PRIVACY POLICY

Hi there,

Here at Kepler Technologies GmbH (also referred to as “Lukrum” and “we”) we are committed to protecting and respecting your privacy. We take your privacy seriously and will use your personal information (or data) to provide the services you sign up for only after obtaining your consent to the collection and processing of your personal data on the terms specified below.

This Privacy Policy explains when, where, and why we collect personal information about people who visit lukrum.tech (“Website”) and provide personal information for the purpose of receiving marketing information pertaining to Lukrum Portfolio Manager, how we use this information, the conditions under which we may disclose it to others, your rights in respect to your personal information, as well as how we keep it secure.

Lukrum may change this Privacy Policy from time to time if doing so will be deemed necessary in order to comply with the applicable laws and actual circumstances of the functioning of the Website, so please periodically check this page to ensure that you’re satisfied with any changes. Additional notifications on any amendments will be sent to your email. If within one week after such notification has been sent you did not unsubscribe, you will be considered as having accepted all the amendments, unless there is an obligation imposed on Lukrum by an applicable law to obtain your explicit consent to the amendments. This can be a case when, for example, the nature of your data processing and purposes for processing change.

Any questions regarding this Policy and our services should be sent to privacy@kepler.finance.

1. What is LUKRUM?

This Website is dedicated to Lukrum Portfolio Manager. It is an application that allows its user to synchronize and keep track of the user’s blockchain assets from different sources and display them on user’s device. The application as well as this Website are products of Kepler Technologies GmbH, registration No. CHE-395.347.099, a company registered at Sumpfstrasse 26, 6312 Steinhausen. Thus, Kepler Technologies GmbH (or “Lukrum”) is a person that collects your data through this Website. This Privacy Policy governs the terms of processing the personal data you provided to Lukrum when you signed up to receive our marketing information.

2. What is personal information and what is processing of personal information?

Personal information (or data) is any information about you and that alone or in combination with other pieces of information gives the opportunity to identify you as a person. It can be your first and last name, your email and member id, your location data, the IP address of your device etc. Processing of the information means any action with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means and so on.

3. What type of information is collected from you?

Lukrum may collect personal information when you sign up to receive our marketing information and when you browse our Website. Such information may include your email address or online identifiers and cookie identifiers that give the opportunity for Lukrum to obtain and analyze the technical information such as frequency of visits to the Website, IP address, site pages most frequently accessed, browser type etc. Online and cookies identifiers alone are non-personally identifiable user information, however such information can be combined with the personal information received from you signed up to receive our marketing information and that is why you need to be aware of the fact that such information is collected and processed. Please see our Cookies Policy for more details on such processing here

4. Why does Lukrum collects information from you?

Lukrum collects the information provided by you on the Website for the following purposes:

• to respond to your inquiries and fulfill your requests, such as respond to your questions and comments;
• to send administrative information to you, for example, information regarding the Website and changes to our terms, conditions, and policies;
• to distribute marketing information, provide you with updates and announcements pertaining to Lukrum Portfolio Manager and related products and services;
• to improve your experience on this Website and to show you the advertising (note that this is done via the use of cookies).

If Lukrum decides to change the purposes of processing specified above, we will inform you on such changes prior to the use of your personal information for the newly set purposes. The notification on such changes will be sent to your email and you will have to provide your consent to the amended purposes unless additional purpose of processing is compatible with those listed above.

5. Who will get access to your personal information?

In order to ensure the Website works fine and provide high-quality services to its users Lukrum hires people, enters into the agreements with independent contractors as well as cooperates with other services providers, companies and organizations. For these reasons some of the information Lukrum collects from you can be passed to the persons mentioned. For example, for marketing analytics and advertising purposes, Lukrum uses the services provided by Google (Google LLC), such as Google Analytics and AdWords. For the same purposes Lukrum uses Facebook Pixel provided by Facebook Inc. We also use Mailchimp services (The Rocket Science Group LLC d/b/a MailChimp) for email delivery automation and MouseFlow (Mouseflow, ApS) for the analyses of the behavior of the Website users. These well-known software providers ensure your data is processed in accordance with the strictest data protections standards.

Although Kepler Technologies GmbH is registered in Switzerland it has contractors and subsidiaries in other countries. As mentioned above, your data may be transferred to the companies in the USA. Your data also may be accessed by the non-EU based providers Lukrum engages.

If you are from the EU, it will be important for you to know that the transfer of your data to the recipients in these countries is secured either by the participation of the contractors from the USA in Privacy Shield Program or on the bases of standard contractual clauses adopted by the European Commission and compliant with the EU data protection laws.

By providing your personal information on the Website you agree to such transfer and processing within the purposes set in Section 4 of this Privacy Policy.

In all cases when we pass the information to other persons, we ensure that your information is being protected and used only for the purposes specified in Section 4 of this Privacy Policy. This is achieved by using only certified services and products, signing agreements on protection of personal data with contractors as well as taking technical measures to ensure the information is protected when stored, used and while being transferred.

You also have to be aware of the fact that Lukrum may disclose your personal information to enforce and comply with the applicable laws. In other words, Lukrum may disclose information necessary for the investigation or legal process on official request from the official bodies acting within their powers.

6. How long will the personal information be processed and stored by Lukrum?

Your personal information will be stored by Lukrum up to the moment you enforce your right to withdraw your consent to the processing of your personal data within the purposes set in Section 4 of this Privacy Policy. This may be done by unsubscribing from the email communication sent to you by Lukrum. Lukrum shall terminate the processing of your personal information when you unsubscribe from our services or mailing lists unless the special retention period for the storage of such data is set by the applicable legislation.

7. Your rights regarding your personal information Lukrum collects and processes

7.1. You have the right to know what personal information Lukrum processes and get details of such processing

That means that you have the right to ask Lukrum to provide you with the confirmation as to whether or not your personal data is being processed by Lukrum, as well as obtain the full information on the terms of such processing, i.e. purposes of collecting and processing, period of processing, third parties that have access to information. You also have the right to obtain your personal data in a structured, commonly used and machine-readable format in order to be able to transmit it to the other controller of data.

7.2. You have the right to request Lukrum to rectify your personal information

This means you have the right to ask that all the inaccuracies in your personal information be corrected. You can also complete the personal information if you feel there is a need to do so.

7.3. You have the right to request Lukrum to erase personal information

You have the right to request Lukrum to erase such data if its processing is no longer necessary in relation to the purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases start of Lukrum will erase it unless otherwise will be required by the applicable legislation.

7.4. You have the right to request Lukrum to restrict the processing of your personal information

You have the right to request the restriction of processing of your personal data in cases provided by the applicable law. For instance, if you want to verify whether the data processed by Lukrum is accurate, the processing of your data may be restricted for the period of time Lukrum will require to verify your personal data at your request

7.5. You have the right to withdraw consent

You can withdraw your consent to the collection and processing of your personal information by Lukrum at any time, without affecting the lawfulness of processing based on consent before its withdrawal. After we receive such withdrawal request from you, we will process it in a timely manner and no longer process your personal information unless the obligation to proceed with processing is set by the applicable law. The phrase “in timely manner” is deciphered below.

If you will face any issues regarding the processing of your personal data or have questions on the same matter, please inform Lukrum and we will take all reasonable efforts to resolve the issue. If you have any such issues, please drop us a line at privacy@kepler.finance. You can also address any of your complaints to the data protection controlling bodies.

8. Time for reply and reaction

Lukrum will make all reasonable efforts to timely address your requests pertaining to the rights described above, however you should expect our response not later than one month from the date of filing such request. Our response time may be extended by two further months if Lukrum is overwhelmed with the number of requests from users. Lukrum will inform you of such extension within one month of receipt of the request, together with the reasons for the delay.

9. Cookies

What are cookies? These are tiny pieces of code that remain in your computer or mobile device when you visit a website. These pieces then enable the server to provide you with the information that is customized to your needs when you use a website as a returning user.

If you visited our Website and came here, to the Privacy Policy, cookies consent message was the first message that you likely saw that prompted you about the fact that cookies are used and active on our Website. Please see the detailed information on how we use cookies in our Cookies Policy here. Cookies Policy is an integral part of this Privacy Policy.

10. Are you already 16 years old?

The privacy of children is one of our major concerns. At Lukrum we can provide services only in case if you as the user are aged 16 or older (or you are of an age of majority and fully able and legally competent to enter into agreements). If you are under 16 you will need to get your parent’s/guardian’s permission before providing any private information to Lukrum.

11. We hope this Privacy Policy helped you understand how your personal information is dealt with at Lukrum. Lukrum will undertake its best effort to make your personal data protected. Should you have any questions, please e-mail us at privacy@kepler.finance. We will be glad to receive any information or comment from you to make our services better for our users and community.

Your Lukrum team.