Privacy Policy
Last updated: October 2026
1. Controller
ASKILI EDUCATION SERVICES - FZCO
IFZA Business Park, DDP, PO Box 342001, Dubai, United Arab Emirates
Email: hello@kompagno.ai
2. What data we process and why
This website has one purpose: the Kompagno waitlist. Signing up also gets you our guide. When you sign up, we process:
- your first name,
- your email address,
- the language of the page you signed up on,
- the source of your sign-up and the keyword from the post, if the link you used carries them (see below),
- the times you signed up and confirmed, the version of the consent text you signed up with, and the IP address from which you clicked the confirmation link, along with the approximate location ActiveCampaign derives from it (double opt-in record),
- whether you open our emails and which links you click in them, and for each open or click, the time, the IP address it came from, and the approximate location ActiveCampaign derives from that address.
Links in our Instagram posts and messages can carry two short markers, for example “?src=ig&kw=brief”: where we shared the link, and the keyword from the post. If you sign up through such a link and the markers are ones we use, we save them as tags (source and keyword) on your contact at ActiveCampaign; other values are discarded.
Purpose: to send you the guide you requested and news about Kompagno and to let you know about the launch and the terms for waitlist members. We use the source and keyword of your sign-up only to see which of our posts bring people to the waitlist. We look at opens and clicks to see which emails and topics interest you, so we can make our emails more useful. We don’t use your data for anything else.
Giving us these details is voluntary, but without them we can’t send you the guide. We don’t use automated decision-making.
Emails to us: If you email hello@kompagno.ai or reply to one of our waitlist emails, we process your email address, your name if you include it, your message, and the usual email metadata (such as when it was sent). We use this only to answer you and to handle your requests, for example to unsubscribe or to exercise your rights (section 7). The legal basis is our legitimate interest in answering messages sent to us (Art. 6(1)(f) GDPR) and, for requests about your rights, our legal obligation to handle them (Art. 6(1)(c) GDPR).
3. Legal basis
Your consent (Art. 6(1)(a) GDPR), which also covers tracking whether you open our emails and click their links. You give it when you sign up and tick the consent box, and when you click the link in the confirmation email (double opt-in). Until you click, the confirmation email is the only email you’ll get from us.
4. Withdrawing consent and unsubscribing
You can unsubscribe at any time, with one click on the unsubscribe link in every email or with a short message to hello@kompagno.ai. Once you’ve unsubscribed, you won’t get any more emails from the waitlist. If you unsubscribe through the link, ActiveCampaign records the IP address you used. Withdrawing applies from then on and doesn’t affect the lawfulness of processing before it.
5. Processors
Email provider: We use ActiveCampaign, LLC (USA) to manage the waitlist and send our emails. Your details are stored there and used only for this waitlist. We have signed a data processing agreement with ActiveCampaign.
Transfer to the US (ActiveCampaign): ActiveCampaign is based in the US, so your details go to a company outside the EU and the UK.
We safeguard this transfer with the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR) and the UK Addendum to them, which are part of our agreement with ActiveCampaign. ActiveCampaign is also certified under the EU-U.S. Data Privacy Framework, including the UK Extension and the Swiss-U.S. Data Privacy Framework. For a copy of the Standard Contractual Clauses, email us at hello@kompagno.ai.
Hosting and sign-up function: This website and its sign-up function run on Netlify, Inc. (San Francisco, USA). When you visit the site, Netlify processes technically necessary connection data (such as your IP address, the time, and the address you requested) in server logs and, to protect against abuse, limits the number of sign-up attempts per IP address. The sign-up function passes your form entries on to ActiveCampaign without storing them at Netlify. The legal basis is our legitimate interest in running the website securely and reliably (Art. 6(1)(f) GDPR). Our data processing agreement with Netlify doesn’t clearly say how long Netlify keeps these logs on our plan. For its enterprise services, the agreement says 90 days online and one year offline. We don’t store these logs ourselves. Netlify processes this data for us as our processor. Under Netlify’s data processing agreement, the transfer to the US is based on the EU-U.S. Data Privacy Framework, including the UK Extension, and otherwise on the EU Standard Contractual Clauses (for the UK, the International Data Transfer Addendum).
Mailbox: Emails to hello@kompagno.ai, including replies to our waitlist emails, are stored in a mailbox hosted by INWX GmbH (Prinzessinnenstr. 30, 10969 Berlin, Germany). INWX processes these emails for us as our processor. According to INWX, it processes personal data in its data centers in Germany.
6. Cookies and email tracking
This website sets no cookies, loads no analytics or advertising services, and embeds no content from third-party servers. Fonts are hosted locally on our server. Apart from the server logs described in section 5, which also contain the address you requested and the page you came from, the only things we record on this website about how you found us are the source and the keyword in the link you used (section 2), and only when you sign up.
In our emails, ActiveCampaign tracks for us whether you open them and which links you click. To do this, each email contains an invisible image, and links pass through a redirect. This tracking is based on your consent (section 3) and stops when you unsubscribe.
7. Your rights
You have the right to access, rectification, erasure, restriction of processing, data portability, and withdrawal of any consent you’ve given. To exercise these rights, contact hello@kompagno.ai. You also have the right to lodge a complaint with a data protection supervisory authority.
Right to object: Where we process data based on our legitimate interests (Art. 6(1)(f) GDPR; sections 2, 5 and 8), you can object to that processing at any time on grounds relating to your particular situation (Art. 21 GDPR). A message to hello@kompagno.ai is enough.
8. How long we keep your data
We keep your waitlist data until you unsubscribe or the waitlist ends, and no longer than 12 months after Kompagno launches. After you unsubscribe, your entry stays on file marked “unsubscribed,” so you don’t get any more emails and we can show that you had consented (legitimate interest, Art. 6(1)(f) GDPR). It’s deleted together with the rest of the waitlist, no later than 12 months after the launch, or earlier if you ask us to.
We keep emails you send us for as long as we need them to deal with your message, and delete them no later than two years after our last exchange. We keep requests about your rights, and our replies, for three years as a record that we handled them.
If you don’t confirm your sign-up, we delete it after 30 days. Statutory retention obligations take precedence.