Privacy Policy

Commitment 01We tell you who answers for your data

K.D.E.P. INVESTMENT LTD, a company registered in the Republic of Cyprus with its address at 17 Megalou Alexandrou, Aglantzia, Nicosia 2121, Cyprus (“K.D.E.P.”, “we”, “our”), decides why and how the personal data described in this policy is used. In the vocabulary of the EU General Data Protection Regulation 2016/679 (“GDPR”) and of Cyprus Law 125(I)/2018, which supplements it, we are the controller.

The policy covers three things: our website at kdep-investment.com; the apps we publish on Apple’s App Store; and messages people send us. Where an app needs to say more — on its App Store page under “App Privacy”, or on a screen inside the app — that extra information applies to the app together with this policy. An app shipped with a privacy policy of its own follows that policy instead.

Commitment 02We collect only what a feature needs

On this website

The site is a set of static pages. It has no sign-up, no forms, no analytics, no advertising and no tracking code. To deliver a page, our web server writes a log line holding your IP address, the date and time, the address you asked for, the page that referred you and the user-agent string your browser sends.

When you write to us

We receive your e-mail address, your name or signature if you include one, what you write, any files you attach and the technical headers that travel with every e-mail.

In our apps

Our first app is still in development. Depending on what an app does, it may handle the following:

Business contacts

For partners, suppliers and customers we keep names, job titles, e-mail addresses and phone numbers, along with the related messages, contracts and invoices.

Sensitive data

We do not ask for health, biometric or other special-category data listed in Article 9 GDPR. If a feature ever needed it, the app would first explain why and ask for your explicit consent.

Commitment 03Every use has a purpose and a legal basis

Where we rely on legitimate interests, we have weighed them against your rights, and you may object (see commitment 09). Consent can be withdrawn whenever you like; doing so does not undo processing that took place before. We never make decisions about you by purely automated means that have legal or similarly significant effects.

Commitment 04Data is never sold, and our helpers are named

We do not sell, rent or swap personal data. We pass it on only as far as each of these recipients needs:

• Hetzner Online GmbH (Germany) runs the server that hosts this website, located in Helsinki, Finland.
• Cloudflare, Inc. (United States) answers DNS queries for our domain and carries traffic to the website, filtering out attacks on the way.
• Google provides our e-mail through Google Workspace.
• Back-end hosting, analytics, crash-reporting or attribution services built into a particular app — each one is listed in that app’s App Store privacy details.
• Apple distributes our apps and takes payment for them, acting as an independent controller under its own privacy policy.
• Accountants, auditors and lawyers, all bound by professional secrecy.
• Courts, regulators and the police, where the law obliges us to disclose data or where disclosure is needed to protect someone’s rights or safety.
• A buyer of, or successor to, our business, who must keep protecting the data as this policy describes.

Each processor acts only on our written instructions, under a contract that meets Article 28 GDPR.

Commitment 05Safeguards travel with data that leaves Europe

Some of the providers above are based, or process data, outside the European Economic Area. Those transfers rest on an adequacy decision of the European Commission — the EU–U.S. Data Privacy Framework, for instance, when the recipient is certified under it — or on the Commission’s standard contractual clauses, with extra measures where they are needed. Ask us and we will send you a copy of the safeguards that apply.

Commitment 06Nothing is kept longer than necessary

Web server logs

Deleted automatically after 14 days.

E-mails and help requests

Kept while the matter is open and for up to 24 months after it closes; longer only when needed for a legal claim.

App and account data

Kept while you use the app; deleted or anonymised within a reasonable time after you delete your account or ask us to, unless the law requires us to keep it.

Accounting and transaction records

Kept for the periods set by Cypriot tax and company law.

Commitment 07We protect what we hold

Our safeguards match the risk: every page travels over encrypted HTTPS, our servers are administered with SSH keys instead of passwords, and access is limited to the people who need it. No system is perfectly secure; if a breach puts your data at risk, we will report it to the Commissioner and tell you whenever the GDPR requires it.

Commitment 08This website sets no cookies

Our pages store nothing on your device. Cloudflare may occasionally place a strictly necessary security cookie to tell people apart from automated traffic. Inside an app, a built-in software kit may keep an identifier on your device for the purposes in commitment 02; where the law makes that depend on your consent, the app asks first.

Commitment 09You remain in control

Under the GDPR, and subject to its conditions, you can:

• find out whether we hold data about you and receive a copy;
• have mistakes corrected and gaps filled in;
• have data erased;
• have its use restricted;
• receive the data you gave us in a portable, machine-readable form, or have it sent to another controller;
• object to uses based on legitimate interests, and to direct marketing at any time;
• withdraw consent you have given.

To use any of these rights, e-mail support [at] kdep-investment.com. We may need to confirm your identity first. You will hear from us within one month; complex or numerous requests can take two months more, and if so we will say so within the first month.

Apple keeps the records of App Store purchases, so refunds and full purchase histories are matters for Apple.

If you believe we have mishandled your data, you may complain to the Office of the Commissioner for Personal Data Protection in Nicosia (www.dataprotection.gov.cy) or to the supervisory authority of the EU country where you live or work. We would welcome the chance to put things right first.

Commitment 10Changes are announced, not hidden

When this policy changes, the new text and the date it takes effect appear on this page. For significant changes we will also give notice inside the apps concerned, or by e-mail if we have your address.

Commitment 11Writing to us