Privacy policy

1. Who is responsible

Revido LLC, 2106 House, Ave Suite 383, Cheyenne, Wyoming 82001, USA, is the operator and controller of Kuvend. Kuvend is independent and non-governmental. It is not affiliated with the Parliament of Albania or any public authority.

Contact [email protected] about privacy or your rights and [email protected] about security.

2. How verification is separated from participation

The isolated issuer temporarily receives the number, requests a one-time code, and issues an anonymous credential. The civic service receives only a cryptographic proof and a proposal-scoped marker. Its schemas reject phone numbers, OTPs, identity sessions, and stable participant identifiers.

In a real WhatsApp trial, Sent uses its managed sender and, together with WhatsApp/Meta, processes the number and delivery data. Sent and Meta do not receive proposal text, votes, arguments, inclusion receipts, or recovery secrets. During beta the issuer does not yet have an independent operator, so Kuvend does not claim that maintainers technically cannot see the number.

3. Data, purposes, and proposed legal basis

• Public content: proposals, revisions, arguments, evidence, chosen public name, moderation history, and results, to operate and document the civic process.
• Anonymous voting: credentials, proofs, proposal-scoped nullifiers, ballot commitments, and inclusion receipts, to accept one valid vote without a citizen profile.
• Verification: the number in request memory only, plus keyed phone and OTP digests for validity, replay prevention, and abuse controls.
• Notifications: an encrypted push subscription and selected topics, only after browser permission.
• Security and administration: named moderator actions, access controls, and audit records in a separate trust domain.

Proposed legal bases are providing the service requested by the user, legitimate interests in security and integrity, consent for notifications and a voluntary public name, and legal obligations where applicable. The final assessment is part of the legal review and DPIA before real processing.

4. What OTP does not prove

The code proves control of a number at that moment. It does not prove identity, age, citizenship, residence, one-person uniqueness, or electoral eligibility. Results are labelled verified-phone participation, are advisory, and do not claim to represent Albanian citizens or residents.

5. IP address and country suggestion

Cloudflare sees the IP address as a network provider. The Kuvend application does not read or retain the IP to suggest a country. It reads only Cloudflare’s two-letter request header, returns that hint to the browser with no-store, and does not write it to a database, analytics system, or application log.

6. Recipients and transfers

Railway supplies application infrastructure and separated databases; Cloudflare supplies DNS, protection, and delivery; Sent and Meta/WhatsApp are intended only for code delivery; an AI provider is used only when a user requests optional assistance. Kuvend does not sell data, show advertising, or load behavioral analytics or tracking SDKs in the browser.

Some processors are outside Albania. Before real verification, Revido LLC must complete processing agreements, subprocessor review, and lawful transfer mechanisms, including standard contractual clauses where required. See Sent’s data processing addendum and privacy policy.

7. Retention

• The plaintext number exists only in request memory and is excluded from backups.
• The challenge and OTP digest expire after five minutes.
• The resend rate-limit digest expires after ten minutes.
• The anonymous device credential lasts up to 30 days.
• AI drafts and audio are discarded after acceptance or cancellation.
• A push subscription remains until unsubscribe, expiry, or provider rejection.
• Accepted content, decisions, results, and public audits are retained for accountability; the final archive period must be approved before a real pilot.

Sent and Meta apply their own retention rules. Contractual limits and deletion behavior are launch conditions. Backups must not silently extend a promised deletion period.

8. Your rights

Under Albanian Law no. 124/2024, you may request information, access, correction, deletion, restriction, objection, and portability where applicable, and withdraw consent without affecting prior processing. Kuvend does not use automated decision-making for moderation or ballot acceptance.

Anonymous design means Revido LLC may be unable to connect a request to your ballot or pseudonym. Keep any inclusion receipt or capability secret the service gives you. We will not create an identity link merely to answer a request.

You may complain to Albania’s Commissioner for the Right to Information and Personal Data Protection, Rr. “Abdi Toptani”, Nd. 5, Tirana 1001, +355 42 23 7200, [email protected], or through its complaint page.

9. Security, children, and changes

Services, keys, databases, and audits are separated by role. No system is risk-free, and cryptography cannot prove that a compromised server did not secretly log data. Do not publish a child’s or another person’s private information. Anyone unable to accept these terms legally should not submit or vote.

Material changes receive a new date and, when they affect processing, a prominent notice before they take effect.