01Introduction
We respect your privacy and process personal data in accordance with Regulation (EU) 2016/679 (GDPR) and the Law of Ukraine on Personal Data Protection. This Policy explains what data we collect, for what purposes, and what rights you have.
02Data Controller
The data controller is a natural person — the owner and operator of the KoloPlus platform (kolo.plus).
Contact for all data protection matters and exercising your rights: privacy@kolo.plus. We respond to written requests within the timeframes set by the GDPR (up to 30 days).
03Data We Collect
- Account: username, email, password (hashed);
- Profile: avatar, bio and voluntarily added data;
- Content: posts, messages, media;
- Technical: IP (usually hashed), device/browser type, cookies;
- Activity: interactions within game mechanics.
04Purposes of Processing
We process data to: provide access to the Platform and its features; ensure security and prevent fraud; improve the service; with consent, show personalised content/ads; comply with the law.
05Legal Bases
- Performance of a contract - access to the Platform;
- Consent - optional cookies, marketing (withdrawable anytime);
- Legitimate interest - security, abuse prevention;
- Legal obligation - statutory requirements.
06Your Rights
You have the right to: access and a copy of your data; rectification; erasure ("right to be forgotten"); restriction and objection; portability; withdraw consent; lodge a complaint with a supervisory authority (Ukraine - the Parliament Commissioner for Human Rights; EU - your local data-protection authority). Requests: privacy@kolo.plus.
07Data Retention
Data is kept only as long as necessary for the purposes or as required by law. Account data - until deletion; security logs - a limited period. After account deletion, data is deleted or anonymised.
08Sharing with Third Parties
We do not sell your data. We may share it with processors acting on our instructions (hosting, analytics, advertising partners such as Google) and as required by law. Processors must ensure appropriate protection.
09Third-Party Advertising (Google AdSense)
The Platform may display ads served by third-party vendors, including Google AdSense. Third-party vendors, including Google, use cookies (including the DoubleClick advertising cookie) to serve ads based on your prior visits to this and other websites.
Google's use of advertising cookies enables it and its partners to serve ads to you based on your visits to our site and/or other sites on the Internet.
You may opt out of personalized advertising via Google Ads Settings or www.aboutads.info. You can manage consent for advertising cookies on our Platform via the consent banner and the Cookie Policy.
10Data Security
We apply technical and organisational measures: password and IP hashing, access controls. No transmission method is fully secure, but we continuously improve protection.
11Cookies
We use cookies and similar technologies. For details, see our Cookie Policy.
12Children's Privacy
The Platform is not intended for persons under 9. Persons aged 9-17 use it only with guardian consent and in kids game mode (no feed, posting or classifieds; ages 9-12 also without messages, media, geolocation or any ads; 13-17 - non-targeted ads only). The consent is recorded. If we learn that we process a child's data without proper consent, the account and the data are deleted (Art. 8 GDPR; Ukrainian law).
13Changes to this Policy
We may update this Policy. Material changes will be announced on the Platform with the date.
14Contact
For privacy and data-protection matters: privacy@kolo.plus.