Privacy Policy
This policy describes what Pioneer Point does with personal information. It is short because the site does very little: it has no forms, sets no cookies and makes no external requests. Everything below describes something that actually happens.
1. Who is responsible for your information
The entity responsible for the personal information described in this policy is:
Kalos investing s.r.o.
Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic
Company number: 10807888
VAT: CZ10807888
Email: info@pioneerpoint.online
Kalos investing s.r.o. publishes the website at pioneerpoint.online under the name Pioneer Point. This policy is written with reference to the Privacy Act 1988 (Cth) and the Australian Privacy Principles, because the site is written for readers in Australia. Section 11 covers the position under European and United Kingdom data protection law, which also applies because the publisher is established in the Czech Republic.
2. What is collected
Three categories exist, and there is no fourth.
2.1 Nothing is collected through the website itself
There is no contact form, no newsletter sign-up, no account, no comment facility, no quiz, no chat widget and no input field of any kind anywhere on this site. The site sets no cookies of its own and permits no third party to set one through it. It uses no localStorage, no sessionStorage, no IndexedDB and no browser fingerprinting. It loads no analytics, no advertising tag, no conversion pixel and no third-party script, and it requests no external resource of any kind—not even a web font. Reading this site therefore involves your browser communicating with the hosting provider and with nobody else.
2.2 Server logs kept by the hosting provider
Like any website, this one is delivered by a hosting provider whose servers record ordinary technical logs for each request. Those logs contain the IP address the request came from, the browser user agent string, the URL requested, the response status and the date and time. Kalos investing s.r.o. does not use these logs to build any profile of a reader and does not attempt to identify anyone from them.
2.3 What you put in an email
If you write to info@pioneerpoint.online, we hold your email address, your name if you give it, and whatever else you choose to include. Nothing on this site asks you to send personal information, and a correction report needs none.
3. Why each category is held, and on what basis
| Category | Purpose | Basis |
|---|---|---|
| Server logs | Keeping the site available, diagnosing faults, and identifying abusive traffic such as automated attacks | Necessary for the legitimate interest of operating a website securely. No consent is sought because no cookie or similar technology is used. |
| Email correspondence | Reading and answering your message, and acting on corrections | You provided it voluntarily for that purpose. |
Neither category is used for marketing. There is no mailing list, and no information from either category is sold, rented or shared with advertisers, affiliate networks or game publishers.
4. How long information is kept
- Server logs: retained for up to 30 days in the ordinary course, and longer only where a specific log is needed to investigate a security incident, in which case it is kept until that investigation is closed and then deleted.
- Email correspondence: retained while the matter is live and then for up to 12 months, after which the message is deleted from the mailbox. Where an email relates to a correction that changed a page, a note of the change may be kept without the sender's personal details.
5. Who information is disclosed to, and cross-border disclosure
The only third party involved in the operation of this site is the hosting provider that serves the pages and, in doing so, creates the server logs described above. No analytics provider, advertising network, content delivery network, font provider, social platform or affiliate network receives any information about your visit from this site, because none of them is contacted by it.
Disclosure outside Australia. Kalos investing s.r.o. is established in the Czech Republic, and the servers that deliver this site and hold the mailbox are located outside Australia, in the European Union. Reading this site or emailing the address above therefore involves your information being handled by recipients outside Australia. This is disclosed here as required by Australian Privacy Principle 8. Recipients in the European Union are subject to the General Data Protection Regulation, which provides a legal framework broadly comparable in effect to the Australian Privacy Principles.
Information may also be disclosed where the law requires it, for example in response to a lawful request from a court or a regulator.
6. Security
The site is served over HTTPS, so the connection between your browser and the server is encrypted. Access to the mailbox and to the hosting account is limited to the people at Kalos investing s.r.o. who need it, and those accounts are protected by unique passwords and multi-factor authentication. Because the site collects nothing, there is no database of reader information to protect, which is the most effective security measure available.
No transmission over the internet can be guaranteed to be completely secure, and this policy does not claim otherwise.
7. Your rights, and how to exercise them
Under the Australian Privacy Principles you may ask for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete or misleading. In practice the only information we are likely to hold is an email you sent us.
Write to info@pioneerpoint.online. We will respond within 30 days. There is no charge for making a request. If we refuse a request, we will explain why in writing.
If you are not satisfied with how we have handled a privacy matter, you may complain to the Office of the Australian Information Commissioner, which oversees privacy law in Australia and accepts complaints from the public. The OAIC will normally expect you to have raised the matter with us first.
8. Data breaches
If a data breach occurs that is likely to result in serious harm to any individual whose information we hold, Kalos investing s.r.o. will assess it promptly and, where the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth) applies, notify the affected individuals and the Office of the Australian Information Commissioner as that scheme requires.
9. Children
This site is not directed at people under 16 years of age. It collects no information from anyone, including children, and it has no account system, no form and no mechanism through which a young person could submit personal information. Parents and carers looking for guidance on young people and online games may find the material published by the eSafety Commissioner useful.
10. Changes to this policy
If this policy changes, the revised version is published on this page with a new effective date at the top. Material changes—for example, if the site ever began to collect information, use cookies or load a third-party script—would be described in a short note at the top of this page, and the change to the site would not be made before this policy and any required consent mechanism were in place.
11. European and United Kingdom data protection
Because Kalos investing s.r.o. is established in the Czech Republic, the General Data Protection Regulation applies to its processing, and the United Kingdom GDPR applies to readers in the United Kingdom.
The legal basis relied upon for server logs is legitimate interests under Article 6(1)(f): operating a website securely and diagnosing faults. There is no consent basis in use anywhere on this site, because the site sets no cookies and uses no similar technology, so there is nothing for which consent could be sought. Email correspondence is processed on the basis that you sent it for the purpose of being answered.
Where the GDPR applies, you have the rights of access, rectification, erasure, restriction of processing, data portability and objection to processing based on legitimate interests, and the right to lodge a complaint with a supervisory authority. In the Czech Republic that authority is the Úřad pro ochranu osobních údajů (Office for Personal Data Protection). Requests are made to info@pioneerpoint.online and answered within one month.