Privacy Policy
Klyqs Effective Date: January 2025 Last Updated: January 2025
1. Introduction
This Privacy Policy explains how 92combo, trading as Klyqs ("we," "us," or "our"), collects, uses, stores, and protects your personal data when you use our website, purchase our products, or use our software.
We are committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
2. Data Controller
The data controller responsible for your personal data is:
92combo Langstwater 681 1069EG Amsterdam Netherlands
Chamber of Commerce (KVK): 86068040 VAT Number: NL004193942B11 Email: alanayoubi@92learns.com
For any privacy-related inquiries, please contact us at alanayoubi@92learns.com.
3. What Data We Collect
3.1 Data You Provide Directly
When you interact with us, we may collect:
Purchase Information:
- Name
- Email address
- Billing address
- Payment information (processed securely by our payment provider)
- Transaction history
Communication Data:
- Emails or messages you send us
- Support requests
- Feedback and survey responses
3.2 Data Collected Automatically
When you visit our website, we may automatically collect:
Technical Data:
- IP address
- Browser type and version
- Operating system
- Device information
- Referring website
Usage Data:
- Pages visited
- Time spent on pages
- Click patterns
- Download activity
3.3 Data We Do NOT Collect
Our desktop software is designed with privacy in mind. We do NOT collect:
- Your creative projects or content
- Images, videos, or files you create
- Your AI-generated content
- Your third-party API keys
- Any data processed locally on your computer
Your work stays on your machine. We never see it, access it, or store it.
4. How We Use Your Data
We use your personal data for the following purposes:
4.1 To Fulfill Our Contract With You
- Process your purchases and payments
- Deliver software licenses and downloads
- Provide customer support
- Send transaction confirmations and receipts
4.2 For Our Legitimate Interests
- Improve our products and services
- Analyze website usage to enhance user experience
- Detect and prevent fraud
- Protect our legal rights
4.3 With Your Consent
- Send marketing communications (only if you opt in)
- Use non-essential cookies for analytics
4.4 To Comply With Legal Obligations
- Maintain financial and tax records
- Respond to legal requests from authorities
- Enforce our Terms of Service
5. Legal Basis for Processing (GDPR)
Under GDPR, we process your personal data based on the following legal grounds:
| Purpose | Legal Basis |
|---|---|
| Processing purchases | Performance of contract |
| Sending transactional emails | Performance of contract |
| Customer support | Performance of contract |
| Fraud prevention | Legitimate interest |
| Website analytics | Legitimate interest or consent |
| Marketing emails | Consent |
| Tax and financial records | Legal obligation |
You have the right to object to processing based on legitimate interests. Contact us to exercise this right.
6. Data Sharing and Third Parties
6.1 Service Providers
We may share your data with trusted third-party service providers who assist us in operating our business:
Payment Processors:
- Process your payments securely
- We do not store your full payment card details
Email Services:
- Send transactional and marketing emails
- Manage our mailing list
Analytics Providers:
- Help us understand website usage
- Provide anonymized or aggregated insights
Hosting Providers:
- Host our website and infrastructure
6.2 Legal Requirements
We may disclose your data if required by law or if we believe disclosure is necessary to:
- Comply with legal obligations
- Protect our rights or property
- Prevent fraud or security issues
- Protect the safety of users or the public
6.3 Business Transfers
If Klyqs is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you of any such change.
6.4 No Selling of Data
We do not sell, rent, or trade your personal data to third parties for their marketing purposes.
7. International Data Transfers
Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When this occurs, we ensure appropriate safeguards are in place:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Transfers to countries with an adequacy decision
- Other legally approved transfer mechanisms
8. Data Retention
We retain your personal data only as long as necessary for the purposes described in this policy:
| Data Type | Retention Period |
|---|---|
| Purchase records | 7 years (legal/tax requirements) |
| Customer support communications | 3 years after last contact |
| Marketing preferences | Until you unsubscribe |
| Website analytics | 26 months |
| Account data | Until deletion requested |
After these periods, we securely delete or anonymize your data.
9. Your Rights Under GDPR
As a data subject in the European Union, you have the following rights:
9.1 Right of Access
You can request a copy of the personal data we hold about you.
9.2 Right to Rectification
You can request correction of inaccurate or incomplete data.
9.3 Right to Erasure ("Right to be Forgotten")
You can request deletion of your personal data, subject to legal retention requirements.
9.4 Right to Restrict Processing
You can request that we limit how we use your data.
9.5 Right to Data Portability
You can request your data in a structured, machine-readable format.
9.6 Right to Object
You can object to processing based on legitimate interests or for direct marketing.
9.7 Right to Withdraw Consent
Where processing is based on consent, you can withdraw it at any time.
9.8 Right to Lodge a Complaint
You have the right to complain to a supervisory authority. In the Netherlands, this is:
Autoriteit Persoonsgegevens Website: https://autoriteitpersoonsgegevens.nl Phone: +31 (0)88 - 1805 250
How to Exercise Your Rights
To exercise any of these rights, contact us at: Email: alanayoubi@92learns.com
We will respond to your request within 30 days. We may ask for verification of your identity before processing your request.
10. Cookies and Tracking Technologies
10.1 What Are Cookies?
Cookies are small text files stored on your device when you visit a website. They help the website remember your preferences and understand how you use the site.
10.2 Cookies We Use
Essential Cookies:
- Required for the website to function
- Cannot be disabled
- Example: Session cookies, security cookies
Analytics Cookies:
- Help us understand how visitors use our site
- Collect anonymized data
- Example: Google Analytics
- Require your consent
Marketing Cookies:
- Used to deliver relevant advertisements
- Track effectiveness of campaigns
- Require your consent
10.3 Managing Cookies
You can control cookies through:
- Our cookie consent banner (when you first visit)
- Your browser settings
- Opt-out tools provided by analytics services
Note: Disabling certain cookies may affect website functionality.
10.4 Do Not Track
Our website does not currently respond to "Do Not Track" browser signals.
11. Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- Encryption of data in transit (HTTPS/TLS)
- Secure payment processing through certified providers
- Limited access to personal data on a need-to-know basis
- Regular security assessments
While we take security seriously, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.
12. Children's Privacy
Our Services are not directed to children under 16 years of age. We do not knowingly collect personal data from children under 16.
If you believe we have collected data from a child under 16, please contact us immediately at alanayoubi@92learns.com. We will take steps to delete such data.
13. Third-Party Links and Services
Our website or software may contain links to third-party websites or require use of third-party services (such as AI providers). This Privacy Policy does not apply to those third parties.
We encourage you to read the privacy policies of any third-party services you use, including:
- AI service providers (e.g., Fal.ai)
- Payment processors
- Any other external services
14. Marketing Communications
14.1 Opt-In
We only send marketing emails if you have explicitly consented to receive them.
14.2 Opt-Out
You can unsubscribe from marketing communications at any time by:
- Clicking "unsubscribe" in any marketing email
- Contacting us at alanayoubi@92learns.com
14.3 Transactional Emails
Even if you opt out of marketing, we may still send transactional emails related to your purchases (receipts, license information, important updates).
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date.
For significant changes, we will notify you via:
- Email (if we have your email address)
- Prominent notice on our website
We encourage you to review this policy periodically.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
92combo Email: alanayoubi@92learns.com Address: Langstwater 681, 1069EG Amsterdam, Netherlands
We aim to respond to all inquiries within 30 days.
17. Summary of Key Points
- We respect your privacy. Your creative work stays on your computer ā€” we never see it.
- We collect minimal data. Only what's necessary to process purchases and improve our services.
- We don't sell your data. Ever.
- You have rights. Access, correct, delete, or port your data at any time.
- We're based in the EU. We comply with GDPR and Dutch data protection laws.
By using Klyqs products and services, you acknowledge that you have read and understood this Privacy Policy.
