Privacy Policy

This privacy policy ("Privacy Policy") governs how ITANU STUDIOS LTD ("ITANU Studios", the "Company", "we", "our" or "us") use, collect and store Personal Data we collect or receive from or about you ("you") in connection with KolHive via https://kolhive.com/ (the "Websites") or through our KolHive applications, extensions and plug-ins for supported mobile, desktop and web platforms (together, the "App"), or through our APIs and supported integrations (the Websites, the App, APIs and integrations collectively, "KolHive"), such as in the following use cases:

• (i) When you browse or visit our Website;
• (ii) When you make use of, or interact with, KolHive:
  • When you create an account and when you log in
  • When you contact us (e.g. customer support, need help, submit a request)
  • When you subscribe to our distribution list(s) / newsletter(s) / blog(s) / social community(s)
  • When you buy a plan, storage or AI credits
  • When you connect another service, such as your Google account
• (iii) When we process your Input (As defined in our Terms of Use) to create Output (As defined in our Terms of Use):
  • When you generate text, videos or pictures
  • When you interact with language model
  • When you record, upload, transcribe or share content
• (iv) When you interact with us on our social media profiles.

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. "Personal Data" or "Personal Information" means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Some provisions of this Privacy Policy apply only where the relevant law applies to you or to our processing of your Personal Data. Nothing in this Privacy Policy limits rights or remedies provided by applicable law.

In short:

• We use your Personal Data to provide KolHive to you, to keep it secure, and as described below. We do not sell your Personal Data, we do not share it for advertising, and KolHive does not show ads.
• When you use a cloud AI feature, the content needed for that request is sent to our processing infrastructure and contracted cloud-computing and AI-processing service providers. The service terms for our managed AI processing restrict use of your content for model training without our permission, and we have not given that permission.
• We do not use your content to train AI models.
• You can delete your chats, files and account at any time. Records of your AI requests on our servers are deleted 30 days after each request, or sooner when you delete the chat.

Shared ITANU account: KolHive OS and KolWrite (available at https://kolwrite.com/) are products of the Company and use a single shared ITANU account. Personal Data associated with your account — such as your profile details, files, transcripts, preferences, and settings — may be synchronized between the two products so that your account works seamlessly across them. Such data remains within the Company's systems and is processed under this Privacy Policy and the KolWrite Privacy Policy (https://kolwrite.com/tos_pp.html#privacy). Deleting your account applies to the shared account and to both products.

Table of Contents:

1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your Personal Data
3. How we share your Personal Data
4. Additional information regarding transfers of Personal Data
5. Your privacy rights
6. Children and teens
7. Interaction with third-party products
8. Analytic tools
9. Specific provisions applicable under California privacy law
10. Contact us

This Privacy Policy can be updated from time to time. If we make significant changes to how we use your Personal Data, we will tell you through KolHive or by email before the changes apply to you, and we will ask for your consent where the law requires it. KolHive is owned and operated by the Company, an Israeli company, which is the data controller. You can contact us about privacy at [email protected].

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

You are not required by law to give us Personal Data. Some features cannot work without it; each section below says what happens if you do not provide it.

When you browse or visit our Website

Data we collect: Technical information that your browser sends when it loads our pages, such as your IP address, browser type and the pages you request, and the language, theme and accessibility choices you make, which are stored in your browser.

Purpose:

• To deliver the Website and keep it secure
• To remember your choices
• To administer the Website and fix faults

Third parties we share with: Contracted website-hosting, content-delivery and security service providers, including bot-prevention services that check sign-up forms. These services operate internationally as described in section 4.

Consequences of not providing: If your browser does not store your choices, the Website will not remember them.

When you create an account and log in

Data we collect:

• Email address
• Name, if you provide it or your sign-in provider shares it
• Password, which is handled by our contracted authentication service and is not stored on our servers
• If you sign in with Google or Apple: the name, email address and profile picture that the provider shares with us
• Preferred Language
• IP address, device type, app version and sign-in times
• Your age band (under 13, 13–15, 16–17 or 18 and over) with its source and the date it was reported, if your device or app store provides it; never your birth date or exact age
• Your acceptance of our Terms of Use and this Privacy Policy, and your privacy choices

Purpose:

• To be able to create an account
• To be able to log in, on each of your devices
• To be able to enjoy features available to registered users only
• To protect your account and detect misuse
• To make the features available on your account appropriate for your age
• To keep a record of what you agreed to

Third parties we share with: Our contracted authentication service, which handles sign-in, passwords and email verification, and Google or Apple if you choose to sign in with them.

Consequences of not providing: Cannot create an account, cannot log in, cannot enjoy all the features of KolHive.

When you contact us for support

Data we collect:

• Full name
• Email address
• Message, and any attachments you choose to add
• Username (on the social media platform from which you reached out to us)
• If you report an AI answer: the identifiers of the conversation and the message, and the name of the AI model

Purpose:

• To process and answer questions
• To provide support (e.g., to solve problems, bugs or issues)
• To investigate AI answers you report. To do this, our support team may view the reported conversation.

Third parties we share with: Our contracted business-email service provider, and the social-media or other platforms you choose to contact us on.

Consequences of not providing: Cannot process and answer questions, cannot provide support.

When you subscribe to our communications or join our waitlist

Data we collect:

• Email address
• Preferred Language
• Where you signed up, and a record of your consent, your confirmation and any unsubscribe request

Purpose:

• To add you to our mailing list or waitlist
• To send you the updates and marketing communications you asked for
• To keep proof of your consent

Third parties we share with: Contracted email-delivery and bot-prevention service providers, which deliver our emails and check that the sign-up is not made by a bot. These services operate internationally as described in section 4.

Consequences of not providing: Cannot send you marketing communications or launch updates.

When you buy a plan, storage or AI credits

Data we collect:

• Billing contact name and email address
• Country, and billing address, company name and tax identification number where you provide them
• The plan, storage or credits you buy, the price, currency and tax
• Payment-provider, transaction, refund and tax-document identifiers

Purpose:

• To determine available billing options and calculate applicable taxes
• To process, reconcile, refund, and support purchases
• To grant or remove the plan, storage or credits associated with a payment
• To create required accounting and tax records and prevent fraud

Third parties we share with: PayPal for purchases made on our Websites or apps, Apple and Google Play for purchases made through their stores, and accounting and tax advisers where required by law. Your full payment-card details are handled by the payment provider and are not stored on our servers.

Consequences of not providing: We may be unable to process the purchase or refund, calculate taxes, or issue a required tax document.

When you create, record, upload, attach, share or submit content for processing through KolHive

Data we collect:

• Input (as defined in our Terms of Use)
• Audio
• Video
• Images
• Prompts, chat messages, instructions, and workspace context
• Files, documents, app specifications, workflow instructions, generated artifacts, and code
• Language, model and settings choices, and technical request information
• Account Information
• Other information you provide

How we collect it: When you record, upload or attach content, enter text, select content for processing, or otherwise ask KolHive to process your content. We collect technical request information automatically when a feature is used.

Purpose:

• To process your request and return the result
• To store your content and keep it in sync across your devices
• To operate, maintain, secure, troubleshoot, and support KolHive
• To measure your use of AI credits and storage
• To prevent misuse and comply with legal obligations
• To improve KolHive using information about how it is used, such as usage counts and error reports

Third parties we share with: Your content is stored on our servers, hosted by a contracted infrastructure provider in Germany, and with contracted file-storage service providers operating internationally. Processing that needs specialised hardware, such as speech recognition, speaker separation and video rendering, runs on GPU computers we operate ourselves in Israel or on contracted cloud GPU servers in other countries, using models we operate. AI features send the content needed for each request to the cloud-computing and AI-processing service providers described in "How AI features use your content" below. The processing locations are described in section 4. When you share content, the people you share it with receive it.

Consequences of not providing: Cannot provide you with the Outputs, generated artifacts, app-building features, or workspace functionality.

When you play online with other people in KolHive apps

Data we collect:

• Your display name (or the name you choose in the app) and a game-specific player ID
• Presence details the app shares, such as whether you are in a game
• Game messages and shared game state sent by the apps in the room
• Invite codes (stored only in a one-way scrambled form) and which rooms you may rejoin
• IP address and network connection information
• If you turn on voice chat or video in an app: your voice while you hold the talk button, and your camera picture while video is on

Purpose:

• To let you play and work together with other people in real time
• To deliver game messages and keep a game's shared state so players can continue later
• To keep online play secure and to prevent abuse

Third parties we share with: Other players in the same game see your display name, your game-specific player ID and what the app shares in the game. When "Direct connections in multiplayer games" is on (the default), your device may connect directly to other players' devices for faster play; those players can then see your device's IP address, and public network-connection service providers see it while the connection is set up. You can turn direct connections off in Settings; games then run only through our servers.

Voice chat and video: Voice chat and video are off until you turn them on in an app. Your voice (only while you hold the talk button) and your camera picture (only while video is on) go directly from your device to the devices of the players the app lets you talk with (for example, your party), encrypted in transit. They do not pass through KolHive's servers, and KolHive does not record or store them. Other players in the same game do not receive them. If your device cannot connect directly to another player's device, voice chat and video with that player are not available. You can mute or block a player at any time and turn voice chat or video off in the app; your device's microphone and camera permissions stay under your control in your device or browser settings.

Voice commands in apps: Some apps you use in KolHive, such as games, let you control them by speaking. When you turn this on, your speech is recognized on your device by KolHive's built-in speech engine; the audio is not recorded, stored or sent to us or to other players, and only the resulting command (for example, the word you said) is used by the app. You can turn it off at any time in the app's settings, and your device's microphone permission stays under your control.

Retention: Game messages are passed on and not stored. Shared game state is kept for up to 7 days after its last change (24 hours for public games); invite codes expire, and permission to rejoin a friend's game lasts 30 days. Voice and video are not stored.

Consequences of not providing: Cannot play online with other people. Turning off direct connections keeps online play available through our servers.

How AI features use your content

The KolHive assistant and other AI features are AI systems, not people. AI can make mistakes, so check important information.

What is sent and when: When you use a cloud AI feature, KolHive sends the content needed for that request, such as your message, the relevant part of the conversation, files or extracts you attach or select, the workspace context the feature needs, and technical request information, to the provider that runs the AI model. It is sent only when you use the feature. Features that run on your device, such as on-device transcription, do not send your content to these providers.

Who processes it:

• Our processing infrastructure and contracted cloud-computing and AI-processing service providers run the models used for chat, transcription, summaries, translation, image generation, search within your content, and voice features.
• Max uses advanced AI models, which may hand parts of a task to other models, on contracted cloud-computing infrastructure. Max is not available in every country.
• Where a feature is configured to use a direct cloud AI API, the necessary request content is sent to that contracted AI-processing service provider.

No training on your content: We do not use your content to train AI models. Our managed cloud AI service terms restrict providers from using content to train or fine-tune AI models without our permission, or, for paid API processing, from using prompts or responses to improve their products. We have not given permission or opted into provider training.

What providers keep: These providers may keep content for a short time to run the service, including caches that speed up answers (up to 24 hours for a managed cloud AI cache), and logs to detect abuse of their services (up to 30 days for a direct cloud AI API), as their terms allow. We have not turned on optional logging of requests and answers in our managed cloud AI projects.

"Help improve KolWrite and KolHive": This setting, under Settings, Security, lets you tell us whether we may use your conversations to improve our products. We do not use conversations for this today. If we start, we will update this Privacy Policy first and will use only the conversations of people who have this setting on.

Providers you choose: If you connect your own AI provider account or API key, or use a local or command-line AI tool, the content needed for that request is sent from your device to that provider or tool, under your own agreement with it. A tool running on your device may itself communicate with external services.

AI apps you connect: If you connect another AI app on your device to KolHive, that app can read and act on your KolHive content within the access you choose in Settings, and it sends what it reads to its own provider under your agreement with that provider. We do not control those apps or providers. You can remove an app's access at any time in Settings.

When you connect your Google account

Data we collect: Depending on what you connect: your tasks, the Google Drive files you pick, and permission to send emails from your Gmail account when you ask KolHive to send one. KolHive cannot read your Gmail messages. Google Calendar is described under "Google Calendar" below. We also receive the name and email address of the connected Google account and an authorization, which we store encrypted.

Purpose: To show and manage your tasks and files in KolHive and to send the emails you ask it to send. If you let the assistant use your other Google data, such as tasks or files, the details it needs are sent to the AI providers described above to answer your request. You can turn the assistant's Google access off, or have it ask you first, under AI access in the AI settings.

Google API data: KolHive's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. We do not use data from Google APIs for advertising, and we do not use it to develop, improve or train generalized AI or machine learning models.

Third parties we share with: Google, and the AI providers described above if you let the assistant use your other Google data.

Consequences of not providing: Calendar, tasks, Drive and email features that depend on your Google account will not work. You can disconnect your Google account at any time in settings; because the account is shared, this affects both KolHive and KolWrite.

Approximate location, language and weather

We do not collect your device's precise location. To choose your language and show local weather, the App may look up your approximate location (country or city) from your IP address through public IP-geolocation services, and fetch weather forecasts for that approximate location from public weather-forecast services.

Web search and web pages

When the assistant searches the web or reads a web page for you, the search terms or the page address are sent to public search engines and websites. In the mobile and desktop apps this happens directly from your device. In the web app it goes through our servers, so those services see our servers rather than your device.

Error reports and performance data

Unless you turn this off, the App automatically sends error reports to our servers. They contain error messages, with personal details removed where we can detect them, and technical details such as app version and device type, and they are linked to your account. We use them to find and fix problems. For every upload or download that fails, and for a small share of those that finish (at most one in ten), the App also sends performance data: whether it was an upload or a download, what kind of transfer it was, its size, how long it took, how many tries it needed and which route it took. We add the country your request comes from. This data never includes file names, links or the content of your files. We use it to find where transfers are slow and to make them faster. We keep each record, linked to your account, for 7 days; after that only anonymous daily totals remain. You can turn all of this off under Settings, Help, Diagnostics.

Sharing and publishing

When you share files, apps or workspaces, publish an app in the KOL Store, or create a public link, the people you share with, or anyone with the link, can see what you shared and the name shown with it. Playing and working with other people in real time, including voice chat and video, is described under "When you play online with other people in KolHive apps" above.

Notifications

If you allow notifications, we deliver them through the push-notification service providers for your device platform, using an identifier for your device.

When you interact with us on social media

Data we collect:

• Social Media Account
• Content of interaction (text, images, etc.), including metadata (for example, timestamp)

Purpose:

• To process and answer questions
• To provide support
• To review our services
• To process your feedback

Third parties we share with: The 3rd party social media platforms may have access to the data communicated.

Consequences of not providing: Cannot contact with you on social media.

Google Calendar

If you choose to connect Google Calendar, we ask Google for permission to view your calendar list and calendar properties and to view, create, update, and delete calendar events. Calendar event data can include an event title, description, date and time, location, meeting link, reminders, attendees, and calendar identifiers. We use this access only to show, sync, and perform the Google Calendar actions you request in KolWrite or KolHive. We may cache Calendar data on your device or in your KolWrite or KolHive account as needed to provide those features.

If you ask an AI feature to use Calendar information, and the applicable Calendar AI permission is enabled, relevant event content may be sent to the AI provider selected for that feature to complete your request. We do not use Google user data for advertising.

We store the Google account identity information needed to identify the connection, the permissions Google granted, and an encrypted Google refresh token. You can disconnect Google from the Integrations settings. Disconnecting removes the stored token and asks Google to revoke it. Events already created in Google Calendar, and content previously imported into or created in the product, remain until you delete them from the place where they are stored.

When you turn on speaker recognition

Data we collect:

• Voice signatures: numbers calculated from short samples of a speaker's voice in your recordings
• Face signatures: numbers calculated from a speaker's face in frames of your video recordings
• The names and pictures you give to the speakers you save
• Which speakers in your recordings match the speakers you saved

How we collect it: Speaker recognition is off until you turn it on. When it is on, the KolHive app calculates the signatures on your device and compares the speakers in your recordings only with the speakers you saved. A signature is kept only for a person you name or save. You can name speakers yourself without turning speaker recognition on.

Purpose:

• To show who is speaking in your recordings and suggest names and pictures for them
• To keep the speakers you saved available on all your devices

We do not use voice or face signatures for any other purpose. We do not use them to train AI models, for advertising, or to recognize people for anyone else. Please save only people who agree to be recognized. Some places treat voice and face signatures as biometric data and require the person's consent; you are responsible for obtaining that consent before you save someone.

Third parties we share with: Signatures are stored encrypted on our servers and are never sent to AI providers. If you also use names with AI, KolHive sends a few frames from the video and short parts of its transcript to the contracted AI-processing service provider for the selected model to find names that are said or shown, for example when someone introduces themselves or a name appears on screen. The AI provider is not asked to recognize anyone's face. This uses your AI credits.

Consequences of not providing: Speakers are not recognized automatically. You can still name them yourself.

When you use KolChat messages and calls

KolChat messages, voice messages, photos, videos, files and reactions in private and group chats are encrypted on the sender's device so our messaging server cannot read their content during ordinary delivery. Public channel posts are different: we can read their text and access attached media, and other KolChat users can view them while the channel is available. Calls are described below. Messages you choose to include in a report, and content you choose to send for cloud AI or cloud transcription, are handled as described elsewhere in this policy.

Data we collect:

• Your KolChat profile: display name, "about" text, profile photo and your privacy choices
• Your phone number, if you add it
• The KolChat accounts you save as contacts, so we can apply your "my contacts" privacy choices
• Information about your devices that is needed to deliver messages: device identifiers, platform, public encryption keys and push-notification tokens
• Delivery information: which account or device sent an encrypted message to which account or device, when, and its size; the members, roles, names, descriptions and photos of groups; the names, descriptions and photos of communities; who joined a call or meeting and when; when you are online and when you were last seen
• The channels you create, administer or follow; their names, descriptions and photos; channel posts and attached media, their authors, reactions and posting times. We can read post text and access attached media; other KolChat users can view them while the channel is available.
• Encrypted messages and encrypted files while they wait to be delivered
• If you join a meeting as a guest without an account: the name you type and your IP address
• Accounts you block, and reports you send, including any messages you choose to add to a report

How we collect it: From you and your devices when you use KolChat. Adding a phone number is optional; we confirm it with a code sent by text message through our contracted authentication service. If you let KolChat find your contacts, your device sends us only the first 5 characters of a coded (hashed) version of each phone number in your address book and finds the matches itself; your address book is not uploaded or stored by us.

Purpose:

• To deliver your messages, files and calls to the right people and devices
• To store and show channel posts and their media to KolChat users, and operate channels and communities.
• To let people who have your phone number, email address or invite link find you, according to your settings
• To notify you about new messages and incoming calls
• To show your profile, online status and last seen according to your privacy choices
• To prevent spam and abuse and to keep accounts secure

Third parties we share with: Notifications are delivered through the push-notification service providers for your device platform; the message preview inside a notification is encrypted for your device, and these services do not receive the content. Incoming calls use your device's calling features (Apple CallKit or Android's calling service), so KolChat calls appear in your device's list of recent calls; on Apple devices that list may sync through your iCloud account according to your Apple settings. Calls connect directly between participants' devices when possible, which lets those devices see each other's IP addresses. In group calls, a participant's device may forward media to others. When participant devices cannot carry a meeting, a media-forwarding server may forward frames encrypted on participants' devices; a device without frame encryption cannot use that route. If a network blocks a direct connection, a network relay may carry the encrypted call connection. If someone transcribes a call or meeting, everyone in it sees a notice. When the person you send a file to is online, the encrypted file may go directly from your device to theirs, which lets both devices see each other's IP address; otherwise encrypted files are stored with our contracted file-storage service provider. Public channel media is stored with our file-storage service and can be viewed by KolChat users while the channel is available. If you ask us to email a meeting invitation, our email provider sends it, and the email contains the meeting link. Anyone who has a meeting link (and its password, if you set one) can join that meeting.

Voice message transcripts: When you tap Transcribe on a voice message, your device decrypts it and sends the audio to our contracted cloud AI-processing service provider to create the text, as described in the third-party AI consent. The text is then sent, end-to-end encrypted, to everyone in that chat. This uses the AI credits of the person who taps Transcribe. Please transcribe other people's voice messages only where they would agree to it.

Consequences of not providing: You cannot use KolChat without an account. Without a phone number, people can still find you by email address, shared spaces, QR code or invite link.

Additional Uses: Some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may anonymize or de-identify your Personal Data, so that it no longer identifies you, and further use it for internal purposes, including, without limitation, to improve the services and for research purposes.

"Anonymous Information" means information which does not enable identification of an individual user, such as aggregated information about the use of our services.

Legal bases (European Economic Area and United Kingdom): Where the GDPR or the UK GDPR applies, we process your Personal Data because it is necessary to provide KolHive under our Terms of Use (account, content, AI features you request, sync, purchases and support); because of our legitimate interests in keeping KolHive secure, preventing misuse, fixing errors and understanding how KolHive is used (you can object to this); because the law requires it (tax, accounting and legal requests); or with your consent (marketing emails, notifications, and other optional features that ask for it). You can withdraw consent at any time; this does not affect processing that has already taken place. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

2.1. Security

We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data, including:

• KolHive connects to our servers over encrypted connections (HTTPS/TLS).
• Files you store are kept in contracted cloud file storage that encrypts stored files with AES-256. Connected Google account authorizations and synced voice signatures are also encrypted in our database.
• Your password is handled by our contracted authentication service, and full payment-card details by PayPal, Apple or Google. Neither is stored on our servers.
• You can lock the App on your device with your device's biometrics or a code.

However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information. If a security incident affects your Personal Data, we will notify you and the authorities where the law requires it.

2.2. Retention of your Personal Data

We keep Personal Data only as long as we need it for the purposes in this Privacy Policy:

• Account information: while your account exists.
• Your content (files, recordings, transcripts, documents and apps): until you delete it or your account, except for KolChat content described below.
• Chats with the assistant: until you delete the chat or your account. When you delete a chat, the text of its messages is erased from our servers, normally at once (if that fails, a later automatic run erases it, normally within six hours), and its attachments are scheduled for deletion. We keep only technical details, such as message identifiers, times, the model used and token counts.
• Records of AI requests (the answers our servers streamed to the App and the technical records needed to continue a conversation and settle its cost): deleted 30 days after the request ends. When you delete a chat, the records of its finished requests are deleted at the same time.
• Usage records (which model was used, token counts and credits, without the content of your requests): while your account exists.
• Purchase records: for as long as tax and accounting laws require, including after you delete your account.
• Error reports and technical logs: 7 to 90 days, depending on how serious the error is.
• Upload and download performance records: 7 days, then only anonymous daily totals are kept.
• Voice and face signatures of a saved speaker: Voice and face signatures of a saved speaker are kept until you delete that speaker or their saved voice or face, or delete your account. Turning speaker recognition off stops new recognition but does not delete signatures you saved.
• KolChat: Private and group chat messages and files are kept on your devices until you or a disappearing-messages timer delete them. On our servers, encrypted messages are deleted as soon as all recipient devices receive them, and at the latest after 30 days; encrypted files are deleted 30 days after they are sent, and profile and group photos when they are replaced or deleted. Channel posts stop appearing in channel feeds after 30 days; their stored records and attached media are then removed through cleanup. Call and meeting records are deleted 30 days after the call or meeting ends, and reports are kept for up to 12 months. Your phone number is kept until you remove it or delete your account.
• Age band: until a newer band from the same source replaces it or you delete your account; a band older than one year is no longer used.
• Support requests: as long as needed to handle your request and keep a record of it.
• Mailing list and waitlist: until you unsubscribe. We keep a record of your consent and unsubscription.
• Records of your acceptance of our Terms of Use and this Privacy Policy: also after you delete your account, as long as we may need them to show what was agreed.

Deleted data may remain in backup copies until those copies are replaced or deleted. In some circumstances we may store your Personal Data for longer periods of time, for example:

• (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements
• (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges
• (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings

3. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

• 3.1. With service providers that process Personal Data on our behalf, such as the hosting, storage, authentication, AI, email, network-relay, notification, security, analytics and payment service providers described in this Privacy Policy. We require them to use it only to provide their services to us and to protect it with the same or equal level of protection as described in this Privacy Policy and required by applicable law. We may also share Personal Data with our affiliated companies on the same terms.
• 3.2. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order.
• 3.3. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events.
• 3.4. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events.
• 3.5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality), or where you ask us to, for example by sharing content with other people.

We do not sell your Personal Data, and we do not share it with third parties for their own advertising or marketing.

3.6. If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to [email protected].

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

4.1. We are based in Israel. We and our service providers store and process Personal Data in several countries. Our main servers are in Germany, and the GPU computers we operate ourselves are in Israel. Contracted cloud-storage and content-delivery providers store files and deliver our Websites through global networks. Our managed cloud AI processing uses a global endpoint, which can route a request to any region where capacity is available. Contracted cloud GPU servers may be located in different countries. Some of our hosting, storage, authentication, AI, email, network-connection, notification, security and analytics service providers are based in the United States and process data internationally. You may request the current recipients of your Personal Data and information about their processing locations under section 3.6.

4.2. The European Commission recognizes Israel as providing an adequate level of protection for personal data. When Personal Data from the European Economic Area, the United Kingdom or Switzerland is transferred to a country that does not have such recognition, we rely on safeguards provided by law, such as the European Commission's Standard Contractual Clauses included in our providers' data processing terms, or a provider's certification under the EU-U.S. Data Privacy Framework. You can ask us about these safeguards at [email protected].

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

5.1. Rights

5.1.1. Depending on the law that applies to you, you have some or all of the following rights:

• a. You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
• b. You have the right to request that we rectify or erase any Personal Data we hold that is inaccurate or misleading.
• c. You have the right to ask us to delete your Personal Data, to restrict how we use it, or to object to our use of it, including for direct marketing.
• d. You have the right to receive Personal Data you gave us in a portable format.
• e. Where we rely on your consent, you have the right to withdraw it at any time.
• f. You have the right to complain to a data protection authority, such as the Privacy Protection Authority in Israel or the authority where you live or work in the European Economic Area or the United Kingdom.

5.2. You can exercise your rights by contacting us at [email protected]. You can also view, change and delete much of your Personal Data yourself in the App. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law, and in any case within one month unless the law allows a longer period, or inform you if we require further information in order to fulfil your request.

When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

5.3. Deleting your account: You can delete your account in the App under Settings, Security, Delete account, or by emailing [email protected] from the email address of your account. Deleting your account deletes the shared account for both KolHive and KolWrite, including your recordings, transcripts, files, chats, AI data and settings stored in the cloud, and signs you out on every device. We keep only the records described in section 2.2 that the law requires or that we need to show what was agreed and what was paid. Copies that other people saved, and content in spaces that belong to other people, are not deleted from their accounts. Deleting your account does not cancel a subscription you bought through Apple or Google Play; cancel it in the settings of your store account.

5.4. Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to [email protected]. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

6. CHILDREN AND TEENS

KolHive is not intended for children under thirteen (13) years old, or under the higher minimum age that applies where they live, and we do not knowingly collect Personal Data from them. If we learn that we have collected Personal Data from such a child without the consent the law requires, we will delete it and may close the account. A parent or guardian who believes this has happened can contact us at the address in the "Contact us" section. People aged 13 to 17 may use KolHive with the permission of a parent or legal guardian.

Age range from your device. On Apple devices the app may ask Apple's Declared Age Range, and on Android devices installed from Google Play it may ask Google Play Age Signals, for your age range. The platform shows its own prompt, and you or your guardian can decline. We receive and store only an age band (under 13, 13–15, 16–17 or 18 and over), its source and when it was reported — never your birth date or exact age. We use it only to make the features available on your account appropriate for your age and to meet our legal obligations. We do not share it, and we keep it until a newer band from the same source replaces it or you delete your account; a band older than one year is no longer used.

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us, including apps made by other users and publishers that you install in KolHive (each a "Third Party Service"). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

8. ANALYTIC TOOLS

KolHive's apps and Websites do not contain advertising trackers. The App sends the error reports and upload and download performance data described in section 1, and our servers keep the technical logs needed to run KolHive and keep it secure.

Depending on your platform and the features you use, integrated service components, including components for sign-in and notifications, send limited technical information to their service operators. This includes device and operating-system information, application and software-component versions, application identifiers, and technical diagnostic information. The operators use this information to operate and maintain their services, assess reliability and compatibility, and understand adoption of their software components. This processing is separate from the optional error and performance reports described in section 1; turning off the App's Diagnostics setting does not turn off all technical processing by those service components. The service-provider and international-transfer provisions in sections 3 and 4 also apply.

Log Files

We use log files to administer KolHive, keep it secure, and find and fix problems.

Note: We reserve the right to remove or add new analytic tools. We will update this Privacy Policy before we add one.

9. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

We do not sell your Personal Information and we do not share it for cross-context behavioral advertising. To exercise the rights described in section 5, contact us at [email protected]. We will not discriminate against you for exercising them.

9.1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.

9.2. Our California Do Not Track Notice: Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. KolHive does not track you across other companies' websites.

9.3. Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

10. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this policy and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].