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Privacy policy

Draft: pending legal review by Koi Ventures. Not yet in effect.

How koigroup.io handles the data of the people who visit it, apply to our programs or write to us.

Who is responsible

This website, koigroup.io (the "Site"), is operated by Koi Ventures [TBD: legal entity name and CUIT], with legal address in Buenos Aires, Argentina [TBD: registered address]. For any question about this policy or your personal data, write to info@koigroup.io.

What data we collect and how

The Site is an informational website. It has no user accounts, login or newsletter, and it does not ask you to fill in any form on the Site itself.

  • Usage data, collected automatically. When you browse the Site, analytics and session-recording tools (see "Cookies and analytics") collect technical data such as your IP address, approximate location derived from it, browser and device type, pages visited, time spent, clicks, scrolling and mouse movements.
  • Server logs. The Site is hosted on Firebase Hosting (Google). Google keeps standard server logs (IP address, requested URL, date and time, user agent) as part of the hosting service.
  • Data you send us through external services. If you apply to a program, you do so on a form hosted by Airtable; if you contact us, you do so by WhatsApp or by email. The data you provide there (for example name, email, phone number and the information about your startup) is processed by those services under their own terms and reaches Koi Ventures, which keeps it to answer you and evaluate your application.

What we use it for

  • To make the Site work and keep it secure.
  • To understand how the Site is used and improve it (aggregated analytics and session recordings).
  • To answer your messages and evaluate applications to our programs.

We do not sell personal data and we do not use it for automated decisions with legal effects on you.

Cookies and analytics

The Site loads two third-party tools that set cookies and similar identifiers in your browser:

  • Google Tag Manager (container GTM-KXVKKLW), which loads the measurement tags configured by Koi Ventures [TBD: list the tags configured in the container, for example Google Analytics].
  • Hotjar (site 3873985), which records anonymized sessions (page interactions, with form inputs and personal fields masked by default) and produces heatmaps.

The Site also loads fonts and icon files from third-party servers (Google Fonts and Font Awesome), which receive your IP address when the files are requested.

How to opt out. You can block or delete cookies in your browser settings; the Site keeps working without them. Hotjar offers an opt-out at hotjar.com/policies/do-not-track. Google offers a browser add-on to opt out of Google Analytics at tools.google.com/dlpage/gaoptout. [TBD: whether a cookie banner with consent will be added before publishing]

Who we share it with

We share data only with the service providers needed to run the Site and respond to you: Google (Firebase Hosting, Google Tag Manager and related measurement services, Google Fonts), Hotjar (session analytics), Airtable (application forms), Meta / WhatsApp (messaging) and the email provider behind info@koigroup.io [TBD: name the email provider]. Each of them processes data under its own privacy policy.

The Site links to the websites of the startups in our portfolio and to other third parties. Those sites have their own privacy policies; this policy does not cover them.

We may also disclose data when required by law or by a competent authority.

International transfers

The providers listed above store and process data on servers located outside Argentina, mainly in the United States and the European Union. Where required, these transfers rely on the providers’ standard contractual safeguards [TBD: confirm the safeguard relied on for each provider, per Law 25.326 and AAIP rules].

How long we keep it

Analytics and session data are kept for the periods configured in each tool [TBD: retention period set in Google Analytics and Hotjar]. Applications and messages are kept while we evaluate them and for [TBD: retention period for applications and contact messages] afterwards, unless you ask us to delete them earlier.

Your rights

Under Argentina’s Personal Data Protection Law No. 25.326 you have the right to access, rectify, update, and delete your personal data, and to object to its processing, free of charge at intervals of no less than six months unless a legitimate interest is shown. To exercise them, write to info@koigroup.io indicating your request.

The Agencia de Acceso a la Información Pública (AAIP), as the control authority of Law No. 25.326, handles complaints about non-compliance with personal data protection rules: argentina.gob.ar/aaip.

Minors

The Site and our programs are addressed to adults. We do not knowingly collect personal data from people under 18. If you believe a minor has sent us data, write to info@koigroup.io and we will delete it.

Changes to this policy

We may update this policy when the Site or the tools it uses change. The current version is always published on this page, with its effective date. Effective date: [TBD: effective date, after legal review].

Contact

Koi Ventures, Buenos Aires, Argentina. info@koigroup.io.