Privacy Policy

01Introduction

This Privacy Policy explains how Kyttx collects, uses, stores, shares, discloses, transfers, protects, and otherwise processes personal data when you access or use the Kyttx Platform.

This Privacy Policy applies to all Users, including Sellers, Merchants, Buyers, Customers, Members, Operators, agencies, team members, contractors, affiliates, visitors, and other persons who access or use Kyttx.

This Privacy Policy is incorporated into and forms part of the Kyttx Master Terms of Service, Seller / Merchant Agreement, Buyer / Member Terms, Operator / Agency Terms, Payment, Payout & Fee Schedule, Refund, Chargeback & Dispute Policy, Acceptable Use Policy, Content & Intellectual Property Policy, Cookie Policy, Data Processing Agreement, Arbitration & Dispute Resolution Agreement, and other applicable Kyttx Policies.

By accessing or using Kyttx, creating an account, purchasing a Seller Offering, selling through Kyttx, acting as an Operator, submitting information, or otherwise interacting with the Platform, you acknowledge this Privacy Policy.

If you do not agree with this Privacy Policy, you must not use the Platform.

02Important Notice

Kyttx is a software platform that enables Sellers to create, host, sell, manage, and deliver Seller Offerings.

Kyttx may process personal data in different roles depending on the context.

In some cases, Kyttx determines why and how personal data is processed. In other cases, Sellers determine why and how personal data is processed, and Kyttx processes the data on behalf of Sellers.

For example:

• Kyttx generally acts as an independent controller for account registration, Platform security, payment-related records, fraud prevention, legal compliance, support, analytics, and Platform operations.
• Sellers may act as controllers for Buyer Data related to their own Seller Offerings, customer relationships, marketing, communities, content delivery, and communications.
• Kyttx may act as a processor or service provider for certain Buyer Data processed on behalf of Sellers, as described in the Kyttx Data Processing Agreement.
• Third-Party Payment Providers, such as Stripe, may act as independent controllers for payment processing, fraud prevention, KYC, identity verification, compliance, and financial services.

This Privacy Policy does not replace any privacy policy, notice, agreement, or obligation that a Seller must provide to Buyers.

03Definitions

Capitalized terms used but not defined in this Privacy Policy have the meanings given in the Kyttx Master Terms of Service.

For purposes of this Privacy Policy:

?Personal Data? means information that identifies, relates to, describes, can reasonably be associated with, or could reasonably be linked to an identified or identifiable person.

?Processing? means any operation performed on Personal Data, including collection, use, storage, disclosure, transfer, deletion, analysis, hosting, transmission, protection, or other handling.

?Controller? means a person or entity that determines the purposes and means of Processing Personal Data.

?Processor? means a person or entity that Processes Personal Data on behalf of a Controller.

?Seller? means a person or entity that creates, sells, hosts, manages, or delivers Seller Offerings through or in connection with Kyttx.

?Buyer? means a person or entity that purchases, accesses, subscribes to, joins, receives, or uses a Seller Offering through or in connection with Kyttx.

?Operator? means a person, agency, contractor, consultant, team member, service provider, or other third party authorized to access or manage a Seller account.

?Buyer Data? means Personal Data relating to Buyers, Customers, Members, subscribers, purchasers, participants, or other end users of Seller Offerings.

?Third-Party Payment Provider? means Stripe, Stripe Connect, banks, acquiring banks, card networks, payment processors, payout providers, fraud prevention providers, identity verification providers, tax providers, financial infrastructure providers, or other third-party providers involved in payments, payouts, settlement, verification, compliance, fraud checks, or related services.

04Personal Data We Collect

Kyttx may collect Personal Data directly from you, automatically through the Platform, from Sellers, from Buyers, from Operators, from Third-Party Payment Providers, from service providers, from public sources, or from other third parties.

The categories of Personal Data we may collect include the categories described below.

05Account Information

When you create or manage an account, we may collect:

• Name.
• Email address.
• Username.
• Password or authentication credentials.
• Account role.
• Account permissions.
• Profile information.
• Business name.
• Seller name.
• Operator or agency name.
• Team membership.
• Account settings.
• Support preferences.
• Communication preferences.
• Account status.
• Verification status.
• Invitation records.
• Login history.
• Security settings.

06Seller Information

If you use Kyttx as a Seller, we may collect:

• Legal name.
• Business name.
• Trade name.
• Email address.
• Phone number.
• Business address.
• Country.
• Tax information.
• VAT or sales tax registration information.
• Business registration information.
• Website.
• Social media profiles.
• Seller Offering descriptions.
• Pricing details.
• Refund policies.
• Checkout settings.
• Subscription settings.
• Payment plan settings.
• Payout settings.
• Payment provider account status.
• Transaction records.
• Refund records.
• Chargeback records.
• Buyer complaint records.
• Fraud and risk review information.
• Seller Content.
• Seller communications.
• Team and Operator permissions.
• Analytics and usage data.

Kyttx may not directly collect or store certain sensitive payment or identity verification information if such information is handled by Third-Party Payment Providers.

07Buyer Information

If you use Kyttx as a Buyer, Customer, Member, purchaser, subscriber, or participant, we may collect:

• Name.
• Email address.
• Account login information.
• Purchase history.
• Seller Offering access records.
• Subscription status.
• Payment status.
• Refund records.
• Chargeback records.
• Dispute records.
• Access logs.
• Course or content progress.
• Community participation data.
• Form submissions.
• Booking information.
• Communications with Sellers.
• Support requests.
• IP address.
• Device information.
• Browser information.
• Approximate location.
• Usage data.
• Analytics data.

Depending on the Seller Offering, Sellers may request or collect additional information from Buyers through forms, onboarding flows, community features, booking tools, or other Platform features. Sellers are responsible for ensuring they have a lawful basis to collect and use such information.

08Operator Information

If you use Kyttx as an Operator, agency, contractor, consultant, team member, or service provider, we may collect:

• Name.
• Email address.
• Business or agency name.
• Account role.
• Permissions.
• Seller accounts accessed.
• Invitation records.
• Access logs.
• Changes made to Seller accounts.
• Buyer Data accessed.
• Content created or edited.
• Revenue-share settings.
• Payout eligibility information.
• Tax information.
• Payment provider information.
• Support communications.
• Security and compliance review information.

09Payment and Transaction Information

Kyttx may collect or receive payment-related information, including:

• Transaction amount.
• Currency.
• Purchase date.
• Seller Offering purchased.
• Payment status.
• Payment method type.
• Last four digits of card, where provided by payment providers.
• Billing country.
• Payment provider transaction ID.
• Payment provider account ID.
• Payout status.
• Withdrawal records.
• Instant withdrawal records.
• Refund records.
• Chargeback records.
• Dispute records.
• Negative balance records.
• Fee records.
• Tax records.
• Fraud signals.
• Payment risk information.

Kyttx does not intend to directly store full card numbers, CVV codes, or complete bank credentials. Such information is generally processed by Third-Party Payment Providers.

Third-Party Payment Providers may collect and process payment information according to their own terms and privacy policies.

10KYC, Identity, Business, and Compliance Information

Kyttx or Third-Party Payment Providers may collect information required for verification, compliance, fraud prevention, risk review, tax, payout eligibility, sanctions screening, or legal obligations.

This may include:

• Legal name.
• Date of birth, where required.
• Address.
• Country of residence.
• Nationality, where required.
• Business information.
• Business registration details.
• Ownership information.
• Beneficial owner information.
• Tax identification numbers.
• Identity verification status.
• Verification documents, where required.
• Sanctions screening results.
• Fraud review information.
• Payment provider compliance information.
• Risk scoring or review data.

Kyttx may rely on Third-Party Payment Providers, such as Stripe, to collect and process certain KYC or identity verification information.

11Content and Communications

Kyttx may collect and process Content and communications, including:

• Seller Content.
• Buyer Content.
• Operator Content.
• Landing pages.
• Checkout pages.
• Storefront content.
• Course content.
• Community posts.
• Comments.
• Form responses.
• Booking details.
• Emails sent through the Platform.
• SMS or other messages sent through the Platform.
• Support tickets.
• Dispute communications.
• Refund communications.
• Chargeback evidence.
• Files and downloads.
• Automations and workflow data.
• AI-generated or AI-assisted content.
• Feedback and survey responses.

Kyttx may review or preserve communications and Content where necessary for support, moderation, safety, fraud prevention, dispute resolution, legal compliance, or enforcement.

12Technical, Device, and Usage Information

When you access or use Kyttx, we may automatically collect:

• IP address.
• Device type.
• Browser type.
• Operating system.
• Referring URLs.
• Pages viewed.
• Actions taken.
• Click data.
• Session data.
• Login data.
• Access times.
• Approximate location.
• Language settings.
• Device identifiers.
• Cookie identifiers.
• Analytics identifiers.
• Error logs.
• Performance logs.
• Security logs.
• Feature usage data.
• API usage data, where applicable.
• Automation usage data.
• Communication deliverability data.
• Metadata related to transactions, accounts, content, and communications.

13Cookies and Similar Technologies

Kyttx may use cookies, pixels, tags, local storage, session storage, software development kits, analytics technologies, and similar tools.

These technologies may be used for:

• Authentication.
• Account security.
• Session management.
• Preferences.
• Platform functionality.
• Analytics.
• Performance monitoring.
• Fraud prevention.
• Advertising.
• Attribution.
• Conversion tracking.
• Support tools.
• Product improvement.
• Debugging.

More information is provided in the Kyttx Cookie Policy.

14Information from Third Parties

Kyttx may receive Personal Data from third parties, including:

• Sellers.
• Buyers.
• Operators.
• Third-Party Payment Providers.
• Fraud prevention providers.
• Identity verification providers.
• Tax providers.
• Analytics providers.
• Hosting providers.
• Communication providers.
• Support providers.
• Social media platforms.
• Advertising platforms.
• Public sources.
• Business partners.
• Service providers.
• Regulators.
• Law enforcement.
• Legal advisors.
• Other Users.

15How We Use Personal Data

Kyttx may use Personal Data for the purposes described below.

16To Provide and Operate the Platform

We may use Personal Data to:

• Create and manage accounts.
• Authenticate Users.
• Provide dashboards.
• Host Seller Offerings.
• Provide Buyer access.
• Manage Seller storefronts.
• Operate checkout-related tools.
• Support payment-related workflows.
• Manage subscriptions.
• Manage payment plans.
• Manage trials.
• Manage communities.
• Manage course access.
• Manage files and downloads.
• Manage forms.
• Manage bookings.
• Manage automations.
• Manage email or SMS tools.
• Provide analytics.
• Provide CRM features.
• Provide Operator access.
• Provide customer support.
• Troubleshoot issues.
• Maintain Platform functionality.

17To Process Payments and Payouts

We may use Personal Data to:

• Enable checkout.
• Route payments through Third-Party Payment Providers.
• Calculate Fees.
• Deduct Fees.
• Manage payouts.
• Manage withdrawals.
• Manage instant withdrawals.
• Manage revenue share.
• Manage Operator commissions.
• Process refunds.
• Manage chargebacks.
• Submit dispute evidence.
• Manage negative balances.
• Apply reserves.
• Apply payout holds.
• Detect payment fraud.
• Comply with payment provider requirements.
• Maintain transaction records.

18To Verify Identity, Business, Tax, and Compliance Information

We may use Personal Data to:

• Verify accounts.
• Verify identity.
• Verify businesses.
• Verify tax information.
• Screen for sanctions.
• Prevent fraud.
• Comply with anti-money laundering obligations where applicable.
• Comply with payment provider rules.
• Comply with tax obligations.
• Assess payout eligibility.
• Assess Seller risk.
• Assess Operator risk.
• Comply with legal obligations.
• Respond to regulators or legal authorities.

19To Manage Risk, Security, Fraud, and Abuse

We may use Personal Data to:

• Protect accounts.
• Detect fraud.
• Detect payment abuse.
• Detect refund abuse.
• Detect chargeback abuse.
• Detect account takeover.
• Prevent unauthorized access.
• Investigate suspicious activity.
• Enforce Kyttx Policies.
• Moderate Content.
• Investigate User reports.
• Protect Buyers.
• Protect Sellers.
• Protect Operators.
• Protect payment providers.
• Protect Kyttx infrastructure.
• Prevent illegal activity.
• Maintain Platform integrity.

20To Provide Support and Communications

We may use Personal Data to:

• Respond to support requests.
• Send account notices.
• Send security alerts.
• Send transaction confirmations.
• Send purchase confirmations.
• Send payout notices.
• Send refund notices.
• Send dispute notices.
• Send policy updates.
• Send product updates.
• Send administrative messages.
• Send legal notices.
• Communicate about account issues.
• Communicate about Platform changes.
• Communicate about Seller Offerings where relevant.

21To Improve and Develop the Platform

We may use Personal Data to:

• Analyze Platform usage.
• Measure feature performance.
• Improve user experience.
• Develop new features.
• Test features.
• Debug errors.
• Monitor uptime and performance.
• Improve checkout flows.
• Improve security.
• Improve fraud prevention.
• Improve analytics.
• Improve automations.
• Train or improve internal systems where legally permitted.
• Generate aggregated or anonymized insights.

22To Market Kyttx

We may use Personal Data to:

• Send marketing communications where permitted.
• Promote Kyttx features.
• Personalize Platform content.
• Measure marketing campaigns.
• Track conversions.
• Run advertising.
• Analyze referrals.
• Attribute traffic sources.
• Show relevant product updates.
• Manage promotional campaigns.

You may opt out of marketing communications where required by law. You may still receive transactional, legal, security, and administrative messages.

23To Comply with Law and Enforce Rights

We may use Personal Data to:

• Comply with applicable law.
• Comply with tax obligations.
• Comply with payment provider requirements.
• Respond to legal requests.
• Respond to regulators.
• Respond to law enforcement.
• Respond to courts or arbitrators.
• Enforce Kyttx agreements.
• Collect amounts owed.
• Defend legal claims.
• Pursue legal claims.
• Preserve records.
• Protect Kyttx rights.
• Protect User rights.
• Prevent harm.

24Legal Bases for Processing

Where applicable law requires a legal basis for Processing Personal Data, Kyttx may rely on one or more of the following legal bases:

• Performance of a contract.
• Steps taken before entering into a contract.
• Legitimate interests.
• Compliance with legal obligations.
• Consent.
• Protection of vital interests.
• Public interest where applicable.
• Another legal basis permitted by applicable law.

Kyttx?s legitimate interests may include operating the Platform, providing services, improving the Platform, preventing fraud, securing accounts, enforcing agreements, supporting payments, managing risk, communicating with Users, and protecting Kyttx, Users, and third parties.

Where we rely on consent, you may withdraw consent where legally permitted. Withdrawal of consent may affect your ability to use certain Platform features.

25How Sellers Use Buyer Data

Sellers may receive or access Buyer Data through Kyttx.

Sellers may use Buyer Data for purposes such as:

• Delivering Seller Offerings.
• Providing Buyer support.
• Managing subscriptions.
• Managing communities.
• Communicating with Buyers.
• Fulfilling purchases.
• Managing refunds.
• Managing disputes.
• Complying with law.
• Conducting permitted marketing where lawful.
• Improving Seller Offerings.

Sellers are responsible for their own privacy notices, legal bases, consents, marketing compliance, communications, data exports, and Buyer Data handling unless Kyttx expressly assumes responsibility in writing.

Kyttx is not responsible for a Seller?s privacy practices, except to the extent required by law.

26How Operators Access Buyer Data

Operators may access Buyer Data if authorized by a Seller or Kyttx.

Operators must use Buyer Data only for authorized purposes and in compliance with Kyttx Policies, Seller instructions, and applicable law.

Kyttx may restrict or revoke Operator access where Kyttx determines that access creates privacy, security, legal, compliance, reputational, or platform risk.

27How We Share Personal Data

Kyttx may share Personal Data as described below.

28Sharing with Sellers

If you are a Buyer, Kyttx may share your Personal Data with the Seller whose Seller Offering you purchase, access, join, or interact with.

This may include:

• Name.
• Email address.
• Purchase details.
• Subscription status.
• Access status.
• Form submissions.
• Booking information.
• Community participation.
• Communications.
• Refund requests.
• Dispute information.
• Usage information related to the Seller Offering.

Sellers may use this information according to their own privacy practices and obligations.

29Sharing with Buyers

If you are a Seller, Kyttx may share certain information with Buyers where relevant to a Seller Offering.

This may include:

• Seller name.
• Business name.
• Storefront information.
• Seller Offering details.
• Support contact details.
• Refund policy.
• Purchase terms.
• Community rules.
• Other information needed to complete or support a transaction.

30Sharing with Operators and Team Members

Kyttx may share Personal Data with Operators, agencies, team members, employees, contractors, or service providers authorized by a Seller or Kyttx to access an account.

Such access may include Buyer Data, Seller Content, account settings, analytics, communications, or other information depending on permissions.

Sellers are responsible for choosing Operators and managing permissions.

31Sharing with Third-Party Payment Providers

Kyttx may share Personal Data with Third-Party Payment Providers, including Stripe and Stripe Connect, as necessary or appropriate to:

• Process payments.
• Process payouts.
• Verify identity.
• Verify business information.
• Verify tax information.
• Prevent fraud.
• Manage chargebacks.
• Process refunds.
• Handle disputes.
• Comply with payment provider rules.
• Comply with law.
• Support payment-related services.

Third-Party Payment Providers may process Personal Data under their own terms and privacy policies.

32Sharing with Service Providers

Kyttx may share Personal Data with service providers that help operate the Platform, including providers of:

• Hosting.
• Cloud infrastructure.
• Databases.
• Analytics.
• Security.
• Fraud prevention.
• Identity verification.
• Tax services.
• Payment support.
• Customer support.
• Email delivery.
• SMS delivery.
• Notifications.
• Logging.
• Monitoring.
• File storage.
• AI tools.
• Product analytics.
• Error tracking.
• Legal and accounting services.

Service providers may process Personal Data only as permitted by their agreements with Kyttx and applicable law.

33Sharing for Legal, Compliance, and Safety Reasons

Kyttx may share Personal Data where necessary or appropriate to:

• Comply with law.
• Respond to legal requests.
• Respond to subpoenas, court orders, or legal process.
• Respond to regulators.
• Respond to law enforcement.
• Respond to arbitrators.
• Enforce Kyttx Policies.
• Investigate fraud.
• Prevent abuse.
• Protect Platform security.
• Protect Buyers.
• Protect Sellers.
• Protect Operators.
• Protect Kyttx.
• Protect payment providers.
• Collect amounts owed.
• Defend legal claims.
• Pursue legal claims.
• Prevent harm.

34Sharing in Business Transfers

Kyttx may share or transfer Personal Data in connection with:

• Incorporation.
• Reorganization.
• Merger.
• Acquisition.
• Sale of assets.
• Financing.
• Investment.
• Corporate restructuring.
• Change of control.
• Transfer to a Dubai, UAE, DIFC, or other entity.
• Assignment or transfer of Platform operations.
• Bankruptcy or insolvency proceedings.

If Kyttx is transferred to another entity, Personal Data may be transferred as part of that transaction.

35Sharing Aggregated or Anonymized Data

Kyttx may use and share aggregated, anonymized, or de-identified data for:

• Analytics.
• Product improvement.
• Benchmarking.
• Marketing.
• Research.
• Reporting.
• Fraud prevention.
• Business development.
• Investor communications.
• Public statistics.
• Platform performance insights.

Such data is not intended to identify a specific person.

36International Data Transfers

Kyttx may process and transfer Personal Data internationally.

Personal Data may be processed in countries where Kyttx, Sellers, Operators, Third-Party Payment Providers, service providers, or infrastructure providers operate.

These countries may have data protection laws that differ from the laws in your country.

Where required, Kyttx may use appropriate transfer mechanisms, contractual safeguards, adequacy decisions, standard contractual clauses, data processing agreements, consent, or other lawful transfer methods.

By using the Platform, you understand that Personal Data may be transferred internationally.

37Data Retention

Kyttx retains Personal Data for as long as necessary or appropriate for the purposes described in this Privacy Policy.

Retention periods may depend on:

• Account status.
• Transaction history.
• Legal requirements.
• Tax requirements.
• Accounting requirements.
• Payment provider requirements.
• Fraud prevention needs.
• Security needs.
• Dispute resolution needs.
• Chargeback defense.
• Refund disputes.
• Buyer complaints.
• Seller disputes.
• Operator disputes.
• Enforcement needs.
• Backup cycles.
• Operational needs.

Kyttx may retain certain records after account closure or termination where necessary for legal, payment, tax, accounting, security, fraud prevention, dispute resolution, or enforcement purposes.

38Security

Kyttx uses reasonable administrative, technical, and organizational measures designed to protect Personal Data.

Security measures may include:

• Access controls.
• Encryption where appropriate.
• Authentication.
• Logging.
• Monitoring.
• Permission controls.
• Secure hosting.
• Security reviews.
• Fraud detection.
• Account protection tools.
• Internal access restrictions.
• Incident response processes.

No system is completely secure. Kyttx does not guarantee that Personal Data will always be secure, available, or error-free.

Users are responsible for protecting their own credentials, devices, accounts, team access, Operator access, and connected services.

39Data Incidents

If Kyttx becomes aware of a data incident affecting Personal Data, Kyttx may investigate and take steps it determines appropriate.

Where required by applicable law, Kyttx may notify affected Users, Sellers, authorities, regulators, or other parties.

Sellers and Operators must promptly notify Kyttx if they become aware of unauthorized access, disclosure, misuse, loss, or compromise of Buyer Data or other Personal Data processed through Kyttx.

40Your Privacy Rights

Depending on your location and applicable law, you may have certain privacy rights.

These may include the right to:

• Access Personal Data.
• Correct Personal Data.
• Delete Personal Data.
• Restrict Processing.
• Object to Processing.
• Withdraw consent.
• Request portability.
• Opt out of certain marketing.
• Opt out of certain analytics or advertising cookies.
• Appeal certain privacy decisions where applicable.
• Lodge a complaint with a data protection authority.

These rights may be subject to limitations, exceptions, verification requirements, and legal restrictions.

To submit a privacy request, contact:

legal@kyttx.com

41Verifying Privacy Requests

Kyttx may verify your identity before responding to privacy requests.

Verification may require:

• Account login.
• Email verification.
• Transaction details.
• Identity information.
• Additional information necessary to confirm your identity or authority.

Kyttx may reject or limit requests that are unverifiable, excessive, abusive, fraudulent, legally restricted, or inconsistent with Kyttx?s legal obligations.

42Buyer Requests Relating to Seller-Controlled Data

If you are a Buyer and your request relates to Personal Data controlled by a Seller, Kyttx may direct you to contact the Seller.

Kyttx may assist Sellers in responding to privacy requests where required by law or the Data Processing Agreement.

Kyttx may not be able to delete or modify Seller-controlled data without Seller instruction unless required by law or Kyttx Policies.

43Seller Responsibilities for Privacy Rights

Sellers are responsible for responding to privacy requests relating to Personal Data they control.

Sellers must cooperate with Kyttx where necessary to respond to privacy requests.

Sellers must not use Kyttx in a way that prevents Buyers from exercising legally required privacy rights.

44Marketing Communications

You may receive marketing communications from Kyttx if permitted by law.

You may opt out of marketing emails by using the unsubscribe link or contacting Kyttx.

Even if you opt out of marketing communications, Kyttx may still send transactional, legal, security, account, support, payment, and administrative communications.

Sellers are responsible for their own marketing communications to Buyers and must comply with applicable law.

45Seller Communications to Buyers

Sellers may use Kyttx tools to communicate with Buyers.

Sellers are responsible for ensuring that their communications comply with:

• Privacy laws.
• Anti-spam laws.
• Marketing laws.
• Telecommunications laws.
• Consent requirements.
• Unsubscribe requirements.
• Kyttx Policies.

Kyttx may restrict Seller communications where Kyttx determines they create legal, spam, privacy, deliverability, reputational, or platform risk.

46Cookies, Analytics, and Advertising Choices

You may be able to manage cookies through browser settings, Platform settings, or consent tools where available.

Disabling certain cookies may affect Platform functionality.

More details are provided in the Kyttx Cookie Policy.

47Children

Kyttx is not intended for persons under 18.

You must be at least 18 years old to use Kyttx.

Kyttx does not knowingly collect Personal Data from persons under 18.

If Kyttx learns that a person under 18 has provided Personal Data, Kyttx may delete the information and terminate access.

48Sensitive Personal Data

Kyttx does not intend for Users to upload or process sensitive Personal Data unless necessary, lawful, properly protected, and permitted by Kyttx.

Sensitive Personal Data may include information relating to:

• Health.
• Biometric data.
• Government identification.
• Financial account information.
• Precise location.
• Racial or ethnic origin.
• Religious beliefs.
• Political opinions.
• Union membership.
• Sexual orientation.
• Criminal history.
• Other sensitive categories under applicable law.

Users must not collect, upload, or process sensitive Personal Data through Kyttx unless they have a lawful basis, required notices, required consents, and Kyttx permission where required.

Kyttx may remove, restrict, or delete sensitive Personal Data where it determines that such data creates legal, privacy, security, or platform risk.

49Automated Decision-Making and Profiling

Kyttx may use automated systems to support:

• Fraud detection.
• Risk scoring.
• Account security.
• Payment review.
• Chargeback risk review.
• Content moderation.
• Sanctions screening.
• Compliance review.
• Platform analytics.
• Personalization.
• Abuse prevention.

Automated systems may affect account access, payout timing, reserves, payment availability, content visibility, or Platform features.

Where required by law, you may have rights related to certain automated decisions.

50AI Tools and Data Use

Kyttx may provide AI-assisted tools.

Personal Data may be processed when Users interact with AI tools, generate content, create workflows, analyze data, or use automated features.

Users are responsible for ensuring they do not submit Personal Data to AI tools in violation of law, Seller obligations, Buyer rights, confidentiality obligations, or Kyttx Policies.

Kyttx may restrict AI tool use where privacy, security, legal, or platform risk exists.

51Third-Party Links and Services

The Platform may contain links to third-party websites, tools, services, or integrations.

Kyttx is not responsible for third-party privacy practices.

Your use of third-party services may be subject to their own privacy policies and terms.

52Region-Specific Terms

Depending on your location, additional privacy rights or requirements may apply.

Kyttx intends this Privacy Policy to be flexible and globally usable, including for Users in the United Arab Emirates, Dubai, the Dubai International Financial Centre, the European Economic Area, the United Kingdom, the United States, and other jurisdictions.

Where local privacy laws provide rights that cannot be waived, those rights apply to the extent required by law.

53European Economic Area, United Kingdom, and Similar Privacy Laws

If applicable privacy laws such as the GDPR, UK GDPR, or similar laws apply, Kyttx may act as a controller or processor depending on the context.

Where Kyttx acts as controller, Kyttx determines the purposes and means of Processing.

Where Kyttx acts as processor on behalf of Sellers, Kyttx processes Personal Data according to the Kyttx Data Processing Agreement and Seller instructions.

Applicable legal bases may include contract performance, legitimate interests, legal obligations, consent, or other lawful bases.

Users may have rights to access, correct, delete, restrict, object, withdraw consent, or request portability, subject to legal limitations.

54United States Privacy Notice

If United States privacy laws apply, you may have rights depending on your state of residence.

These rights may include access, correction, deletion, portability, opt-out, and appeal rights.

Kyttx does not intend to sell Personal Data in the traditional sense. However, certain analytics, advertising, or tracking activities may be considered ?sharing,? ?targeted advertising,? or similar terms under some privacy laws.

Where required, Kyttx may provide opt-out mechanisms for applicable advertising or tracking activities.

55UAE, Dubai, and DIFC Privacy Context

Kyttx may operate, incorporate, transfer, or process data through entities or infrastructure connected to Dubai, the United Arab Emirates, or the Dubai International Financial Centre.

Where UAE, Dubai, DIFC, or other applicable privacy laws apply, Kyttx will process Personal Data in accordance with applicable legal requirements.

Users may have rights under applicable local privacy laws, subject to legal limitations and exceptions.

56Do Not Track

Some browsers may send ?Do Not Track? signals.

The Platform may not respond to all Do Not Track signals unless required by law.

You may manage cookies and tracking through browser settings or available consent tools.

57Changes to This Privacy Policy

Kyttx may modify this Privacy Policy from time to time.

Kyttx may provide notice by posting an updated version, updating the ?Last Updated? date, sending email notice, displaying in-app notice, updating the dashboard, or using another reasonable method.

Changes are effective when posted or when otherwise stated.

Your continued use of the Platform after changes become effective constitutes acknowledgement of the updated Privacy Policy.

Kyttx may make immediate changes where required or appropriate due to legal requirements, privacy requirements, payment partner requirements, security issues, fraud risk, compliance issues, operational changes, corporate restructuring, or urgent platform needs.

58Contact

For privacy requests, legal notices, or questions about this Privacy Policy:

legal@kyttx.com

For support:

support@kyttx.com

Website:

https://kyttx.com