Kinly.
Privacy Policy

Welcome to the Kinly. Privacy Policy ("Policy")!

This document outlines how we collect, store, protect, and share your information, as well as who we may share it with. We encourage you to read this Policy alongside our Terms of Use.

While using the Kinly. mobile application ("App") or visiting our website (thekinly.com), where we provide information about the App, we collect certain information about you. Additionally, you may choose to share information with other Kinly. users ("Users") through the App. In some cases, we may also need to share your information with third parties.

Kinly. operates globally, which means your data may be transferred to and processed in countries like the United States and the United Kingdom, regardless of where you live. This Policy explains how we safeguard your personal data during such international transfers, so please read it carefully.

Who We Are

WGF TECH s.r.o. acts as the data controller for the personal information collected and processed through the Kinly. app and website (referred to as "we," "our," or "us" in this Policy).

If you have any questions, you can reach our Data Protection Officer at [email protected] or by mail at:

WGF TECH s.r.o.
Prikop 843/4, Zabrdovice (Brno-stred), 602 00 Brno, Czech Republic

1. Collection of Information

1.1 Registration Information

When you download the Kinly. app and create an account ("Account"), we collect specific personal details ("Registration Information") to help personalize your experience and ensure community safety. This may include:

• Full name
• Username
• Email address
• Mobile phone number
• Gender identity
• Date of birth
• Sexual orientation (optional)
• Profile photos
• Location data (if permitted)
• Social media login details (if you link accounts like Facebook or Instagram)

You will also be asked to set a secure password during registration. After creating your account, you can review and update most of this information by logging into the app. Note that your location may be automatically updated if location permissions are granted. It’s your responsibility to keep your information accurate and up-to-date, especially your contact details.

Certain Registration Information, like your name, username, sexual orientation (if you choose to share it), and profile photos, may be visible to other users when they view your profile.

1.2 Profile Information

We encourage you to carefully consider the personal information you share on your Kinly. profile. To ensure your safety, we advise against posting sensitive details such as your full name, email address, phone number, home address, credit card information, or any data that could be misused.

When interacting with other users via messages or posting on the app, you control the amount of personal information you disclose. Please exercise caution when sharing sensitive data.

1.3 Identity Verification (Including Biometric Data)

To maintain a secure environment and protect our community, Kinly. uses Didit for identity verification. We may ask users to complete KYC (Know Your Customer) verification by providing documents like a government-issued ID and a selfie for facial recognition. This process helps us confirm that you are a real person and not a bot or fake account.

During verification, Didit may use facial recognition technology to compare your selfie to the photo on your ID. Verification images are stored securely but will not be displayed on your profile.

1.4 Purchase Information

If you opt to buy premium features or services within the app, we will securely process your payment information. This data is retained only for transaction completion, fraud prevention, and compliance with legal requirements.

We use automated systems to detect and prevent fraudulent transactions. If a payment is flagged as suspicious, it may be automatically blocked, and you will be notified. You can contact our support team if you believe a transaction was wrongly flagged.

1.5 Location Data

With your consent, Kinly. may access your device’s location services to enhance your experience by suggesting nearby profiles and events. This includes data like GPS coordinates and nearby Wi‑Fi access points. Location sharing is optional and can be adjusted in your device’s settings at any time:

• iOS: Settings > Privacy > Location Services > Kinly.
• Android: Settings > Location > App Permissions > Kinly.

1.6 Device Information

We collect data about the device you use to access Kinly., including:

• Device type and model
• Operating system and version
• Unique device identifiers

This information helps us optimize app performance and troubleshoot issues. If you allow, the app may also access your contacts solely to help you find friends on Kinly.

1.7 Cookies and Tracking Technologies

When using Kinly. or visiting our website, we may use cookies and similar technologies to personalize your experience and gather usage statistics. Cookies help us remember your preferences and improve our services. For more details, please refer to our Cookie Policy.

1.8 Customer Support Communications

If you reach out to our Customer Support team, we may collect your email address, device information, and any messages you send to assist with your inquiry. We keep records of customer interactions, including complaints or reports about other users, for up to 6 years after account deletion.

1.9 User-Generated Content and Interactions

Any content you share on Kinly., including photos, bios, or messages, may be visible to other users depending on your privacy settings. While we encourage openness, please be mindful of what you choose to share.

1.10 Surveys and Promotions

Occasionally, we may invite you to participate in surveys, contests, or promotional campaigns. Participation is voluntary, and any information you provide will be handled according to this Privacy Policy.

2. Use of Your Information

Our primary goal at Kinly. is to provide you with a safe, enjoyable, and personalized experience. To achieve this, we may use your Registration Information and other collected data in the following ways:

2.1 Providing and Enhancing Our Services

We use your information to:

• Offer you access to Kinly. features and services, including user profiles, messaging, and group chats.
• Keep you informed about updates, new features, and important changes within the app.
• Personalize your in-app experience, such as recommending profiles based on your preferences.
• Conduct research and analyze app usage to improve functionality and performance.
• Test new features, tools, and algorithms to enhance user experience.

2.2 Communication and Support

• Contact you with important information regarding your account, such as security updates, changes to our Terms of Use, or Privacy Policy.
• Respond to your questions, feedback, or support requests through our Customer Support channels.

2.3 Safety and Security

We take community safety seriously. To maintain a safe environment, we may use your data to:

• Detect and investigate fraud, spam, or suspicious activity.
• Enforce our Terms of Use, including taking action against users who violate policies.
• Resolve disputes and troubleshoot issues.
• Protect the rights, safety, and well-being of users and third parties.

2.4 Identity Verification and Fraud Prevention

To ensure authenticity and prevent fake profiles or bots, Kinly. uses Didit for KYC verification. We process your submitted documents and selfies to confirm your identity and safeguard the platform from malicious users.

2.5 Marketing and Promotions

With your consent, we may send you promotional messages about special offers, events, or new features. These communications can be sent via email, push notifications, or in-app messages. You can manage or withdraw your consent at any time through the Settings section in the app or by using the opt-out link provided in each message.

2.6 Matching Algorithms

To help you find meaningful connections, Kinly. uses advanced matching algorithms powered by machine learning. These algorithms analyze various data points to recommend potential matches based on:

• Information from your profile (e.g., age, gender, sexual orientation, distance).
• Your interactions within the app (e.g., swipes, matches, and likes).
• Location data (if enabled) to suggest users nearby.

Our matching system aims to suggest profiles most compatible with you, increasing the chances of finding genuine connections.

The legal basis for processing profile and location data is the necessity to provide our services to you, as outlined in Article 6(1)(b) GDPR. For behavioral data (e.g., app interactions), we rely on our legitimate interests under Article 6(1)(f) GDPR, specifically to enhance your experience by providing personalized recommendations. If sensitive data is included in your profile (e.g., gender identity or sexual orientation), we only process it with your explicit consent.

2.7 Moderation and Content Review

To maintain a respectful community, Kinly. employs both automated systems and human moderators to review user-generated content, such as profile photos, bios, and messages. If any content violates our Terms of Use, the offending account may receive a warning, be temporarily suspended, or be permanently banned.

Users can contest moderation decisions by reaching out to our Customer Support team.

2.8 Legal Compliance and Lawful Basis

We process your personal data in accordance with EU and UK data protection laws, ensuring transparency regarding our legal grounds for processing. Depending on the activity, our lawful bases include:

You have the right to withdraw consent or object to our use of your data where applicable. Instructions on how to manage these preferences can be found within the app's Settings or by contacting our Customer Support.

3. Data Processing Details

3.4 Data Processors

To provide the best possible experience on Kinly., we work with trusted data processors that assist us in handling, securing, and improving our services. Below is a breakdown of these processors, the data they collect, and their intended use:

3.6 Additional Data Processors

To ensure the smooth operation and continuous improvement of Kinly., we may engage additional service providers, contractors, and third parties. These processors help us operate, enhance, customize, and market our services. We share data with them strictly for the purposes outlined in this Privacy Policy.

3.7 Sharing Consumer Information with App Stores

By registering on Kinly., you give us consent to share specific user information with app stores (such as Google Play) to facilitate certain processes, like refunds. The shared data may include:

• Age
• Unique User ID (UUID)
• In-app consumption status
• Time spent on the app
• Platform type
• Account status
• Total amount of refunds received
• Delivery status

This data is sent to app stores when you request a refund, helping them assess refund eligibility and improve their processes.

Withdrawing Consent:
You may withdraw your consent at any time by contacting us at [email protected]. Additionally, if you wish to stop the sharing of your data with app stores, you can manage these settings within your app store account (e.g., through Google's Privacy Portal).

3.8 Moderation Practices

We use a combination of automated tools and human moderators to review user accounts and content uploaded to Kinly. This includes:

• Reviewing names, bios, and profile pictures.
• Human moderators conduct manual reviews for fairness and accuracy.

Content Violations:
If a profile violates our Terms of Use, it may receive a warning, be restricted, or face account suspension. Users in the EU and UK have the right to appeal moderation decisions. To contest actions taken against your account, please contact [email protected].

3.9 Third Parties: Other Users and Social Media

Kinly. is designed to connect people, but it's important to understand which information may be visible to others. Data that may be publicly accessible to other users includes:

• Name
• Username
• Gender identity
• Date of birth
• Profile photos
• Location (approximate)
• Sexual orientation (optional)

Important Privacy Notes:

• Be cautious with personal information you share publicly on your profile.
• Although Kinly. prohibits screenshots and screen recordings, we cannot fully prevent other users from capturing your profile content.
• If you use social login (e.g., Google Authentication), we may access certain details like your profile picture and friend lists (if permission is granted).

Managing Social Connections:

• If you no longer wish to have your Kinly. account linked to a third-party service (e.g., Google), you can remove access through your account settings on that platform.

3.10 Data Received from Third Parties

In addition to data collected directly from you, we may also receive personal information from third parties, including:

• Social Networks: When you connect your Kinly. account through services like Google Authentication, we may access basic profile data.
• Marketing Partners: If you interact with Kinly. via ads or promotions on partner sites, we may receive information like referral sources and campaign interactions.
• Other Users: In cases where another user reports inappropriate behavior, we may receive additional information about you, such as message content or reported activity.

3.11 Law Enforcement, Legal Obligations, and Safety

We are committed to maintaining a safe and respectful environment on Kinly. In certain situations, we may share your data with law enforcement agencies, legal bodies, or attorneys, including:

• Compliance with Legal Requests: We may disclose your data to comply with lawful court orders, government investigations, or legal processes.
• User Safety: If there is evidence of harm, illegal activities, or threats, we may share your location and contact details with law enforcement or non-governmental organizations to protect you or others.
• Enforcement of Rights: If you violate our Terms of Use or infringe upon intellectual property rights, we may share your data with legal authorities or involved third parties.
• Crisis Situations: In cases of self-harm or suicidal ideation, we may proactively reach out to local authorities or mental health organizations to ensure user safety.

We will only share the necessary data required to handle the specific issue and, where possible, will notify affected users unless prohibited by law.

4. Kinly. Approach to Children's Privacy

4.1 Age Restrictions

Kinly. is strictly for users who are 18 years or older (or the age of legal majority in their country of residence). We do not knowingly collect or process personal information from anyone under this age threshold. If you are under 18, you are prohibited from using our app and its services.

4.2 Reporting Underage Users

If you become aware that someone under the age of 18 has registered on Kinly., please notify us immediately. We take the privacy and safety of minors seriously and will act promptly upon such reports.

You can report an underage profile through:

• The in-app reporting feature on the user's profile, or
• By contacting us directly at [email protected].

We will investigate all reports and take appropriate action in line with the Children's Online Privacy Protection Act (COPPA) and other relevant regulations.

4.3 Our Actions Upon Discovery

If we discover that a user under the age of 18 has created an account and provided false or misleading information, we will:

• Immediately terminate the underage user's account.
• Delete all personal data associated with the account from our systems.
• Notify the reporting party (when appropriate) that action has been taken.

These steps are taken to uphold legal obligations and ensure the safety and integrity of the Kinly. community.

5. Security

At Kinly., we take the protection of your personal data seriously. We've implemented industry-standard security measures to prevent unauthorized access, misuse, alteration, or loss of your information.

• Data Protection: We use encryption, secure servers, and regular security audits to safeguard your data.
• Access Control: Only authorized personnel have access to sensitive user data.
• Ongoing Monitoring: Our technical team continuously monitors the app to detect and address vulnerabilities.

However, no system is 100% secure. While we strive to protect your data, we cannot guarantee absolute security from unauthorized access, hacking, or data breaches.

Your role in protecting your account:

• Always log out after using the app, especially on shared devices.
• Do not share your password with anyone.
• Use strong, unique passwords and update them regularly.
• If you suspect unauthorized access to your account, please contact our support team immediately at [email protected].

6. Linking Other Accounts to Kinly.

Kinly. offers seamless login options using your Google account, enhancing your experience while keeping it secure.

6.1 Using Google Authentication

When you sign in using your Google account, you authorize Google to share certain details with us, such as:

• Name
• Email address
• Profile picture

We use this data to create and manage your Kinly. account. You can review and manage permissions through your Google Account Settings.

6.2 Managing Linked Accounts

You have the option to link or unlink your Google account from Kinly. at any time. To unlink your account:

1. Visit your Google Account Settings.
2. Navigate to "Security" > "Third-party apps with account access".
3. Remove Kinly. from the list.

Important: Unlinking your Google account will stop any further data sharing but will not automatically delete any data already stored on Kinly. To delete your account and all associated data, please visit the Account Settings within the app.

7. Your California Privacy Rights

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and other applicable laws, in addition to the general rights outlined in Section 8.

7.1 Your CCPA Rights

As a California user, you have the right to:

• Know what personal information we have collected, used, and shared over the past 12 months.
• Request deletion of your personal data, subject to certain legal exceptions.
• Opt-out of the sale of personal information (Note: Kinly. does not sell user data).
• Be free from discrimination for exercising any of these privacy rights.

7.2 "Shine the Light" Law

Under California Civil Code Section 1798.83, you can request information about how we share personal data with third parties for their direct marketing purposes. To submit such a request, contact us at:
[email protected]

7.3 Promotional Sharing

Occasionally, we may partner with third parties for joint promotions. If you participate, we may share limited data (e.g., contact info) with the partner. You will be informed before entering such promotions and will have the option to opt out.

7.4 Do Not Track (DNT)

California law requires us to disclose how we respond to Do Not Track signals. Currently, Kinly. does not track user behavior across third-party sites and does not respond to DNT signals.

We also do not knowingly permit third parties to collect personal data about your online activities when using Kinly..

8. Your Rights

Depending on your location and applicable privacy laws (e.g., GDPR in the EU/EEA or CCPA in California), you may have the following rights regarding your personal data:

• Right to be Informed: Know what data is collected and how it's used.
• Right of Access: Request a copy of your personal data.
• Right to Rectification: Correct inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data in certain cases.
• Right to Restrict Processing: Limit how we use your data under specific circumstances.
• Right to Data Portability: Receive your data in a machine-readable format for transfer to another provider.
• Right to Object: Object to data processing based on legitimate interests or for marketing.
• Rights Related to Automated Decision-Making: Ensure human involvement in decisions that significantly affect you.

8.1 Exercising Your Rights

To exercise any of these rights, contact us at:
[email protected]

For security purposes, we may need to verify your identity before processing your request.

If you are unsatisfied with how we handle your data or respond to your requests, you have the right to file a complaint with your local data protection authority:

• EU/EEA Users: Contact your national Data Protection Authority.
• UK Users: Contact the Information Commissioner's Office (ICO) at ico.org.uk.
• California Users: Contact the California Attorney General or submit a complaint through [email protected].

8.2 EU Representative

In accordance with Article 27 of the GDPR, Kinly. has appointed WGF TECH s.r.o. as its official GDPR representative in the EU.
For GDPR-related matters, you can contact them at:

• Postal Address: Prikop 843/4, Zabrdovice (Brno-stred), 602 00 Brno, Czech Republic.
• E-mail Address: [email protected].

9. Data Locations

To provide Kinly. globally, your data may be processed and stored on secure servers located in different countries, including the United States, European Union, and other jurisdictions where our third-party service providers operate.

• Hosting: User data is stored on Hetzner servers in secure data centers.
• Third-Party Processors: Services like Firebase, Didit, and Google Play may process your data in accordance with their privacy policies.
• Cross-border Transfers: When data is transferred outside of the EU/EEA or UK, we ensure adequate protection using legal safeguards such as:
  • Standard Contractual Clauses (SCCs) approved by the European Commission.
  • Other recognized transfer mechanisms under GDPR.

If you'd like more information about our data transfer safeguards, contact us at [email protected]

10. Data Retention and Deletion

We retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy and as required by applicable laws. The retention period depends on the type of data and the legal basis for its processing (refer to Section 2).

10.1 Account Deletion

When you delete your Kinly. account:

• Your profile will be immediately deactivated and no longer viewable within the app.
• We offer a 28-day grace period during which you can restore your account if it was deleted accidentally.
• After 28 days, we will begin the process of permanently deleting your personal data from our systems.

10.2 Exceptions to Data Deletion

Certain data may be retained beyond account deletion under specific circumstances:

• Legal Compliance: We may keep data to comply with legal obligations (e.g., tax or accounting records for in-app purchases).
• Evidence of Compliance: If an account was banned or blocked, we may retain information about the violation for legal and evidential purposes.
• Ongoing Disputes: If there's an unresolved issue or legal claim, we will retain relevant data until the matter is resolved.
• Legitimate Business Interests: We may keep data for purposes such as fraud prevention or ensuring user safety (e.g., preventing banned users from creating new accounts).

10.3 Data Shared with Third Parties

Please note that even after account deletion, Kinly. cannot control data that has been:

• Shared with other users (e.g., messages, shared media).
• Copied or stored by third parties (e.g., screenshots or screen recordings).
• Accessed by third-party applications connected to your account.

We recommend reviewing and managing permissions granted to third-party apps to ensure your data is properly controlled.

11. Data Breach Notification

We take the security of your personal data seriously. However, in the event of a data breach that compromises your personal information, we will act in accordance with GDPR (General Data Protection Regulation), CCPA (California Consumer Privacy Act), and other applicable data protection laws.

In case of a breach, we will:

• Assess the nature and scope of the incident.
• Take immediate steps to contain and mitigate any potential damage.
• Notify affected users within 72 hours of becoming aware of the breach, if required by law.
• Provide clear instructions on how users can protect themselves from potential risks.
• Cooperate with data protection authorities and relevant legal bodies as necessary.

If you suspect unauthorized access to your data, please contact us immediately at [email protected].

12. Beta Programs

Occasionally, we may offer Beta Programs for new features through platforms like Apple TestFlight or Google Play Beta.

If you choose to participate:

• We may collect additional usage data and feedback to improve app performance.
• Beta versions may have limited privacy and security protections compared to the official release.

For Apple TestFlight, please review Apple's TestFlight Privacy Policy for more details on how your data is handled during beta testing.

13. Changes to This Policy

As Kinly. evolves, we may update this Privacy Policy to reflect new features, legal requirements, or changes in data practices.

• Notification of Changes:
  • Minor updates will be reflected directly in this document.
  • For material changes (e.g., changes to how we process sensitive data), we will notify users via email or in-app notifications.
• Reviewing the Latest Version:
  • The most current version will always be available at https://thekinly.com/privacy-policy/.
  • We encourage users to review this policy periodically to stay informed.