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Privacy policy

Last updated: [date of publication]

Draft for the client's lawyer — not legal advice

This template describes how KamgeniX works today. It has not been reviewed by a lawyer and must not be published as it is. Text in [square brackets] is missing information or a question for the lawyer.

This policy explains what personal data KamgeniX collects, why we use it, and your rights under the EU General Data Protection Regulation (GDPR).

1. Who is responsible

The data controller is [company name], [address], Italy.

Contact for privacy questions: [privacy email address]. [Data protection officer, if one is required.]

2. What we collect

  • Account: email address, password (stored only in hashed form) and whether you hire or sell.
  • Profile: name, photo, country, city, languages, skills and bio. Freelancer profiles are public.
  • Orders: what was ordered, your requirements, deliveries, prices and fees.
  • Messages and files you send in chats and deliveries.
  • Reviews and replies.
  • Withdrawals (freelancers): account holder, bank name, IBAN or account number, SWIFT/BIC and the bank's country.
  • Technical data: IP address, browser type and logs kept for security.
  • Cookies: see the cookie policy.

3. Why we use it

  • To run your account and your orders: performance of a contract.
  • To send you emails about your account and orders: performance of a contract.
  • To pay freelancers and keep accounting and tax records: legal obligation.
  • To keep KamgeniX safe, prevent fraud and handle disputes: legitimate interests.

We don't sell your data and we don't use it for advertising.

4. Who we share it with

  • The other party to your order sees your public profile, your messages and files, and the order details.
  • Supabase, which provides our database, file storage and sign-in, hosted in the European Union.
  • [Website hosting provider, e.g. Hostinger; EU data centre to confirm.]
  • [Email sending provider.]
  • [Payment partner, not yet chosen.]
  • The banks used to pay freelancers.
  • Authorities, where the law requires it.

5. Transfers outside the EU

Many freelancers on KamgeniX live outside the European Union, for example in Cameroon, Côte d'Ivoire, Nigeria or South Africa. When you order from them, they receive the order details and messages they need to do the work. Freelancers' payouts are sent to banks in their country.

[Lawyer: legal basis for these transfers, e.g. Article 49(1)(b) GDPR or standard contractual clauses.]

6. How long we keep it

  • Account and profile: while your account is open, then [period].
  • Files in chats and deliveries: deleted 90 days after the order is completed or cancelled.
  • Messages and order records: [period].
  • Accounting records, including payouts: [10 years], as Italian law requires.
  • Security logs: [period].

7. Your rights

You can ask to access, correct or delete your data, to restrict or object to how we use it, and to receive it in a portable format. Write to [privacy email address].

You can also complain to the Italian data protection authority (Garante per la protezione dei dati personali, garanteprivacy.it) or to the authority in your country.

8. Security

Data is encrypted in transit. Database rules limit each person to the data they are allowed to see, files in orders and chats are private, and passwords are stored hashed.

9. Children

KamgeniX is not intended for people under 18.

10. Changes

We publish changes to this policy here and tell you about important ones.