Privacy Policy

1. Introduction

This Privacy Policy explains how Coingarage s.r.o., with registered office at Krakovská 583/9, Nové Město, 110 00 Prague, Czech Republic, Company ID No. 11667974 ("Company", "we", "us", or "our"), collects, uses, stores, and protects personal data in connection with the Comforto pre-launch campaign, waitlist, and related websites, including hey.comforto.ai and related services (the "Platform").

We are committed to protecting your privacy and processing personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR").

For privacy-related questions, please contact us at support@coingarage.io.

2. Who We Are

Data Controller:

Coingarage s.r.o.
Krakovská 583/9, Nové Město
110 00 Prague
Czech Republic
Company ID: 11667974

3. What Personal Data We Collect

Depending on how you interact with our campaign and services, we may collect:

Information you provide directly

• Email address
• Username / nickname
• Referral code / referral activity
• Messages or support requests

Automatically collected information

• IP address
• Device type
• Browser type
• Operating system
• Usage activity on the microsite
• Cookies and similar technologies

Potential future data categories

If implemented in future phases:

• Device fingerprinting signals
• Browser fingerprinting signals
• Connected social media account identifiers

We will update this Privacy Policy before materially expanding data categories.

4. How We Use Your Data

We may process your personal data for the following purposes:

• Registering and managing your waitlist account
• Operating referral systems, points, rewards, and leaderboards
• Sending campaign updates and launch notifications
• Fraud prevention and abuse detection
• Analytics and campaign performance measurement
• Improving user experience and platform performance
• Customer support
• Compliance with legal obligations

5. Legal Basis for Processing (GDPR)

We rely on one or more of the following legal bases:

• Consent - where required (e.g. optional marketing communications / cookies)
• Performance of a contract - administering campaign participation
• Legitimate interests - analytics, fraud prevention, system security, business improvement
• Legal obligations - where required by applicable law

6. Cookies and Tracking Technologies

We may use cookies, pixels, and similar technologies, including:

• Meta Pixel
• TikTok Pixel
• Google Analytics
• X / Twitter Pixel
• Wistia analytics tools

These tools help us understand campaign performance, improve our services, and measure advertising effectiveness.

Where required by law, we will request your consent before using non-essential cookies or tracking technologies.

7. Communications

We may send you:

• Waitlist updates
• Reward / campaign notifications
• Product launch news
• Important service-related notices

You may unsubscribe from non-essential communications at any time.

8. Sharing of Data / Service Providers

We may share personal data with trusted processors who support our business operations, including:

All processors are engaged under appropriate contractual and data protection safeguards where required.

9. International Transfers

Some service providers may process data outside the European Economic Area (EEA). Where this occurs, we take reasonable steps to ensure appropriate safeguards are in place, including Standard Contractual Clauses or equivalent lawful transfer mechanisms where required.

10. Data Retention

We retain personal data only as long as reasonably necessary for:

• Campaign administration
• Analytics
• Fraud prevention
• Legal compliance
• Future launch communications (where lawful)

Inactive waitlist data may be deleted or anonymised after a reasonable retention period.

11. Security

We use reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration. However, no system can guarantee absolute security.

12. Your Rights (GDPR)

Subject to applicable law, you may have the right to:

• Access your data
• Correct inaccurate data
• Request deletion
• Restrict processing
• Object to processing
• Data portability
• Withdraw consent
• Lodge a complaint with your supervisory authority

To exercise rights, contact support@coingarage.io.

13. Children

Our services are not intended for persons under the age of 18 (or local legal age where higher).

14. Changes to this Policy

We may update this Privacy Policy from time to time. The latest version will always be published on the Platform with the updated effective date.

15. Contact

Coingarage s.r.o.
Krakovská 583/9, Nové Město
110 00 Prague
Czech Republic
support@coingarage.io