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Privacy Policy

Last updated: July 13, 2026

This Privacy Policy describes how ALAS TECHNOLOGY LLC, the data controller, collects, uses and protects your personal data, following international data-protection principles such as lawfulness, transparency, purpose, minimisation and security.

1. Data we collect

We collect the data you provide (such as your name and email at purchase or in the contact form), the identity-verification (KYC) data processed through our identity-verification partner, the data needed to issue and manage your Pass and its accesses, the transaction data needed to process payment, and the browsing data collected through cookies and similar technologies (such as device identifiers and pages visited).

2. Purposes of processing

We use the data to process the purchase, verify your identity, issue and activate your Pass, release and manage accesses, provide support, send service-related communications by email, ensure platform security, comply with legal obligations and, with your consent, measure the performance of our campaigns.

3. Legal basis for processing

Each processing activity relies on an appropriate basis: performance of the contract (to verify identity, issue the Pass, deliver accesses and provide support), compliance with legal obligations (including fraud prevention and identity-verification requirements), our legitimate interest in protecting and improving the service, and your consent — particularly for analytics and marketing cookies, which you may grant or withdraw at any time.

4. Cookies

We use essential cookies (always active) and, with your consent, analytics and marketing cookies, including advertising-platform pixels. You control these choices at any time. Learn more in our Cookie Policy.

5. Data sharing

We do not sell your data. We may share it with processors that provide services strictly necessary to deliver the service — such as the identity-verification partner, the payment processor, the VIP-lounge program operator, hosting and analytics — always under confidentiality obligations and only to the extent necessary for each purpose.

6. Information security

We adopt technical and organisational measures to protect your data against unauthorised access, loss or misuse. Our commitment to security and privacy follows internationally recognised standards, such as those for information-security management (ISO/IEC 27001) and privacy-information management (ISO/IEC 27701).

7. Retention

We keep data only for as long as necessary for the purposes described or to comply with legal obligations, including those relating to identity verification and fraud prevention. Once that period ends, the data is securely deleted or anonymised.

8. Your rights

You may request confirmation, access, correction, portability or deletion of your personal data, object to certain processing and withdraw consents, by contacting us through our Support.

9. International transfers

As we operate globally, your data may be processed in other countries. In such cases, we adopt appropriate safeguards to ensure a level of protection consistent with this policy, regardless of where the data is processed.

10. Contact and data protection officer

The data controller is ALAS TECHNOLOGY LLC. To exercise your rights or clarify privacy questions, contact our data protection officer (DPO) through our Support, or directly by email at [email protected].

Privacy Policy — Lounge Secreto