Privacy Policy

The data controller responsible for your personal data is FUNNELIX SP. Z O.O. (KRS 0001249286, NIP 1133205977) of Grochowska 56, 04-282 Warszawa, Poland. You can contact us about privacy matters at support@conclave.academy, or by post at the address above.

We keep data collection to the minimum needed to run the Service:

• ▸Account email address — provided when you register, used to identify your account and communicate with you.
• ▸Hashed password — we never store your password in plain text; it is stored only as a salted hash.
• ▸Reading history — the Oracle readings you run and their results, so you can review past appraisals and so we can operate the token balance.
• ▸Essential cookie data — a session identifier and security tokens needed to keep you signed in (see our Cookie Policy).
• ▸Payment records — when paid top-ups are enabled, our third-party payment processor handles your card details; we retain only a transaction reference and status, never full card numbers.

We rely on the following lawful bases under applicable data-protection law:

• ▸Performance of a contract — to create and maintain your account, run Oracle readings, and manage your token balance.
• ▸Legitimate interests — to keep the Service secure, prevent abuse, and improve how it works, balanced against your rights.
• ▸Legal obligation — to keep records we are required by law to retain, such as those relating to payments.
• ▸Consent — where we ask for it, for example for non-essential preference cookies; you can withdraw consent at any time.

• ▸authenticate you and keep your account secure;
• ▸run Oracle readings and show you your reading history and token balance;
• ▸send essential service messages, such as security notices and support replies;
• ▸process token top-ups through our third-party payment processor when enabled;
• ▸detect, prevent, and investigate fraud, abuse, and technical problems;
• ▸comply with our legal obligations.

We do not sell your personal data, and we do not use it for third-party advertising or tracking.

We share personal data only with the service providers that help us operate CONCLAVE, and only to the extent needed:

• ▸Our third-party payment processor — to take payment for token top-ups securely when purchases are enabled.
• ▸Our hosting and infrastructure provider — to store data and run the application.

These providers act as processors on our instructions under appropriate data protection terms. We may also disclose data where required by law or to protect our legal rights. Where data is transferred across borders, we rely on appropriate safeguards recognised by applicable data-protection law.

We keep your account data for as long as your account is active. If you close your account, we delete or anonymise your personal data within 30 days, except where we must keep certain records to meet legal obligations. Reading history is retained while your account is open so you can access it, and is removed when your account is deleted.

Under applicable data-protection law you have the right to:

• ▸Access — obtain a copy of the personal data we hold about you;
• ▸Rectification — have inaccurate or incomplete data corrected;
• ▸Erasure — ask us to delete your data where there is no overriding reason to keep it;
• ▸Portability — receive your data in a structured, machine-readable format;
• ▸Objection & restriction — object to, or restrict, certain processing;
• ▸Withdraw consent — where processing is based on consent.

You can download a structured, machine-readable copy of your account data — profile, wallet activity, tributes and Oracle readings — at any time from Settings → Your data once signed in. For any other request, or to exercise the rights above, email support@conclave.academy. We will respond within one month. You may also lodge a complaint with your local data protection authority.

CONCLAVE uses only essential and preference cookies and does not run third-party advertising or tracking cookies. For full details, see our Cookie Policy.

We may update this Privacy Policy from time to time. Where changes are material, we will give reasonable notice by email or on-site notice. Your continued use of the Service after a change takes effect means you accept the updated policy.

For any privacy question or request, contact FUNNELIX SP. Z O.O. at Grochowska 56, 04-282 Warszawa, Poland, or by email at support@conclave.academy.