Privacy Policy

Malkot Foundation ("MALKOT," "we," "us," or "our") respects your privacy and is committed to protecting your personal information.

Malkot Foundation is responsible for the personal information described in this Policy where it acts as the data controller or equivalent responsible organization.

Malkot Foundation Palm Harbor, Florida, United States Email: info@malkot.org

This Policy explains what personal information we collect, why we use it, where it is processed, who may process it on our behalf, how long we retain it, and the rights available to you. It is intended to address applicable requirements including the EU GDPR, applicable Portuguese and European data protection laws, Brazil's LGPD, and applicable U.S. state privacy laws including the CCPA/CPRA. Your specific rights may vary by location and applicable law.

Depending on how you use MALKOT, we may collect:

• Identity and contact information, such as name, email address, telephone number, location and preferred language.
• Account and profile information, including identifiers, preferences, roles, permissions and account activity.
• Service, booking and program information, including requested services, providers, registrations, sessions, attendance, waitlists, dates, cancellations and related communications.
• Community information, including registration, profile information and content or communications you choose to provide.
• Provider or professional information, where you provide services through MALKOT.
• Transaction information, including transaction identifiers, amounts, currency, payment status and limited billing information. Full payment-card credentials may be processed directly by our payment provider rather than stored by MALKOT.
• Communications, including inquiries, support requests, feedback and correspondence.
• Technical and security information, such as IP address, browser/device information, authentication activity, timestamps, security events and application/audit logs.
• Privacy records, including Policy acknowledgements, Terms acceptance, consent choices and privacy requests.

We seek to collect only information reasonably necessary for the purposes described in this Policy.

MALKOT does not seek to collect sensitive personal information unless reasonably necessary for a particular service or legal purpose. If sensitive information is required, we will apply the additional protections and legal requirements that apply.

We may process personal information to:

• create, authenticate and administer accounts;
• provide MALKOT services and administer bookings, programs, registrations, waitlists and attendance;
• connect users with appropriate services or providers and administer community functionality;
• process transactions and refunds;
• send account, booking, program, security and other service-related communications;
• provide support, maintain records and audit trails;
• protect users and the platform against fraud, abuse and unauthorized access;
• maintain, troubleshoot and improve platform reliability and security;
• comply with legal obligations and establish, exercise or defend legal claims; and
• send marketing communications where permitted by law and, where required, with your consent.

Where GDPR applies, our legal basis may include performance of a contract, compliance with a legal obligation, legitimate interests, consent, or another basis permitted by law. Where we rely on consent, you may withdraw it at any time without affecting processing that was lawful before withdrawal.

MALKOT does not sell personal information and does not provide personal information to third parties for their own independent marketing purposes.

We use trusted service providers and data processors to operate MALKOT, including providers of application/cloud infrastructure, database and authentication services, email delivery, payment processing, security, monitoring, backups and other necessary operational services. They may process personal information on MALKOT's behalf and, where required by law, are subject to appropriate contractual, confidentiality, security and data-protection obligations.

We may also disclose personal information where necessary to provide a service you request, comply with applicable law or valid legal process, investigate fraud or abuse, protect MALKOT or others, or establish, exercise or defend legal claims.

Malkot Foundation is based in the United States. Personal information collected through MALKOT will be transferred to, processed in, and stored in the United States.

If you use MALKOT from Portugal, another EU/EEA country, Brazil, the United Kingdom or another jurisdiction outside the United States, your personal information will therefore be processed outside your country. U.S. privacy laws may differ from those in your country.

Where applicable law requires safeguards for international transfers, MALKOT will use an appropriate lawful transfer mechanism, which may include an applicable adequacy framework, Standard Contractual Clauses or other permitted contractual and organizational safeguards. Service providers acting on our behalf may also process information in the United States or other countries where permitted by applicable law.

For personal data subject to Brazil's LGPD, MALKOT will apply an international-transfer mechanism permitted by the LGPD and applicable ANPD regulations. For information about applicable safeguards, contact info@malkot.org.

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected or for legitimate operational or legal purposes. Retention may depend on the duration of your account or relationship with MALKOT, provision of services, financial/accounting/legal requirements, security and fraud-prevention needs, dispute resolution, and applicable limitation periods or legal claims.

When information is no longer required, we will delete, anonymize or otherwise handle it in accordance with applicable law.

MALKOT uses reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration or disclosure. Measures may include access controls, authentication, encryption in transit, protected credentials, role-based permissions, audit logging and backups.

No Internet-based service can guarantee absolute security. If a personal-data breach occurs, MALKOT will investigate it and notify affected individuals and/or competent authorities where required by law.

Depending on where you live and applicable law, you may have rights to:

• know whether and how we process your personal information;
• access and correct your personal information;
• request deletion;
• restrict or object to certain processing;
• request data portability;
• withdraw consent;
• opt out of certain legally defined processing;
• receive information about organizations with which information has been shared;
• request review of certain automated decisions; and
• complain to an appropriate privacy or data-protection authority.

These rights may be subject to legal exceptions. Under the GDPR, applicable rights may include access, rectification, erasure, restriction, objection, portability and withdrawal of consent. In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados (CNPD). Under the LGPD, Brazilian data subjects may exercise applicable rights and may, where applicable, petition the Autoridade Nacional de Proteção de Dados (ANPD). Under applicable U.S. state laws, additional rights may apply, including rights concerning sale, sharing, targeted advertising, sensitive information or automated decision-making. MALKOT does not currently sell personal information or share it for cross-context behavioral advertising.

Marketing communications are separate from communications necessary to operate your account or provide MALKOT services. Where consent is required for marketing, it will be requested separately and will not be a condition of creating an account or receiving an unrelated service. You may withdraw marketing consent or unsubscribe at any time.

MALKOT may continue to send necessary account, security, booking, registration, transaction and other service-related communications where permitted by law.

MALKOT may use cookies, local storage and similar technologies necessary for authentication, security, preferences and operation of the platform. Non-essential technologies will be used in accordance with applicable consent requirements. Please see the MALKOT Cookie Policy for additional information and available controls.

MALKOT will not knowingly collect personal information from children contrary to applicable law. Where a MALKOT service permits participation by a minor, we will implement age-appropriate safeguards and obtain parental or guardian authorization where required.

If you believe information concerning a child has been collected improperly, contact info@malkot.org.

To exercise applicable privacy rights, contact:

Malkot Foundation Palm Harbor, Florida, United States Email: info@malkot.org

We may take reasonable steps to verify your identity before fulfilling certain requests and will request only information reasonably necessary for that purpose. We will respond within the timeframe required by applicable law.

We may update this Privacy Policy when our services, processing practices, service providers or legal obligations change. The current version and effective date will appear on this Policy. Where required by law, we will provide additional notice or obtain consent before a material change takes effect.

Malkot Foundation Palm Harbor, Florida, United States Email: info@malkot.org Website: malkot.org