Legal

At Kiln, protecting your personal data is our priority.

When you use the website https://kiln.fi/ (hereinafter the "Website") and our SaaS Platform (hereinafter the “Platform”), we may collect personal data about you.

The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").

1. Who is the data controller?

The data controller is Kiln, a French simplified joint stock company, registered with the Registry of Trade and Companies of Paris under the number 839 230 125 and whose head office is located at 17 rue Henry Monnier, 75009 Paris(hereinafter “Us” or “We”).

2. What personal data we collect?

Personal data is data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

We may collect the following personal data:

Identification data (e.g. name and surname, email address, wallet address);
Data relating to your professional life (e.g. your position, your company name);
Economic and financial data (e.g. the amount of money you entrust to us);
Data related to your credit cards.

We inform you, when collecting your personal data, whether some of these data are mandatory or optional. Mandatory data are indicated with an asterisk.

3. On what legal basis, for what purposes and for how long do we keep your personal data?

Purposes

Legal basis

Data retention period

To provide you with our services on our Website and Platform (staking of the user’s cryptoassets, whitelabelled staking functionality for businesses)

Performance of a contract to which you are party

Your personal data is retained for the duration of your account.

If your account is inactive for a period of 2 years, it will be deleted after a reminder from us without answer.

In addition, personal data may be archived for probationary purposes for a period of 5 years.

To send direct marketing, newsletters

For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news.

For our prospects: your consent

Personal data is retained for a period of 3 years starting from the last contact with us (e.g. communication, action) or until you withdraw your consent.

To answer to your contact request

Taking steps at your request prior to entering into a contract

Your data is retained for 3 years for direct marketing purposes.

To process your applications

Taking steps at your request prior to entering into a contract

The data is retained for the necessary time to process your application.

If your application is unsuccessful, we may wish to retain your data and will inform you if so. If you do not object to the retention of your data, they will be retained for 2 years after your last contact with us.

To process data subjects’ requests to exercise their rights

Our legitimate interest in responding to your requests and keeping records of them

If we ask you for proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted.

If you exercise your right to object to direct marketing: we keep this information for 3 years.

4. Who are the recipients of your personal data?

‍Will have access to your personal data:

(i) The staff of our company;
(ii) Our processors: hosting provider, mailing provider, external recruitment website, form builder tool, user journey analysis tool, customer relationship management software, cryptocurrency custodian, cryptocurrency transaction analysis software;
(iii) If applicable: public and private organisations, exclusively to comply with our legal obligations.

5. Are your personal data likely to be transferred outside the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company Amazon Web Services, located in Ireland.

As part of the tools we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR : in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited to the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or under an approved certification mechanism; or
The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.

6. What rights do you have regarding your personal data?

You have the following rights regarding your personal data:

Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.
Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.
Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.
Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.
Right to erasure: (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.
Right to file a complaint to a competent supervisory authority: (in France, the CNIL), under GDPR article 77, if you consider that the processing of your personal data constitutes a breach of applicable regulations.
Right to define instructions related to the retention, deletion and communication of your personal data after your death (article 40-1 of French law “informatique et libertés”).
Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.
Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing to us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

7. Contact information for data privacy matters

Contact email: legal@kiln.fi
Contact address: 17 Rue Henry Monnier, 75009 Paris

8. Modifications

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

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