PRIVACY POLICY
Kuno Development Ltd. Privacy Policy
Last update: July 15, 2024
At Kuno Development Ltd. (hereafter "Kuno Development", "we", "us", "our"), protecting the privacy of our users is a top priority. This Privacy Policy explains how we collect, use, and share information when you use our product, OogaBooga, accessible via our website and application OogaBooga.io (collectively referred to as the "Interface").
This privacy policy is intended to inform you about the processing of your personal data when you access and/or use our Interface (the "Privacy Policy", the "Policy"). Therefore, it applies to all your interactions with us via our Interface. We advise you to read this Policy carefully to understand how we collect and process data and for which purpose.
This Privacy Policy does not apply to any processing of data collected via channels other than the Interface (including any other services or applications provided by third parties). For those, we advise you to consult the corresponding and applicable privacy policies.
1. Identity of the Data Controller
We, Kuno Development Ltd., act as the data controller of your personal data. This means we decide "why" and "how" your personal data is processed in connection with the Interface and in line with this Policy.
2. Categories of Data We Process
When you use the Interface, the categories of data we collect are limited to the following:
Data automatically collected when you use the Interface:
- IP Addresses and Browser Information: This includes your IP address, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. This data is collected automatically to enhance your experience and maintain security;
- Cookies and Tracking Technologies: We may use cookies and similar technologies to store information on your device. For more details, refer to Section 6 (Cookies and Tracking Technologies) of this Policy; and
- Behavioral data related to your use of the Interface: Content viewed, features accessed, and your status on our Interface, such as launches, taps, clicks, scrolling data, etc.
We do not collect private keys, wallet seeds, or any other sensitive personal data. Never trust anyone or any application that asks you to enter your private keys or wallet seed.
3. How and Why We Use Your Personal Data
We process your personal data for the following purposes and on the following legal bases:
| Purpose | Legal Basis | Categories of Data Concerned |
|---|---|---|
| To provide the Interface, assess, analyze, and improve performance, and perform maintenance work | Legitimate interest to optimize our tools and ensure user satisfaction | Personal data automatically collected as described under Section 2 |
| To communicate with you and answer your queries, and provide support | Legitimate interest to ensure proper communication | Personal data you provide as described under Section 2 |
| To maintain a secure environment, prevent fraud, and ensure security | Legitimate interest to ensure compliance with applicable laws and security | Personal data automatically collected as described under Section 2 |
| To comply with legal and regulatory obligations | Necessary for compliance with legal obligations | Personal data you provide and data automatically collected as described under Section 2 |
We do not process your personal data for any purpose that is incompatible with the purposes listed above;
We use your data to deliver and enhance the performance of our Interface. This is based on our legitimate interest to optimize our services and ensure user satisfaction; and
We use your data to maintain a secure environment, prevent fraud, and ensure compliance with legal obligations.
3. Sharing Your Personal Data
We may share your personal data with third parties under the following circumstances:
- Service Providers: To help us operate, provide, and enhance our services (e.g., analytics, security); and
- Legal Compliance: When required by law or necessary to protect our rights.
We ensure that any third parties with whom we share data adhere to strict data protection standards.
4. Transfer of Personal Data
We do not transfer your personal data outside the jurisdictions where we operate except as otherwise provided for in this Policy. All data processing is conducted within our secure systems.
5. Data Retention Period
We retain your personal data only for as long as necessary for the purposes specified in this Policy and in accordance with applicable laws. This means the retention periods may vary depending on the purpose of the processing.
When determining the appropriate retention period, we consider the category and amount of personal data, potential risks and harm, specific processing purposes, availability of alternative means, and applicable legal requirements.
6. Cookies and Other Tracking Technologies
Cookies and similar tracking technologies are text files that can be stored on your devices when you visit an online service. We use cookies to store information on your device for later access. Except for necessary cookies, you are free to refuse the deposit of cookies at any time. For more information, please refer to the settings in your browser.
7. Your Rights
In accordance with applicable personal data protection regulations, including the GDPR, you have the following rights: access, rectification, deletion, objection, restriction of processing, and data portability of your personal data.
Please note that some of these rights are subject to specific conditions. If your situation does not meet these conditions, we may not be able to respond to your request. We will inform you of the reasons for any refusal.
- Right of access – You may request access to your personal data at any time.
- Right of rectification – You have the right to ask us to rectify any inaccurate or incomplete personal data.
- Right to erasure / to be forgotten – You can ask us to delete your personal data if it is no longer necessary for the processing.
- Right to restriction of processing – You may request that we restrict the processing of your personal data on grounds relating to your particular situation.
- Right to data portability – You may request portability of the personal data you have provided us with.
- Right to object – You may object at any time to our processing of your personal data.
- Right to withdraw consent – You have the right to withdraw consent at any time for processing based on consent.
8. Residents of the EEA (European Economic Area)
If you are a resident of the European Economic Area ("EEA"), you have certain rights and protections under the law regarding the processing of your personal data.
8.1. Legal Basis for Processing
If you are a resident of the EEA, when we process your personal data we will only do so in the following situations: We need to use your personal data to perform our responsibilities under our contract with you. We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services. You have consented to the processing of your personal data for one or more specific purposes.
8.2. Data Subject Requests
If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can contact us as indicated below.
8.3. Questions or Complaints
If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.
For contact details of your local Data Protection Authority, please see: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
9. Contact Us
If you have any questions regarding the processing of your personal data under this Policy, including exercising your rights, contact us by email at [email protected].
10. Changes to this Privacy Policy
We periodically review this Policy to ensure compliance with applicable data protection regulations. Updates will be posted on this page.
We encourage you to review this Policy regularly. Any modifications will take effect when posted or on the specified effective date. Your continued access and use of the Interface indicate your acknowledgment and acceptance of the updated Privacy Policy.