ONE TO A MILLION

1. Data Controller & Scope: This Privacy, GDPR & Behavioral Research Policy explains how Gunn R&D Ltd (a New Zealand limited liability company, "we", "us", or "our") collects, uses, and safeguards personal data and empirical telemetry across the One to a Million Digital Time Capsule Vault. Gunn R&D Ltd operates as the primary Data Controller in full compliance with the New Zealand Privacy Act 2020, the European Union / United Kingdom General Data Protection Regulation (EU/UK GDPR Regulation 2016/679), the ePrivacy Directive 2002/58/EC, and the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA).

2. Information We Collect & Legal Basis for Processing:
(a) Public Capsule Content (Contract Performance & Consent): When you purchase a capsule or arm an auto-sniper lock, you provide a public handle (@handle), a message, an optional hyperlink, and optional uploaded media (images or MP4 videos). This content is published publicly to the Vault Ledger and Throne upon moderation clearance.
(b) Private Billing & Order Data (Contractual Necessity & Anti-Fraud): We collect your buyer email address (buyer_email) and payment transaction identifiers. Credit card numbers, CVVs, and raw payment methods are processed and vaulted exclusively by Stripe, Inc. via Stripe Checkout and Setup Intents; Gunn R&D Ltd never touches or stores raw payment card numbers.
(c) First-Party Behavioral Psychology & Telemetry (Consent & Legitimate Research Interest): For academic, empirical study, and platform optimization purposes (e.g. decision latency, scroll gaze, price anchoring, local hour chronobiology), we collect edge geolocation (coarse country, city, region, timezone from Cloudflare headers), user agent device classification, funnel stages, dwell durations, and interaction counts. Telemetry data is never sold to third parties or data brokers.

3. Cookie Notice & Telemetry Consent Opt-Out ("Essential Only"): We respect visitor privacy and do not use invasive third-party ad tracking pixels. We use client-side local storage (otm_vid, otm_sid, otm_telemetry_consent) to maintain session continuity and behavioral research statistics. Visitors may select "Essential Only" at any time via the consent banner or modal, which deletes the visitor identifier from local storage and completely suppresses telemetry tracking pings to our servers.

4. GDPR Article 17 "Right to Erasure" & Buyer Anonymization: In accordance with GDPR Article 17, the NZ Privacy Act 2020 (Principle 7), and CCPA deletion rights, any buyer may request the erasure or anonymization of their personal email and telemetry records. Upon receiving an erasure request (or via administrative privacy tools), personal emails are permanently overwritten with redacted@privacy.invalid across both capsule ledger and sniper lock records, and telemetry session logs are unlinked or deleted without altering the permanent, sequential numbering of the Vault.

5. International Data Transfers & Cloud Providers: Data is processed using high-security globally distributed edge infrastructure provided by Cloudflare, Inc. (Cloudflare Workers, D1 SQLite, R2 object storage) and Stripe, Inc. (payments), adhering to standard contractual clauses (SCCs) and GDPR Article 46 transfer mechanisms.

6. Sanctions & Prohibited Jurisdictions: In compliance with the New Zealand Russia Sanctions Act 2022, United Nations sanctions resolutions, and OFAC regulations, transactions, uploads, and paid services are strictly barred to individuals or entities located in Cuba (CU), Iran (IR), North Korea (KP), Syria (SY), Russia (RU), Belarus (BY), and sanctioned regions of Ukraine (Crimea, Donetsk, Luhansk).

7. Contact & Privacy Inquiries: To exercise data rights (access, rectification, portability, or erasure), contact the Data Protection Officer at Gunn R&D Ltd via email: privacy@gunn-rd.co.nz or legal@gunn-rd.co.nz.