privacy policy
# Privacy Policy
## 1. Introduction
LupoTek (“LupoTek”, “we”, “us”, “our”) is committed to protecting your personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Liechtenstein Data Protection Act (DSG).
This Privacy Policy explains how we collect, use, disclose, and protect personal data when you access or use our website, products, services, and related offerings (collectively, the “Services”).
For the purposes of applicable data protection law, LupoTek acts as the data controller of your personal data unless otherwise stated.
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## 2. Personal Data We Collect
### 2.1 Data you provide to us
We may collect personal data that you provide directly, including:
- Identity data (name, organisation)
- Contact data (email address, phone number, mailing address)
- Account or registration information
- Payment and transaction data (processed via secure third-party providers)
- Communications (support requests, feedback, enquiries)
- Content you upload or submit
- Any other data you choose to provide
### 2.2 Data collected automatically
We may automatically collect:
- Usage data (pages visited, interactions, session duration)
- Technical data (IP address, browser type, operating system, device identifiers)
- Log and diagnostic data
- Cookie and tracking data (see Section 5)
### 2.3 Data from third parties
We may receive personal data from:
- Analytics providers
- Business partners
- Publicly available sources
- Social media platforms (if you interact with us through them)
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## 3. Legal Bases for Processing
We process your personal data on one or more of the following legal bases:
- Performance of a contract – to provide Services requested by you
- Legitimate interests – to operate, improve, and secure our Services
- Legal obligations – to comply with applicable laws and regulations
- Consent – where required (e.g. marketing communications or certain cookies)
Where processing is based on legitimate interests, we ensure those interests are not overridden by your rights and freedoms.
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## 4. How We Use Personal Data
We use personal data to:
- Provide, operate, and improve our Services
- Manage accounts, transactions, and billing
- Communicate with you (including service updates and support)
- Send marketing communications (where permitted or with consent)
- Personalise user experience and content
- Conduct analytics and research
- Maintain security, prevent fraud, and enforce our rights
- Comply with legal and regulatory obligations
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## 5. Cookies and Tracking Technologies
We use cookies and similar technologies to:
- Ensure functionality of the Services
- Analyse usage and performance
- Personalise content
Where required by law, we will obtain your consent before placing non-essential cookies.
You may manage cookie preferences through your browser settings.
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## 6. Disclosure of Personal Data
We may disclose personal data to:
- Service providers and processors acting on our behalf
- Affiliates or related entities
- Professional advisers
- Authorities or regulators where legally required
- Third parties in connection with corporate transactions
- Other parties with your consent
All third-party processors are required to handle personal data in accordance with applicable data protection laws.
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## 7. International Data Transfers
Personal data may be transferred outside the European Economic Area (EEA).
Where this occurs, we ensure appropriate safeguards are in place, such as:
- Transfers to countries recognised as providing adequate protection
- Standard Contractual Clauses approved by the European Commission
- Other lawful transfer mechanisms under GDPR
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## 8. Data Retention
We retain personal data only for as long as necessary to:
- Fulfil the purposes outlined in this Policy
- Comply with legal obligations
- Resolve disputes and enforce agreements
Data is securely deleted or anonymised when no longer required.
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## 9. Your Rights
Under GDPR, you have the right to:
- Access your personal data
- Rectify inaccurate or incomplete data
- Erase your personal data (“right to be forgotten”)
- Restrict processing
- Object to processing (including for direct marketing)
- Data portability
- Withdraw consent at any time (where applicable)
To exercise your rights, contact us using the details below.
You also have the right to lodge a complaint with the Liechtenstein Data Protection Authority.
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## 10. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse.
However, no system is completely secure, and we cannot guarantee absolute security.
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## 11. Children’s Data
Our Services are not directed to individuals under 18 years of age, and we do not knowingly collect personal data from children.
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## 12. Changes to this Privacy Policy
We may update this Privacy Policy periodically. Updates will be posted with a revised “Effective Date.”
Continued use of the Services after changes are published constitutes acceptance of the updated Policy.
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Contact Us: If you have questions or wish to exercise your rights, contact email: legal@lupotek.org (will be online and active to the best of our ability; we cannot guarantee public addresses will remain active 100% of the time). For general public information, you may also contact the Liechtenstein Data Protection Authority.