KENWELL PRIVACY POLICY
Effective Date: July 25, 2025
Last Updated: July 25, 2025
1. INTRODUCTION AND DATA CONTROLLER
At Kenwell, your privacy is our highest priority. This Privacy Policy describes how we collect, use, store, share, and protect your personal data when you use our Services, in strict compliance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD).
The controller of your personal data is:
Owner: Yankpmayk Portela
Registered Address: Carrer de la Independència, 333, 08026 Barcelona, Spain
Email: legal@kenwell.io
2. WHAT PERSONAL DATA WE PROCESS AND WHY
We collect and process different categories of personal data based on your interaction with our Services:
| Data Category | Examples | Purpose of Processing | Legal Basis for Processing (GDPR) |
|---|---|---|---|
| Identification and Contact Data | Username, email address. | Create and manage your user account; communicate with you for operational and support purposes. | Art. 6.1.b) GDPR: Performance of a contract |
| Service Usage Data | Game progress, achievements, settings, preferences, interactions with other users. | Provide and personalize the Service experience; enable social functionalities. | Art. 6.1.b) GDPR: Performance of a contract |
| Technical and Device Data | IP address, device type and operating system, unique device identifiers, crash logs. | Ensure the security of the Services; diagnose and resolve technical issues; improve and optimize our Services. | Art. 6.1.f) GDPR: Legitimate interest |
| Browsing Data | Cookies and similar technologies. | Analyze the use of our website to improve it; personalize the user experience. | Art. 6.1.a) GDPR: Consent (for non-essential cookies) |
| Communication Data | Content of your support service inquiries. | Process and resolve your requests and inquiries. | Art. 6.1.b) GDPR: Performance of a contract |
3. DATA RETENTION
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, tax, or accounting obligations.
Account data: Will be retained while you maintain an active account. If you delete your account, your data will be deleted within 30 days, unless we must retain it in blocked form for legal claims.
Technical data: Will be retained in aggregated or anonymized format, or briefly for security and diagnostic purposes.
4. DATA SECURITY
We have implemented high-level technical and organizational security measures to protect your personal data against unauthorized destruction, loss, alteration, access, or disclosure. These include password encryption, access controls, backups, and monitoring systems.
5. DISCLOSURE OF DATA TO THIRD PARTIES
We do not sell or rent your personal data. We only share information with third parties in the following cases:
Service Providers: Providers who render services to us act as data processors and are contractually obligated to protect your data.
Legal Obligation: We may disclose your data to public authorities, courts, or tribunals when required by law.
6. USER RIGHTS REGARDING YOUR DATA
You have the right to exercise the following rights:
Access: Request confirmation and access to your data.
Rectification: Request correction of inaccurate data.
Erasure: Request deletion of your data.
Objection: Object to processing.
Restriction of Processing: Request restriction under certain circumstances.
You may exercise these rights by sending a written request with your Kenwell platform security token to legal@kenwell.io.
If you consider your rights have not been addressed, you can file a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.
7. CHANGES TO THE PRIVACY POLICY
We reserve the right to modify this Privacy Policy. We will notify you of any substantial changes through the Services or by email so that you may review them before they become effective.