Privacy policy

1. Data controller

The controller is [Company name, address, registration number — placeholder]. Data protection contact: privacy@kinnexi.com (placeholder address).

2. Data we process

• Account data: name, email address, language, role in the family.
• Life Memory Graph: people, places, events, photos, music and preferences your family adds about the recipient.
• Call data: schedule, call times and duration, transcripts and AI-generated summaries.
• Billing data: plan and subscription status (payment details are handled by Paddle, not by us).
• Technical data: device and log data needed to run and secure the service.

3. Why we process it and on what legal basis

• To provide the service you subscribed to: performance of a contract.
• To process information about the recipient's life and wellbeing that may reveal health-related details: explicit consent.
• To secure the service and prevent abuse: legitimate interests.
• To keep accounting and tax records: legal obligation.

4. Health-adjacent data

Conversations may touch on wellbeing or health. We only process such information with explicit consent, which can be withdrawn at any time, and we apply data minimisation: summaries focus on what helps your family stay connected, and Kinnexi does not make medical assessments.

5. AI processing

Video conversations are generated by an AI avatar provided by Tavus. Summaries are generated by Google Gemini from call transcripts. Kinnexi is instructed to rely only on information your family provides and never to invent memories. No decisions with legal or similarly significant effects are made by automated means.

6. Retention

Placeholder durations, to be confirmed:

• Video: not stored by Kinnexi beyond real-time processing by our video provider.
• Transcripts: 90 days after the call.
• Summaries and Life Memory Graph: until you delete them or your account.
• Billing records: as required by law.

7. Your rights

You have the right to:

• access your data and receive a copy (export from your account);
• rectify inaccurate data;
• erase your data, including by deleting your account;
• data portability;
• object to or restrict certain processing;
• withdraw consent at any time.

To exercise your rights, write to privacy@kinnexi.com (placeholder). You can also lodge a complaint with a supervisory authority, such as the CNIL in France.

8. Cookies

We only use cookies that are essential to run the service, such as keeping you signed in and remembering your language. We do not use advertising or tracking cookies.

9. International transfers

Some providers may process data outside the European Economic Area. Where they do, transfers are protected by the European Commission's Standard Contractual Clauses (SCCs) or an adequacy decision.

10. Subprocessors

We rely on the following providers to run Kinnexi: