Privacy Policy
1. Introduction
INTI ÑAN ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (theintinan.com) and use our services.
INTI ÑAN is operated by Inti Nan Holdings S.A., a corporation registered in the Republic of Panama.
This policy describes how we collect, use, and safeguard your information. Where our processing relies on a legal basis such as performance of a contract or our legitimate interests, that basis is identified in Section 4 below.
2. Information We Collect
Information You Provide
- Email address: Required to create your account and deliver your Karpay and other content
- Test responses: Your answers during the Karpay Initiation and other tests. These are processed only to determine which of our predetermined pathways you most closely match. They are not stored against you once your pathway has been assigned. See Data Retention below.
- Payment information: Processed securely by our payment processor; we do not store your payment card details
Information Collected Automatically
When you visit our website, we automatically collect:
- Device information: Browser type, operating system, device type
- Usage data: Pages visited, time spent, click patterns, scroll depth
- IP address: Used for analytics and security purposes
- Cookies and similar technologies: See our Cookie Policy for details
3. How We Use Your Information
We use your information to:
- Deliver your personalized Karpay reports and test results
- Create and manage your account
- Process payments for paid services
- Send transactional emails (account access, purchase confirmations, content delivery)
- Send educational content related to your pathway (you may opt out at any time)
- Analyze website performance and improve our services
- Protect against fraud and unauthorized access
- Comply with legal obligations
4. Legal Basis for Processing (GDPR)
If you are in the European Economic Area (EEA), we process your data under the following legal bases:
| Purpose | Legal Basis |
|---|---|
| Delivering services you requested | Performance of contract |
| Processing payments | Performance of contract |
| Sending transactional emails | Performance of contract |
| Sending educational content | Legitimate interest (with opt-out) |
| Analytics and improvement | Legitimate interest |
| Security and fraud prevention | Legitimate interest |
| Legal compliance | Legal obligation |
5. Information Sharing
We do not sell your personal information.
We share your information only with the following third-party service providers who assist in operating our services:
| Category of provider | Purpose | Data Shared |
|---|---|---|
| Database and authentication provider | Storing your account and serving your content | Email address, first name, test result, account data |
| Payment processor | Taking payment for paid services | Payment and billing information |
| Transactional email provider | Sending account, delivery and purchase emails | Email address, email content |
| Business email provider | Correspondence with you, on an end-to-end encrypted service | Email address, email content |
| Website analytics provider | Measuring how the site is used | Anonymized usage data, IP address |
| Website hosting provider | Serving the website | Server logs, IP addresses |
| AI processing provider | Pathway matching | test responses, transmitted only to determine which predetermined pathway you match. Not used to build an individual profile and not retained by us after matching. Under the commercial terms we hold with our provider, your responses are not used to train their models. The provider retains inputs and outputs on its own systems for a limited period, ordinarily 30 days or less, and may retain content for up to two years where it is investigating a suspected breach of its usage policy or where the law requires it. |
A current list of the named providers behind these categories is available on request from privacy@theintinan.com.
These providers are contractually obligated to protect your data and use it only for the purposes we specify.
We may also disclose your information if required by law or to protect our rights, safety, or property.
6. Data Storage and Security
Your data is stored on servers operated by:
- Our database and authentication provider: Cloud infrastructure (US-based servers)
- Our website hosting provider: US-based servers with a global content delivery network
We implement appropriate technical and organizational measures to protect your data, including encryption in transit (HTTPS) and at rest, secure authentication via magic links, and access controls.
However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.
7. Data Retention
We retain your personal data for as long as necessary to:
- Provide our services to you
- Comply with legal obligations
- Resolve disputes and enforce agreements
Test responses are not retained against you. They are processed only to determine your pathway and are discarded from your record once that pathway is assigned.
A copy of the answers and the resulting scores is kept in anonymous form to improve the accuracy of the test. That record holds no email address, no account identifier, no session identifier and no timestamp finer than the date. It cannot be linked back to you, and it is therefore not returned in an Access request and not affected by a Deletion request.
If you begin a test and do not finish it, your answers so far are held with your email address so you can return and continue where you left off. These incomplete tests are deleted automatically 31 days after you last worked on them, whether or not you come back.
What we retain about you, while your account remains active so you can continue to access your content, is: your email address; your first name, where you gave one; your test result, which is your pathway together with your Enneagram type and wing, your Soul Type and your three Healing rankings; the date you completed your test; a log of the transactional emails we have sent you; and your authentication record, which is what allows a magic link to sign you in.
Karpay and pathway content is standard material organized by pathway; it is not a personal record created about you.
Payment records are retained as required by tax and financial regulations.
You may request deletion of your data at any time (see Your Rights below).
8. Your Rights
All Users
- Access: Request a copy of your personal data
- Correction: Request correction of inaccurate data
- Deletion: Request deletion of your data
- Opt-out: Unsubscribe from educational emails at any time
EEA Residents (GDPR)
- Restriction: Request restriction of processing
- Portability: Receive your data in a portable format
- Object: Object to processing based on legitimate interest
- Withdraw consent: Where processing is based on consent
Canadian Residents (PIPEDA)
- Access: Request access to your personal information held by us
- Correction: Challenge the accuracy and completeness of your information
- Withdrawal of consent: Withdraw consent to collection or use of your personal information, subject to legal or contractual restrictions
- Complaint: You may file a complaint with the Office of the Privacy Commissioner of Canada if you believe we have handled your information improperly
California Residents (CCPA)
- Know: Request disclosure of data collected about you
- Delete: Request deletion of your data
- Non-discrimination: We will not discriminate against you for exercising your rights
We do not sell your personal information. California residents may submit a "Do Not Sell" request, though we have no personal information sales to cease.
To exercise any of these rights, contact us at: privacy@theintinan.com
We will respond within 30 days (or sooner as required by applicable law).
9. International Transfers
Your information may be transferred to and processed in countries other than your own, including the United States, where our service providers operate.
For transfers from the European Economic Area, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses and, where our providers are certified under the EU-US Data Privacy Framework, that framework.
For transfers from the United Kingdom, we rely on the UK International Data Transfer Agreement or the UK Addendum to the Standard Contractual Clauses.
10. Children's Privacy
Our services are not intended for anyone under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 18, we will delete it promptly.
11. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites. We encourage you to review their privacy policies before providing any personal information.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date. Your continued use of our services after changes are posted constitutes acceptance of the revised policy.
13. Contact Us
For questions about this Privacy Policy or to exercise your rights, contact us at:
Privacy inquiries: privacy@theintinan.com
General support: support@theintinan.com
Website: theintinan.com
Registered Office:
Inti Nan Holdings S.A.
c/o NDM Law
Oceania Business Plaza, Torre 2000, 37th Fl, Office C
Panama City, Republic of Panama