Privacy Policy

1.1. Personal Information: We may collect personal information that you provide to us when you use our Services, including but not limited to: name, email address, postal address, phone number, payment information, government-issued identification numbers, date of birth, nationality, IP address, device information, identifiers, browser data, usage data and any other information that directly or indirectly identifies you as required under Panamanian data protection laws.

2.1. Provision of Services: We use your personal information to provide, maintain, and improve our Services, as well as to communicate with you about your account and our offerings, in accordance with Panamanian data protection law.

2.2. Lawful Basis for Processing: We process your personal information on the following legal grounds:

– With your consent, which you can withdraw at any time;

– When necessary to perform our contractual obligations to you under our terms of service (if any);

– To comply with our legal obligations under Law 81 of 2019 on Personal Data Protection of the Republic of Panama and applicable international laws;

– For our legitimate business interests, including operating and improving our Services, preventing fraud, and ensuring network security, provided these interests are not overridden by your rights and freedoms;

– To protect your vital interests or those of others; and

– For reasons of substantial public interest as permitted by applicable law.

2.3. Analytics and Personalization: We may also use usage information to analyze trends, administer the Services, track users’ movements around the Services, and gather demographic information about our user base. We may also use this information to personalize your experience with our Services.

2.4. Processing: We will only process your personal information for the purposes specified at the time of collection or as otherwise set forth in this Privacy Policy. If we intend to process your information for a different purpose, we will obtain your consent unless the processing is otherwise permitted by law.

3.1. Third-Party Service Providers: We may share your personal information with third-party service providers that help us operate our Services, such as hosting providers, payment processors, and analytics providers, subject to appropriate data processing agreements that ensure compliance with Panamanian data protection laws, including Law 81 of 2019 on Personal Data Protection. We will only share personal information that is necessary for the specific service being provided and require our service providers to process such data in accordance with our instructions and appropriate technical and organizational security measures.

3.2. Legal Compliance: We may disclose your personal information if required to do so by applicable Panamanian law, including Law 81 of 2019 on Personal Data Protection, or in response to valid legal requests from competent authorities, such as subpoenas or court orders.

4.1. Risk of Disclosure: We take reasonable measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee the absolute security of your personal information.

4.2. Minimal Disclosure: We will only disclose the minimum information necessary to comply with such requests and will notify you unless prohibited by law.

5.1. Technologies: We use cookies, web beacons, pixels, and similar tracking technologies (“Tracking Technologies”) to collect information about your browsing activities and to distinguish you from other users of our Services. These technologies help us analyse trends, track users’ movements around our Services, gather demographic information about our user base, remember your preferences and settings, and otherwise improve and personalize your experience.

5.2. Types of Tracking Technologies: The types of Tracking Technologies we use include:

– Essential cookies: Necessary for the Services to function and cannot be switched off;

– Performance/analytics cookies: Help us understand how visitors interact with our Services;

– Functionality cookies: Enable enhanced features and remember your preferences; and

– Targeting/advertising cookies: Used to deliver relevant advertisements and track ad campaign performance.

5.3. Your Control of Cookies: You can control cookies through your browser settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the Services.

5.4. Consent to Tracking Technologies: By using our Services, you consent to our use of Tracking Technologies as described above. For more detailed information about the specific cookies we use and the purposes for which we use them, please contact us using the information in Section 12.

6.1. Withholding Personal Information: You may choose not to provide certain personal information. While this may limit your ability to access or use certain features of our Services, we will respect your choice and only process your personal data with your consent or where we have another lawful basis under Panamanian law. You have the right to withdraw consent at any time by contacting our data protection officer using the information in Section 12.

6.2. Opt out: You may opt out of receiving promotional communications from us by following the instructions provided in those communications or by contacting us directly.

7.1. Transfers: We may transfer your personal information to countries outside Panama. When we do so, we implement appropriate safeguards in accordance with Panamanian data protection laws, including:

– Transferring data only to countries deemed to provide adequate protection for personal data;

– Implementing binding corporate rules for intra-group transfers; and

– Obtaining your explicit consent where required by law.

7.2. Safeguards: We will provide you with details of these safeguards upon request. You acknowledge that personal data transferred outside Panama may be subject to access by foreign authorities in accordance with applicable laws.

8.1. Retaining Data: We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable laws. Specifically:

– Account information and user profiles are retained while your account remains active and for up to 24 months after account closure;

– Transaction records and financial data are retained for 7 years as required by Panamanian financial regulations;

– Usage data and analytics are retained for 12 months;

– Chat histories and support communications are retained for 24 months;

– Marketing communications preferences are retained until you opt-out; and

– Cookies and device identifiers are retained according to their individual expiration dates.

8.2. Deletion Requests: You may request deletion of your personal information at any time, subject to our legal obligations to retain certain records. When information is deleted, it will be permanently erased from our systems within 90 days.

8.3. Registry Compliance: In accordance with Panama Law 81 of 2019, Article 19, we maintain a registry of personal data processing activities. This registry includes details of processing purposes, data categories, recipients, retention periods, and security measures. The registry is available for inspection by the National Authority for Transparency and Access to Information (ANTAI) upon request. We ensure all data processing activities are documented and comply with Panamanian data protection requirements, including registration obligations for data controllers processing personal information of Panamanian residents.

9.1. Individual Notification: In the event of a data breach that compromises your personal information, we will notify you and the relevant supervisory authorities without undue delay and no later than 15 days after becoming aware of the breach, in accordance with Panama Law 81 of 2019 on Personal Data Protection. The notification will include:

– A description of the nature of the breach;

– The categories and approximate number of data subjects concerned;

– The likely consequences of the breach;

– The measures taken or proposed to address the breach and mitigate its effects; and

– The name and contact details of our data protection officer.

9.2. Public Notification: Where individual notification would involve disproportionate effort, we may issue a public communication or similar measure to ensure affected individuals are informed in an equally effective manner.

10.1. Rights: You have the following rights regarding your personal information:

– Right to Access: You may request details of your personal information we hold and how we process it.

– Right to Rectification: You may request correction of any inaccurate personal information.

– Right to Erasure: You may request deletion of your personal information where there is no compelling reason for continued processing.

– Right to Restrict Processing: You may request we restrict processing of your personal information in certain circumstances.

– Right to Data Portability: You may request to receive your personal information in a structured, commonly used format and transmit it to another controller.

– Right to Object: You may object to processing based on legitimate interests, direct marketing, and research/statistical purposes.

– Rights Related to Automated Decision Making: You have rights regarding automated individual decision-making and profiling.

10.2. Exercise: To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days. We may need to verify your identity before proceeding with your request. In some cases, legal requirements and other legitimate interests may require us to retain your data. If you are not satisfied with our response, you may file a complaint with the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI) or seek judicial review under Panamanian law.

10.3. Appeal Rights: If you are dissatisfied with our response to your data subject rights request, you have the right to file an appeal with the National Authority for Transparency and Access to Information (ANTAI) in accordance with Panama Law 81 of 2019 on Personal Data Protection. You may also seek judicial review of any adverse determination regarding your personal data rights.

11.1. Updates: We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new Privacy Policy on this page and sending you a notification via email at least 30 days before the changes take effect. Your continued use of our Services after such notice constitutes acceptance of the updated Privacy Policy.

12.1. Details: If you have any questions or concerns about this Privacy Policy or our practices regarding your personal information, please contact us here [email protected].

13.1. Whole Agreement: This Privacy Policy constitutes the entire agreement between you and us regarding the collection, use, disclosure, and safeguarding of your personal information and supersedes all prior or contemporaneous agreements, representations, warranties, and understandings, whether oral or written concerning those matters.

13.2. Waiver: No waiver by us of any term or condition set forth in this Privacy Policy shall be deemed a further or continuing waiver of such term or condition or a waiver of any other term or condition, and any failure of us to assert a right or provision under these Terms shall not constitute a waiver of such right or provision.

13.3. Token Tracking: Please note that while we do not specifically connect your token use activity to your Personal Information, public transactions on a public blockchain are visible and may be used together with metadata or other information to identify you or identify your transaction habits or history. Such trackability is inherent in the nature of public blockchains and in receiving or purchasing any KAU or KAG Tokens, you accept the risk inherent in such tracking.

13.4. Governing Law and Jurisdiction. This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Panama, including Law No. 81 of March 26, 2019 on Personal Data Protection. Any disputes arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Panama City, Republic of Panama.