This Privacy Policy explains how Irgen Kini, trading as Irgen Kini PF, a sole proprietorship registered in Albania, with registered address at Njesia Bashkiake nr.5, Rruga Frang Bardhi, Godina Kristal Center, Kati i Dyte 1016, Tirane, Shqiperi (the "Author"), handles personal data collected through irgenkini.com. It sits alongside the Terms and Conditions and uses the same defined terms.
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.
What is collected
Only what each step needs. When you ask for access, the following is recorded:
- Your email address, as you typed it at checkout.
- The date and time you accepted the Terms and Conditions.
- The order reference, the amount, the currency, and any discount code you used.
- Whether 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:
- Your email address, and your first name if you chose to give it.
- For the audit, the answer you chose to each question, your score and your result band.
- Whether you ticked the box to receive Operating Notes.
- The campaign tags in the link you arrived from, if any, such as which post sent you.
- The 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.
Why it is collected, and on what legal basis
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.
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.
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.
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.
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.
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:
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.
delivers email. Your address and the contents of your receipt or audit result pass through them so the message can reach your inbox.
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.
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.
How long it is kept
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.
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.
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.
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:
- Ask what is held about you, and receive a copy of it;
- Have anything inaccurate corrected;
- Ask for your data to be deleted, subject to records the Author must keep by law;
- Ask that processing be restricted, or object to processing based on legitimate interest;
- Receive your data in a portable format; and
- Complain 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.
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.
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.
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.