Irgen Kini
Legal · 11 sections

Privacy Policy

What is collected when you buy, join the waitlist or take the audit, why, and what you can ask for.

Effective date
14 October 2026
Controller
Irgen Kini, trading as Irgen Kini PF
Contact
ask@irgenkini.com
01

Who is responsible

Irgen Kini, trading as Irgen Kini PF, is the data controller for the personal data described here. That means the Author decides what is collected and why. Questions, requests, and complaints all go to ask@irgenkini.com.

02

What is collected

Only what each step needs. When you ask for access, the following is recorded:

  • 01Your email address, as you typed it at checkout.
  • 02The date and time you accepted the Terms and Conditions.
  • 03The order reference, the amount, the currency, and any discount code you used.
  • 04Whether that order is pending, paid, or failed, and when it changed.

When you join the launch waitlist or take the Scope Leak Audit, the following is recorded:

  • 01Your email address, and your first name if you chose to give it.
  • 02For the audit, the answer you chose to each question, your score and your result band.
  • 03Whether you ticked the box to receive Operating Notes.
  • 04The campaign tags in the link you arrived from, if any, such as which post sent you.
  • 05The date and time you submitted.

Nothing else. There is no account, no profile, and no address or phone number unless you send one by email.

Your card details are never collected, seen, or stored by the Author. Payment happens on the payment provider's own page, and only the outcome of that payment comes back.

03

Cookies, analytics, and tracking

This site sets no cookies, runs no analytics, and loads no advertising or tracking scripts, so there is no consent banner because there is nothing to consent to. The only thing kept in your browser is your progress through the Scope Leak Audit, in session storage, so a reload does not lose your answers; it is never sent anywhere until you submit your email, and your browser discards it when you close the tab. Fonts and images are served from irgenkini.com rather than a third party network, so visiting the site does not report your visit to anyone else.

The hosting provider keeps ordinary server logs, which can include IP addresses, for security and reliability. Those are the provider's own operational records, not something the Author uses to profile visitors.

04

Why it is collected, and on what legal basis

4.1

To sell and deliver the Product. Your email and order details are needed to take payment, and to send you your receipt with the Product attached to it. The legal basis is performance of the contract between you and the Author.

4.2

To prove you accepted the Terms. The acceptance timestamp records that the Terms were agreed before access was granted. The legal basis is the Author's legitimate interest in being able to evidence the licence you were granted, and compliance with the Author's legal obligations.

4.3

To follow up on a payment that failed. Where a payment does not complete, the Author may contact you once to help you finish the purchase. The legal basis is legitimate interest. You can ask to be left alone at any time and that will be the end of it.

4.4

To keep proper business records. Records of completed sales are kept for accounting and tax purposes. The legal basis is compliance with a legal obligation.

4.5

To send your audit result and tell you about the launch. If you take the Scope Leak Audit or join the waitlist, your email is used to send your result and to tell you when early access opens. If you ticked the Operating Notes box, you will also receive that email every two weeks. The legal basis is your consent, which you can withdraw at any time by replying to any email or writing to ask@irgenkini.com.

Your data is never sold, rented, or used to train any artificial intelligence model, and you will not be added to a marketing list as a result of buying.

05

Who else handles it

Three service providers process data on the Author's behalf, each under its own agreement, and each only for the purpose described:

PokPay

takes the payment. You enter your card details on their page, not this one. They receive your email address so the payment can be matched to your order.

Resend

delivers email. Your address and the contents of your receipt or audit result pass through them so the message can reach your inbox.

Clever Cloud

hosts the site and stores the order and waitlist records described in Section 2.

Beyond these, data is disclosed only where the law requires it, or where it is necessary to establish or defend a legal claim.

06

Where it is held

The service providers above may process data outside Albania, including within the European Economic Area and, depending on the provider, the United States. Where that happens, it is done under the safeguards those providers offer for international transfers, such as the European Commission's standard contractual clauses.

07

How long it is kept

7.1

Records of completed purchases, including the acceptance timestamp, are kept for as long as the licence lasts and for as long as accounting and tax law requires them to be retained.

7.2

Records of orders that were never completed are kept only as long as they are useful for the follow-up described in Section 4.3, and are deleted on request.

7.3

Waitlist and audit records are kept until you withdraw your consent or ask for them to be deleted, and in any case no longer than they are useful for the purposes in Section 4.5.

08

Your rights

Under Albanian Law No. 9887 On the Protection of Personal Data, as amended, and under the EU General Data Protection Regulation (2016/679) where it applies to you, you can:

  • 01Ask what is held about you, and receive a copy of it;
  • 02Have anything inaccurate corrected;
  • 03Ask for your data to be deleted, subject to records the Author must keep by law;
  • 04Ask that processing be restricted, or object to processing based on legitimate interest;
  • 05Receive your data in a portable format; and
  • 06Complain to your data protection authority — in Albania, the Commissioner for the Right to Information and Protection of Personal Data.

Write to ask@irgenkini.com and the Author will respond within the period the applicable law allows. There is no charge for exercising any of these rights.

09

Security

The site is served over HTTPS, payment happens on the provider's own secure page, and access to the order records is limited to the Author. No system is perfectly secure, and the Author does not claim otherwise, but the data held is deliberately minimal so that there is little to lose.

10

Children

The Product is sold to adults acting for business purposes, and the site is not directed at children. Personal data is not knowingly collected from anyone under 18. If you believe a child has provided data, write to ask@irgenkini.com and it will be deleted.

11

Changes and contact

This Policy may be updated from time to time. The current version always lives at irgenkini.com/privacy, with the effective date above updated accordingly. Where a change materially affects how your data is handled, past purchasers will be told by email where that is feasible.

For anything in this Policy, including a request to see or delete your data, contact Irgen Kini, trading as Irgen Kini PF, at ask@irgenkini.com.

This Policy was last updated on 14 October 2026. The current version always lives at irgenkini.com/privacy.