Privacy Policy

The controller of your personal data is [LEGAL NAME], [ENTITY TYPE AND REGISTRATION NUMBER], [REGISTERED ADDRESS], Ukraine. For anything in this policy, including a request to see or delete your data, write to support@kynvor.watch.

Paddle.com Market Ltd is the merchant of record for your purchase and is a separate controller of the payment data it collects. We never see your card details.

When you buy a key, we store exactly this:

• Your email address, so we can send you the key and send it again if you lose it.
• Your device code — the eight characters shown on the watch face. It is not your watch’s serial number: it is the first part of a cryptographic hash of an identifier your watch generates. We cannot reverse it, and it cannot be used to locate, contact or identify a device. Because we store it next to your email, we treat it as personal data anyway.
• The order: which face, what it cost, when, whether it was paid or refunded, and the reference our payment provider gave it.
• The key we issued, and whether it is still valid.
• The notification from our payment provider that told us your payment succeeded, kept as received. We keep it so that a message delivered twice cannot issue you a second key and charge you twice. It contains what Paddle chose to send, which may include your country and the transaction details.
• Your messages, if you write to support, and our replies.

That is the whole record. There is no name field, no address field, no phone number and no marketing list.

• No cookies for visitors. Browsing and buying set no cookie at all. The only cookie this site issues is the login session for the shop’s own administrator, and you will never be given one.
• No analytics or tracking. We do not run Google Analytics or any equivalent, there are no advertising pixels, and no third-party script runs on these pages. Fonts are served from this site rather than from a font provider, so loading a page does not tell anyone else that you did.
• No profiling, no automated decisions. Nothing here decides anything about you automatically.
• No selling of data. We do not sell, rent or share your data for anyone else’s marketing, ever.
• No contact from your watch. Once the key is in, the watch face checks it offline. It does not report to us that it is running, where it is, or what it is showing.

Two small things are stored by your browser and never sent to us:

• The faces you mark with the heart, so the catalogue can remember them. This is written only when you use that control, it is a list of face names, and clearing your browser data removes it.
• A single flag on the confirmation page recording that your key has already been displayed, so it is not shown again to whoever picks up the phone next. It is deleted when you close the tab.

Neither is used to recognise you, and neither leaves your device.

Under the GDPR we rely on the following legal bases:

• Performance of a contract — the email, device code, order and key. Without them we cannot issue the key you paid for, send it to you, or send it again later. If you do not give them, we cannot sell you a key.
• Legitimate interests — keeping the payment notification so a duplicate cannot charge you twice, and limiting how often a single address can call our forms so the shop is not overwhelmed. We think you would expect both, and neither builds a profile.
• Legal obligation — records we are required to keep. Because Paddle is the merchant of record, most tax and invoicing records are held by Paddle rather than by us.

Three suppliers, each doing one job, none of them permitted to use your data for their own purposes except as noted:

• Paddle.com Market Ltd (United Kingdom) — takes the payment as merchant of record. Paddle receives your payment details directly; we never do. Paddle is a separate controller for its own compliance obligations and has its own privacy notice.
• Resend (United States; sending infrastructure in the EU) — delivers the emails that carry your key. It processes your address and the content of the message.
• Fly.io (United States) — hosts the application and the database. The data itself is stored on a volume in Frankfurt, Germany.

We may also disclose data where the law requires it, and we will tell you if that happens unless we are forbidden from doing so.

The database is in the European Union. The person who runs this shop is in Ukraine, so administering it means your data is accessed from outside the EEA. Ukraine is not the subject of a European Commission adequacy decision, so where the GDPR applies to you this transfer relies on the standard contractual clauses and on the safeguards described here — in particular that the record is small, that access is restricted to one person, and that the panel it is accessed through requires a password and a second factor and records every action taken in it.

Two of our three suppliers are companies in the United States, so hosting the site and sending your key both involve a transfer there. Each relies on its own transfer mechanism — standard contractual clauses, and where applicable the EU–US Data Privacy Framework — set out in its data processing agreement.

A licence key has no expiry, which is the whole promise of the product — so the record that lets us recognise, re-send and support that key is kept for as long as the key is meant to work. Deleting it would mean that a customer who writes in five years from now with a replaced watch cannot be helped.

• Orders and keys — kept for the life of the licence, unless you ask us to erase them.
• Payment notifications — kept while they still serve their purpose of preventing a duplicate charge, and then deleted.
• Support messages — kept while the matter is open and for a reasonable period after.
• Orders that were never paid — an abandoned checkout leaves a record with your address in it. We delete these once it is clear no payment is coming.

If the GDPR or the UK GDPR applies to you, you have the right to ask us for a copy of your data, to correct it, to have it erased, to restrict or object to how we use it, and to receive it in a portable form. Write to support@kynvor.watch and we will answer within one month.

One thing to know before asking for erasure. Your key is not stored on your watch by us — it is stored in the order record. Erase that record and we can no longer prove the key is yours, re-send it, or reissue it if you change watches. The face you have already unlocked keeps working; what you lose is our ability to help you afterwards. We will say so before acting, and proceed if that is still what you want.

You can also complain to a data protection authority — in the EU, the one where you live or work.

The site is served over HTTPS only. The administration panel is protected by a password and a one-time code, locks itself after repeated failures, and writes every action to an audit log. Payment notifications are rejected unless they carry a valid signature, so an unsigned message cannot issue a key or refund one. We do not store card data because we never receive it.

No system is perfect. If we ever discover a breach affecting your data, we will tell you and the relevant authority as the law requires.

This shop is not aimed at children and we do not knowingly collect data from anyone under 16. If you believe a child has given us their data, write to us and we will delete it.

If we change what we collect or who processes it, we will update this page and the date at the top. Where a change materially affects you and we hold your address, we will email you.