AenVault Privacy Policy

Summary of key points

This summary is provided for convenience only. The full Policy below applies.

• Who is responsible. The operator named in Article 1.2 and on the Legal Notice page is the controller of your personal data (Article 1).
• What we process. Your account details, the Content you write, records of your Capsules and purchases, automated review results, Reports and requests, and technical data used to run and protect the Platform (Article 2).
• Automated review. Before Content is saved, it is checked automatically, including by a third-party artificial intelligence review service. The result decides whether your message is saved (Article 4).
• Public Content. Content is locked from everyone, including you, until its Collection opens. It is then public and stays in the Archive, which has no fixed end date. Anything about you or other people in your Content becomes public too (Article 5).
• Payments. Payments are taken by a separate Payment Provider. We do not receive your card details (Article 6).
• Referrals. A referral cookie is used only with your consent. The Payment Provider sends notifications of purchases to our referral-tracking service whatever your cookie choices (Article 7).
• Deletion. You can delete a Capsule or your account after a 14-day waiting period, and you can make a Legal Deletion Request. A short record of each sealed Capsule is kept after its Content is deleted (Articles 10 and 11).
• Your rights. Depending on the law that applies to you, you have rights over your personal data, including under the GDPR, the UK GDPR and Law No. 6698 of Türkiye (Article 13).

Article 1 — Who We Are and Scope

1.1. Controller. The person or entity that operates the AenVault website at aenvault.com (the "Platform") and provides the digital time capsule service offered through it (the "Service") is the controller of the personal data described in this Privacy Policy (this "Policy"). In this Policy, that person or entity is referred to as "AenVault", "we" or "us". AenVault decides why and how this personal data is processed, except where this Policy says that another party, such as the Payment Provider, processes personal data for its own purposes.

1.2. Contact details.

• Controller: Mehmet Karakulak
• Email for data protection requests: legal@aenvault.com

These details, and the operator's other legal contact details, are also published on the Platform's Legal Notice page, which can be viewed without signing in. If they change, the current details are published on that page and in this Policy.

1.3. Who this Policy applies to. This Policy applies when you visit the Platform, create an account, create or purchase a Capsule, view opened Capsules or the Archive, make a Report or respond to one, make a Legal Deletion Request or another request, or contact us. It also covers people whose personal data we receive from others in connection with the Service, such as the holder of a secondary notification email address, people mentioned in Content or in a Report, and people who take part in our referral programme (Article 7.5).

1.4. Terms used. "Personal data" means any information relating to an identified or identifiable natural person. "Terms" means the AenVault Terms of Service. Other capitalised terms, such as "Account Holder", "Capsule", "Capsule Owner", "Content", "Package", "Collection", "Writing Window", "Opening Date", "Display Period", "Archive", "sealed", "primary email address", "Payment Provider", "Message Rules", "Report" and "Legal Deletion Request", have the meanings given in the Terms.

1.5. Related documents. This Policy should be read together with the Terms, the Refund Policy, the Cookie information and the Legal Notice page.

1.6. Processing by other parties. This Policy does not describe how the Payment Provider, or any other third party whose website or service you use directly, processes personal data for its own purposes. Their own privacy notices apply to that processing.

1.7. Mandatory rights. Nothing in this Policy removes or limits any right you have under applicable data protection or consumer law that cannot be waived or limited by contract (Article 1.7 of the Terms). Where such a right applies, a provision of this Policy applies only to the extent that law permits.

Article 2 — Personal Data We Process

2.1. Categories. We process the following categories of personal data.

2.2. What you need to provide. To create a Capsule, you need an account with a verified email address, and you provide the Content. Without this information, we cannot provide the Service. You do not need an account to view public pages; in that case, we process technical and security data and your cookie choices. A secondary notification email address is optional. To make a Report about a rights violation, you need to give your name or your company's name, your role and an email address that you verify. To make a Report under "other", you need to give a verified email address and a description. Reports under the other topics do not require an email address.

2.3. Secondary notification email address. You may add an optional secondary notification email address to a Capsule (Article 3.6 of the Terms). We use it only to send the notification that is also sent to your primary email address when your Capsule's Collection opens. We send nothing else to it. It cannot be used to sign in, reset a password, manage Capsules or make a Legal Deletion Request. You can change or remove it on the "My Capsules" page at any time, including after the Capsule is sealed. If you give us an email address that belongs to someone else, you should do so only if that person knows about it and expects to receive this notification. The holder of that address can contact us using the details in Article 1.2.

2.4. Information about other people. Content, Reports, responses to Reports and the requests we receive may contain personal data about people other than the person who gives it to us. We receive that data from the person who provides it and process it for the purposes in Article 3. The Message Rules do not allow personal information, a first name together with a surname, or a photograph of anyone under 18 in Content (Article 8.2 of the Terms). Responsibility for information about third parties in Content is set out in Articles 3.4 and 8.1 of the Terms.

2.5. Sensitive information. We do not ask you to provide information about health, religious or philosophical beliefs, racial or ethnic origin, political opinions, sex life or sexual orientation, criminal matters or similar sensitive matters. Please do not include such information about yourself or anyone else in your Content: Content is reviewed by automated systems and is made public when its Collection opens. If Content contains such information, it is processed like all other Content until it is removed in one of the cases set out in Article 4.5 of the Terms. Anyone can report opened Content under Article 9 of the Terms.

2.6. What we do not collect. You enter your payment details in the Payment Provider's checkout. We do not receive or store your card details (Article 6).

2.7. How we use Content. We use Content only to provide the Service as described in the Terms, within the limits of the licence in Article 10.2 of the Terms, and to handle Reports, Legal Deletion Requests and official orders and requests.

Article 3 — Why We Use Personal Data and Our Legal Bases

3.1. Purposes and legal bases. We use personal data only for the purposes below. The legal bases named in the table are those of the General Data Protection Regulation (GDPR) and the UK GDPR. Article 3.5 explains the conditions we rely on where Law No. 6698 of Türkiye applies.

3.2. Consent. Where we rely on your consent, you can withdraw it at any time through the "Cookie preferences" link in the footer of the Platform. Withdrawing consent does not affect processing carried out before you withdrew it. We do not treat your acceptance of the Terms, your having taken note of this Policy or any confirmation you give at checkout as consent to processing that requires consent.

3.3. Legitimate interests. Where we rely on our legitimate interests, we take your interests and fundamental rights into account. You can object to this processing as set out in Article 13.

3.4. Contract. Where we rely on the performance of the contract with you, the processing is needed to provide the Service you have asked for. If you do not provide the information concerned, we cannot provide that part of the Service.

3.5. Law No. 6698 of Türkiye. Where Law No. 6698 on the Protection of Personal Data applies, we process personal data for the same purposes on the corresponding conditions in Article 5 of that Law: processing that is necessary for the establishment or performance of a contract with you, processing that is necessary to comply with a legal obligation, processing that is necessary for the establishment, exercise or protection of a right, processing that is necessary for our legitimate interests without harming your fundamental rights and freedoms, and your explicit consent where that Law requires it. We collect personal data electronically: through the Platform and its forms, by email, from the Payment Provider and the referral-tracking service, and automatically through cookies and similar technologies.

Article 4 — Automated Content Review

4.1. What is checked. When you use Save Message, your Content is checked before it is saved. An automated check looks for phone numbers, email addresses, identification numbers and links. The message text and a reduced-size copy of the photograph are also reviewed against the Message Rules by a third-party artificial intelligence review service. The original photograph is not sent to the review service. If there is no final review result for the current version of your Content when your payment is confirmed, the review is completed after payment (Article 4.1 of the Terms).

4.2. The review service. The review service receives the Content sent to it for review, including Content that is then not saved because it is not found acceptable or because the review cannot be completed. It processes that Content to provide the review to us.

4.3. Records we keep. We keep the automated review records described in Article 2.1. They show the result and the categories concerned. They do not contain the Content.

4.4. How the result is used. The result of the review decides automatically whether your Content is saved and whether your Capsule can be sealed.

• If the Content is not found acceptable, or the review cannot be completed because of a technical error or timeout, the Content is not saved, and you are told so that you can revise it or try again. A version you saved earlier stays as it was (Article 5.3 of the Terms).
• If the Content is not found acceptable after your payment has been taken, the Capsule is not sealed and is removed, we inform you at your primary email address, and the payment is refunded (Article 7.2 of the Terms).
• Names are not checked automatically. The rule on a first name together with a surname is applied only when a Report is made or during a review by an administrator.
• Each use of Save Message counts towards the limit on message checks (Article 5.2 of the Terms).

Automated review can produce an incorrect result (Article 14.4 of the Terms).

4.5. Your options. If you believe a decision made by automated review is wrong, you can contact us using the details in Article 1.2. Where applicable data protection law gives you the right to obtain human intervention, to express your point of view or to contest a decision based solely on automated processing, you can exercise that right in the same way. Reports about opened Capsules are decided by a human administrator, not by automated systems (Article 9.7 of the Terms).

Article 5 — Public Display of Content and Information About Other People

5.1. Before sealing. Content that you have saved but not yet paid for is shown only to you, in your account. It is not shown to anyone else.

5.2. Before the Collection opens. From the moment a Capsule is sealed until the Opening Date of its Collection, its Content is not shown or made available to anyone, including you (Article 4.2 of the Terms). Our systems still process it technically in order to operate the Service, for example to encrypt and store it.

5.3. When the Collection opens. On the Opening Date, the Content of every Capsule in the Collection is made public and can be viewed by anyone, anywhere. After the three-month Display Period, Content is kept in the Archive, which has no fixed end date (Articles 2.7 and 2.8 of the Terms). Anything in your Content that identifies or concerns you or another person is public as well. Once Content has been public, others may have copied or shared it, and we cannot control or remove those copies (Article 10.4 of the Terms).

5.4. Hidden Content. When an opened Capsule is reported, it is hidden while the Report is handled, except for Reports under "other" (Article 9.2 of the Terms). While a Capsule is hidden, its Content is not shown to the public. An administrator can view the hidden Content in order to decide the Report.

5.5. If you appear in Content. If an opened Capsule contains personal data about you, you can report it using the report button on the Capsule's page, under the topic "personal information or photo", or contact us using the details in Article 1.2 to exercise your rights under Article 13. Where applicable data protection law or another mandatory legal requirement requires us to remove Content, we remove it (Article 4.5 of the Terms).

Article 6 — Payments and the Payment Provider

6.1. Payment outside our systems. Payments are taken outside AenVault's own systems, through the Payment Provider used for the relevant transaction. You enter your payment details in the Payment Provider's checkout, which is displayed within your dashboard on the Platform. We do not receive or store your card details.

6.2. The Payment Provider's role. Before you complete a purchase, the checkout step and the Payment Provider's terms and privacy notice tell you which Payment Provider is handling the transaction and which party is responsible for collecting the payment, invoicing and taxes. The Payment Provider's own use of the personal data it collects at checkout is described in its privacy notice. Requests about data that the Payment Provider holds for its own purposes should be made to the Payment Provider.

6.3. What we send to the Payment Provider. To create the checkout, we send the Payment Provider the Package being purchased, identifiers that link the payment to your Capsule and, where they apply, a discount code and a referral code (Article 7.1). We do not send the text or the photograph of your Content to the Payment Provider.

6.4. What we receive. The Payment Provider notifies us whether your payment has succeeded, and of refunds and payment disputes concerning your purchase. If a notification about a payment is delayed, we ask the Payment Provider for the status of the payment. We record the purchase and payment records described in Article 2.1 and use them for the purposes in Article 3.

6.5. The Payment Provider's checkout technologies. The Payment Provider's checkout may use cookies or similar technologies under the Payment Provider's own notices. The Cookie information explains more.

Article 7 — Referral Programme

7.1. Referral links. Partners, such as content creators, may share links to the Platform that contain a referral code. If you consent to non-essential cookies, the referral-tracking service can record your visit from the partner's link, the referral code is kept in your browser, and the code is passed to checkout and stored in your purchase and payment records. If you do not consent, the referral code is not kept in your browser and is not passed to checkout. The Cookie information explains how this works and how to change your choice.

7.2. Referral-tracking service. We use a third-party referral-tracking service to attribute purchases to partners, to calculate commissions and to reverse commissions when a payment is refunded or disputed.

7.3. Purchase notifications. The Payment Provider sends notifications of purchases made on the Platform directly to the referral-tracking service. This happens whatever your cookie choices, including for purchases made without a referral code. These notifications, and information that the referral-tracking service obtains from the Payment Provider about a purchase, may include your email address.

7.4. What partners receive. Partners do not have access to Content or to the personal data of the people who buy Capsules.

7.5. Data of referral partners. If you take part in our referral programme as a partner, we process your identity and contact details, your referral link and code, the referral and commission records kept in the referral-tracking service, and the bank or money transfer account details needed to pay your commission. We use this data to manage our agreement with you, to calculate and pay commissions and to keep the records the law requires. We share it with the referral-tracking service and with the bank or money transfer service used to pay you.

Article 8 — Who We Share Personal Data With

8.1. Recipients. We share personal data only as needed for the purposes in Article 3. The recipients are:

• The Payment Provider: the information described in Article 6.
• Service providers that help us run the Platform: providers of hosting and serverless computing, database and user authentication, file storage for photographs, rate limiting and abuse protection, and encrypted backup storage. They process personal data to provide their services to us.
• Email services: services used to send our emails, including verification codes and notifications, and to receive and store the messages you send us and our replies.
• The automated review service: the message text and reduced-size copies of photographs, for the review described in Article 4.
• The referral-tracking service: the information described in Article 7.
• Banks and money transfer services: the information needed to pay commissions to referral partners (Article 7.5).
• The Capsule Owner: in a Report about a rights violation, the reporter's name or company name and the basis of the claim. The reporter's email address, postal address and documents are not shown to the Capsule Owner (Article 9.3 of the Terms).
• Reporters: notices about the progress and outcome of their Report. Reporters are not given the Capsule Owner's email address or account details.
• Courts, public authorities and law enforcement bodies: where a lawful order, request or other legal requirement applies (Article 17 of the Terms).
• A successor operator: if the operation of the Platform and the Service is transferred, as described in Article 16.2.

8.2. Public display. Content that is made public in the Display Period and the Archive is visible to everyone (Article 5.3).

Article 9 — International Transfers

9.1. Where data is processed. The Payment Provider, the service providers listed in Article 8, the automated review service and the referral-tracking service may process personal data in countries other than the one in which you live, including countries outside Türkiye, the United Kingdom and the European Economic Area whose data protection laws differ from the law of your country.

9.2. Safeguards. Personal data is transferred to another country only as applicable data protection law allows. Where the GDPR or the UK GDPR applies, transfers take place on a basis recognised by that law for transfers to other countries. Where Law No. 6698 of Türkiye applies, transfers abroad take place under the conditions in Article 9 of that Law.

9.3. More information. You can ask us for information about the safeguards that apply to a transfer, and for a copy of them where applicable law gives you that right, using the details in Article 1.2.

Article 10 — How Long We Keep Personal Data

10.1. Retention. We keep personal data only for as long as it is needed for the purposes in Article 3. The periods below follow the Collection lifecycle described in the Terms. Where no fixed period is given, we keep the data for as long as the purpose described lasts.

10.2. Backup copies. We keep encrypted backup copies of our database and use them only to restore the Platform after a failure. Backup copies contain the personal data held in the database when they were made, including message text in encrypted form. When personal data is deleted from our live systems, it may remain in backup copies made before the deletion. We do not state a date by which deleted data is removed from backup copies, and we do not guarantee that it is removed from every backup copy by any particular date.

10.3. Longer or shorter periods. We keep personal data for longer where the law requires it, where official proceedings concerning it are pending (Article 17.4 of the Terms) or where it is needed to establish, exercise or defend legal claims. We delete it earlier where it is no longer needed for the purposes for which we keep it.

Article 11 — Deleting Capsules and Your Account, and Legal Deletion Requests

11.1. Deleting a Capsule. You can delete any of your Capsules from the "My Capsules" page, including after it has opened (Article 11.1 of the Terms). To confirm, you enter a one-time code sent to your primary email address and type "DELETE". The deletion takes place 14 days after your request, and you can cancel it until then. When it takes place, the message and the photograph are permanently deleted from our live systems. The record described in Article 10.1 is kept, the payment records are kept, and copies may remain in backup copies (Article 10.2). We email you when your request is received and when the Capsule has been deleted.

11.2. Deleting your account. You can request the deletion of your account (Article 11.2 of the Terms).

• If you have sealed Capsules, you choose whether to keep or delete them.
• The deletion takes place 14 days after your request, and you can stop it until then by signing in. We email you when your request is received and when your account has been deleted.
• When it takes place, your account is deleted, including your sign-in details and your profile information. Capsules for which payment has not been completed are deleted.
• If you chose to keep your Capsules, they stay in their Collections and open on their Opening Dates, and their Content remains public in the Display Period and the Archive. If you chose to delete them, their Content is deleted on the same day.
• The records that we keep after an account is deleted (Article 10.1) are no longer linked to an account.
• After your account has been deleted, we send you no notifications about your Capsules. If you need support for a Capsule you kept, you will need to give the email address of the account and proof of payment (Article 3.5 of the Terms).

11.3. Legal Deletion Requests. A Capsule Owner can ask for the permanent deletion of a sealed Capsule through a Legal Deletion Request, which is assessed under the grounds and exceptions available under data protection law and other mandatory legal requirements (Article 12 of the Terms).

• Account still active: sign in, open the Legal Deletion Request screen and enter the Capsule number. We check that the Capsule is recorded in your account and that the number is correct.
• Account deleted: use the Legal Deletion Request form, which is available without signing in, and enter the email address recorded for the Capsule when it was sealed and the Capsule number. If they match the record described in Article 11.4, we send a one-time verification code to that email address. The code is generated and checked on our servers, can be used once and is valid for a short time only. Limits apply to the number of requests and to failed attempts. For this purpose, we process the email address and Capsule number you enter, the code, the attempts made and your IP address. Entering the code correctly shows that you currently have access to that email address. The code is used only to verify ownership. It is not used for signing in or account recovery, and it does not create an account or give access to any Content.

Completing ownership verification does not delete the Capsule automatically. A human administrator makes the final decision, and the request and its outcome are recorded in our administrative records. We email you when your request is received and about its outcome. If the request is approved, the Capsule's Content is permanently removed, as described in Article 11.5.

If you cannot use either channel, for example because you can no longer sign in to an account that has not been deleted, you can still exercise your data protection rights by contacting us using the details in Article 1.2 (Article 13).

11.4. The record kept for each sealed Capsule. When a Capsule is sealed, we store with the Capsule record a copy of the email address of the account at that moment. This copy is taken from our account records on our servers. We use it only to verify ownership in Legal Deletion Requests made after an account has been deleted, including to send the verification code to that address, and in support requests from people who have lost access to their email address (Article 3.5 of the Terms). It is not displayed in any interface, it is not used to send notifications, and it is kept even if the account is deleted or the Capsule is removed (Article 10.1).

11.5. What removal means for your data. When a Capsule is deleted or removed, its message text and photograph are permanently deleted from our live systems and cannot be restored. The record of the Capsule and the payment records are kept as set out in Article 10.1, and copies may remain in backup copies as set out in Article 10.2. Content that was already public may have been copied by others (Article 5.3).

11.6. Pending processes. While a Report about a Capsule is being handled, or while a Capsule is subject to an official order or request, the deletion of that Capsule, and the deletion of the account of its Capsule Owner, wait until that process has ended (Articles 11 and 17.4 of the Terms).

11.7. Separate processes. A Report, a payment dispute, a Legal Deletion Request and the deletion of your own Capsule or account are separate processes. The outcome of one does not decide the outcome of another (Article 7.5 of the Terms).

Article 12 — Cookies and Similar Technologies

12.1. Cookie information. Information about the cookies and similar technologies used on the Platform, the choices available to you and how to change them is set out in the Cookie information. You can change your choices at any time through the "Cookie preferences" link in the footer of the Platform.

12.2. Consent. Your acceptance of the Terms or your having taken note of this Policy is not consent to non-essential cookies.

Article 13 — Your Rights

13.1. Your rights. Depending on the law that applies to you, you may have the right to:

• be informed about how your personal data is used;
• access your personal data and receive a copy of it;
• have inaccurate or incomplete personal data corrected;
• have your personal data erased;
• restrict the processing of your personal data;
• object to processing based on our legitimate interests;
• receive personal data you have provided to us in a structured, commonly used and machine-readable format, and have it transmitted to another controller;
• withdraw your consent at any time (Article 3.2);
• not be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, and, where such a decision is made, obtain human intervention, express your point of view and contest the decision (Article 4.5); and
• complain to a data protection authority.

13.2. How to use your rights. Contact us using the details in Article 1.2. Account Holders can also use the functions available in their account, such as changing the secondary notification email address and deleting a Capsule or the account. To protect personal data, we may ask for the information we need to confirm your identity and to find the data your request concerns. We respond within the time limits set by applicable law. If we cannot comply with a request in full, we tell you why.

13.3. How the Service affects some requests. Once a Capsule is sealed, its Content is not shown or made available to anyone, including you, until its Opening Date, and it cannot be edited (Articles 4.2 and 4.4 of the Terms). These features of the Service do not remove any right that applicable data protection law gives you. We handle a request concerning personal data in a sealed Capsule under that law, including any exceptions it provides, and we explain our decision. A Capsule Owner can delete their own Capsule at any time (Article 11.1) or make a Legal Deletion Request (Article 11.3).

13.4. If the GDPR or the UK GDPR applies. We respond to your request without undue delay and in any event within one month of receiving it. Where necessary, taking into account the complexity and number of requests, this period may be extended by two further months, and we tell you if this happens.

• European Union and European Economic Area: you can lodge a complaint with the data protection supervisory authority of the country where you habitually reside, where you work or where you believe an infringement took place.
• United Kingdom: you can make a complaint to us about how we process your personal data, using the details in Article 1.2. We acknowledge the complaint within 30 days of receiving it, take appropriate steps to respond to it and inform you of the outcome. You can also complain to the Information Commissioner's Office.

13.5. If Law No. 6698 of Türkiye applies. Under Article 11 of Law No. 6698 on the Protection of Personal Data, you can apply to us to:

• learn whether your personal data is processed;
• request information about the processing if your personal data has been processed;
• learn the purpose of the processing and whether your personal data is used in line with that purpose;
• know the third parties in Türkiye or abroad to whom your personal data is transferred;
• request the correction of your personal data if it is incomplete or inaccurate;
• request the erasure or destruction of your personal data under the conditions in Article 7 of that Law;
• request that the correction, erasure or destruction be notified to the third parties to whom your personal data has been transferred;
• object to a result to your detriment that arises from the analysis of your personal data exclusively by automated systems; and
• claim compensation for damage you suffer because of the unlawful processing of your personal data.

You can apply by any method recognised under that Law and the rules of the Personal Data Protection Board, including by email to the address in Article 1.2 from an email address that you have previously given us and that is registered in our systems, such as your primary email address. We conclude your application as soon as possible, depending on the nature of the request, and within thirty days at the latest. This is free of charge, except for any fee permitted under the Board's rules where answering involves an additional cost. If your application is rejected, our answer is insufficient or we do not answer in time, you can complain to the Personal Data Protection Board within thirty days of learning of our answer and in any case within sixty days of the date of your application.

13.6. Other countries. The law of the country where you live may give you other rights over your personal data. We handle requests under the law that applies.

13.7. Data held by the Payment Provider. For personal data that the Payment Provider holds for its own purposes, make your request to the Payment Provider (Article 6.2).

Article 14 — Children

14.1. Age requirement. The Platform and the Service are for people who are at least 18 years old. People under 18 cannot open an account or purchase a Capsule (Article 3.3 of the Terms). We do not knowingly allow people under 18 to open an account. If you believe that a person under 18 has opened an account, contact us using the details in Article 1.2.

14.2. Capsules addressed to children. A Capsule may be addressed to a child, but the recipient of a message does not become a User and does not have an account (Article 3.4 of the Terms). The Message Rules do not allow a child's personal information, a child's first name together with their surname, or a photograph of anyone under 18 in Content (Article 8.2 of the Terms). Content that includes information about a child is made public like all other Content (Article 5.3).

Article 15 — Security

15.1. Measures. We apply technical and organisational measures to protect personal data, including the following:

• message text is encrypted on our servers before it is stored, and it is decrypted only on our servers;
• photographs are kept in private storage that is encrypted by the storage provider, and they are made available only through short-lived links generated by our servers, never through permanent public links;
• from sealing until the Opening Date, our systems refuse access to Content for everyone, including the Capsule Owner;
• visitors to the Platform cannot access our database directly, and access to administrative functions is limited to administrator accounts;
• the keys and credentials used to operate the Service are kept only on our servers;
• verification codes are generated and checked on our servers, can be used once and expire after a short time, and rate limits protect the Platform against abuse and automated attempts;
• you enter your payment details in the Payment Provider's checkout rather than in forms of our own; and
• our backup copies are encrypted.

15.2. No absolute protection. No system can provide absolute security, and we cannot guarantee that unauthorised access will never occur. Nothing in this Article limits any responsibility that applies to us under data protection law (Article 4.6 of the Terms).

15.3. Personal data breaches. If a personal data breach occurs, we notify the competent authorities and the people affected where applicable law requires us to do so.

Article 16 — Changes to This Policy and Change of Operator

16.1. Changes. We may update this Policy for valid reasons, including a change in the law, in the personal data we process, in the purposes for which we process it, in the providers we use or in the operator. The current version of this Policy and the date on which it takes effect are published on the Platform. For material changes, we give reasonable advance notice by email to the primary email address of Account Holders or by a prominent notice on the Platform. Where applicable law requires your consent to a change, or a specific form of notice, we obtain or give it as that law requires.

16.2. Change of operator. If the operation of the Platform and the Service is transferred to another person or entity, as described in Articles 13.5 and 13.6 of the Terms, personal data is transferred only as applicable data protection law allows. This Policy is updated to identify the operator responsible for personal data, and the new operator's details are published on the Legal Notice page.

16.3. Mandatory rights. Nothing in this Policy deprives you of the protection of mandatory data protection law, of your right to complain to a data protection authority, or of any right you have under applicable law to bring proceedings before the courts of your own country.