Last updated: 07/10/2025

At kuntroversie, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use, and share your information as described in this Privacy Policy.

Remember that your use of kuntroversie's Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the kuntroversie website. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

1. What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (including the EU GDPR). This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

2. Data Controller & Contact Information

For the purposes of the General Data Protection Regulation (GDPR) and other applicable French data protection laws, the data controller is:

kuntroversie EURL

142 Rue de Rivoli, 75001, Paris

privacy@kuntroversie.com

If you have any questions or comments about this Privacy Policy, please contact us using the information above.

3. Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

| Category of Personal Data | Examples | Purpose of Collection | Third Parties With Whom We Disclose |

| :--- | :--- | :--- | :--- |

| **Profile or Contact Data** | First and last name, email, phone number, physical address. | Providing, Customizing and Improving the Services; Marketing; Corresponding with You. | Service Providers; Business Partners. |

| **Payment Data** | Payment card type, last 4 digits of card number, billing address. (Note: Full payment details are processed by our payment partners). | Processing transactions; Providing the Services. | Service Providers (specifically our payment processors like Stripe, PayPal). |

| **Commercial Data** | Purchase history, products or services purchased. | Providing, Customizing and Improving the Services; Marketing. | Service Providers; Business Partners. |

| **Device/IP Data** | IP address, device type, operating system, browser type. | Providing, Customizing and Improving the Services; Security; Analytics. | Service Providers; Advertising Partners. |

| **Web Analytics** | Web page interactions, referring webpage, browsing statistics. | Providing, Customizing and Improving the Services; Marketing; Analytics. | Service Providers; Advertising Partners. |

| **Consumer Demographic Data** | Physical address, date of birth, gender. | Providing, Customizing and Improving the Services; Marketing. | Service Providers. |

| **Geolocation Data** | IP-address-based location information. | Providing, Customizing and Improving the Services; Compliance. | Service Providers. |

| **Other Identifying Information** | Emails, letters, and other communications you send us. | Corresponding with You; Improving Services. | Service Providers; Parties You Authorize. |

4. Our Commercial or Business Purposes for Collecting Personal Data

* Providing, Customizing and Improving the Services:** Creating your account, processing orders, providing support, personalizing your experience, and for internal analytics and product development.

* **Marketing the Services:** Marketing and selling the Services, and showing you interest-based advertisements.

* **Corresponding with You:** Responding to your inquiries and sending you information about Kuntroversie.

* **Legal and Safety Reasons:** To meet legal obligations, enforce our Terms of Use, protect the rights and safety of our users, us, or others, and to prevent fraud.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

5. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, our legal bases for processing your Personal Data are:

* **Contractual Necessity:** To perform our contract with you (our Terms of Use). This includes processing your Profile, Contact, and Payment Data to create your account and process your transactions.

* **Legitimate Interests:** For our legitimate business interests, such as to improve our Services, for marketing, and for security and fraud prevention, where these interests are not overridden by your data protection rights.

* **Consent:** In specific cases, we may ask for your consent to process your data, for example, for certain types of marketing communications. You may withdraw your consent at any time.

* **Legal Obligation:** To comply with our legal obligations under French and European law.

6. Categories of Sources of Personal Data

We collect Personal Data from:

* **You:** Directly when you provide it to us, create an account, make a purchase, or contact us.

* **Automatically:** Through cookies and similar technologies when you use our Services.

* **Third Parties:** Such as vendors, analytics providers, and advertising partners.

### 7. How We Disclose Your Personal Data

We disclose your Personal Data to:

* **Service Providers:** Parties that help us provide the Services (e.g., hosting, payment processing, analytics, customer support).

* **Advertising Partners:** To help us market our services and serve relevant ads.

* **Business Partners:** Our affiliates and other partners we work with.

* **Legal Authorities:** When required by law, or to protect our rights and the rights of others, as described in the "Legal and Safety Reasons" section.

* **Successors:** In connection with a merger, acquisition, or bankruptcy.

8. International Data Transfers

kuntroversie is headquartered in France. Your Personal Data is processed and stored in France and other countries within the European Economic Area (EEA).

If we transfer your Personal Data outside the EEA to a country not deemed to provide an adequate level of data protection, we will ensure appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses, to protect your data in accordance with GDPR requirements.

9. Tracking Tools, Advertising and Opt-Out

We use cookies and similar technologies "Cookies" for essential functions, analytics, and advertising. You can manage your Cookie preferences through our Cookie Preference Center [Link to your Cookie Settings] or your browser settings.

We may engage in interest-based advertising. You can learn more about this and opt-out from many third-party ad networks at [Your Opt-Out Link or refer to sites like http://www.youronlinechoices.eu/].

10. Data Security and Retention

We implement appropriate technical and organizational measures to protect your Personal Data. However, no method of transmission over the Internet is 100% secure.

We retain your Personal Data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law (e.g., for tax, legal, or accounting purposes).

11. Personal Data of Children

Our Services are not directed to children under the age of 16. We do not knowingly collect Personal Data from children under 16. If we learn we have collected such data, we will delete it promptly. If you believe a child under 16 has provided us with data, please contact us at privacy@kuntroversie.com.

12. Your Privacy Rights Under GDPR

If you are in the EEA, UK, or Switzerland, you have the right to:

* **Access** your Personal Data.

* **Rectify** inaccurate Personal Data.

* **Erase** your Personal Data (the "right to be forgotten").

* **Restrict** the processing of your Personal Data.

* **Data Portability**.

* **Object** to processing based on our legitimate interests.

* **Withdraw Consent** at any time, where processing is based on consent.

To exercise these rights, please contact us at privacy@kuntroversie.com. We may need to verify your identity before processing your request. You also have the right to lodge a complaint with your local data protection authority. The French supervisory authority is the CNIL (Commission nationale de l'informatique et des libertés).

13. Contact Information

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

kuntroversie EURL

142 rue de rivoli 75001, Paris

privacy@kuntroversie.com

Privacy Policy