Effective Date: February 21th, 2024
Elevate Eco s.r.o., Reg. number 21273006, a company registered at Cimburkova 916/8, Žižkov (Praha 3), 130 00 Praha (“Company”, "we," "us," or "our") owns and operates crypto platform https://kunava.io (the "Platform"). We are committed to protecting each User’s personal data in accordance with the highest standards and as bound by the laws of the Czech Republic. By accessing or using the Platform, you consent to the practices described in this Privacy Policy (the “Policy”). By using the Platform, you acknowledge that you have read and understood this Privacy Policy and agree to its terms and conditions. If, for some reason, you do not agree with this Policy, you shall cease to use the Platform and any of the services offered by the Platform.
1.
GDPR Compliance
Our Platform complies with the General Data Protection Regulation (GDPR), which is a European Union (EU) regulation designed to protect the privacy and personal data of EU residents. We are committed to ensuring that your personal information is processed in accordance with the GDPR's principles and requirements.
2.
GDPR Principles
2.1. Lawfulness, Fairness, and Transparency: We process your personal information lawfully, fairly, and in a transparent manner. We will always provide you with clear information about how we collect, use, and store your data.
2.2. Purpose Limitation: We collect your personal information for specified, explicit, and legitimate purposes. We do not process your data in a manner that is incompatible with these purposes.
2.3. Data Minimization: We only collect and process personal information that is necessary for the purposes we have specified. We strive to minimize the amount of personal data we collect and retain.
2.4. Accuracy: We take reasonable steps to ensure that your personal information is accurate and kept up to date. You have the right to request correction of any inaccurate data we hold about you.
2.5. Storage Limitation: We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by law. We regularly review the data we hold and securely delete any information that is no longer needed.
2.6. Integrity and Confidentiality: We implement appropriate technical and organizational measures to ensure the security and confidentiality of your personal information. We protect your data against unauthorized or unlawful processing and accidental loss, destruction, or damage.
2.7. Accountability: We take responsibility for our data processing activities and have implemented measures to demonstrate our compliance with GDPR requirements. We maintain records of our data processing activities and have appointed a Data Protection Officer to oversee data protection matters.
3.
Data Controller
The Company acts as the data controller for the personal information we collect and process through our Platform. As the data controller, we are responsible for determining the purposes and means of processing your personal data.
Our contact details as the data controller are outlined below:
Elevate Eco s.r.o.
Cimburkova 916/8, Žižkov (Praha 3), 130 00 Praha
[email protected]
If you have any questions, concerns, or requests regarding the processing of your personal information or if you wish to exercise your rights under the GDPR, you can contact us using these contact details.
We are committed to cooperating with data protection authorities and will resolve any complaints or disputes regarding the use and disclosure of personal information in accordance with the GDPR's principles. The information under Your request to exercise any of the data privacy rights will be provided to you free of charge, unless the Company determines that your request is manifestly unfounded or excessive. The Company aims to take proper care of any and all User Information, however, should there occur a data privacy breach, the Company undertakes to remedy the breach and immediately notify the affected data owners in written.
4.
Information We Collect
4.1. Personal Information:
We may collect personal information that can identify you as an individual or is reasonably linked to you. The types of personal information we collect may include, but are not limited to:
· Full name;
· Contact information (email address, phone number);
· Date of birth;
· National identification number;
· Photographs or other forms of identification;
· Cryptocurrency wallet addresses;
· Transaction history;
· User-generated content.
4.2. Non-Personal Information:
We may also collect non-personal information about you automatically when you use the Platform. This may include:
· Device information (such as IP address, browser type, operating system);
· Usage information (such as pages visited, actions taken);
· Cookies and similar technologies.
5.
How We Use Your Information
5.1. We may use the information we collect from you for the following purposes:
· To provide and maintain the Platform;
· To verify your identity and prevent fraud;
· To process transactions and facilitate cryptocurrency exchanges;
· To improve and personalize your experience on the Platform;
· To communicate with you about the Platform and provide customer support;
· To send you promotional and marketing communications (solely upon your consent and even following the consent was granted, you can opt-out of these communications at any time);
· To comply with applicable laws, regulations, and legal processes;
· To protect our rights, privacy, safety, or property, and that of our users or others.
6.
How We Share Your Information
6.1. We may share Your Information with third parties if 1) required by law; 2) to allow proper operation of the Platform (for the purposes of servicing the Platform, including providing customer service and marketing assistance, performing business and sales analysis, supporting the Platform’s functionality, surveys and other features offered through the Platform); 3) in case there is another legitimate interest.
Any data gathered will be shared, if appropriate, with any of the offices of the Company and any third parties who provide services on our behalf, solely within the extent of the consent you have provided. User Information that we collect may be transferred within our offices in the Czech Republic (or outside of the country), in which case if any third party processes User Information, we will list such third parties within this Policy.
Although unlikely, in certain instances we may be required to provide User Information in response to a court order, subpoena, or government investigation. We may release certain User Information when we believe that such a release is reasonably necessary to enforce or apply our Privacy Policy, to abide by the laws, where applicable, or to protect the interests and/or safety of the Company. We may also share User Information in the event of a merger, restructuring, reorganization, dissolution or other sale or transfer of some or all of Company’s assets, liquidation or similar proceeding, where applicable.
In case the Company shares User Information with third parties, such third parties will be bound to use it only for the purposes for which we disclose it to them and in line with the consent that you have submitted with respect to your User Information and such third parties will be bound by the obligations related to User Information processing of the same level of data protection. User Information will be shared with those employees, agents and third-party providers on a need-to-know only basis and subject to non-disclosure undertaking.
We reserve the right, and you hereby expressly authorize us, to share User Information in the cases listed above.
You may request from the Company the list and categories of your data that are shared with third parties at:
[email protected].
6.2. The Platform may have links to other websites operated by other companies and not covered by this Privacy Policy. We do not accept any responsibility or liability for other websites’ privacy policies. The Company is not responsible for the privacy practices of any third-parties, and you should contact such third-parties directly to determine their respective privacy policies.
6.3. We do not sell or rent your personal information to third parties for marketing purposes.
7.
Data Security
We implement reasonable security measures to protect the confidentiality and integrity of your personal information. However, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.
8.
Data Transfer Outside EU
We may need to transfer and process your personal information outside the European Union (EU) or the European Economic Area (EEA). This may occur if our service providers or partners are located in countries outside the EU/EEA or if we need to store data on servers located in such countries.
When transferring your personal information to countries outside the EU/EEA, we take appropriate measures to ensure the security and lawful processing of your data. These measures may include:
· We may transfer your data to countries that the European Commission has determined to have an adequate level of data protection.
· Contractual obligations that require the recipient of the data to protect your personal information to the same standards as required within the EU/EEA.
· In certain situations, we may rely on your explicit consent as a legal basis for transferring your personal information outside the EU/EEA.
9.
Data Retention
We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. The specific retention period may vary depending on the type of data and the purposes for which it was collected:
· Account Information:
We will retain your account information for as long as you maintain an active account with our Platform. If you request the deletion of your account, we will securely delete your account information within a reasonable timeframe, unless retention is necessary for legal, regulatory, or legitimate business purposes.
· Transaction Data:
We may retain transaction data, including transaction history, for a certain period of time to comply with legal and regulatory obligations, prevent fraud, resolve disputes, and enforce our terms of service. This retention period may exceed the duration of your account with us.
· Compliance with Legal Obligations:
We may retain your personal information for longer periods if required by applicable laws, regulations, or governmental authorities. This may include retaining data to comply with tax obligations, accounting requirements, or other legal obligations that are applicable to our business operations.
· Aggregated and Anonymized Data:
We may retain and use aggregated and anonymized data derived from your personal information, which does not identify you personally, for as long as needed for various purposes, including statistical analysis, improving our services, and marketing activities.
10.
Children's Privacy
The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided personal information to us, please contact us, and we will delete such information.
11.
Use of Cookies
11.1. What are cookies?
Cookies are small text files that are placed on your device (computer, tablet, or mobile device) when you visit the Platform. They store information about your visit, such as your preferences and actions, which can be retrieved and recognized by the Platform during subsequent visits. Cookies enable us to provide you with a more personalized and efficient browsing experience.
11.2. Types of cookies We use
We use the following types of cookies on our Platform for different purposes:
Necessary Cookies:
· PHPSESSID: This cookie is essential for the Platform to function properly. It maintains the user's session and enables the Platform to recognize you as you navigate through different pages.
Purpose: Session management and user authentication.
Analytical Cookies:
· sbjs_migrations, sbjs_current_add, sbjs_first_add, sbjs_current, sbjs_first, sbjs_udata, sbjs_session: These cookies are set by our third-party analytics service to collect anonymous information about Platform usage, user behaviour, and preferences.
Purpose: Platform analytics and improvement of user experience.
· cc4r_geo: This cookie stores geographical information to provide location-specific content and services.
Purpose: Geolocation functionality for personalized content and services.
· wp_mkg_uid: This cookie is used to track the user's interactions with marketing campaigns and measure their effectiveness.
Purpose: Marketing campaign tracking and performance measurement.
· _gid, ga: These cookies are set by Google Analytics, a widely used analytics service. They collect information about how visitors use Platform, such as which pages are visited most frequently and if they encounter any error messages. The information collected is aggregated and anonymous, and it helps us improve the performance and functionality of our Platform. For more information about Google Analytics cookies, please refer to Google's Privacy Policy.
Purpose: Platform analytics and performance enhancement.
Please note that the above list may not be exhaustive, and other cookies may be used on our Platform for similar purposes, in which case this policy will be modified and information on the types of Cookies will be supplemented. However, we strive to provide transparency and ensure that your privacy rights are protected.
11.3. How to manage cookies
You have the option to manage and control cookies through your browser settings. You can choose to accept or decline cookies, delete existing cookies, or set your browser to notify you when cookies are being sent. Please note that if you disable or reject cookies, some features of our Platform may not function properly, and your browsing experience may be affected.
Browser settings: You can typically find the cookie settings in your browser's "Options" or "Preferences" menu. The "Help" function within your browser should provide you with the necessary information on how to manage cookies.
Third-party tools: You can also opt-out of certain third-party cookies by using online tools or services that allow you to control and manage your cookie preferences.
For more information on how to manage cookies, you can refer to the help section of your browser or visit www.allaboutcookies.org.
11.4. Updates to use of cookies
We may update this Policy from time to time to reflect changes in our practices or legal obligations. We will notify you of any material changes by posting the updated Cookie Policy on our Platform. We encourage you to review this policy periodically to stay informed about how we use cookies and similar technologies.
12.
Your rights
As a user of our Platform, you have certain rights regarding your personal information. We are committed to respecting and facilitating the exercise of these rights. This section outlines the rights you may have under applicable data protection laws.
· Right to Access:
You have the right to request access to the personal information we hold about you. This includes information about the categories of data we process, the purposes of processing, the recipients or categories of recipients with whom we share your data, and the expected retention period. To exercise this right, please contact us using the contact details provided in this Privacy Policy.
· Right to Rectification:
If you believe that the personal information we hold about you is inaccurate or incomplete, you have the right to request the correction or amendment of your data. You can update certain information directly through your account settings on the Platform. For any other requests, please contact us, and we will promptly address your concerns.
· Right to Erasure:
You have the right to request the deletion of your personal information under certain circumstances. This includes situations where your data is no longer necessary for the purposes for which it was collected, you withdraw your consent, or you object to the processing and there are no overriding legitimate grounds for us to continue processing your data.
· Right to Restriction of Processing:
Under certain circumstances, you have the right to request the restriction of the processing of your personal information. This means that we will temporarily suspend processing your data but will not erase it. This right may apply, for example, if you contest the accuracy of your data or if you believe that the processing is unlawful, but you do not want your data to be deleted.
· Right to Data Portability:
You have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format and have the right to transmit that data to another data controller. This right applies when the processing is based on your consent or is necessary for the performance of a contract, and the processing is carried out by automated means.
· Right to Object:
You have the right to object to the processing of your personal information in certain circumstances, including when the processing is based on legitimate interests or for direct marketing purposes. Upon receiving your objection, we will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.
· Right to Withdraw Consent:
If we rely on your consent as the legal basis for processing your personal information, you have the right to withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of any processing based on consent before its withdrawal.
· Right to Lodge a Complaint:
If you believe that we have violated your rights under applicable data protection laws, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will make every effort to address and resolve your concerns.
13.
Modifications to this Privacy Policy
13.1. To improve the services we can offer you, the Company may choose to expand its capabilities for obtaining information about users in the future. If we modify this Privacy Policy, we will update the “Date Last Modified” and such changes will be effective upon posting.
13.2. Regardless of any changes we make to our Privacy Policy, we will always use your User Information in accordance with the version of the Policy in place at the time you provided your information, unless you give your express consent for us to do otherwise.
13.3. You should review this Privacy Policy regularly to ensure that you are aware of any amendments made.
14.
User Consent and Our Contacts
By using this Platform, you consent to the collection and use of information as specified above.
If you feel that we are not abiding by this Privacy Policy, if you have any questions or concerns about this Privacy Policy or want to exercise your rights, you should contact us at
[email protected].
If you do not accept this Privacy Policy, you should cease using the Platform.