Your data,
your terms.

coup is a pre-incorporation startup project currently operated by its founding team as private individuals. We are developing a peer-to-peer community exchange application based in the Netherlands.

Until formal incorporation is completed, the data controller responsible for your personal data is:

• coup (operating name, pre-incorporation)
• Founding team: Tuan-Dai, Henry Buchhalla, Sinan Ceviker
• Based in: Groningen, the Netherlands
• Contact: tuandai.do@thecoup.nl

This Privacy Policy has been prepared in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and the Dutch implementation thereof (Uitvoeringswet AVG).

When you register for the coup waitlist, we collect only the following data:

• Email address - to send you a confirmation of your registration and to notify you when the coup app becomes available for download.

We do not collect your name, phone number, date of birth, payment information, or any other personal data at this stage. We do not collect any special categories of personal data as defined in Article 9 GDPR.

We use the data collected exclusively for the following purposes:

• To send you a confirmation email upon successful registration on the waitlist.
• To notify you by email when the coup app is available for download, including the link to download the app.
• To determine which cities have sufficient waitlist interest to prioritise our launch rollout (study location, used in aggregate only).

We will not use your data for any other purpose without obtaining your explicit consent. We will not send you marketing newsletters, promotional campaigns, or third-party communications.

The legal basis for processing your personal data is your freely given, specific, informed, and unambiguous consent pursuant to Article 6(1)(a) GDPR, which you provide by actively ticking the consent checkbox on our waitlist registration form.

You have the right to withdraw your consent at any time (see Section 7 below). Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

We do not sell, rent, or trade your personal data to any third party.

Your data may be processed by third-party service providers acting as data processors on our behalf, solely for the purposes described in Section 3. These currently include:

• Email delivery service providers used to send confirmation and launch notification emails. These providers are bound by data processing agreements (verwerkersovereenkomsten) and may not use your data for their own purposes.

We will update this policy if additional processors are engaged. We do not transfer your personal data to countries outside the European Economic Area (EEA). If this changes, we will ensure appropriate safeguards are in place pursuant to Chapter V GDPR before any transfer takes place.

We retain your personal data for the duration strictly necessary to fulfil the purposes described above:

• If the coup app launches: your email address and study location will be retained until we have sent you the launch notification email. After sending that email, we will delete your waitlist data unless you have separately consented to receive further communications within the app itself.
• If the coup project does not launch or is discontinued: we will delete all waitlist data within 30 days of that decision.
• If you withdraw your consent before launch: we will delete your data within 14 days of receiving your withdrawal request.

As a data subject under GDPR, you have the following rights, which you may exercise at any time by contacting us at the email address in Section 1:

• Right of access (Art. 15): request confirmation of whether we process your data and receive a copy of what we hold.
• Right to rectification (Art. 16): request correction of inaccurate data.
• Right to erasure (Art. 17): request deletion of your personal data ('right to be forgotten'). We will comply within 14 days unless a legal obligation requires retention.
• Right to restriction of processing (Art. 18): request that we limit the processing of your data in certain circumstances.
• Right to data portability (Art. 20): request your data in a structured, commonly used, machine-readable format.
• Right to withdraw consent (Art. 7(3)): withdraw your consent at any time by emailing tuandai.do@thecoup.nl with the subject "Unsubscribe - Waitlist". Withdrawal does not affect prior processing.
• Right to lodge a complaint (Art. 77): if you believe we are processing your data unlawfully, you may lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), autoriteitpersoonsgegevens.nl.

Our waitlist landing page uses only technically necessary cookies required for basic page functionality. We do not use tracking cookies, analytics cookies, advertising pixels, or any similar third-party tracking technologies on this page without your separate, explicit consent.

If we add any such technologies in the future, we will update this policy and present a cookie consent banner accordingly.

We take appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. This includes the use of industry-standard secure email infrastructure and limiting access to your data to the founding team members only.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Autoriteit Persoonsgegevens within 72 hours and inform you without undue delay where required by Article 34 GDPR.

Our waitlist is intended for persons aged 18 or older. We do not knowingly collect personal data from individuals under the age of 18. If you become aware that a person under 18 has registered, please contact us so we can delete the relevant data.

We may update this Privacy Policy from time to time. If we make material changes, we will notify registered waitlist members by email at least 14 days before the changes take effect. The date of the most recent version is always shown at the top of this document.

Your continued presence on the waitlist after the effective date of a revised policy constitutes acceptance of the updated terms. If you do not accept the changes, you may withdraw from the waitlist as described in Section 7.

For any questions, requests, or concerns relating to this Privacy Policy or the processing of your personal data, please contact:

• coup - Privacy Contact
• Email: tuandai.do@thecoup.nl
• Response time: within 3 business days

Given that coup is not yet incorporated as a legal entity, we are processing data as private individuals. Once formal incorporation as coup B.V. (or equivalent) is completed, this policy will be updated to reflect the legal entity as data controller.