Privacy Policy
Effective date: 2026-05-04 • Jurisdiction: Switzerland & France (NOVAK) • GDPR / nFADP
KOM-5A is designed as a long-term, governance-first ecosystem. Privacy and security are not “nice to have” — they are part of the core product and of the trust we build with users, partners and investors. During the current private testing phase, we run with a strict, transparent data discipline: we log what we need to secure the system, we minimise what we store, and we keep a clear audit trail of how the platform is used.
Who We Are
KOM-5A is imagined and engineered by the founder in Switzerland and operated commercially by NOVAK in France (registered at the Greffe du Tribunal de Commerce de Lisieux, 992 548 107 RCS).
For the purposes of data protection law, KOM-5A / NOVAK act as the data controller for the platform and related services.
Official contact: info@kom-5a.com
Our Principles
- Minimal data — we only collect what we need to run, secure and improve the platform.
- No data selling — we do not sell your personal data, and we do not build ads profiles from private activity.
- Security-first — logs, monitoring and controls are designed like a financial platform: traceable and auditable.
- Transparency — clear rules, no dark patterns, no hidden “consents”.
- User rights — GDPR and Swiss data protection rights are built into our processes from day one.
What We Collect
- Account data — basic profile details you give us (e.g., email, username, region). Optional fields are clearly marked as optional.
- Usage & device logs — IP address, timestamps, pages visited, actions performed, error traces, and security events (e.g., failed logins, suspected abuse, unusual traffic).
- Interaction & reward signals — likes, follows, posts and other on-platform actions that are needed to run features such as K5A rewards, ranking, or anti-abuse systems.
- Cookies & local storage — only what is necessary for sessions, security, and performance analytics during the test phase.
- Support & contact messages — if you email us or use contact/support forms, we keep your message and related metadata to follow up and document decisions.
Why We Use Your Data
- To run the core features you choose to use.
- To protect accounts and infrastructure from bots, fraud and attacks.
- To debug errors, monitor performance and keep KOM-5A stable.
- To improve flows, remove friction and design a better experience.
- To comply with legal obligations and enforce our Terms of Use.
Legal Basis (GDPR / nFADP)
- Legitimate interests — securing the platform, preventing abuse, and improving the service.
- Contractual necessity — providing the features you actively use (e.g., account, posts, rewards).
- Consent — when required by law (we will ask explicitly and allow you to withdraw it).
AI Monitoring & Spartacus
KOM-5A uses internal AI systems (called Spartacus) to analyse technical signals and patterns. The goal is to detect abuse, protect the community, stabilise the infrastructure and support moderation — not to manipulate users.
- We use AI to flag anomalies, suspicious traffic and repeated abuse attempts.
- We may combine logs (IPs, device fingerprints, error patterns) to protect KOM-5A and its users.
- We do not use AI to take decisions that produce legal or similarly significant effects without human review.
Data Retention
We keep personal data only as long as needed for the purposes above. Logs and test data are generally kept for the duration of the private testing phase plus a limited audit period, then deleted or irreversibly anonymised unless longer retention is required by law or to resolve ongoing incidents.
Sharing & Service Providers
We do not sell your personal data. We rely on carefully selected service providers (for example cloud hosting, email delivery, analytics, security monitoring). They only process data on our instructions, under contracts and confidentiality duties.
Where data is transferred outside Switzerland or the EU/EEA, we use appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms.
Your Rights
- Right of access to the personal data we hold about you.
- Right to rectification of inaccurate or incomplete data.
- Right to deletion (erasure) in the cases provided by law.
- Right to restriction or objection to certain processing activities.
- Right to data portability where applicable.
- Right to lodge a complaint with a data protection authority (FDPIC in Switzerland, or your local authority in the EU/EEA).
To exercise your rights, contact us at privacy@kom-5a.com or via the official contact email info@kom-5a.com. We may ask you to verify your identity before acting on your request.
Children
KOM-5A is not directed to children under 16. We do not knowingly collect personal data from children. If you believe a child has used KOM-5A and provided personal data, please contact us so we can investigate and delete the data where appropriate.
Changes to This Policy
As KOM-5A evolves from private testing to wider availability, this policy will be updated to reflect new features, new legal requirements and the final corporate structure. When we make material changes, we will provide clear notice inside the product. The latest version will always be available on this page.
For Investors & Partners
Data protection is not a separate “legal file” for us — it is part of the architecture of KOM-5A. Logs, rewards, referrals and anti-abuse systems are designed from the start with auditability in mind. This policy summarizes that approach publicly and sets the standard we will keep as the platform grows to the next million users.