Privacy Policy
Last updated: July 13, 2026
DRAFT — pending review. This document is a working draft provided for convenience. It has not been reviewed by a lawyer and is not legal advice. Confirm it matches the analytics and cookies actually deployed before relying on it.
1. Who we are
Project K.E.M. (the "Site") is operated by [OPERATOR LEGAL NAME] ("we", "us", "our"). This policy explains what information we collect when you visit the Site, how we use it, and the choices you have.
2. Information we collect
We aim to collect as little personal data as possible:
- Consent choice. When you accept or reject non-essential cookies, we store that choice in your browser's local storage so we do not ask again. This stays on your device.
- Server and security logs. Our hosting and API infrastructure may automatically record technical data such as IP address, user agent, and request time. We use this to operate the Site securely, prevent abuse, and enforce rate limits.
- Analytics (only if enabled and consented). If analytics are enabled, we use [Google Analytics 4] to understand aggregate traffic. Analytics scripts and cookies load only after you grant consent. If you reject, no analytics scripts run and the Site continues to work normally.
- Account data (only if you register). If you sign in, we process the identifiers provided by your chosen sign-in method (for example, an email address) to maintain your account.
We do not knowingly collect sensitive personal information and we do not sell your personal information.
3. Cookies and local storage
Essential local storage (such as your consent choice and, if applicable, your session) is required for the Site to function. Non-essential analytics or advertising cookies are set only after you consent via the cookie banner. You can withdraw consent at any time by clearing the Site's stored data in your browser, which will remove your saved choice and stop non-essential scripts on your next visit.
4. How we use information
We use the limited data above to operate, secure, and improve the Site; to prevent abuse; to understand aggregate usage (where analytics are enabled and consented); and to maintain accounts where applicable.
5. Legal bases (EEA/UK visitors)
Where the GDPR applies, we rely on: our legitimate interests in operating and securing the Site (server logs); your consent (analytics and any advertising cookies); and, where you register, performance of a contract (your account).
6. Sharing and processors
We share data only with service providers that help us run the Site, acting on our instructions — for example [Vercel] (frontend hosting), [Cloudflare] (network/CDN and tunnel), and, if analytics are enabled, [Google Analytics]. We do not sell personal information or share it for cross-context behavioral advertising. We may disclose information if required by law.
7. Data retention
We retain technical logs only as long as needed for security and operations, and analytics data per the analytics provider's retention settings. Account data is retained while your account is active.
8. Your rights
Depending on where you live, you may have the right to access, correct, delete, or restrict processing of your personal data, to object to processing, to data portability, and to withdraw consent. To exercise these rights, contact us using the details below. You can also opt out of analytics at any time by rejecting or clearing cookies.
9. International transfers
Our providers may process data in countries other than yours. Where required, we rely on appropriate safeguards for such transfers.
10. Children
The Site is not directed to children and is intended for users who are adults in their jurisdiction. We do not knowingly collect personal data from children.
11. Security
We take reasonable technical and organizational measures to protect data, including transport encryption (HTTPS) and access controls. No method of transmission or storage is completely secure.
12. Changes to this policy
We may update this policy from time to time; material changes will be reflected by updating the "Last updated" date above.
13. Contact
Privacy questions or requests: [privacy@projectkem.com] (owner to provision this mailbox or substitute a working address).
See also our Terms of Service.
IMPORTANT DISCLAIMER:
The information provided by Project K.E.M. is for informational purposes only and does not constitute financial advice, investment recommendations, or an offer to buy or sell securities. The signals generated are the result of a mathematical model and should not be the sole basis for any investment decision.
Past performance is not indicative of future results. All investments involve risk and the potential for loss. Users should conduct their own research and consult with qualified financial professionals before making investment decisions.
Project K.E.M. is not a registered investment advisor and does not provide personalized financial advice.