Privacy Policy of Kobino

Effective Date: 2025 Jun 10

1. Introduction

Kobino ("Company", "we", "us", or "our") is dedicated to protecting the privacy and security of the personal data of our users, partners, and affiliates. This Privacy Policy outlines our practices regarding the collection, use, disclosure, transfer, and protection of your personal information in full compliance with applicable laws—including the GDPR, relevant local data protection laws, and U.S. sanctions regulations.

2. Definitions

• Personal Data: Any information relating to an identified or identifiable natural person.
• Processing: Any operation performed on personal data, including collection, storage, transmission, or erasure.
• Third Party: Any entity, organization, or individual not directly controlled by Kobino.

3. Information Collection

3.1 Direct Collection

• We collect personal data that you voluntarily provide when creating an account, subscribing to our services, communicating with us, or engaging in any interactions on our website and platforms.
• This may include, but is not limited to, your name, contact details, social media profiles, and transactional records.

3.2 Indirect Collection

• We may obtain data from our business partners, publicly available sources, or other third parties to enhance and tailor our services.

4. Legal Bases and Purpose of Processing

• Consent: Where required, we obtain your explicit consent prior to processing your data.
• Contractual Necessity: Processing is necessary for the performance of contractual obligations between you and Kobino.
• Legitimate Interests: We process data to ensure optimal service delivery, improve user experience, secure our networks, and for other legitimate business purposes.
• Compliance with Legal Obligations: We process data as mandated by law, including in response to valid requests by public authorities.

5. Use of Data

• To provide, maintain, and enhance our social media management services.
• To communicate with you regarding service updates, offers, or legal notices.
• For analytics, research, and improvement of our marketing strategies.
• To ensure compliance with U.S. sanctions, EU data protection laws, and other regulatory frameworks.

6. Data Sharing and Third-Party Disclosures

6.1 With Business Partners

• Personal data may be shared with our trusted partners and service providers under strict confidentiality and data protection agreements.
• Any international transfer, including transfers outside the European Economic Area (EEA), shall be conducted using approved mechanisms (e.g., Standard Contractual Clauses, Binding Corporate Rules).

6.2 Compliance with U.S. Sanctions

• We strictly adhere to U.S. sanctions regulations. Accordingly, we do not engage in any business, data transfers, or collaborations with entities or individuals subject to such sanctions.
• All third-party relationships are subject to rigorous due diligence to ensure full compliance with these laws.

7. Data Security and Retention

• Security Measures: We implement industry-standard technical and organizational measures (e.g., encryption, access controls, regular audits) to protect your data from unauthorized access, loss, or misuse.
• Data Retention: Personal data is retained only as long as necessary for the purposes outlined herein or as required by applicable law.
• Breach Notification: In the unlikely event of a data breach, we will promptly notify affected users and relevant authorities in accordance with legal requirements.

8. User Rights

Depending on your jurisdiction, you may have rights regarding your personal data, including the right to:

• Access, correct, update, or delete your data.
• Object to or restrict certain types of processing.
• Request data portability.
  To exercise these rights, please contact us at legal@kobino.store.

9. Children’s Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children without appropriate consent. If such data is inadvertently collected, we will take steps to delete it immediately.

10. Policy Amendments

We reserve the right to update or modify this Privacy Policy at any time. Changes will be posted on our website and become effective immediately upon publication. Users are encouraged to review this policy periodically.

11. Governing Law and Dispute Resolution

This Privacy Policy is governed by and construed in accordance with the laws of the Kurdistan Region of Iraq and applicable international standards. Any disputes arising in connection with this policy shall be subject to the exclusive jurisdiction of the courts in the Kurdistan Region of Iraq, unless otherwise agreed upon in writing.

12. Contact Information

For questions, concerns, or further clarifications regarding this Privacy Policy, please contact us at:

• Email: legal@kobino.store
• Address: Hewler, Kurdistan Region, Iraq

By using our services, you consent to the practices described in this Privacy Policy.