KOTLIN FOUNDATION CODING
COMPETITION PRIVACY POLICY

• Collection of Information
• Use of Information
• Sharing of Information
• Analytics
• Your Choices
• Additional Disclosures for Individuals in Europe
• Consumer and Data Subject Access Requests
• Contact Us

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you fill out a form, submit or post content through our Services or participate in our Competition, communicate with us via third-party platforms, or otherwise interact with us. The types of information about you that we collect include your name, email address, school affiliation, country, an explanation of your background, a link to your Submission, an explanation of your Submission, and any other information you choose to provide.

In connection with the Competition, information shared with GitHub will be governed by the GitHub privacy policy, available here.

Information We Collect Automatically

We automatically collect certain information about your interactions with us or our Services, including:

• Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
• Information Collected by Cookies and Similar Tracking Technologies: The Foundation Member that hosts the Services may use cookies and/or analytics tools. Further information about this collection and your choices with respect to it is accessible here: JetBrains Privacy Policy.

We use the information we collect to operate the Competition and contact you with updates concerning the Competition. We also use the information we collect to:

• Communicate with you about products, services, and events offered by the Kotlin Foundation and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
• Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of the Kotlin Foundation and others;
• Comply with our legal and financial obligations;
• Create de-identified, anonymized or aggregated information; and
• Carry out any other purpose described to you at the time the information was collected.

We share personal information in the following circumstances or as otherwise described in this policy:

• We share the personal information of Competition winner(s) publicly on our website or the websites of our Foundation Members, including the winners’ names, school affiliations, countries of residence, a Third Party Service link to their winning Submission, and any promotional content we may create with the Competition winner(s).
• We share personal information with vendors and service providers that access personal information to perform work for us, such as companies that assist us with web hosting.
• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• We may share personal information if we believe that your actions are inconsistent with our policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of the Kotlin Foundation, our users, the public, or others.
• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• We may share personal information in connection with, or during negotiations concerning, any merger, sale of assets, financing, or acquisition of all or a portion of our organization by another entity.
• Personal information is shared between and among the Kotlin Foundation and our current and future Foundation Members and their directors and employees.
• We share personal information with your consent or at your direction.

Communications Preferences

You may opt out of receiving promotional emails from the Kotlin Foundation by following the instructions in those communications or by contacting us at privacy@kotlinfoundation.org. If you opt out, we may still send you non-promotional emails, such as those about the Competition.

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., operating the Competition).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our services and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store personal data associated with your Submission and the Competition until and unless you request that we delete it unless required by applicable laws to maintain the data. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. For any personal information submitted in connection with the Competition directly to GitHub, see GitHub’s retention policy here.

Data Subject Requests

Subject to those certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at privacy@kotlinfoundation.org.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Consumer and Data Subject Requests

The Kotlin Foundation honors data subject access requests, regardless of the residency or location of the data subject, subject to certain limitation. If you would like to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing, please email us at privacy@kotlinfoundation.org.

If you have any questions about this Privacy Policy, please contact us at privacy@kotlinfoundation.org or by submitting a contact form through our Services.

Last Updated: August 2023.