Privacy Policy
Last updated: April 16, 2024
This Privacy Policy describes how kelupuu ("we", "us", or "our") collects, uses, stores, and shares information about you when you access or use our website at kelupuu.com and any related services, workshops, or learning tools we provide (collectively, the "Service"). By using the Service, you agree to the practices described in this policy.
If you do not agree with any part of this policy, please discontinue use of the Service.
1. Information We Collect
1.1 Information You Provide Directly
We collect information you voluntarily submit to us, including but not limited to:
Account registration data — your name, email address, password, and any profile details you choose to add.
Workshop and course participation data — responses to exercises, assignment submissions, progress records, and feedback you provide.
Communications — messages you send us via contact forms, email, or support channels.
Payment information — billing name, address, and payment card details processed through our third-party payment processors. We do not store full card numbers on our systems.
Preferences and settings — language preferences, notification settings, and any customisations you apply within the Service.
1.2 Information Collected Automatically
When you use the Service, certain technical data is collected automatically:
Device and browser data — IP address, browser type and version, operating system, device identifiers, and screen resolution.
Usage data — pages visited, features used, time spent on content, click patterns, session duration, and referring URLs.
Log data — server logs recording access times, error reports, and request details.
Cookies and similar technologies — see Section 5 for full details on our use of cookies.
1.3 Information From Third Parties
We may receive information about you from third-party sources, including:
Authentication providers — if you choose to sign in using a third-party account (such as a social login service), we receive basic profile information permitted by your settings on that service.
Analytics partners — aggregated or anonymised data about how users interact with the Service.
Payment processors — confirmation of transaction status and billing address verification results.
2. How We Use Your Information
We use the information we collect for the following purposes:
Service delivery — to create and manage your account, process enrolments, deliver workshop content, track your progress, and provide support.
Personalisation — to adapt content, exercises, and recommendations to your learning history and stated preferences.
Communication — to send transactional messages such as enrolment confirmations, password resets, and service notices. Where you have opted in, we may also send educational updates and promotional communications.
Payment processing — to handle transactions securely through our payment partners.
Security and fraud prevention — to detect, investigate, and prevent unauthorised access, abuse, or other harmful activity.
Analytics and improvement — to understand how the Service is used and to improve its design, content, and performance.
Legal compliance — to meet applicable legal obligations, enforce our terms, and respond to lawful requests from authorities.
3. Legal Basis for Processing
We process your personal data only where we have a valid legal basis to do so. Depending on the context, this may include:
Contract performance — processing necessary to fulfil the agreement between you and us when you register for or use the Service.
Legitimate interests — processing that serves our reasonable business interests, such as improving the Service and preventing fraud, provided those interests are not overridden by your rights.
Consent — where you have given clear consent, such as for optional marketing communications or non-essential cookies. You may withdraw consent at any time.
Legal obligation — processing required to comply with applicable laws or regulatory requirements.
4. Sharing of Information
We do not sell your personal data. We may share your information in the following circumstances:
4.1 Service Providers
We engage trusted third-party companies to help operate the Service, including hosting providers, payment processors, analytics services, email delivery services, and customer support tools. These providers access your data only as necessary to perform their functions and are bound by confidentiality and data protection obligations.
4.2 Collaborative Features
Where the Service includes collaborative exercises or group workshops, your display name, submitted work, and participation activity may be visible to other participants in the same session or group, according to the settings of that activity.
4.3 Business Transfers
If we are involved in a merger, acquisition, restructuring, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your personal data becomes subject to a materially different privacy policy.
4.4 Legal Requirements
We may disclose your information if required to do so by law or in response to valid legal process, or where we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud.
4.5 With Your Consent
We may share your information for any other purpose with your explicit consent.
5. Cookies and Tracking Technologies
We use cookies and similar technologies to operate and improve the Service. Cookies are small text files stored on your device.
| Category | Purpose | Required |
|---|---|---|
| Essential | Enable core functions such as authentication, session management, and security. | Yes |
| Functional | Remember your preferences, language selection, and personalisation settings. | No |
| Analytics | Collect aggregated usage data to help us understand how the Service is used and where improvements can be made. | No |
| Marketing | Track engagement with our communications and, where applicable, deliver relevant promotional content. | No |
You can manage your cookie preferences through your browser settings or through any consent tool we provide. Disabling certain cookies may affect the functionality of the Service.
6. Data Retention
We retain your personal data for as long as your account is active or as needed to provide the Service. We also retain data as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
When data is no longer required for any of these purposes, we securely delete or anonymise it. Anonymised or aggregated data that cannot reasonably be used to identify you may be retained indefinitely for analytical purposes.
7. International Data Transfers
kelupuu operates as an international platform serving users across multiple regions. Your data may be processed and stored in countries other than your own. Where we transfer personal data internationally, we take appropriate steps to ensure that your information receives a level of protection consistent with applicable data protection standards, including the use of standard contractual clauses or other recognised transfer mechanisms where required.
8. Your Rights and Choices
Depending on your location and applicable law, you may have the following rights regarding your personal data:
Access — the right to request a copy of the personal data we hold about you.
Correction — the right to request correction of inaccurate or incomplete data.
Deletion — the right to request that we delete your personal data, subject to certain exceptions.
Restriction — the right to request that we limit how we process your data in certain circumstances.
Portability — the right to receive your data in a structured, machine-readable format where technically feasible.
Objection — the right to object to processing based on legitimate interests or for direct marketing purposes.
Withdrawal of consent — where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us using the details in Section 12. We will respond to your request within a reasonable timeframe and in accordance with applicable law. We may need to verify your identity before fulfilling certain requests.
9. Children's Privacy
The Service is not directed to children under the age of 16. We do not knowingly collect personal data from children under this age. If we become aware that we have inadvertently collected personal data from a child under 16, we will take prompt steps to delete that information. If you believe we may have collected data from a child, please contact us immediately.
10. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include encryption of data in transit, access controls, and regular security assessments.
However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.
11. Third-Party Links and Services
The Service may contain links to third-party websites or integrate with external tools and platforms. This Privacy Policy applies only to our Service. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies before sharing any personal data with them.
12. Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact us:
Company: kelupuu
Address: Unit 10 The Court, Ashbourne Industrial Estate, Ashbourne, Co. Meath, Ireland
Email: contact@kelupuu.com
Phone: +353 86 875 8652
Website: kelupuu.com
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you by email or through a prominent notice within the Service.
Your continued use of the Service after any changes take effect constitutes your acceptance of the revised policy. We encourage you to review this page periodically.