EdgeStories

Effective as of October 3, 2026.

California Notice at Collection/State Privacy Rights Notice: See the State privacy rights notice section below for important information about your rights under applicable state privacy laws.

Kaiyu Hsu ("EdgeStories," "we," "us" or "our") provides EdgeStories, an independent publication of original research into the data between people, published as visual essays. This Privacy Policy describes how EdgeStories processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website at www.edgestories.com and the emails we send to subscribers) and the other activities described in this Privacy Policy, including the research behind our stories (collectively, the "Service").

Notice to European users: Please see the Notice to European users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe", and "European" should be understood accordingly).

You can download a printable copy of this Privacy Policy as plain text at www.edgestories.com/privacy.md.

Index

Personal information we collect
Tracking & Other Technologies
How we use your personal information
Retention
How we share your personal information
Your choices
Other sites and services
Security
International data transfer
Children
Changes to this Privacy Policy
How to contact us
State privacy rights notice
Notice to European users

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your email address if you subscribe to receive our new stories, and your name and email address when you write to us.
Communications data based on our exchanges with you, including when you contact us by email, through social media, or otherwise, such as a correction, a reply to a story, a research tip, a question about a story's data or methods, a press inquiry or a privacy request.
Marketing data, such as the fact that you have subscribed to receive our new stories, when you signed up, and which page the subscribe form was on. Nothing else is attached to your email address.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

Public sources, such as public archives and records, social media platforms, and other publicly available sources. Our stories are built from public records of how people interact, and we call the personal information we obtain from them "Research data". Most of the personal information we hold is Research data, and much of it is about people who have never used the Service. For example, we have collected English Wikipedia's public log of thanks between editors (who thanked whom, and when, identified by username and user ID) and public details of those editors' accounts (registration date, edit count and whether the account is a bot), and we record the follow and unfollow events that Bluesky publishes on its public network (which account followed which, identified by their Bluesky account identifiers, and when). Each story states its sources alongside its findings.
Service providers that provide services on our behalf or help us operate the Service or our business, such as our hosting provider, which records the request data described below.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction with the Service, such as:

Device data, such as your IP address and your browser's user agent (which indicates your browser type and operating system), which our hosting provider records with the address of each page or file you request and the time of the request, for security and operations. Reading a story sends nothing about you beyond what any web server receives. When a story includes an interactive piece that calls a paid upstream service, the piece also counts requests per IP address in fixed time windows to stop abuse; the counters are used for nothing else.

For more information concerning our automatic collection of data, please see the Tracking & Other Technologies section below.

Tracking & Other Technologies

Cookies and other technologies. Our website is built to collect as little as possible, and our automatic data collection does not rely on cookies or other tracking technologies. Cookies are small data files placed on your computer or mobile device when you visit a website; similar technologies include browser web storage (such as HTML5 local storage) and web beacons (also known as pixel tags). No cookies are set for tracking, the website shows no advertising, no third-party analytics or advertising scripts are loaded, and the website's fonts are served from its own domain rather than from a font provider. Here is what the Service uses, by category:

Essential: none of our own. Our website has no accounts or logins, so it needs no cookies to work. Our hosting provider, Vercel, may set a cookie of its own that is strictly necessary to protect the website, for example if it asks your browser to complete a security check to keep out automated attacks.
Functionality / performance: none. We do not store your preferences, or anything else, in cookies or in your browser's web storage.
Analytics: none. We do not use analytics services, so no cookie, script or web beacon measures how you use the Service.

We do not use advertising or social media cookies.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

provide the Service;
enable security features of the Service, such as the rate limits on interactive pieces;
communicate with you about the Service; and
provide support for the Service, and respond to your requests, questions and feedback, including corrections and replies to our stories.

Research and journalism. We use Research data to research and publish our stories, which study the structure of relationships between people, such as who follows or thanks whom and how those ties form and fade, rather than any one person. Private individuals appear in our stories only in aggregate, as rates, distributions and structures, never as named individuals or pairs. We name people only when they are public figures acting in public roles and the behavior a story discusses is that public role. Anyone named unflatteringly is contacted before the story runs, and their reply is included. We do not publish the raw Research data.

Direct marketing. We may send you direct marketing communications, which for us means emailing you our new stories if you subscribe. You may opt out of our marketing communications as described in the Opt-out of communications section below.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you, and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including publishing our stories, analyzing and improving the Service and promoting our business. The figures our stories publish about private individuals are data of this kind: rates, distributions and counts, with no names.

Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

Specifically:

Your email address stays on our subscriber list until you unsubscribe or ask us to delete it. When you write to kai@kyh.io from that address to do either, it will be removed.
Request logs are kept by our hosting provider, Vercel, under its own retention periods.
The raw Research data behind a story's analysis, such as the Wikipedia records described above, is kept offline on our own computers, outside our website and its database, and is never published: only the aggregate results of the analysis are. We keep it so that a story's findings can be checked and corrected.
The Bluesky follow events we record are kept in our database as a continuing historical record, because the research they support is about how connections form and end over time, so there is no fixed date on which they are deleted.

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection). We do not sell your personal information or share it with advertisers. Your email address in particular goes to no one except the service providers that store it and carry our email, and the parties described under Professional advisors, Authorities and others, and Business transferees below.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology and email delivery). Our website is hosted on Vercel, which also records the request logs described above. Subscriber emails, any rate-limit counters and the Bluesky follow events we record are stored in a Turso (libSQL) database. Our email provider hosts our mailbox and delivers the email we send and receive.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in EdgeStories, financing of EdgeStories, or the sale, transfer or merger of all or part of EdgeStories or its assets). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of EdgeStories as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Our stories are public. They may name public figures acting in public roles, and they publish everyone else only in aggregate. If you send us a correction or a reply to a story, or reply when we contact you before a story runs, we may quote your message in the story it concerns. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states and Europe can find additional information about their rights below.

Opt-out of communications. You may opt out of our emails at any time by writing to kai@kyh.io from the address you subscribed with, and it will be removed from our list. If you opt out, you may still receive replies to messages you send us.
Cookies and other technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Our website sets no cookies of its own, so it works with cookies blocked.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals because the Service does not track you across other websites.
Declining to provide information. We need to collect personal information to provide certain services. If you do not give us your email address, we cannot send you our new stories, but you can still read everything on our website.
Delete your information. To have your email address deleted, write to kai@kyh.io from that address and it will be removed. If you believe our Research data includes information about you, you can write to the same address to ask what it holds about you, or to ask us to correct or delete it; your rights over it depend on where you live and on the exceptions the law makes for research and journalism.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are based in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy related right that may be available to you, please contact us via one of the methods listed below.

Email: kai@kyh.io

State privacy rights notice

Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the "State Privacy Laws").

This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. To confirm your identity, we will ask you to send your request from, or confirm it from, the email address the request concerns; for a request about Research data, we may also ask you to show that you control the account the request concerns.

For purposes of this section, the term "Personal Information" has the meaning given to "personal data", "personal information" or other similar terms and "Sensitive Personal Information" has the meaning given to "sensitive personal information," "sensitive data", or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws.

Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information:

The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting and/or selling Personal Information.
The categories of third parties with which we share Personal Information.
The categories of Personal Information that we sold or disclosed for a business purpose.
The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

Access. You can request a copy of the Personal Information that we have collected about you.

Appeal. You can appeal our denial of any request validly submitted.

Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.

Deletion. You can ask us to delete the Personal Information that we have collected from you.

Opt-out.

Opt-out of certain processing for targeted advertising purposes. We do not process your personal information for targeted advertising purposes.
Opt-out of or appeal profiling/automated decision making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.
Opt-out of other sales of personal data. We do not sell your Personal Information within the meaning of State Privacy Laws.

Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.

Sensitive Personal Information. We do not intentionally collect or process Sensitive Personal Information.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your right to opt-out of the "sale" or "sharing" of your Personal Information. We do not sell your Personal Information or "share" it for cross-context behavioral advertising, as the State Privacy Laws define those terms, so there is nothing to opt out of. If that ever changes, we will update this Privacy Policy first, offer a way to opt out, and honor Global Privacy Control ("GPC") signals as valid opt-out requests, as required by applicable law.

Exercising other state privacy rights. You may submit requests to exercise any of the other state privacy rights listed above via email to kai@kyh.io.

Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Information practices. The following describes our practices currently and during the past 12 months:

Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described above in the Privacy Policy.
Retention. The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
Deidentification. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Personal information that we collect, use and disclose. We have summarized the Personal Information we collect, the purposes for which we collect it and the third parties to whom we may disclose it by reference below to both the categories defined in the Personal information we collect section of this Privacy Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). This chart describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in the emails you send us, may contain other categories of personal information not described below.

Personal Information ("PI") we collect	CCPA statutory category	Purposes	Categories of third parties to whom we "disclose" PI for a business purpose	Categories of third parties to whom we "sell" or "share" PI
Contact data	Identifiers; California Customer Records	Service delivery and operations; Direct marketing; Compliance and protection	Service providers; Professional advisors; Authorities and others; Business transferees	None
Communications data	Identifiers; California Customer Records	Service delivery and operations; Research and journalism; Compliance and protection	Service providers; Professional advisors; Authorities and others; Business transferees; Other users and the public	None
Marketing data	Commercial information; Internet or other electronic network activity information	Direct marketing; Compliance and protection	Service providers; Professional advisors; Authorities and others; Business transferees	None
Research data	Identifiers; Internet or other electronic network activity information	Research and journalism; To create aggregated, de-identified and/or anonymized data; Compliance and protection	Service providers; Professional advisors; Authorities and others; Business transferees; Other users and the public	None
Device data	Identifiers; Internet or other electronic network activity information	Service delivery and operations; Compliance and protection	Service providers; Professional advisors; Authorities and others; Business transferees	None

Additional information for California residents.

Shine the light law. Under California's Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. We do not disclose personal information to third parties for their own direct marketing purposes. You may send us requests for this information to kai@kyh.io. In your request, you must include the statement "Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email kai@kyh.io.

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.

Notice to European users

General

Where this Notice to European users applies. The information provided in this "Notice to European users" section applies only to individuals in the United Kingdom and the European Economic Area (i.e., "Europe" as defined at the top of this Privacy Policy).

Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.

Controller. Kaiyu Hsu, who provides EdgeStories, is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called 'UK GDPR' (as and where applicable, the "GDPR")). See the 'How to contact us' section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract, we are about to enter into or have entered into with you ("Contractual Necessity").
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation ("Compliance with Law").
Where we have your specific consent to carry out the processing for the Purpose in question ("Consent").

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see 'How we use your personal information'.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Contact data; Communications data; Device data	Contractual Necessity.
Security	Device data	Compliance with Law. Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks.
Research and journalism	Research data; Communications data	Legitimate Interests. We have a legitimate interest in researching and publishing journalism about how people interact, which we pursue in a way designed to protect the people involved: private individuals appear in our stories only in aggregate, and we name only public figures acting in public roles.
Direct marketing	Contact data; Marketing data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law. Legitimate Interests. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Data sharing in the context of corporate events	Any and all data types relevant in the circumstances	Legitimate Interests. We and any relevant third parties have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). However, we would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate.
To create aggregated, de-identified and/or anonymized data	Any and all data types relevant in the circumstances	Legitimate Interests. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Service operates as intended, and to publish our research in an aggregated form that does not identify private individuals.
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for Compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through the Service.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to kai@kyh.io. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://www.edpb.europa.eu/about-edpb/our-members_en

For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner's Office, Water Lane, Wycliffe House, Wilmslow – Cheshire SK9 5AF. Tel. +44 303 123 1113. Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We are based in the U.S. and many of our service providers, advisers or other recipients of data are also based in the U.S. This means that your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

It is important to note that the U.S. is not the subject of a general 'adequacy decision' under the GDPR – the EU-U.S. Data Privacy Framework and its UK Extension cover only organizations certified under them, and we are not certified. Basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information transferred to us, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
Transfers to territories without an adequacy decision. We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above). However, in these cases we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or, in limited circumstances, we may rely on an exception, or 'derogation', which permits us to transfer your personal information to such country despite the absence of an 'adequacy decision' or 'appropriate safeguards' – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at kai@kyh.io.

This template was prepared and made publicly available by General Legal, PC ("General Legal"). It is provided for general reference purposes only and does not constitute, and should not be construed as, legal advice, or an endorsement or review of any particular transaction in which it is used. Use of this template does not create an attorney-client relationship with General Legal. General Legal has not reviewed, and takes no position on, any modifications made to this document or the deal terms it is used to document.