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Privacy Policy

Last updated: 31 July 2025

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1. Who we are

Kumbengo Inc. ("Kumbengo," "we," "our," or "us") designs and sells downloadable audio plug-ins through kumbengo.com and any related plug-in installers, licensing services, or support channels (collectively, the "Services"). Our Services are hosted on the Wix.com platform, processed through Wix Payments, and activated via our own license server running on Wix infrastructure.

Contact Information:

  • Email: info@kumbengo.com

  • Mail: Kumbengo Inc., 16192 Coastal Hwy, Lewes, DE 19958, USA

 

2. How we collect information

We collect Personal Information when you:

  • Submit a form on the site (contact, subscription, checkout)

  • Complete a purchase through Wix Payments

  • Activate or update a plug-in (our license server receives device and activation data)

  • Interact with our emails

  • Browse the site (cookies, pixels, and tracking scripts run automatically)

 

3. Information we collect and why

Device & Site Usage:

  • Examples: IP address, browser type, OS, referring pages, time-zone, cookies, click-stream

  • Purpose: Load the site, security logging, analytics, cookie banner functionality

  • Lawful Basis: Legitimate interests (site security and improvement)

  • Retention: 24 months

Order & Billing:

  • Examples: Name, address, phone, email, DAW, payment token (via Wix Payments), VAT/Tax ID

  • Purpose: Contract fulfillment, fraud screening, product tailoring, taxation

  • Lawful Basis: Contract performance, legal obligation

  • Retention: 7 years

Support:

  • Examples: Support messages, attachments, session files, crash dumps

  • Purpose: Customer support, bug resolution

  • Lawful Basis: Legitimate interests; consent if you voluntarily provide extra data

  • Retention: 4 years

License Telemetry:

  • Examples: Plug-in ID, hashed machine ID, DAW version, OS version, activation logs, crash logs

  • Purpose: Enforce EULA, prevent piracy, improve product

  • Lawful Basis: Legitimate interests, contract

  • Retention: Duration of license + 3 years

Marketing Preferences:

  • Examples: Opt-in status, ad-tracking IDs

  • Purpose: Send marketing offers (only with opt-in in EEA)

  • Lawful Basis: Consent, legitimate interests

  • Retention: Until consent withdrawn or 2 years of inactivity

Sensitive Data: We do not knowingly collect special-category data (biometric, health, precise geolocation, etc.). If you believe you've submitted such data, contact us for deletion.

 

4. How we communicate with you

We may contact you by email or (rarely) by phone or post to:

  • Confirm purchases or deliver license keys

  • Respond to support inquiries

  • Send critical service updates (e.g., version changes)

  • Send marketing offers (only if you opted in)

All marketing emails include an unsubscribe link.

 

5. How we share information

We share Personal Information with trusted partners only for the reasons outlined below:

  • Wix.com Ltd. – hosting, database, email, and infrastructure

  • Wix Payments – secure transaction processing (PCI-DSS Level 1)

  • Analytics – Google Analytics 4 and Plausible (anonymized usage stats)

  • Advertising Partners – Google Ads, Meta Ads (only if consented)

  • Customer Support Providers – Zendesk, Gmail

  • Authorities or Acquirers – as required by law or in the event of a business transfer

We do not sell your Personal Information for monetary consideration. We only "share" data for advertising purposes with your consent.

 

6. International Transfers

We may process your information in the U.S., Israel, EU, or other jurisdictions where Wix operates. For EEA, UK, or Swiss data transfers to the U.S., we rely on:

  1. Wix’s certification under the EU-U.S. Data Privacy Framework (DPF)

  2. Standard Contractual Clauses (SCCs), when applicable

 

7. Cookies & Similar Technologies

We use the following types of cookies:

  • Essential Cookies – core functionality, security, login sessions (e.g., XSRF-TOKEN, svSession)

  • Analytics Cookies – help us improve site performance (e.g., GA4, Plausible)

  • Advertising Cookies – support targeted marketing (only set with your consent)

You can view the current cookie list at: https://support.wix.com/en/article/cookies-and-your-wix-site

Third-party apps (e.g., Meta, Google Ads) may use their own cookies governed by their privacy policies.

We currently do not respond to Do Not Track (DNT) browser signals.

 

8. Automated Decision-Making

We use automated tools (e.g., fraud screening) to protect our services. If such a process produces a legal or significant impact, you may request a manual review.

 

9. Security

We take security seriously and implement:

  • TLS 1.3 for encryption in transit

  • AES-256 for encryption at rest

  • PCI-DSS Level 1 compliance via Wix Payments

  • ISO 27001/27701 certified hosting

  • MFA and least-privilege staff access

  • Routine security testing

 

10. Retention & Deletion

We retain data only as long as necessary for the purposes above. After that, we securely delete or anonymize it. Tax data is retained for 7 years; crash logs are scrubbed after 3 years.

 

11. Your Rights

Depending on your jurisdiction, you may have rights including:

  • Accessing or correcting your data

  • Requesting deletion or data portability

  • Withdrawing consent

  • Opting out of profiling or targeted ads

These rights apply under GDPR (EU/UK), nFADP (Switzerland), CPRA (California), and other state laws (e.g., Colorado, Virginia, Texas, Oregon). Canadian users are covered under PIPEDA and Québec Law 25.

To exercise your rights, email us at info@kumbengo.com.

You may also file a complaint with your local data authority. For example, U.S. residents may contact the FTC at https://www.ftc.gov.

 

12. Withdrawing Consent or Deleting Data

You can withdraw consent at any time by:

  • Clicking the unsubscribe link in emails

  • Adjusting preferences in the cookie banner

  • Emailing info@kumbengo.com

We will verify your identity and respond within 30 days.

 

13. Minors

Our services are not intended for children under 13. We do not knowingly collect information from minors. If we become aware of such data, we will delete it.

 

14. Changes to This Policy

We update this policy at least annually. If changes are material, we will notify you by email 30 days in advance. The latest version will always be posted on this page.

 

15. Accessibility

This Privacy Policy is available in accessible HTML and PDF formats. Alternate formats (e.g., braille, large print) are available upon request.

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