Privacy Policy

Last updated: January 16, 2024

This Privacy Policy includes important information about your personal data and we encourage you to read it carefully.

1. General information

This Privacy Policy applies to the mobile app Kintro (hereinafter - the App) operated by Kintro Limited (hereinafter – we, Kintro) and its associated website https://www.kintro.co/ (hereinafter – the Website). Unless otherwise specified under specific sections, this Privacy Policy applies to both the App and the Website.

The services offered by us via the Website and/or App (hereinafter jointly referred to as the Platform) can function only if we collect, store, transfer, delete and/or otherwise use ("collect and use") specific data relating to you. Personal data means all information relating to an identified or identifiable natural person such as your name, date of birth, address or email address.

We follow the requirements of the so-called European Union General Data Protection Regulation (GDPR) and other laws protecting information about you at Kintro. To know more please carefully read this Privacy Policy.

More details about how to get in contact with us can be found under Sections 3 and 9 of this Privacy Policy.

Our Privacy Policy supplements the Kintro terms and conditions hereinafter – the Terms) that form the basis of your contract with Kintro. By using the Platform, you enter into a legally binding contract between you and Kintro conditions of which are described in the Terms.

2. How and when should I read this Privacy Policy?

This Privacy Policy describes which of your data we collect and for what purposes we collect and use it when you use the services offered by us on the Platform. This Privacy Policy also contains important information on the protection of your data, especially the statutory rights you have in connection with it. This is important to you – please read this Privacy Policy carefully.

Certain services on our Platform are offered by third-party suppliers. When you use these services, the data protection regulations of the third-party suppliers will then apply in addition to this data protection statement. Prior to your use of such services, the third-party suppliers may require you to provide permission under data protection law.

This policy may be amended from time to time. Please visit our Website and/or App once in a while - you will find the latest version of this policy there.

3. Who is responsible for protecting my information?

We are: Kintro Limited

Our company number is: 304932414

Our address is: 20-22 Wenlock Road, London, N1 7GU, United Kingdom

Our e-mail address: support@kintro.co

4. Why and how do you collect and use my data?

4.1. To enable you to use the Platform, allow us to provide our services and perform our Terms

In order to provide our services and perform a contract (our Terms) with you, enable you to undertake commercial transactions via the Platform, buy and sell meetings or to leave reviews, communicate with other members and enable other functionality of the Platform, we collect and use your personal data. To use the Platform, you need to have a Kintro account.

Most of your personal data are required to perform a contract (the Terms) with you. In case you do not provide us with this personal data, we will not be able to conclude and execute a contract (the Terms) with you. Part of your data are required to fulfill our legal obligations when you are a member of our Platform. In case you do not provide us with this personal data, we will not be able to comply with legal requirements and provide our services.

Unless stated otherwise below, Kintro collects and uses your personal data for as long as we keep your Kintro account - for 30 days from the date you request us to delete your Kintro account or for 5 years of inactivity on your account.

4.1.1. To enable registration on the Platform

When you register as a member on the Platform, you must provide the following data in order to complete the registration procedure and access your Kintro account:

Full name;

Location;

Email address (necessary unless you register with an Apple account);

Password (necessary unless you register with a Facebook or Apple account);

Headline (optional);

Profile picture (optional).

Legal basis for the collection and use of data is the performance of a contract (the Terms) to which you are party or in order to take steps at your request prior to entering into a contract (the Terms) (Art. 6 (1) (b) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.2. To determine your location

When you register on the Platform, we will use your IP address to determine your general location (country and city or region) at the time of registration to show your profile for the purpose of helping other members to plan their meetings with people nearby. You can at any time choose to change your location (country and city or region) under "Edit Profile" on your Kintro account.

Legal basis for the collection and use of data is the legitimate interest of Kintro and our members to make meeting planning easier and more efficient (Art. 6 (1) (f) of the GDPR).

With your consent, we will determine your more precise location (district of a city that you are in) from various sources (GSM radio cells, GPS location, WLAN etc.) in order to further facilitate meetings of our members nearby. If you wish to revoke your permission, you can at any time prevent your location data being collected in the future by adjusting the settings in your mobile device or web browser. If you do so, you may no longer be able to use the Location Services.

Legal basis for this collection and use of data is your consent (Art. 6 (1) (a) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.3. To authenticate via Facebook and Apple

If you register using your Facebook Ireland Ltd. (Ireland), Facebook, Inc. (USA) (hereinafter - Facebook) or Apple Inc. (USA) (hereinafter – Apple) account, you will be transferred from our Platform to a separate Facebook or Apple login window and asked to enter the log-in details for your Facebook or Apple account.

If you enter your Facebook log-in details, Kintro will receive from Facebook the following data from your Facebook account (you may choose not to provide your full name and/or profile photo):

Profile picture;

Full name;

Email address.

If you enter your Apple log-in details, Kintro will receive from Apple the following data from your Apple account (you may choose not to provide your email address):

Full name;

Email address.

The data we obtain from Facebook or Apple will be used to set up your Kintro account. Link between your Kintro and Facebook or Apple accounts will also be used to enable you to access your Kintro account.

Collection and use of data are based on your consent (Art. 6 (1) (a) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.4. To enable you to complete your profile

If you decide to add additional profile details to the account you create on the Platform, we collect and use the following data when you choose to provide it:

Headline;

Profile picture;

Information that you choose to provide in the “About me” field.

Legal basis for such collection and use is your consent (Art. 6 (1) (a) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.5. To show other members relevant information regarding your activity on the Platform

When you are a registered member on the Platform, we collect, use and make public on the Platform the following information for the purpose of providing other members with the relevant information:

Number of admirers;

Number of people that you admire;

Checkmark symbol if your account has been verified;

Number of meetings with other users;

Overall review rating/score;

Insight count.

Legal basis for such collection and use is our legitimate interest to ensure that our members would access important information about each other (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.6. To enable you to create new topics and insights

If you create new topics on the Platform, we will collect and use the following data for the purpose of creating and publishing your topics and insights on the Platform:

Topic title;

Topic description including your experience with a particular topic;

Photo or image;

Description of service offerings (option title, price, duration, option icon);

Selection of a charity and percentage given to that particular charity.

In order to publish your topics and insights on the Platform, you will need to complete and activate your profile – upload your profile picture, add a description and verify your email address.

Legal basis for such collection and use is your consent (Art. 6 (1) (a) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.7. To enable notifications for you

When you are a registered member on the Platform, we will provide you with push notifications regarding general system updates, reminders regarding your meetings with other members, new messages from other members, meeting suggestions and arrangements, your new admirers and other important messages.

Legal basis for the collection and use of data is the performance of a contract (the Terms) to which you are party (Art. 6 (1) (b) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.8. To enable you to communicate with other members

If you communicate with other members on the Platform, we collect and use the following data:

Name of the member you are communicating with;

Message contents;

Date and time of messages;

Your device;

Information whether the other member has seen your messages;

Other data submitted in messages.

Legal basis for the collection and use of data is the performance of a contract (the Terms) to which you are party (Art. 6 (1) (b) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.9. To confirm your identity

When you write your introduction message to another member, we will ask additional information to confirm your identity in order to ensure the safety of our members. For this, Kintro collects and uses the following data:

Email address;

Your photo;

Photo of your ID.

Legal basis for the collection and use of data is the legitimate interest of Kintro and its members to make meetings with other members safer (Art. 6 (1) (f) of the GDPR).

Photo of your ID is directly transferred to our service provider Veriff OÜ (Estonia) that provides us with Document Verification services.

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.10.

If you approach another member in order to organize a meeting, we will collect and use the following data:

Chosen talk (meeting) option;

Meeting location;

Meeting time and date.

Legal basis for the collection and use of data is the performance of a contract (the Terms) to which you are party (Art. 6 (1) (b) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.11. To enable you to leave reviews to other members on the Platform

If you leave reviews to other members, Kintro collects and use the following data for the purpose of making reviews publicly available on the Platform:

Review;

Keywords that best describe your meeting;

Member name;

Date and time of the review.

Legal basis for such collection and use is your consent (Art. 6 (1) (a) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.12. To receive reviews from other members

When you receive reviews from other members, we will collect and use the following data for the purpose of making reviews publicly available on the Platform:

Review;

Keywords that best describe your meeting;

Member name;

Date and time of the review.

Legal basis for such collection and use is the legitimate interest of our members and Kintro to build trust among Kintro members (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.13. To send you important communication regarding the Platform

If you register on the Platform, we will send you e-mails and/or push notifications (when you use the App) for the purpose of providing important notifications e.g. the Terms, Privacy Policy changes.

Legal basis for the collection and use of data is the performance of a contract (compliance with our Terms) to which you are party (Art. 6 (1) (b) of the GDPR) and compliance with the legal obligations to which Kintro is subject (Art. 6 (1) (c) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.1).

4.1.14. To provide you with customer support service

If you send us query, request or complaint, we will collect and use the following data for the purpose of providing you with customer support services you request on the Platform:

Your profile information;

Platform usage information;

Transaction information;

Communications;

Age;

Gender;

IP address;

Session information;

Topic listings and photos;

Inquiries;

Other information submitted by you.

The type of information we collect can vary depending on your inquiry.

Legal basis for the collection and use of data is the performance of a contract (the Terms) to which you are party (Art. 6 (1) (b) of the GDPR).

In order to send the customer support services, Kintro uses email.

Personal data collected and used for this purpose are kept for 2 years from the day the request is resolved.

4.1.15. To resolve any purchase-related disputes between members

If you purchase and/or sell and/or swap items on the platform and get involved in a dispute with another member, we will collect and use any of your personal data held by Kintro necessary to solve the dispute.

We base such collection and use on a legitimate interest to settle disputes between our members and defend the rights and interests of Kintro (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for 1 year from the date you request us to delete your Kintro account or for 5 years of inactivity on your account.

4.1.16. To retain temporarily your deleted account

If you decide to delete your account, we will take reasonable efforts to make sure it is no longer viewable on the Platform. For up to 30 days it is still possible to restore your account if it was accidentally or wrongfully deactivated or in case you change your mind and wish to return to the Platform and take action in case someone else would gain access to your account and delete it without your knowledge.

Legal basis for such storage of your data is the legitimate interest of Kintro and our members to restore your account when necessary (Art. 6 (1) (f) of the GDPR).

Personal data are kept for this purpose for 30 days from the date of deletion of your Kintro account.

4.2. To improve your experience when using the Platform

We collect and use your personal data in order to improve your experience when using the Platform by sending you notifications and otherwise making the use of the Platform more pleasant.

Unless stated otherwise below, Kintro collects and uses your personal data for as long as we keep your Kintro account - for 30 days from the date you request us to delete your Kintro account or for 5 years of inactivity on your account.

4.2.1. To send you push notifications on your phone

If you install our Mobile App, we will send you push notifications alerting you about general updates from the system, new messages from other members, reminders about upcoming meetings, meeting suggestions and arrangements, notifications about members who follow you.

Legal basis for such collection and use is our legitimate interest to provide our members with notifications that we deem relevant to them (Art. 6 (1) (f) of the GDPR).

You can at any time go to Push Notification Settings on your Kintro account and turn off some or all types of push notifications.

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.2).

4.2.2. To improve our Platform

We are committed to the best performance of the Platform. When the Platform is being used, Kintro gathers information about actions performed on the Platform (button clicks, visiting time, notifications read, other information depending on a particular business case) and other data described under 4.1, 4.2, 4.4 and 0 of this Privacy Policy in order to help us make decisions on how to improve the Platform and make it a better experience for our members.

Legal basis for such collection and use is our legitimate interest to maintain performance and improve the Platform (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.2).

4.3. To ensure the security of your account and the Platform, supervise compliance with and enforce the Terms

Kintro strives to ensure that the accounts of our members and the Platform itself would be secure and protected from cyber-attacks, unauthorized access and other related risks. At the same time, we actively supervise compliance with and enforce our Terms.

Unless stated otherwise, Kintro collects and uses your personal data for as long as we keep your Kintro account - for 30 days from the date you request us to delete your Kintro account or for 5 years of inactivity on your account.

4.3.1. To track visits to the Platform for security purposes

When you connect to the Website or App, we collect and use the following data (logfiles), even if you are not logged in as a member:

IP address of your device;

Browser used by your device;

Content and URLs you connect to;

Date and time of your connections.

In the event of access via mobile devices, the following log files are also captured as part of your use of the App:

Model and manufacturer of your mobile device;

Operating system used by your mobile device (iOS, Android).

This data is used for security purposes, especially the prevention of cyber-attacks such as data scraps and denial of service attacks and for preventing impermissible multiple applications.

Legal basis for such collection and use is our legitimate interest to protect the Platform and its users and ensure its security and the legitimate interest of our members to ensure their safety on the Platform (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for 6 months.

4.3.2. To moderate your activity on the Platform

In order to ensure the security of the Platform and its members we regularly moderate your activity on the Platform. We may check your listings proactively (automatically) or we may check your listings, comments, messages when we receive other members’ reports.

If you communicate with another Kintro member via private messages we collect and use information contained in your introduction (first) message to prevent spam or illegal activities on the Platform.

Legal basis for such collection and use is our legitimate interest to protect the Platform and its users and ensure its security and the legitimate interest of our members to ensure their safety on the Platform (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.3).

4.3.3. To issue and enforce warnings

If you as a member violate our Terms or take other actions that result in a warning being issued to you, we collect and use the following data to issue and enforce the warning:

Username;

Kind of warning received by member;

Date of warning received by member.

Legal basis for such collection and use is our legitimate interest to protect the Platform and its users and ensure its security and the legitimate interest of our members to ensure their safety on the Platform (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.3).

4.3.4. To enforce bans

If you violate the Terms in a way that results in you getting banned, we will use your ban reason, time and your profile data.

Legal basis for such collection and use is our legitimate interest to protect the Platform and its users and ensure its security and the legitimate interest of our members to ensure their safety on the Platform (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for 1 year from the moment you have been blocked.

4.4. To enable purchases of meetings

Payments on the Platform are carried out via payment service provider that provides payment processing and escrow services.

Unless stated otherwise below, Kintro collects and uses your personal data for as long as we keep your Kintro account - for 30 days from the date you request us to delete your Kintro account or for 5 years of inactivity on your account.

4.4.1. To allow you to add a bank card for payments

When you add a bank card or purchase items via the Platform, we collect and use the following data for the purpose of allowing you to make payments:

Full name;

Last four digits of your credit card number;

Expiration date.

When you add a bank card or purchase items via the Platform, our payment service provider Stripe, Inc (Ireland) (hereinafter - Stripe) receives the following data:

Full name;

Credit card number;

Expiration date;

Security code (CVV/CVC) number.

Legal basis for the collection and use of data is the performance of a contract (compliance with the Terms) to which you are party (Art. 6 (1) (b) of the GDPR).

Personal data are required to perform a contract (the Terms) with you. In case you do not provide us with this personal data, we will not be able to conclude and execute a contract (the Terms) with you.

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.4).

4.4.2. To allow you to add a bank account for withdrawal purposes

When you add a bank account to withdraw payments received via the Platform, we collect and use the following data for the purpose of allowing you to receive payments:

Account holder’s name;

Account number;

Address;

Phone number;

Date of birth;

Last 4 digits of the social security number (for the US members).

Legal basis for the collection and use of data is the performance of a contract (compliance with the Terms) to which you are party (Art. 6 (1) (b) of the GDPR).

4.4.3. To enable you to pay and/or receive payments on the Platform

If you sell your items on the Platform, to be able to sell your products on the Platform, you need to accept the payment service provider Stripe Terms an conditions. This happens during the onboarding flow on our website. In accordance with the Stripe Terms and Conditions, Kintro will share personal data about you with Stripe. Stripe processes this information in accordance with applicable laws and with the Stripe Privacy Policy.

If you buy items on the Platform, Stripe will collect the payment information required according to the payment method selected (e.g. credit card etc.) and needed to verify and process your transaction. To this extent, the data protection regulations of Stripe and the relevant payment service provider will apply.

We do not receive your full card data (we only receive data described in 4.4.1 above) as this data is masked and forwarded to the Stripe handling the transaction. This information will be used by us solely for the purpose of confirming payment.

Kintro uses the services of Stripe in order to generate on its payment page the input fields to collect payment data. The purpose of this processing is determined by Kintro, as the publisher of the Platform and its payment page. However, Stripe determines the data input fields and communicates with the payment service provider selected by Stripe.

If you need to contact Stripe directly, you can contact their data protection officer at the following email address: dpo@stripe.com. We acknowledge that you may, in general, contact either Kintro or Stripe to exercise your respective rights. Kintro and Stripe will forward your request to the other party where this is needed for fulfilling data subject’s rights.

Legal basis for the collection and use of data is the performance of a contract (compliance with the Terms) to which you are party (Art. 6 (1) (b) of the GDPR).

Personal data are required to perform a contract (the Terms) with you. In case you do not provide us with this personal data, we will not be able to conclude and execute a contract (the Terms) with you.

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.4) or for 13 months from the day of transaction, whichever period is longer.

4.4.4. To implement Know Your Customer (KYC) checks

Whenever you are about to reach a pay-in or pay-out threshold, Stripe will request you to provide a copy of your passport, ID card or driver’s license, including the provisional license. In that case, Stripe will collect and use the following data in order to allow Stripe as a payment service provider to perform a safety check (so-called Know Your Customer, KYC):

Full name;

Date of birth;

Country;

Address;

Information present on the provided document (exact list depends on the document provided): document number, picture, gender, nationality, date of issue, date of expiry, place of birth, personal code, signature, other information on a particular document.

As a separate safety check, Stripe may also request a photo/screenshot of the bank statement listing transactions of one-month period. In that case, Stripe collects and uses the following information:

Full name;

Date of birth;

Country;

Address;

Information present on the provided statement: account owner’s full name, transaction history (deposits, charges, withdrawals) and other information present on a particular statement.

This is necessary in order for Stripe to receive necessary information for them to comply with the legal obligations to which Stripe is subject (Art. 6 (1) (b) of the GDPR).

Personal data collected and used for the aforementioned purpose is transferred directly to our payment service provider Stripe.

4.4.5. To issue refunds

If a seller fails to show up to the agreed upon meeting with a buyer, or buyer deems that the meeting was not as agreed upon or is unhappy with the meeting, we collect and use the data used to make a purchase (see 4.4.1 above) for the purpose of issuing a refund to the buyer’s account.

Legal basis for the collection and use of data is the performance of a contract (compliance with the Terms) to which you are party (Art. 6 (1) (b) of the GDPR).

Personal data are required to perform a contract (the Terms) with you. In case you do not provide us with this personal data, we will not be able to conclude and execute a contract (the Terms) with you.

Transaction data are kept for 13 months from the day of transaction.

4.4.6. To keep financial records

If you participate in purchase-sale and/or other transactions when using the Platform, Kintro will collect and use the following data in order to carry out its accounting-related duties:

Full name;

Address;

VAT identification number (where applicable);

Value and description of supplied goods and/or services.

This is necessary in order to comply with the legal obligations to which Kintro is subject (Art. 6 (1) (c) of the GDPR).

Financial regulations require us to keep accounting documents that confirm the transactions for 10 years.

In order to send the keep its financial records, Kintro uses accounting services provided by Clever Accounts Limited (United Kingdom) and for this purpose shares personal data.

4.5. To carry out marketing activities

We seek to present you with marketing material and try to ensure that it would be both relevant and engaging.

4.5.1. To send you marketing messages via email

If you register on our Platform and become its user, Kintro will send you our newsletter and for other marketing emails (hereinafter - Marketing Emails) containing the latest information on our products and services, special offers and marketing campaigns.

We base such collection and use on our legitimate interest to present you as our customer with marketing messages that we consider relevant to you (Art. 6(1)(f) of the GDPR, Art. 69(2) of UK Law on Electronic Communications).

Your permission for the sending of Marketing Emails can be given and withdrawn by you at any time with future effect. You can click "Unsubscribe" at the end of the Marketing Email. Withdrawal of permission will not affect the lawfulness of collection and use carried out prior to withdrawal of permission.

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account - for 30 days from the date you request us to delete your Kintro account or for 5 years of inactivity on your account, unless you unsubscribe from our Marketing Emails prior to that.

In order to send the Marketing Emails, Kintro uses services provided by SendGrid, Inc. (USA) and for this purpose shares personal data. Data are protected in accordance to Standard Contractual Clauses.

4.5.2. To evaluate the efficiency of promotional campaigns

When you use the Platform, Kintro analyzes its marketing activities and how you use the Platform (when you register, login, create a listing, sell or swap or purchase something, upload an item’s photo, open our App, register or install the app, etc.) for the purpose of evaluating the efficiency of promotional campaigns, and to better comprehend the behavior of visitors after they have looked at a certain ad and visited our Platform or downloaded our App.

We base such collection and use on our legitimate business interest to evaluate efficiency of our promotional campaigns in order to improve them (Art. 6 (1)(f) of the GDPR).

In order to carry out the aforementioned evaluating, we use services provided by the following service providers and for this purpose transfer personal data:

Adjust GmbH (Germany);

Looker Data Sciences, Inc. (USA). Data are protected in accordance to Model Contractual Clauses.

In order to optimize our advertising campaigns, we send certain information on your activities like app opens, sessions, registrations, logins, information about you listing an item, uploading item’s photo or buying an item, etc. to Google and Facebook advertising platforms. Thus, we transfer the data of your activities to the following recipients:

Facebook. Data are protected in accordance to Model Contractual Clauses;

Google. Data are protected in accordance to Model Contractual Clauses.

Personal data collected and used for this purpose are kept until they are anonymized, or, at the latest, for as long as we keep your Kintro account - for 30 days from the date you request us to delete your Kintro account or for 5 years of inactivity on your account.

4.5.3. To manage our social media profiles

If you are interested in our activity and follow our profiles on social media, we collect and use the following data about you in order to manage our social networking sites:

Name and surname;

E-mail address;

Gender;

Country;

Picture;

Message;

Time and date the message was received;

Content of the message;

Message attachments;

Response to the message;

Time of response to the message;

Information about Company’s rating;

Comments on a post;

Post shares;

Information about post reactions.

We base such collection and use on our legitimate interest to manage our social media profiles (Art. 6(1)(f) of GDPR).

In order to manage our social media accounts, we receive and provide data to the following social media platform operators:

LinkedIn Ireland Unlimited Company (Ireland);

LinkedIn Corporation (USA) (data is protected in accordance to Model Contractual Clauses);

Facebook Ireland Ltd. (Ireland);

Facebook, Inc. (USA) (data is protected in accordance to Model Contractual Clauses);

Twitter, Inc. (USA) (data is protected in accordance to Model Contractual Clauses).

Personal data collected and used for this purpose are kept as long as you are registered on a specific social media network.

4.6. For legal purposes

Sometimes we need to collect and use personal data in order to protect the rights of Kintro and/or its members or to comply with the legal obligations.

4.6.1. To handle your requests related to personal data

If you use your statutory rights regarding your data (see 6 below), we will collect and use the data contained in your request in addition to any other personal data held by Kintro for the purpose of examining the request, responding to it and, when necessary, taking necessary action.

We base such collection and use on a legitimate interest to exercise our members’ rights (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for two years from the day we respond to your request.

4.6.2. To provide information to law enforcement and other state institutions

If we have reasonable grounds to suspect that you are involved in illegal activities, we will collect and use necessary data of your profile data (see 4.1), data related to your purchases on the Platform (see 4.4) and data collected and used for security purposes (see 4.3.1) in order to notify the law enforcement and other state institutions.

Kintro also provides the aforementioned data to the law enforcement and other state institutions when we receive requests for information in relation to investigations carried out by these institutions.

This is necessary in order to comply with the legal obligations to which Kintro is subject (Art. 6 (1) (c) of the GDPR).

Personal data are required to fulfill our legal obligations when you are a member of our Platform. In case you do not provide us with this personal data, we will not be able to comply with legal requirements.

4.6.3. To defend the rights and interests of Kintro

If you get involved in a dispute with Kintro or we need to carry out enforcement of our Terms or otherwise defend, enforce, exercise and uphold our rights, we will collect and use all of your personal data held by Kintro to the extent necessary to resolve a particular situation.

We base such collection and use on a legitimate interest to defend the rights and interests of Kintro (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for 1 year following the moment we became aware of the aforementioned circumstances or for the duration of a dispute or legal proceedings, depending on which one of these periods is longer.

5. What are the recipients of my personal data?

Kintro transfers or shares personal data with service providers only insofar as necessary and allowed in accordance with applicable laws. Service providers to which your personal data are transferred or shared with for specific purposes are described under 4 above. In addition, we appoint the following service providers that, as a result, receive personal data as recipients of data.

We constantly conduct and improve technical maintenance of the Platform to protect the security and confidentiality of personal data we process and to perform certain business-related functions that help make our services available and functional. For this reason, we transfer your profile data to service providers which provide cloud and hosting services, IT security, maintenance and technical services, communications services:

Amazon Web Services, Inc. (USA) (data are protected in accordance to Model Contractual Clauses);

Salesforce.com, Inc. (USA) (data are protected in accordance to Model Contractual Clauses);

Rapid7, Inc., Rapid7 LLC (USA) (data are protected in accordance to Model Contractual Clauses);

New Relic, Inc. (USA) (data are protected in accordance to Model Contractual Clauses);

One More Cloud, Inc. (USA) (data are protected in accordance to Model Contractual Clauses);

Slack Technologies, Inc. (USA) (data are protected in accordance to Model Contractual Clauses);

Bugsnag Inc. (USA) (data are protected in accordance to Model Contractual Clauses);

BeLive Studios Ltd. (UK);

Google Ireland Ltd. (Ireland), Google LLC (USA) (data are protected in accordance to Model Contractual Clauses);

Apple Distribution International (Ireland), Apple Inc. (USA) (personal data is protected by the service provider entering into the EU Standard Contractual Clauses for the transfer of data as approved by the European Commission);

Microsoft Ireland Operations Limited (Ireland), Microsoft Corporation (USA) (data are protected in accordance to Model Contractual Clauses).

You may download a copy of the Model Contractual Clauses at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en. We transfer personal data to attorneys, attorney’s assistants, notaries, bailiffs, auditors, consultants, IT service providers, insurance companies, archiving services that provide services to Kintro.

Kintro is statutorily obligated to provide personal and/or usage data to investigative, criminal prosecution or supervisory authorities if and insofar as required for the avoidance of risk to the public and for the prosecution of criminal acts.

Kintro may share your data with third parties when transferring rights and obligations pertaining to the contractual relationship between you and Kintro to such third parties in accordance with the Terms, in particular in the case of the transfer of a sector of activity, a merger through the foundation of a new company, a merger through absorption, de-merger or any change in control affecting Kintro. Prior to such an event Kintro will inform you separately about the details of sharing your data and will obtain your consent where legally necessary.

6. What statutory rights do I have regarding my data?

Subject to conditions, limitations, and exceptions established by statutory data protection provisions, you have the right at any time:

to be informed of the data we collect and use and to request access or demand a copy of the data concerned (right to be informed). All the data that you have actively provided for us on the Platform (4.1 and 4.4) can also be accessed by you at any time in your Kintro account;

to demand the correction of inaccurate data and, subject to the nature of the collection and use, the completion of incomplete data (right to rectification). All the data that you have actively provided us with on the Platform (4.1 and 4.4) can also be amended by you yourself at any time in your Kintro account (except sent messages and any forum posts or reviews);

subject to just cause, to demand the deletion of your data (right to deletion);

to demand restriction of the collection and use of your data, provided the statutory criteria are met (right to restrict processing);

subject to the statutory criteria being met, to receive the data you have provided in a structured, current and machine-readable form and to transfer this data to another processor or, where technically feasible, to have it transferred by Kintro (right to data portability);

not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, unless the statutory conditions for such automated decision-making are met;

to object to the collection and use of data – only where the collection and use is based on a task carried out in the public interest or in the exercise of official authority vested (Art. 6 (1)(e) of GDPR) or legitimate interest (Art. 6 (1)(f) of GDPR), including profiling, based on the same data collection and use grounds as explained in other sections of this statement (right to object). You also have the right to at any time object to the collection of your personal data for direct marketing purposes;

to withdraw at any time any permission you have provided to us. Such withdrawal will not affect the lawfulness of collection and use carried out prior to withdrawal and based on the permission granted;

not to receive discriminatory treatment while exercising your rights.

To exercise any of the rights specified in this section, you can contact Kintro and submit your request using the contact details (9 below). Regardless of any other legal remedy, you also have the right at any time to submit a complaint to the supervisory authorities.

7. Do you use cookies?

Yes, we use cookies on our Website as described in the table below.

Cookie Category Cookie name Cookie purpose Cookie expiry

Strictly necessary cookie _ cfduid This cookie is used to distinguish users 1 month

Strictly necessary cookie Kintro_session Session cookie 1 week

Strictly necessary cookie Kintro_session.sig Session cookie 1 week

Third - party analytics cookie _ ga This cookie is used by Google analytics to distinguish visitors 2 years

Third - party analytics cookie gat grag UA 137570010_1 This cookie is used by Google Analytics to limit the frequency of queries 1 minute

Third - party analytics cookie _ gid This cookie is used by Google Analytics to distinguish visitors 24 hours

8. How can I manage cookies?

You can configure your browser to decline some or all cookies or to ask for your permission before accepting them. Please note that by deleting cookies or disabling future cookies you may be unable to access certain areas or features of our website. For information on how to adjust or change your browser settings, visit www.aboutcookies.org or www.allaboutcookies.org.

For the information on, policy and control options for the third-party cookies, please read cookie policies of such third parties.

You can control the use of functionality cookies, targeting cookies or advertising cookies by adjusting your browser settings.

To find out how to manage cookies in your browser, please visit one of the links below:

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Google Chrome: https://support.google.com/chrome/answer/95647

Opera: https://www.opera.com/help/tutorials/security/privacy

Internet Explorer: https://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies

Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

9. What are your contact details?

If you have any questions, comments or complaints regarding how we collect, use and store information about you, Kintro has Data Protection Officer to help you. If you need his / her help, please send an e-mail to support@kintro.co. Alternatively, you can send a letter:
Kintro Limited

Data protection officer

20-22 Wenlock Road

London

N1 7GU

United Kingdom

Personal data are required to perform a contract (the Terms) with you. In case you do not provide us with this personal data, we will not be able to conclude and execute a contract (the Terms) with you.

Personal data collected and used for this purpose are kept for as long as we keep your Kintro account (see 4.4).