Kintsu Foundation Privacy Policy

Last Updated: October 8, 2024

This Data Protection and Privacy Policy (“Privacy Policy”) describes how we collect, use, protect, and disclose any Personal Data or data we receive when providing our services to you, including through our website (https://Kintsu.xyz) and its subdomains, our online or offline offerings, and our Services.

For the purposes of this Policy, “Foundation”, “we”, “us” or “our” means the Kintsu Foundation, a Cayman Islands foundation company, and our personnel, affiliates and related companies. “You” and “your” refers to you as the user of the Services. Capitalized terms have the meanings provided in the Definitions section of this Policy, elsewhere in this Policy, or in the Terms of Use https://Kintsu.xyz/terms-service.

Please read this Privacy Policy carefully. By using, accessing, connecting to, or use any of the Services, you agree and consent to the collection, use, disclosure, retention and security of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access, or connect to any of the Services.

OUR COMMITMENT TO YOUR PRIVACY

We are committed to respecting the privacy of the users of our Services and minimising the collection of personal information. As a general principle, we do not collect or store Personal Data about users of the Services, except where necessary to ensure the usability and functionality of our Services, to communicate with you, to maintain security, or to comply with legal obligations.

This Privacy Policy sets out the limited categories of Personal Data we may collect, the purposes for which it is used, and the measures we take to safeguard your data. Our goal is to provide transparency and uphold your privacy at every step.

CHANGES TO THIS POLICY

Please note that we may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will update the “Last Updated” date at the top of this Notice. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you by posting notice of such changes on the Services, or by other means consistent with applicable law.

You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

DEFINITIONS

For the purposes of this Privacy Policy, the following terms have the following meanings:

• “Appropriate Safeguards” means such legally enforceable mechanism(s) for transfers of Personal Data as may be permitted under Data Protection Laws from time to time.
• “Data Controller” has the meaning given in applicable Data Protection Laws from time to time.
• “Data Protection Laws” means, as binding on either party:
• the Cayman Islands Data Protection Act, as revised (“DPA”);
• any laws that replace, extend, re-enact, consolidate or amend any of the foregoing; any ‘code of practice’ promulgated under section 42 of DPA; and any binding decision of the courts and tribunals of the Cayman Islands that relate to the application or interpretation of any of the foregoing;
• any other Data Protection Laws as may be applicable to you.
• “Data Subject” means the identified or identifiable natural person to whom Personal Data relates.
• “Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• “Process” or “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Services” means any services provided by us, including through our website (https://Kintsu.xyz) and its subdomains, our online or offline offerings.

COLLECTION OF INFORMATION

We collect several types of information from and about users of our Services, including:

• Information you provide to us directly, such as when you create an account, contact us, or otherwise interact with our Services;
• Information we collect automatically when you use the Services, including information about your device and how you use our Services;
• Information we receive from third parties, such as service providers and business partners.

INFORMATION YOU PROVIDE TO US

The information we collect on or through our Services may include:

• Account Information: If you create an account with us, we may collect your name, email address, and other contact information.
• Communications: When you contact us, we may collect records and copies of your correspondence with us.
• Wallet Information: When you connect a digital wallet to our Services, we collect your wallet address and information about your transactions that are publicly available on the blockchain.

INFORMATION WE COLLECT AUTOMATICALLY

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Usage Details: Details of your visits to our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.
• Device Information: Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, and other technical information.

USE OF YOUR INFORMATION

We use the information that we collect about you or that you provide to us, including any Personal Data:

• To provide, maintain, and improve our Services;
• To process your requests and transactions;
• To communicate with you about our Services;
• To comply with our legal and regulatory obligations;
• To protect the security and integrity of our Services;
• To prevent fraud, debug issues, and enforce our terms and conditions;
• For any other purpose with your consent or as permitted by applicable law.

DISCLOSURE OF YOUR INFORMATION

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates, and their respective employees, contractors, service providers, and agents who need to know such information to process it on our behalf or to provide services available on the Services;
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Foundation, our users, or others;
• With your consent or at your direction.

DATA RETENTION

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

SECURITY OF YOUR INFORMATION

We have implemented appropriate technical and organizational measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. However, due to the inherent nature of the Internet and related technology, we cannot guarantee the security of your Personal Data and expressly disclaim any such obligation.

YOUR RIGHTS

Under certain circumstances, you have rights under Data Protection Laws in relation to your Personal Data, including the right to:

• Request access to your Personal Data;
• Request correction of your Personal Data;
• Request erasure of your Personal Data;
• Object to processing of your Personal Data;
• Request restriction of processing your Personal Data;
• Request transfer of your Personal Data;
• Withdraw consent.

You can exercise any of these rights by contacting us at legal@Kintsu.xyz. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).

INTERNATIONAL TRANSFERS

We may transfer your Personal Data to countries outside of your jurisdiction of residence. When we do so, we will ensure that appropriate safeguards are in place to protect your Personal Data, including through the use of standard contractual clauses or other legally acceptable mechanisms.

CHILDREN’S PRIVACY

Our Services are not intended for children under the age of 18, and we do not knowingly collect Personal Data from children under 18. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information.

THIRD-PARTY WEBSITES

The Services may contain links to third-party websites and services. We are not responsible for the practices employed by any websites or services linked to or from our Services, including the information or content contained within them.

CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Email: legal@Kintsu.xyz

Kintsu Foundation
Leeward Management Limited, Suite 3119, 9 Forum Lane, Camana Bay, PO Box 144, George Town Grand Cayman, KY1-9006, Cayman Islands.