Introduction
Aylo Freesites Ltd (hereinafter “we”, “us” or “our”) operates the website and is the controller of the information collected or provided via kopona.org.
Please read this Privacy Notice carefully, as your access to and use of kopona.org signifies that you have read and understand all terms within this Privacy Notice. We respect your privacy and are committed to protecting your personal data.
If you have any questions about our privacy practices, please see the section “Contact Information” below for information on how to contact us.
1. Scope
For the purposes of this Privacy Notice, “process”, “processed” or “processing” means any operation or set of operations performed on personal data or on sets of personal data (excluding disclosure thereof), whether by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure, or destruction. Information on disclosure of personal data or of sets of personal data may be found in the “Disclosure of Your Personal Information” section below.
This Privacy Notice applies to information we process:
2. The Data We Process About You
We may process different kinds of personal data about you, depending on whether you chose to create an account with us.
Persons who visit kopona.org without logging in or registering (“Unregistered Users”):
For persons who choose to create an account on kopona.org (“Registered Users”), we process the same categories of information described above for Unregistered Users, and additionally the following information:
Please use caution in providing user contributions. By providing user contributions you are making that content and information publicly available. User contributions can be read, collected, used, and disclosed by others, and we cannot control who accesses your user contributions or what other users may do with the information you voluntarily post or submit. User contributions are governed by the kopona.org terms of use found at terms.
We may process your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.
kopona.org prohibits minors from using the platform. kopona.org is forbidden for persons under the age of 18 or the applicable age of majority in the jurisdiction from which kopona.org is accessed. As indicated throughout this Privacy Notice, some users may be asked to provide some information to us and our service providers for us to make sure that you are over the age of majority required to have access to the kopona.org. We do not knowingly process personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us to have that minor’s personal information deleted.
3. The Sources from Which We Process Personal Information
We process Personal Information in the following ways:
4. Purposes for Which We Process Your Personal Information
We process personal information for the purposes described below.
5. Our Legal Bases under Canadian and European Union (EU) Privacy Law
To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your personal data only where:
Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.
6. Disclosure of Your Personal Information
We disclose personal information:
For more information on recipients of personal information, please see the section “Contact Information” below on how to contact us.
7. Cookies and Automatic Data Collection Technologies
As you navigate through and interact with kopona.org, we use automatic data collection technologies to collect website activity data. The technologies we use for this automatic data collection may include cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit kopona.org.
We currently use the following types of cookies, which are set by kopona.org:
Analytics, Functionality and Advertising/Targeting cookies can be switched off at any time by accessing the 'Manage cookies' option that is located at the footer of kopona.org. However, if you decline to accept these cookies, some functionality on kopona.org may be disabled and can interrupt your access to certain parts of kopona.org.
Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use kopona.org, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only to provide Google Analytics services to us and will not use this information for other purposes. In addition, kopona.org uses Google Signals, which are also services provided by Google that help us to run remarketing campaigns, collect more accurate data, and understand in a better way how users engage with kopona.org on different devices (cross-device activity). Google Signals apply to Google users who accept personalized advertising on their Google accounts. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023) 4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.
8. Third-party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on kopona.org are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you click to view, access, or use any of the third-party feature on kopona.org or directed to such third-party website. Unless expressly stated otherwise, kopona.org does not provide any personal information to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access kopona.org to provide targeted content.
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
9. Your Choices About How We Collect, Use and Disclose Your Personal Information
We strive to provide you with choices regarding the personal information you provide to us.
You can access the Cookie Banner anytime by clicking on the 'Manage cookies' option that is located at the footer of kopona.org.
10. California Rights and Choices
As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, Consumers have the right to:
kopona.org does not sell, nor has it sold in the past twelve (12) months personal information to third parties for monetary or other valuable consideration. We may however disclose certain personal information with third parties, service providers and entities within our corporate group to enable them to perform certain services on our behalf, and namely to make kopona.org function properly, as further described in the section above titled Disclosure of Your Personal Information.
We respect California residents' right to exclude personal information from such sharing arrangements and grant them the option to opt-out of any future sale of their personal information. If you are a Registered User and the CCPA is applicable to you and you would like to exercise your rights, please use the buttons at the bottom of this page or email us with the email subject line “CCPA Request”.
In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
11. Resident's Rights - Jurisdictions in the United States, Where Applicable
We do not sell, trade, or exchange the Registered Users' personal information with anyone for money.
12. Biometric Information
We employ third-party service providers to verify your identity, age, and the authenticity of the identification documents you provide using facial recognition technology. Facial recognition technology creates a mathematical representation of your facial features from the live scan of your face, your selfie, and the government-issued ID you submit or previously submitted to us. Information derived from this mathematical representation, which may be considered biometric information under the laws of certain states and countries, is shared by our service providers with us as further described below.
Your biometric information will be processed to:
Please note that this section entitled “Biometric Information” applies to relevant users who wish to upload content onto kopona.org but does not apply to identifiers processed by our third-party age verification service providers solely for the purpose of granting you access to kopona.org to view the contents found thereon.
13. Notice to Law Enforcement
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:
We reserve the right to refuse online service through kopona.org, namely in cases where the above requirements are not met and require formal legal service at the above address. In such an event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
14. Transfers of Your Personal Information to Other Countries
Where the laws of your country allow you to do so, by using kopona.org you consent to the transfer of information that we process about you, including personal information, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer personal information to countries outside of the EEA or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws.
Where available, we rely on decisions of the European Commission, known as “adequacy decisions”, recognizing that certain countries offer a level of protection of personal data that is essentially equivalent to the EEA. In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.
For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.
15. Retention of Personal Information
We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider several factors, including what personal data we are processing, the risk of harm from any unauthorized disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.
Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, we will delete your personal information from our systems.
For more information on data retention periods, please see the section “Contact Information” below on how to contact us.
Where permissible, we will also delete your personal information upon your request as explained above in the section “Your Rights Related to Your Personal Information”.
16. Third-Party Links and Sites
If you click on a link to a third-party website, you will be taken to websites we do not control. This Privacy Notice does not apply to the privacy practices of these websites. Read the Privacy Notice of other websites carefully. We are not responsible for these third-party practices.
17. Changes to Our Privacy Notice
We may modify or revise our Privacy Notice from time to time, We may attempt to notify you of any material changes as required by law. Please also periodically review the most up-to-date version of our Privacy Notice, which will be posted at this location, so you are aware of any changes, the date of change will be reflected in the “last modified date” mention.
18. Contact Information
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
19. Your Rights Related to Your Personal Information
Subject to local law and applicable legal requirements and exemptions, you have certain rights regarding your personal data:
If we ask for your consent to process your personal data, you have the right to withdraw your consent at any time with effect for the future. Note that, in that case, you may no longer able to use several functionalities on kopona.org or access kopona.org in some cases.
You can exercise your rights of access or deletion of your data by following the dedicated links in the section “Manage Your Personal Data” below. Please note that we have one month to respond to your request.
Prior to processing an access or deletion request of your data, we will need to verify your identity and ensure your right to access or delete the information. This is an appropriate and reasonable security measure to ensure that personal data is not disclosed to any person who has no right to receive it or deleted in an unauthorized way.
Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be able to respond to your request. Additionally, in some cases, to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address). If you delete your account, your personal data and all account related information including, but not limited to, user profile data, sharing data and any data or content specifically associated with your account will no longer be accessible by you. If, after deleting your account, you wish to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
20. Manage Your Personal Data
Registered Users may request a copy of their personal data or request the deletion of their personal data via the links below. Please note that the below website is governed by the present Privacy Notice.