Privacy Policy
How we collect, use, and protect your personal information in the KESK ecosystem.
Last updated: March 1, 2025
Overview
Kesk Systems OÜ and its associated platforms ("KESK", "we", "us", or "our") are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our token sale platform, mobile applications, websites, and related services.
By participating in the KESK token sale or using our services, you consent to the data practices described in this policy. If you do not agree with this policy, please do not use our services.
Information We Collect
Personal Information
- Name, email address, phone number, and postal address
- Date of birth and government-issued identification
- Financial information for KYC/AML compliance
- Cryptocurrency wallet addresses and transaction history
- Employment and income information for accredited investor verification
Technical Information
- IP address, browser type, and device information
- Usage data, including pages visited and time spent
- Cookies and similar tracking technologies
- Blockchain transaction data and smart contract interactions
Communications
- Support requests and correspondence with our team
- Survey responses and feedback
- Marketing preferences and communication history
How We Use Your Information
Token Sale Operations
- Processing token purchases and managing investor accounts
- Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
- Verifying accredited investor status where required
- Distributing tokens and managing vesting schedules
Platform Services
- Providing access to staking, governance, and other platform features
- Processing transactions and calculating rewards
- Maintaining account security and preventing fraud
- Improving our services and developing new features
Legal Compliance
- Complying with securities laws and regulations
- Responding to legal requests and government inquiries
- Enforcing our terms of service and other agreements
- Protecting against fraud, abuse, and illegal activities
Information Sharing and Disclosure
We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:
Service Providers
We may share information with trusted third-party service providers who assist us in operating our platform, including KYC verification services, payment processors, and technical infrastructure providers.
Legal Requirements
We may disclose information when required by law, court order, or government request, or when we believe disclosure is necessary to protect our rights, property, or safety, or that of others.
Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction, subject to the same privacy protections outlined in this policy.
Blockchain Data
Transactions on blockchain networks are publicly visible. While wallet addresses may be pseudonymous, blockchain data is permanent and publicly accessible.
Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:
- Encryption of data in transit and at rest using industry-standard protocols
- Multi-factor authentication for account access
- Regular security audits and penetration testing
- Limited access to personal information on a need-to-know basis
- Secure data centers with physical and network security controls
- Incident response procedures for potential security breaches
While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.
Your Rights and Choices
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Access: Request a copy of the personal information we hold about you
- Rectification: Request correction of inaccurate or incomplete information
- Erasure: Request deletion of your personal information (subject to legal requirements)
- Portability: Request transfer of your data to another service provider
- Restriction: Request limitation of how we process your information
- Objection: Object to processing based on legitimate interests or direct marketing
To exercise these rights, please contact us at privacy@kesk.app. We will respond to your request within 30 days, subject to verification of your identity.
Data Retention
We retain your personal information for as long as necessary to:
- Provide our services and maintain your account
- Comply with legal obligations and regulatory requirements
- Resolve disputes and enforce our agreements
- Prevent fraud and abuse of our platform
Generally, we retain KYC information for 7 years after account closure, transaction records for 10 years, and marketing communications until you opt out. Blockchain transaction data is permanent and cannot be deleted.
International Data Transfers
Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for international transfers, including:
- Standard contractual clauses approved by relevant data protection authorities
- Adequacy decisions for countries with equivalent privacy protections
- Binding corporate rules for transfers within our organization
Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us:
Email: privacy@kesk.app
Address: Kesk Systems OÜ, Tööstuse tn 3-5, 10413 Tallinn, Estonia
Registration Number: 17216767
Data Protection Officer: dpo@kesk.app
We will make every effort to respond to your inquiries and resolve any privacy concerns promptly.
Policy Updates
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:
- Posting the updated policy on our website
- Sending email notifications to registered users
- Displaying prominent notices on our platform
Your continued use of our services after such modifications constitutes acceptance of the updated Privacy Policy.