Knoesis Technologies Limited is the Data Controller in respect of personal data processed through the FORUM platform at dailyforum.co.uk. As Data Controller, Knoesis determines the purposes and means of processing your personal data in accordance with the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.

For all privacy-related enquiries, requests to exercise your data rights, or to contact our data protection function, please write to legal@knoesis.co.uk with the subject line "Privacy Enquiry". We will respond within the timeframes required by applicable law.

Knoesis Technologies Limited will appoint a Data Protection Officer ("DPO") in accordance with Article 37 UK GDPR when the scale and nature of its processing activities requires it. At the time of this Policy's effective date, data protection functions are managed by Knoesis's legal and compliance team. Contact details for data protection matters are as set out in Clause 1.2 above.

Knoesis Technologies Limited is registered with the Information Commissioner's Office ("ICO") as required under the Data Protection Act 2018. Our ICO registration number is available upon request at legal@knoesis.co.uk.

When you create an Account or use the Service, you provide us with the following personal data:

• Account registration data: your email address, chosen display name, and handle, provided during registration via Firebase Authentication.
• Authentication credentials: managed and stored by Google Firebase Authentication. Knoesis does not store raw passwords. Authentication data is processed in accordance with Google's applicable data processing terms.
• Profile information: any optional profile information you choose to add, including a display name or avatar image.
• Debate content: all arguments, challenges, and debate contributions you submit to the Platform. This content is User-Generated Content as defined in our Terms of Service and is associated with your Account and publicly visible to other registered users.
• Communications: any correspondence you send to Knoesis, including support requests, appeals, and legal notices.

When you access and use the Service, we automatically collect the following technical and usage data:

• Device and access data: IP address, browser type and version, operating system, device identifiers, and access timestamps.
• Usage data: pages visited, debates viewed and entered, arguments submitted, side selections, time spent on Platform features, notification interactions, and return visit patterns.
• Performance data: debate win/loss records, persuasion scores, engagement resilience metrics, credibility ratings, streak data, and reputation metrics. This data is generated by your participation and is publicly associated with your Account profile.
• Moderation data: flags submitted by you or applied to your content, moderation actions taken, and any Account restrictions or terminations.

The Platform uses Google Firebase services for backend infrastructure, authentication, and data storage. Firebase automatically collects certain technical data including device information, crash reports, and performance metrics in accordance with Google's Firebase data processing terms. Knoesis configures Firebase in accordance with its data minimisation obligations under UK GDPR.

The Platform serves advertisements through Google AdSense. When advertisements are displayed, Google AdSense may collect and process data including your IP address, browser characteristics, and advertising identifiers for the purposes of serving contextually relevant advertisements and measuring advertising performance. Please see Section 8 of this Policy and our separate Advertising Information Notice for full details.

The Platform uses cookies and similar tracking technologies. Full details of the cookies used on the Platform, their purposes, and how to manage your cookie preferences are set out in Clause 9 of this Policy.

Knoesis does not:

• Sell your personal data to third-party advertisers, data brokers, or any other third parties
• Build individual micro-targeting profiles for the purpose of cross-platform behavioural advertising
• Collect special category data (such as health, racial or ethnic origin, political opinions, religious beliefs, biometric data, or sexual orientation) as part of its intended data collection
• Track your browsing activity outside of the dailyforum.co.uk domain

Under Article 6 of the UK GDPR, Knoesis processes your personal data on the following lawful bases:

Where Knoesis relies on Legitimate Interests as its lawful basis, it has conducted a balancing test confirming that: (a) the legitimate interest pursued is genuine and clearly identified; (b) the processing is necessary for that purpose; and (c) the processing does not override the fundamental interests or rights and freedoms of data subjects. Users may request a summary of Knoesis's legitimate interests assessment by contacting legal@knoesis.co.uk.

Where processing is based on your consent (including consent to advertising cookies), you may withdraw that consent at any time without detriment to your use of the Service. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. To withdraw advertising consent, adjust your cookie preferences via the Platform's cookie management tool or your browser settings.

We use your personal data to provide, operate, and maintain the FORUM Service, including:

• Creating and managing your Account
• Authenticating your identity on each login via Firebase Authentication
• Enabling your participation in Debates, including storing and displaying your arguments and performance records
• Operating the reputation system and calculating your performance metrics
• Sending you notifications related to your debate activity, including challenge alerts, outcome notifications, and Platform updates
• Processing and responding to your reports and flags

We use personal data to maintain the safety and integrity of the Platform:

• Running automated profanity and contextual content filters against your submitted Content
• Reviewing flagged Content associated with your Account
• Investigating reported violations of our Terms of Service
• Enforcing Account suspensions and terminations
• Cooperating with law enforcement and regulatory authorities as required by law

We use aggregated and anonymised usage data to understand how users interact with Platform features, identify and resolve technical issues, develop new features and improve existing ones, and monitor Platform performance and debate engagement patterns. Knoesis does not use your personal data for individual profiling for commercial purposes.

We use Google AdSense to serve advertisements on the Platform. Advertising data processing is described fully in Clause 8 of this Policy and in our Advertising Information Notice. Knoesis does not share your individually identified personal data with advertisers. Advertising on the Platform is served contextually, meaning it is matched to the content of the Platform rather than to an individual profile of your behaviour outside the Platform.

We use personal data to comply with our legal and regulatory obligations, including under the Online Safety Act 2023, respond to law enforcement requests and court orders, exercise or defend legal claims, and maintain records required by applicable law.

Knoesis does not sell your personal data. We share personal data only to the extent necessary to deliver the Service or comply with our legal obligations, as described below.

Your Account data, debate content, and usage data are stored and processed using Google Firebase infrastructure, operated by Google LLC. Google processes this data as a Data Processor acting on Knoesis's instructions, under a Data Processing Agreement in compliance with UK GDPR Article 28. Data processed through Firebase may be stored on servers located in the European Economic Area or the United Kingdom. Where transfers outside these territories occur, they are subject to appropriate transfer mechanisms including Standard Contractual Clauses or equivalent safeguards recognised under UK law.

Google AdSense operates as an independent Data Controller in respect of advertising-related data it collects through the Platform. When you interact with advertisements served by AdSense, Google may process your data for its own purposes in accordance with Google's privacy policy. Knoesis does not control or have access to the data processed by Google AdSense independently. Please refer to Clause 8 and our Advertising Information Notice for full details.

Knoesis will disclose personal data to law enforcement agencies, regulatory bodies (including the ICO and Ofcom), or courts of competent jurisdiction where required to do so by law, court order, or legal process. Where legally permissible, Knoesis will notify affected users of such disclosure requests.

Knoesis may disclose personal data where necessary to establish, exercise, or defend legal claims in which Knoesis is involved, including in connection with potential litigation, arbitration, or regulatory proceedings.

In the event of a merger, acquisition, restructuring, or sale of Knoesis's assets, your personal data may be transferred to the relevant successor entity. Knoesis will provide notice of any such transfer and will ensure that the successor entity is bound by privacy obligations no less protective than those in this Policy.

Knoesis does not share your personal data with any third parties other than as described in this Clause 5. Knoesis does not share personal data with data brokers, advertising networks (other than Google AdSense as described), social media platforms, or any other commercial third parties for their independent use.

Knoesis retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law:

Where you delete your Account, Knoesis will remove or anonymise your personal data in accordance with the schedule above. Certain data may be retained beyond Account deletion where required by law, to protect Knoesis's legal interests, or to maintain the integrity of historical debate records. In such cases, data is anonymised to the extent technically feasible so that it can no longer reasonably be attributed to you as an individual.

Moderation records are retained for extended periods to enable Knoesis to identify patterns of abusive behaviour across Accounts and time periods, comply with regulatory reporting obligations under the Online Safety Act 2023, and defend against legal claims arising from moderation decisions. This retention is proportionate to the purposes described and does not involve retention of substantive Content beyond what is necessary.

Under UK GDPR, you have the following rights in respect of your personal data processed by Knoesis. These rights are subject to applicable exemptions and limitations under UK law.

• Right of Access (Article 15): You have the right to request a copy of the personal data Knoesis holds about you and information about how it is processed. We will respond to access requests within one calendar month of receipt.
• Right to Rectification (Article 16): You have the right to request correction of inaccurate or incomplete personal data. You may update certain Account information directly via your Account settings.
• Right to Erasure (Article 17): You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, you have withdrawn consent (where consent was the lawful basis), or you object to processing and there is no overriding legitimate interest. This right is subject to exceptions including legal obligation and the exercise or defence of legal claims.
• Right to Restriction of Processing (Article 18): You have the right to request that Knoesis restricts processing of your data in certain circumstances, including where you contest the accuracy of the data or object to its processing pending determination of that objection.
• Right to Data Portability (Article 20): Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to Object (Article 21): You have the right to object to processing of your personal data carried out on the basis of Legitimate Interests. Knoesis will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defence of legal claims.
• Rights in Relation to Automated Decision-Making (Article 22): Where automated moderation systems take decisions that produce legal or similarly significant effects on you, you have the right to request human review of that decision by contacting legal@knoesis.co.uk.

To exercise any of your rights under UK GDPR, please submit a written request to legal@knoesis.co.uk with the subject line "Data Rights Request", clearly identifying the right you wish to exercise and providing sufficient information to verify your identity. Knoesis will respond within one calendar month of receipt of a valid request. Where a request is complex or numerous, we may extend this period by a further two months, in which case we will notify you within the first month.

The exercise of your data rights is free of charge. Knoesis may charge a reasonable administrative fee or refuse to act on requests that are manifestly unfounded or excessive, including repetitive requests. In such cases, Knoesis will notify you of the reason.

If you are dissatisfied with Knoesis's response to a data rights request or with any aspect of our data processing, you have the right to lodge a complaint with the Information Commissioner's Office ("ICO"), the UK's supervisory authority for data protection. The ICO can be contacted at ico.org.uk or by telephone on 0303 123 1113. Knoesis would welcome the opportunity to address your concerns directly before you contact the ICO.

FORUM displays advertisements served through the Google AdSense programme, operated by Google LLC. Advertisements are displayed to registered users as a means of supporting the provision of a free-to-access Service. Knoesis does not operate its own advertising targeting infrastructure and does not create individual user profiles for advertising purposes.

Google AdSense operates as an independent Data Controller in respect of data it collects through its advertising technology. When advertisements are displayed on the Platform, Google's advertising systems may collect and process your IP address and general geographic location, browser type and device characteristics, advertising identifiers, and interactions with advertisements. Knoesis does not have access to or control over this data as processed independently by Google.

To the extent that Knoesis influences the nature of advertising displayed on the Platform, it does so through contextual signals -- meaning advertisements are matched to the general subject matter of the Platform rather than to an individual profile of your personal characteristics or behaviour outside the Platform. Knoesis does not pass individually identified user data to Google AdSense for advertising targeting purposes.

Where the use of advertising cookies by Google AdSense requires your consent under PECR and UK GDPR, such consent will be obtained through Knoesis's cookie consent mechanism prior to the placement of non-essential cookies. You may withdraw advertising consent at any time via the Platform's cookie management tool or your browser settings without affecting your ability to use the core Service.

For full details of how Google processes data in connection with its advertising services, please refer to Google's Privacy Policy at policies.google.com/privacy. To opt out of Google's advertising personalisation, visit adssettings.google.com.

Knoesis does not sell your personal data to advertisers, share your name, email address, debate content, or reputation data with advertisers, allow advertisers to target individual users by name or Account identity, operate retargeting campaigns that track your behaviour across third-party websites, or allow sponsored content to be inserted into debate arguments or presented as User-Generated Content.

Cookies are small text files placed on your device when you access a website. The Platform uses cookies and similar technologies as described below.

• Strictly Necessary Cookies: Essential for the Platform to function. They include cookies that manage your authenticated session and maintain your Account login state via Firebase Authentication. These cookies do not require your consent as they are necessary for the provision of the Service you have requested.
• Functional Cookies: Enable the Platform to remember your preferences and settings, such as your community scope, notification preferences, and interface settings. These may require your consent where they are not strictly necessary.
• Analytics Cookies: Where used, these cookies collect information about how users interact with the Platform in aggregate. Analytics data is collected and processed in anonymised or aggregated form wherever possible.
• Advertising Cookies (Google AdSense): Placed by Google AdSense for the purpose of serving and measuring advertisements. These cookies are non-essential and are only placed with your prior consent obtained through Knoesis's cookie consent mechanism.

You can manage your cookie preferences at any time via the cookie management tool available on the Platform. You may also control cookies through your browser settings. Please note that blocking strictly necessary cookies may affect the functionality of the Platform and your ability to remain logged in.

Knoesis does not currently alter its data collection and use practices in response to Do Not Track signals from browsers, as there is no universally accepted standard for how such signals should be interpreted. Knoesis will review this position as industry standards and regulatory guidance develop.

Knoesis implements appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

• Use of Google Firebase's enterprise-grade security infrastructure, including encryption of data in transit (TLS) and at rest
• Firebase Authentication for secure credential management, eliminating the need for Knoesis to store raw passwords
• Access controls limiting internal access to personal data to those with a legitimate operational need
• Closed platform architecture requiring Account authentication before any Content is accessible
• Regular review of security practices and third-party service provider security standards

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, Knoesis will notify you without undue delay in accordance with Article 34 UK GDPR. All reportable breaches will be notified to the ICO within 72 hours of Knoesis becoming aware of the breach, in accordance with Article 33 UK GDPR.

Despite Knoesis's implementation of appropriate security measures, no transmission of data over the internet or electronic storage system can be guaranteed to be completely secure. Knoesis does not accept liability for security incidents that arise despite its implementation of reasonable security measures, or that result from factors outside its reasonable control including the compromise of your own device or credentials.

Google Firebase infrastructure is operated across multiple global regions. Data stored and processed through Firebase may be transferred to and stored in countries outside the United Kingdom and the European Economic Area, including the United States. Such transfers are conducted pursuant to the EU-US Data Privacy Framework, Standard Contractual Clauses adopted by the European Commission and recognised under UK adequacy regulations, or other transfer mechanisms providing equivalent protection as recognised by the ICO.

Google AdSense data processing is similarly subject to international transfer mechanisms as described in Google's privacy documentation. For details, please refer to Google's Privacy Policy.

You have the right to request information about the specific transfer mechanism used for transfers of your personal data to third countries. Please contact legal@dailyforum.co.uk for this information.

The Service is not directed at children under the age of 13. Knoesis does not knowingly collect personal data from children under 13. If Knoesis becomes aware that it has inadvertently collected personal data from a child under 13, it will take steps to delete such data promptly. If you believe that a child under 13 has created an Account on the Platform, please contact legal@dailyforum.co.uk.

Users between the ages of 13 and 17 may use the Service with the consent of a parent or legal guardian as required by our Terms of Service. Knoesis will apply additional care to the processing of personal data of users known or reasonably believed to be under 18, consistent with its obligations under the ICO's Age Appropriate Design Code as applicable to the Platform's functionality and scale.

Knoesis reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, the law, or our operational requirements. Material changes will be communicated to registered users by email or by prominent notice on the Platform no less than 14 days before the changes take effect.

Your continued use of the Service following notification of material changes constitutes your acknowledgement of the updated Privacy Policy. If you do not agree to the updated Policy, you must close your Account and cease using the Service.

The effective date and version number at the top of this Policy indicates the current version. Previous versions are available upon request at legal@knoesis.co.uk.

Knoesis Technologies Limited — Data Protection and Privacy
Email: legal@knoesis.co.uk  ·  Subject line: "Privacy Enquiry" or "Data Rights Request"
Platform: knoesis.co.uk

If you remain dissatisfied after contacting Knoesis, you may contact the Information Commissioner's Office:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113  ·  ico.org.uk