstances.
- Portability: Obtain and reuse your Personal Data for your own purposes across different services.
- Objection: Object to certain types of processing, such as direct marketing or processing based on legitimate interests.
- Withdrawal of Consent: Where we rely on your consent, you may withdraw it at any time.
To exercise these rights, please contact us using the details in Section 10 below.
8. SECURITY MEASURES
We employ technical and organizational measures to safeguard Personal Data from unauthorized access, disclosure, alteration, or destruction. While no security system is foolproof, we continuously review and update protocols to mitigate potential risks.
9. CHILDREN’S PRIVACY
Our services are not available to individuals under the age of 16 or the local age of digital consent if higher. We do not knowingly collect Personal Data from children. If we become aware of such data, it will be deleted.
10. CONTACT DETAILS
For questions about this Policy or to exercise your data protection rights, you may reach us via:
- Email: [email protected]
11. UPDATES TO THIS POLICY
We may update this Policy to reflect changes in our practices or legal requirements. Updates will be posted with a revised “Last Updated” date at the top of the document. Continued use of our services after such updates constitutes acceptance of the revised Policy.