Privacy Policy — Club Koa

Effective Date: 4 October 2026 Last Updated: 11 October 2026

Club Koa ("Club Koa", "KOA", "KOA Commerce", "we", "us" or "our") respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, disclose and protect information when you access or use Club Koa websites, marketplaces, storefronts, dashboards, business tools, payment-related features, communication tools and associated services (collectively, the "Platform").

Club Koa is a sole proprietorship business based in Jaipur, Rajasthan, India. Our business and contact details are provided in Section 31.

For privacy requests and grievances, email no-reply@clubkoa.xyz.

For purposes of applicable privacy and data-protection laws, Club Koa acts as the relevant data fiduciary, controller or business in relation to personal information processed directly by Club Koa, except where another party independently determines the purposes and means of processing.

This Privacy Policy applies to buyers, sellers, creators, service providers, founders, businesses, team members, visitors and other users of the Platform.

1. What Club Koa Is

Club Koa provides subscription-based software for project management, commerce and business activities. Its tools enable eligible users to manage projects, collaborate with teams, create digital storefronts, list and sell their own physical products, digital products or services, receive orders or enquiries, deliver digital content and communicate with customers.

Club Koa charges for access to its software. Users offer their own products or services and manage their own bank or payment-provider accounts, including verification required by the relevant provider.

Depending on the features available to a user's account, Club Koa may also provide:

storefront and website functionality;
customer relationship management tools;
product and service management;
order management;
subscriptions;
digital downloads;
customer communications;
business dashboards;
analytics;
projects and workflows;
team collaboration;
business intelligence;
automation; and
AI-assisted functionality.

Some areas or features of Club Koa may require an invitation, invite code, activation, subscription, verification or other eligibility requirement.

2. Information We Collect

The information Club Koa collects depends on how you interact with the Platform.

2.1 Account Information

When you create, activate or use a Club Koa account, we may collect:

your name;
username or display name;
email address;
telephone number;
profile photograph or avatar;
authentication credentials in protected form;
invitation or referral information;
account type;
country or region;
preferred language;
authentication-provider information; and
information required to secure or recover your account.

If you sign in using Google or another third-party authentication service, we may receive information you have authorised that provider to share with Club Koa, such as your name, email address, profile image and authentication identifier.

3. Seller, Creator and Business Information

If you create a seller account, business profile or storefront, we may collect or process:

business or trading name;
business description;
logo and branding;
business category;
products or services offered;
website and social-media links;
business address;
billing information;
tax or registration information;
GST, VAT or similar tax information where applicable;
bank or payout information;
identity-verification information;
business-verification information;
government-issued documents where legally or operationally required;
authorised representative information;
beneficial-owner information where legally required;
pricing;
shipping information;
fulfilment policies;
refund and cancellation policies;
team-member information; and
other information necessary for operating a business through Club Koa.

Information that you choose to publish as part of your public business profile, storefront or product/service listings may be visible to other users and potentially to the general public.

4. Product, Service and User Content

Users may create, upload, publish or otherwise provide content including:

physical-product listings;
digital-product listings;
service listings;
photographs;
videos;
documents;
downloadable files;
product descriptions;
pricing;
specifications;
service packages;
portfolios;
business information;
proposals;
project requirements;
customer-facing policies;
ratings;
reviews;
comments; and
other user-generated content.

Club Koa may process, store, host, display and distribute such information as reasonably necessary to operate the Platform and provide the requested functionality.

Information intentionally designated as public may be accessible to other users and may be indexed by search engines.

Users should not place confidential, highly sensitive or unnecessary personal information in publicly accessible profiles, storefronts or listings.

5. Buyer and Transaction Information

When you purchase, subscribe to, enquire about or interact with a product or service through Club Koa, we may collect or process information including:

buyer name;
contact information;
billing information;
delivery or shipping address;
order details;
products or services purchased;
transaction amount;
currency;
payment status;
order status;
subscription status;
invoices;
refund information;
cancellation information;
fulfilment information;
delivery information;
communications relating to the transaction;
ratings or reviews; and
transaction history.

For physical products, relevant order and delivery information may be disclosed to the seller, logistics provider or delivery partner as necessary to fulfil the order.

For services, relevant contact, project or requirement information may be provided to the service provider as necessary to perform the requested service.

6. Payment and Payout Information

Payments and payouts may be facilitated through independent payment gateways, payment processors, banks, acquiring institutions or other financial-service providers.

Depending on the provider, information processed may include:

payment method;
transaction identifier;
billing information;
payment status;
card type;
limited card information such as the last four digits;
bank-account or payout information;
settlement information;
refund details;
KYC or verification information; and
fraud-prevention or regulatory-compliance information.

Club Koa does not intend to directly store full payment-card numbers, CVV/CVC security codes or similar sensitive card-authentication information where payments are processed through authorised third-party payment processors.

Payment providers may process personal information independently in accordance with their own legal obligations, contractual terms and privacy policies.

7. Communications

Where Club Koa provides messaging or communication functionality, we may process:

buyer-seller communications;
customer enquiries;
seller responses;
team messages;
support requests;
dispute-related communications;
reviews;
comments;
notifications; and
other communications sent through the Platform.

Communications may be retained where reasonably necessary for:

customer support;
transaction management;
fraud prevention;
dispute resolution;
safety;
enforcement of Platform rules;
regulatory compliance; or
legal obligations.

8. Technical and Usage Information

When you access or use Club Koa, certain technical information may be collected automatically, including:

IP address;
browser type;
device type;
operating system;
device identifiers;
approximate geographic area derived from network information;
language;
pages and screens visited;
interactions and clicks;
referring website or source;
login activity;
session information;
timestamps;
diagnostic information;
errors and crash data;
performance information; and
security-related events.

We may use this information to operate, secure, analyse and improve Club Koa.

9. Cookies and Similar Technologies

Club Koa may use cookies, browser storage, pixels, SDKs and similar technologies to:

maintain login sessions;
authenticate users;
remember user preferences;
secure accounts;
prevent fraud;
operate Platform features;
understand usage;
measure performance;
improve the user experience; and
provide analytics.

Where applicable law requires consent for non-essential cookies or similar technologies, Club Koa will seek the appropriate consent before using them.

Users may also control certain cookies through browser settings or other privacy controls provided by Club Koa.

Disabling essential technologies may cause some Platform functionality to stop working correctly.

10. How We Use Personal Information

Club Koa may use personal information to:

create and manage accounts;
authenticate users;
operate invite-code and activation systems;
create storefronts;
create business profiles;
display products and services;
process orders;
facilitate subscriptions;
facilitate payments and payouts;
deliver digital products;
facilitate physical-product fulfilment;
connect buyers and sellers;
enable service-provider engagements;
provide messaging functionality;
provide CRM features;
manage business activities;
provide dashboards and analytics;
personalise Platform functionality;
improve recommendations and discovery;
provide AI-assisted features;
provide customer support;
verify users or businesses;
prevent fraud and abuse;
investigate suspicious activity;
secure accounts;
enforce Club Koa policies;
resolve disputes;
improve Platform performance;
develop new features;
maintain business and accounting records;
comply with taxation requirements;
comply with legal or regulatory obligations;
protect Club Koa and its users; and
provide transactional or service-related communications.

Where permitted by law, Club Koa may also send marketing, promotional or product-update communications.

Users may unsubscribe from non-essential promotional communications where an unsubscribe mechanism is available.

11. Artificial Intelligence and Automated Features

Certain Club Koa features may use artificial intelligence, machine learning or automated systems.

These features may assist with activities including:

business planning;
content creation;
product descriptions;
business recommendations;
analytics;
business insights;
search and discovery;
categorisation;
customer support;
fraud detection;
automation; and
Platform improvement.

Information entered into an AI-enabled feature may be processed as necessary to provide the requested functionality.

Where Club Koa uses external AI or technology infrastructure providers, relevant information may be transmitted to those providers solely as reasonably necessary for the relevant service and subject to appropriate contractual, technical or privacy safeguards.

Users should avoid submitting highly sensitive personal information, passwords, card credentials, medical information or confidential third-party information into general-purpose AI features unless the relevant Club Koa feature expressly requires such information and appropriate safeguards are provided.

12. Information Shared With Sellers and Service Providers

Club Koa operates as a platform connecting independent participants.

When a buyer purchases from or engages with a seller, creator or service provider, Club Koa may disclose information reasonably necessary to complete or support that transaction.

Such information may include:

buyer name;
relevant contact information;
delivery information;
purchased product;
purchased service;
project requirements;
order information;
transaction status; and
related communications.

Sellers and service providers are expected to handle buyer information responsibly and in accordance with applicable law and Club Koa policies.

Where a seller or service provider independently determines how personal information will be used outside Club Koa, that seller or service provider may act as an independent data fiduciary, controller or business and may be independently responsible for its privacy practices.

13. Third Parties With Whom Information May Be Shared

Club Koa may disclose information to trusted third parties where reasonably necessary for operating the Platform.

These parties may include:

payment gateways;
payment processors;
banks;
payout providers;
cloud-hosting providers;
database and infrastructure providers;
authentication providers;
email providers;
notification providers;
file-storage providers;
content-delivery providers;
analytics providers;
customer-support services;
cybersecurity providers;
fraud-prevention providers;
logistics providers;
delivery partners;
identity-verification providers;
business-verification providers;
AI technology providers;
accounting professionals;
tax advisers;
legal advisers;
auditors;
regulators;
courts;
government authorities; and
parties involved in a genuine merger, acquisition, restructuring, financing or transfer of the Club Koa business.

Information will be disclosed only where reasonably necessary for the relevant purpose or where disclosure is otherwise permitted or required by law.

14. Sale of Personal Information

Club Koa does not sell users' personal information for monetary consideration as part of its ordinary business model.

Club Koa's primary business is providing commerce, marketplace, business-management and related digital services.

If Club Koa later introduces advertising or another activity that legally constitutes the "sale" or "sharing" of personal information under an applicable privacy law, this Privacy Policy and the Platform's privacy controls will be updated as legally required.

15. Public Profiles and Storefronts

Club Koa is designed to allow users to create a public business presence.

Depending on your settings and the features you use, publicly visible information may include:

display name;
business name;
profile image;
business logo;
biography;
storefront;
product listings;
service listings;
portfolios;
prices;
reviews;
ratings;
follower information;
website links;
social links; and
other content intentionally published by you.

You should consider information published through a public profile or storefront to be publicly accessible.

Removal of information from Club Koa does not necessarily remove copies already cached by search engines, stored by browsers or legitimately obtained by another user.

16. Data Security

Club Koa uses reasonable technical, organisational and administrative safeguards designed to protect personal information from:

unauthorised access;
unauthorised disclosure;
alteration;
loss;
misuse;
destruction; and
other inappropriate processing.

Security measures may include:

encrypted network transmission;
access controls;
authentication controls;
database protections;
infrastructure monitoring;
activity logging;
backups;
recovery processes;
access restrictions; and
security controls applied to technology providers.

However, no online platform, transmission method or storage system can guarantee absolute security.

Users are responsible for maintaining the confidentiality of their login credentials and should notify Club Koa promptly if they believe an account has been compromised.

17. Data Retention

Club Koa retains personal information only for as long as reasonably necessary for the purposes for which it was collected or as required by applicable law.

Information may be retained to:

maintain an active account;
operate a storefront;
provide purchased products or services;
preserve transaction records;
maintain digital-product purchase records;
satisfy taxation obligations;
maintain accounting records;
prevent fraud;
resolve disputes;
enforce agreements;
respond to legal claims; and
satisfy regulatory requirements.

Different categories of information may therefore have different retention periods.

Where information is no longer reasonably required, Club Koa may delete, anonymise, aggregate or securely isolate it, unless continued retention is required by law or legitimate legal necessity.

18. Account Closure and Data Deletion

Users may request closure or deletion of their Club Koa account through available account settings or by contacting Club Koa.

Deletion of an account may not immediately remove:

completed transaction records;
invoices;
taxation records;
accounting records;
payment records;
fraud-prevention information;
unresolved dispute records;
information required by law;
information necessary for legal claims;
information already shared with another user as part of a completed transaction; or
temporary copies held in secure backup systems.

Where legally required, information that no longer needs to be retained will be deleted or anonymised.

19. Your Privacy Rights

Depending on your jurisdiction and applicable law, you may have rights including the right to:

obtain information about how your personal information is processed;
request access to your personal information;
request correction of inaccurate information;
request completion of incomplete information;
request deletion or erasure;
withdraw consent where processing is based on consent;
object to certain processing;
request restriction of certain processing;
receive certain information in a portable format;
opt out of certain advertising or sharing practices where applicable;
exercise rights relating to sensitive information where applicable;
raise a grievance;
nominate another person where provided by applicable law; and
contact an appropriate data-protection regulator.

Club Koa will not unlawfully discriminate against users for exercising applicable privacy rights.

We may require reasonable verification of your identity before processing a privacy request.

Privacy requests may be submitted to:

Email: no-reply@clubkoa.xyz

20. Privacy Rights in India

Where applicable Indian data-protection laws apply, Club Koa will process personal data in accordance with applicable requirements.

Club Koa will take reasonable measures to process personal information only for lawful purposes and in accordance with applicable consent, notice, security and user-rights requirements.

Where applicable, users may have rights relating to:

access to information regarding processing;
correction of personal information;
completion or updating of information;
erasure of information;
withdrawal of consent;
grievance redressal; and
nomination.

Where processing is based on consent, withdrawal of consent may prevent Club Koa from continuing to provide functions that require the relevant information.

Privacy or grievance requests may be submitted to:

Club Koa – Privacy & Grievance Contact Email: no-reply@clubkoa.xyz

21. European Economic Area and United Kingdom

Where European Union, European Economic Area or United Kingdom data-protection law applies, personal information may be processed under one or more applicable legal bases, including:

performance of a contract;
compliance with legal obligations;
legitimate interests;
protection of vital interests where appropriate; or
consent.

Eligible users may have rights including:

access;
correction;
erasure;
restriction;
objection;
data portability; and
withdrawal of consent.

Users may also have the right to lodge a complaint with an appropriate supervisory authority.

22. California and Other U.S. State Privacy Rights

Residents of California and certain other U.S. states may have additional privacy rights under applicable state laws.

Depending on applicable law, these may include rights to:

know what categories of personal information are collected;
request access;
request correction;
request deletion;
know categories of information disclosed to third parties;
opt out of qualifying sales or sharing;
opt out of certain targeted advertising;
limit certain uses of sensitive personal information; and
exercise privacy rights without unlawful discrimination.

Club Koa does not sell personal information for monetary consideration as part of its ordinary business model.

Where additional opt-out or privacy mechanisms are legally required, Club Koa will provide the applicable functionality.

23. International Data Transfers

Club Koa may use service providers or infrastructure located outside the country in which a user resides.

Accordingly, information may be transmitted to, stored in or processed in other jurisdictions.

This may occur in connection with:

cloud hosting;
payment processing;
authentication;
analytics;
artificial intelligence;
security;
communications;
storage; and
other technology services.

Where applicable law requires specific safeguards for international transfers, Club Koa will use legally recognised mechanisms or other appropriate safeguards.

24. Children and Minors

Club Koa Commerce is primarily intended for adults who are able to enter into commercial transactions.

Unless Club Koa specifically provides a legally compliant parental or guardian consent mechanism, persons under 18 years of age should not independently create seller accounts, receive commercial payouts, enter commercial agreements or otherwise engage in transactions requiring legal capacity through the Platform.

Where Club Koa becomes aware that personal information from a minor has been collected without consent or authorisation required under applicable law, appropriate steps may be taken to restrict or delete the information.

Parents or lawful guardians may contact:

no-reply@clubkoa.xyz

regarding concerns relating to a minor's information.

25. Business Accounts and Team Members

Club Koa may allow business owners or authorised administrators to invite users to participate in business workspaces.

Depending on assigned permissions, authorised administrators may be able to:

invite or remove team members;
assign roles;
manage permissions;
manage products or services;
access business activity;
manage customers;
manage orders;
access business information;
configure integrations; and
manage Platform settings.

Users should be aware that information they create or upload within a business workspace may be accessible to authorised persons associated with that workspace.

26. Third-Party Services and Websites

Club Koa may contain links to or integrations with independent third-party services including:

payment providers;
logistics providers;
social networks;
websites;
technology services; and
other platforms.

Club Koa does not control the independent privacy practices of these third parties.

When you directly interact with an independent third-party provider, that provider's privacy policy and terms may apply.

27. Fraud, Safety and Platform Integrity

Club Koa may process information where reasonably necessary to detect, prevent, investigate or address:

fraudulent transactions;
payment abuse;
fake accounts;
impersonation;
spam;
account takeover;
malicious activity;
prohibited products;
prohibited services;
marketplace manipulation;
abuse of Club Koa systems;
security incidents; and
violations of Club Koa policies.

Information may be shared with relevant payment providers, financial institutions, professional advisers, regulators or law-enforcement authorities where reasonably necessary and legally permitted.

28. Legal Requests and Protection of Rights

Club Koa may access, preserve or disclose relevant information where reasonably believed necessary to:

comply with applicable law;
respond to lawful court orders;
respond to valid legal or regulatory requests;
comply with government processes;
enforce Platform terms and policies;
investigate violations;
prevent fraud;
protect Platform security;
protect Club Koa's legal rights;
protect users or third parties; or
establish, exercise or defend legal claims.

Where appropriate and legally permitted, Club Koa may notify affected users regarding requests for their information.

29. Business Transfers

As Club Koa is operated as a sole proprietorship, the business, Platform, intellectual property, customer relationships or related assets may in the future be transferred, reorganised or contributed to another legal entity or business structure.

If such a legitimate business transfer occurs, relevant personal information may form part of the transferred business assets, subject to applicable law.

Where legally required, users will be informed of material changes affecting the identity of the entity responsible for their personal information.

30. Changes to This Privacy Policy

Club Koa may update this Privacy Policy periodically to reflect changes in:

the Platform;
products or services;
technology;
service providers;
business operations;
legal requirements; or
regulatory requirements.

The current version will show its latest revision date.

Where a material change significantly affects how personal information is processed, Club Koa may provide additional notice through the Platform, email or another appropriate method where legally required.

Continued use of Club Koa will not substitute for affirmative consent where applicable law specifically requires such consent.

31. Contact and Grievance Redressal

Questions, complaints, grievances or privacy-related requests may be submitted to:

Club Koa A Sole Proprietorship Business

Privacy & Grievance Email: no-reply@clubkoa.xyz

This email address accepts incoming messages and is monitored for privacy requests and grievances, despite the "no-reply" name.

You may also email us with questions about Club Koa, its business location or official correspondence.

Principal Place of Business: 112, Central Spine Vidhyadhar Nagar Jaipur, Rajasthan India

Where applicable law gives users a right to approach a competent regulatory or data-protection authority, users may exercise that right in accordance with applicable law.

32. Our Privacy Commitment

Club Koa is designed to help individuals and businesses build, operate, sell and grow.

Personal information entrusted to Club Koa is intended to be used to operate, secure and improve that experience, facilitate legitimate commerce, provide services requested by users, comply with legal obligations and protect the Club Koa community.

Club Koa does not treat the sale of users' personal information as part of its ordinary business model.