Kinfide Global Privacy Policy

At Kinfide Inc. privacy is not a feature; it is our core architecture. We operate an encrypted vault platform designed, with great care for your privacy, to securely map your assets for your loved ones. Because our platform utilizes a Zero-Knowledge Architecture, the contents of your vault are encrypted before they ever leave your device. We cannot access, read, or view the contents of your vault. Your decryption keys are cryptographically locked, ensuring they can only ever be accessed and unlocked by your chosen beneficiaries.

This Global Privacy Policy (hereinafter “Privacy Policy”) is designed to provide users, customers, and visitors with important information about the types of personal data Kinfide Inc. and its affiliates (“Kinfide,” “we,” “us,” “our”) collect from or about you and our practices for collecting, using, sharing, or processing of that data.

This Privacy Policy addresses data collected by Kinfide where we act as the controller or business, in connection with our webpage(s), the information on this Website, our mobile application (the “Mobile App”), and the services and resources available or enabled via the Website or the Mobile App (each a “Service” and collectively with the Website and Mobile App, the “Services”).

The Personal Information We Collect

We collect information from you when you provide it to us or when you use our Services, and from trusted third-parties as further described below. We ensure that we only collect and process data that we believe is necessary to provide our Services to you.

Information we collect from you

• Account Information. We collect information you provide when setting up your Kinfide account (for example, your name, email, location, and any images that you may upload as part of your profile). For your Trusted Steward(s) and Beneficiaries, we collect details like their names, email addresses, and any other information you may provide to us about them.
• Payment Information. We use a Payment Card Industry (PCI) compliant third-party payment processor, to collect and secure your payment method, payment card details, and billing information when you subscribe for the Services. We do not have access to your payment method details or otherwise receive or store any billing data where payment is made for a Kinfide subscription through the Google Play or Apple App Store.
• Support and Correspondence. We keep records of your communications with us via email, phone, websites, social media, chatbots, or otherwise. We collect your contact information to respond to you and in the normal course of our business operations. If you communicate with us via a chatbot or use our automated communication tools to facilitate your communications with us, including those offered by a third-party, these tools may collect and record the contents of any communications you send through them. They may also collect analytics information, such as device and usage information. We may disclose this information to our relevant service providers for the purpose of providing these tools, improving our customer support, generating summaries, and internal marketing purposes.
• Events, Surveys, or Program Information. Information you provide to us when you register for any of our events, webinars, and surveys; or share your attendee information with us as part of a conference or seminar. This typically includes, but is not necessarily limited to, identifiers such as your name, contact information, and location.

Information automatically collected when using the Services

This is information we collect to protect, maintain, and improve our Services for users.

• Device and Technical Usage Information. When you use the Services, we collect information from your browsers and devices, which provides us with technical usage information. This includes information about hardware, equipment, and devices used, applications, operating systems, cookies, server logs, authentication details, IP address, location data, analytics information, software errors and crash data, quality and performance metrics, and other technical details necessary for us to operate and maintain our Services, as well as for fraud prevention, and security monitoring. In some cases, we may ask you for certain diagnostic reports and other information necessary to help us identify and solve problems with our Services. This information is sent to us only on a case-by-case basis, or by users who decided to participate in our beta programs, or who otherwise explicitly choose to send diagnostic data to us.
• Product Usage Information. With your permission, we collect, in a privacy-preserving manner, information about how you and your systems use the Services. This helps us understand how our products perform, improve your experience, and keep everything running smoothly. This includes information about pages visited, features used, or time spent in different areas of the product. It also includes data from automated or system-initiated activity, like service account usage, API calls, or command-line operations. We may also collect information about how our systems respond to these interactions, including performance, latency, or error events. In some cases, your product usage information may overlap with limited technical usage information. We may also use your usage information in aggregate or deidentified forms to help us understand usage trends, improve product reliability, tailor our communications with you based on your interactions with the Services, and support product adoption and development.

Information we receive from other sources

• Cookies and Similar Technologies. We and our marketing partners use cookies and other tracking technologies to collect information about your interactions with the Services for essential, functional, analytical, and advertising purposes. For more information, please see our Cookie Policy, which includes information on how to control or opt out of these cookies and tracking technologies.
• Partner Network. We work with channel partners, technology partners, system integrators, and hyperscalers who provide consulting, implementation, training, and other services around our products. Some of these partners also help us to market and promote the Services, generate leads for us, and resell the Services. We may receive information from these partners, such as billing information, contact information, what Services you have purchased or may be interested in, evaluation information you have provided, what events you have attended, your region or country, and other service data.

How We Use Information and Legal Bases

• To provide our Services to you. We use your information to create an account, which allows you to create your vault, map your assets, choose your Trusted Steward(s), designate your Beneficiaries, and perform other account-related activities. We use your information to provide you with a rich customer experience that includes troubleshooting and support services. We use your information to provide you with insights, usage reports and other information related to your account and use of our Services. We use your contact and billing information to process and accept payments for our subscription Services.
• To assist and communicate with you. We use your contact information to provide emergent and proactive service notifications, product updates, and to market and promote the Services to you, using email, mail, phone, and system notifications in accordance with your permissions. We also use information we collect and receive to provide support services in response to your questions or requests for information. Depending on your request, we may use information we collect about your use of our Services to troubleshoot your concern.

We may use your communications with us for training and quality assurance, such as to understand and help manage the number of requests received, to ensure the quality and accuracy of the responses that were provided to you, and for dispute resolution purposes. We use automated technology to review your communications and improve your support experience. For example, we may use chatbots or other automated technology to help identify the nature of your request, suggest articles or content to facilitate our responses to you, and obtain feedback from you.

• To market our Services. We use information about how you use our Services, such as products or features used, events attended, content requested, promotions you’ve engaged with and browsing activity to optimize the delivery of our advertisements and measure the effectiveness of our marketing initiatives. Our Cookie Policy further explains how we use cookies and similar tracking technology to help us market our Services to you.
• To operate and improve our Services. We use information we collect and receive about you to conduct surveys, product research, and to measure the effectiveness of our training programs and Services. We may use third-party services to help us collect data or analyze data that we have collected about you. We also use aggregated or otherwise deidentified data to develop insights into how our Services are used.
• To secure our Services. We use information we collect and receive about you to enforce our Terms, prevent, detect, and investigate fraud, combat spam, control access to the Services, and to monitor, enforce, and improve the security of the Services we provide.
• To comply with our legal obligations. We use information we collect and receive about you to protect our and our users’ rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process.

Legal Bases

If you are located in the European Economic Area, United Kingdom, or Switzerland, our legal bases for collecting and using personal data as described in this Privacy Policy depends on the personal data and the specific context in which we collect it. In some cases, we may rely on multiple legal bases to process your data. For example, our legal bases to process your personal data include:

• Performance of contract with you, such as to provide and maintain our Services for your use. It is necessary for us to process your personal data to provide, improve, and secure our Services for you.
• In furtherance of our legitimate interests, we process your personal data to develop and train new technology, to analyze and improve our existing services, and to customize content used for our marketing purposes. Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
• With your consent, such as when you tell us we may use your location or non-essential cookies and similar technologies. When we process your information based on your consent you may revoke your consent at any time, in some cases this may not affect any processing that has already taken place.
• To comply with a legal obligation, including to prosecute, exercise, or defend a lawsuit, arbitration, or similar legal proceeding, or to respond to lawful requests by public authorities.

How we share information

We share your personal information as described below and in this Privacy Policy, and as permitted by applicable law.

• We may share your information within the Kinfide companies and in some cases, with prospective affiliates to operate, improve, and market affiliated services to you. This includes affiliate companies that own, operate, or enable us to provide the Services to you. Unless you are notified otherwise, information shared with corporate affiliates will remain subject to this Privacy Policy.
• We share information with third-party service providers (such as ICT and security service vendors, website hosting facilities, and email distribution services), contractors, and other third-parties we use to support our business. These third-party service providers are required to protect information we share with them and may not use any identifying information other than to provide services we contracted them to provide. They are not allowed to use the information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party).
• We may disclose your information to third-party marketing services so that Kinfide can advertise on those platforms and measure advertisement effectiveness. We do not sell your personal data. However, the use of third-party cookies or the sharing of data with third parties for the purposes of providing personalized advertising may be considered a sale or sharing of your data under applicable privacy laws. Depending on where you live, you may have the right to opt out of having your information shared for this purpose. View our Cookie Policy for more information on our use of tracking technology for the purposes of targeted advertising.
• At your direction, with separate, specific notice to you, or with your consent;
• We may share your information in connection with any anticipated or actual corporate transaction, such as a divestiture, merger, consolidation, assignments, or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer it must use your information only for the purposes disclosed in this Privacy Policy.
• We may disclose your information to enforce our terms, to detect, investigate, prevent, or take action against illegal activities, fraud, or situations regarding the safety or rights of Kinfide, our employees, you, or others.
• We may disclose your information as required by law or administrative order, which includes responding to relevant government or regulatory requests. Please remember that the contents of your vault are encrypted on your device, and your decryption keys are cryptographically locked, and can only be accessed and unlocked by your chosen beneficiaries. No one at Kinfide has access to the encrypted contents of your vault. Therefore, we cannot provide any information regarding the contents of your vault in response to a government or regulatory request. (Please refer to our Law Enforcement Request Guidelines for more information).

Retention and Deletion

We retain your personal information no longer than is needed for the business purposes for which it was collected, unless a longer retention period is required or permitted by law, or you instruct us to delete your information. We will deidentify, aggregate, or otherwise remove or mask your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time. Please note that copies of information that you have updated, modified, or deleted may continue to reside in our systems for a period of time, and we may maintain copies of this information as part of our business records.

International Data Transfers

As a global organization, Kinfide has international affiliates, utilizes third-party service providers, and maintains a global infrastructure. Information that we collect and maintain will be transferred to and processed in the United States and other countries around the world. Those countries may have data protection laws that are different from the laws of your country.

We have taken appropriate steps and put safeguards in place to help ensure that any access, processing, or transfer of your information remains protected in accordance with this Privacy Policy and in compliance with applicable data protection law. Such measures provide your information with a standard of protection that is at least comparable to that under the equivalent local law in your country, no matter where your data is accessed from, processed, or transferred.

Such measures include the following:

• Adequacy decisions of the European Commission confirming an adequate level of data protection in countries outside the European Union.
• Ensuring that the third-party partners, vendors, and service providers to whom data transfers are made have appropriate mechanisms in place to protect your personal information. For instance, our agreements signed with our third-party partners, vendors and service providers incorporate strict data transfer terms (including, where applicable, model clauses issued by the European Commission or the United Kingdom for restricted transfers to third countries), and require all contracting parties to protect the personal information they process in accordance with applicable data protection law. Our agreements with our third-party partners, vendors, and service providers may also include, where applicable, their certification under approved privacy frameworks, or reliance on the service provider's Binding Corporate Rules, as defined by the European Commission.
• Carrying out periodic risk assessments and implementing various technological and organization measures to ensure compliance with relevant laws on data transfer.

Children's Privacy

Our Services are not intended for minors. If you inform us or we otherwise become aware that we have unintentionally received personal data from a minor without a parent’s or guardian’s consent, we will delete this data from our records.

Your Rights

Depending on your jurisdiction, you may have certain rights and choices with respect to your information. We’ve explained your rights and how to exercise them below:

• Access to information. You can ask us to confirm if we are processing your personal information, provide you with details about our processing, and access much of the information you have provided us when you log into your account. To request access to information, contact us using the method provided in the Contact Us section.
• Correct your information. You can update your information within your settings and modify the contents of your vault from your account. To edit your personal information, visit your profile in your account settings. You may also contact us about correcting or updating your information using the method provided in the Contact Us section.
• Delete your information. You have the right to instruct us to remove data permanently from our systems and backups. To ensure that no one’s data is deleted without their consent, you must first delete your account through an authenticated session. After your account has been deleted, you may contact us and ask for the data to be expunged. Once the request is authenticated, we will begin removing your information from our active systems. To request permanent deletion of your personal information, please contact us using the methods provided in the Contact Us section. Please note we may retain versions of your information in accordance with our retention policy or until they are overwritten.
• Object to Certain Uses. You can object to any processing of your personal information that is done on the basis of our legitimate interests, unless we have compelling legitimate grounds for processing which override your interests and rights, or if we need to continue to process your information for the establishment, exercise, or defense of a legal claim. In some cases, if you object to our use, it may mean no longer using the Services. To exercise this right, contact us using the methods provided in the Contact Us section of this Privacy Policy.
• Restrict How We Use Information. You can ask us to restrict the processing of your personal information under certain circumstances (e.g. when you wish to contest the accuracy of your data). You can also ask us to suspend your account at any time by contacting us as described in the Contact Us section of this Privacy Policy. When your account is suspended, you will not be able to provide ongoing or future data to us that is associated with your account.
• Consent Withdrawal. You can withdraw your consent where our processing is based on a consent you have previously provided us. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so, or if your withdrawal of consent was limited to certain processing activities. Please note, withdrawal of your consent will not affect the lawfulness of any processing carried out before your withdrawal.
• Manage Communications We Send You. You may opt-out of marketing emails from us directly through the email. You may opt-out of sales and marketing phone calls from us by letting us know during the call or by contacting us as described in the Contact Us section. Please be aware that you cannot opt-out of receiving necessary account- and privacy-related messages from us.
• Cookie Preferences. You may opt-out of certain cookies set via our website through our consent banner or your browser settings. Please see the Cookie Policy for more information.
• Complaints. If you would like to raise a concern about our use of your information, please contact us first as described in the Contact Us section. We respond to all requests we receive from individuals wishing to exercise their data protection or privacy rights in accordance with applicable data protection laws. Please note, we may also ask you to verify your identity in order to help us respond to your request securely and efficiently. Depending on the laws in your local jurisdiction, you may be able to appeal any decisions made regarding your rights. For individuals in Europe, the United Kingdom, and Switzerland, you may lodge a complaint about the collection and use of your personal data with a data protection authority in relation to the General Data Protection Regulation and other applicable laws. Should you have the right to appeal a decision to not take action on a request under applicable law, instructions on how to make that appeal will be included in our response to you.

Updates

We may update this Privacy Policy from time to time to reflect changes to our personal data handling practices or respond to new legal requirements. We encourage you to periodically review this page for the latest information on our privacy practices. We maintain the right to send you an email or in-app notification informing you of substantive changes.

Contact Us

Please direct any questions or comments about this Privacy Policy or our privacy practices to us or our Data Protection Officer at privacy@kinfide.com.

Cookie Policy

This Kinfide Cookie Policy (“Cookie Policy”) describes how we and our business partners deploy cookies and similar technologies.

What are cookies and similar technologies?

Cookies are small text files that are stored in your web browser that allow us or a third party to recognize you. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Cookies can be used to collect, store, and share pieces of information, such as IP addresses, about your activities across websites, including on our Website. However, there are other similar technologies, such as pixels, that store and access information on your device in a similar manner to cookies. Therefore, the single term “cookies” for this Cookie Policy, refers to cookies and similar technologies.

Types of cookies we use and why

The following information lists the different types of cookies implemented on our Website, who serves those cookies, the cookie name, a brief description of the cookie, and the expiration of the cookie.

We use both session cookies and persistent cookies.

Session cookies

Help us recognize a single visit to our Website. They let us identify you while you browse, then expire when you close your browser or after a short period of inactivity.

Persistent cookies

Stay on your device for a set amount of time, which is described in this Cookie Policy. They continue to work even after you close your browser. For example, if you choose to stay signed in to Kinfide, we use a persistent cookie to remember that preference, so you don't have to sign in again the next time you visit.

Categories of cookies

Cookies can either be first-party, where Kinfide sets and uses those directly, or third-party which are set by third parties, such as our analytics provider, through our Website or server.

We use cookies and similar technologies in the following categories described in the table below:

Managing Cookies

Most browsers allow you to control how cookies are used, block certain types of cookies, and clear existing cookies and browsing data. To manage your cookie preferences at any time, including withdrawing your consent to non-essential cookies, follow the instructions in your browser settings.

Your cookie preferences are stored on the browser and device you use to access our Website. If you clear your browser cookies or cache, use a different browser or device, or otherwise remove the information used to remember your preferences, you may be asked to make your cookie choices again the next time you visit our Website.

Some of our advertising partners participate in industry self-regulatory programs that provide information about interest-based advertising and offer tools to help you manage your advertising preferences. Depending on where you live, you can learn more or opt out by visiting:

• United States: Digital Advertising Alliance (DAA) AdChoices Tool
• European Economic Area (EEA) and United Kingdom: European Interactive Digital Advertising Alliance (EDAA)
• Canada: Digital Advertising Alliance of Canada (DAAC)

If you interact with social networking services through our Website, or if those providers set cookies on our Website, you may also be able to manage your advertising preferences through your account settings with those providers. For more information, please refer to the privacy and advertising settings made available by providers such as Google, Meta, and Reddit. These opt-out tools and settings are provided by third parties, and we do not control their operation, availability, or accuracy. If your browser is configured to reject cookies when you visit these opt-out pages, if you later clear your browser cookies, or if you use a different browser or device, your opt-out preferences may no longer apply. You may need to update your preferences for each browser and device that you use.

For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

Updates to this Cookie Policy

We may update this Cookie Policy from time to time to reflect changes to our Website, our use of cookies and similar technologies, our business practices, or applicable laws. We encourage you to review this Cookie Policy and your cookie preferences periodically, so you stay informed about how and why we use cookies.