<h1>Privacy Policy</h1>
            <p>Last updated: October 6, 2026</p>

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

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

                <p>Please read this Privacy Policy carefully, so you can understand our practices and your rights in
                    relation to personal data. "<strong>Personal Data</strong>" or "<strong>Personal
                        Information</strong>" 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.</p>

                <blockquote>
                    <p><strong>Important note:</strong> 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.</p>
                </blockquote>

                <p>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.</p>

                <blockquote>
                    <p><strong>In short:</strong></p>
                    <ul>
                        <li>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.</li>
                        <li>When you use a cloud AI feature, the content needed for that request is sent to the
                            provider that runs the AI model. Our managed AI features run on Google Cloud, including
                            Anthropic's Claude models for Max. Google's terms for these services say that Google will
                            not use your content to train or fine-tune AI models without our permission, and we have
                            not given that permission.</li>
                        <li>We do not use your content to train AI models.</li>
                        <li>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.</li>
                    </ul>
                </blockquote>

                <blockquote>
                    <p><strong>Shared ITANU account:</strong> KolHive OS and KolWrite (available at <a
                            href="https://kolwrite.com/">https://kolwrite.com/</a>) 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
                        (<a href="https://kolwrite.com/tos_pp.html#privacy">https://kolwrite.com/tos_pp.html#privacy</a>).
                        Deleting your account applies to the shared account and to both products.</p>
                </blockquote>

                <h4><strong>Table of Contents:</strong></h4>
                <ol>
                    <li>What information we collect, why we collect it, and how it is used</li>
                    <li>How we protect and retain your Personal Data</li>
                    <li>How we share your Personal Data</li>
                    <li>Additional information regarding transfers of Personal Data</li>
                    <li>Your privacy rights</li>
                    <li>Children and teens</li>
                    <li>Interaction with third-party products</li>
                    <li>Analytic tools</li>
                    <li>Specific provisions applicable under California privacy law</li>
                    <li>Contact us</li>
                </ol>

                <p>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 <a
                        href="mailto:info@kolhive.com">info@kolhive.com</a>.</p>

                <h4><strong>1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED</strong></h4>

                <p>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.</p>

                <h5><strong>When you browse or visit our Website</strong></h5>
                <p><strong>Data we collect:</strong> 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.</p>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To deliver the Website and keep it secure</li>
                    <li>To remember your choices</li>
                    <li>To administer the Website and fix faults</li>
                </ul>
                <p><strong>Third parties we share with:</strong> Cloudflare, which hosts and protects our Websites.
                    Sign-up forms on our Websites use Cloudflare Turnstile to check that a person, not a bot, is
                    submitting them.</p>
                <p><strong>Consequences of not providing:</strong> If your browser does not store your choices, the
                    Website will not remember them.
                </p>

                <h5><strong>When you create an account and log in</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Email address</li>
                    <li>Name, if you provide it or your sign-in provider shares it</li>
                    <li>Password, which is handled by Google Firebase Authentication and is not stored on our servers</li>
                    <li>If you sign in with Google or Apple: the name, email address and profile picture that the
                        provider shares with us</li>
                    <li>Preferred Language</li>
                    <li>IP address, device type, app version and sign-in times</li>
                    <li>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</li>
                    <li>Your acceptance of our Terms of Use and this Privacy Policy, and your privacy choices</li>
                </ul>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To be able to create an account</li>
                    <li>To be able to log in, on each of your devices</li>
                    <li>To be able to enjoy features available to registered users only</li>
                    <li>To protect your account and detect misuse</li>
                    <li>To make the features available on your account appropriate for your age</li>
                    <li>To keep a record of what you agreed to</li>
                </ul>
                <p><strong>Third parties we share with:</strong> Google Firebase Authentication, which handles sign-in,
                    passwords and email verification, and Google or Apple if you choose to sign in with them.</p>
                <p><strong>Consequences of not providing:</strong> Cannot create an account, cannot log in, cannot enjoy
                    all the features of KolHive.</p>

                <h5><strong>When you contact us for support</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Full name</li>
                    <li>Email address</li>
                    <li>Message, and any attachments you choose to add</li>
                    <li>Username (on the social media platform from which you reached out to us)</li>
                    <li>If you report an AI answer: the identifiers of the conversation and the message, and the name
                        of the AI model</li>
                </ul>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To process and answer questions</li>
                    <li>To provide support (e.g., to solve problems, bugs or issues)</li>
                    <li>To investigate AI answers you report. To do this, our support team may view the reported
                        conversation.</li>
                </ul>
                <p><strong>Third parties we share with:</strong> Google, which provides our email service, and 3rd
                    party platforms such as "X" when you contact us there.</p>
                <p><strong>Consequences of not providing:</strong> Cannot process and answer questions, cannot provide
                    support.
                </p>

                <h5><strong>When you subscribe to our communications or join our waitlist</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Email address</li>
                    <li>Preferred Language</li>
                    <li>Where you signed up, and a record of your consent, your confirmation and any unsubscribe
                        request</li>
                </ul>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To add you to our mailing list or waitlist</li>
                    <li>To send you the updates and marketing communications you asked for</li>
                    <li>To keep proof of your consent</li>
                </ul>
                <p><strong>Third parties we share with:</strong> Google, which delivers our emails, and Cloudflare
                    Turnstile, which checks that the sign-up is not made by a bot.</p>
                <p><strong>Consequences of not providing:</strong> Cannot send you marketing communications or launch
                    updates.</p>

                <h5><strong>When you buy a plan, storage or AI credits</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Billing contact name and email address</li>
                    <li>Country, and billing address, company name and tax identification number where you provide
                        them</li>
                    <li>The plan, storage or credits you buy, the price, currency and tax</li>
                    <li>Payment-provider, transaction, refund and tax-document identifiers</li>
                </ul>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To determine available billing options and calculate applicable taxes</li>
                    <li>To process, reconcile, refund, and support purchases</li>
                    <li>To grant or remove the plan, storage or credits associated with a payment</li>
                    <li>To create required accounting and tax records and prevent fraud</li>
                </ul>
                <p><strong>Third parties we share with:</strong> 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.</p>
                <p><strong>Consequences of not providing:</strong> We may be unable to process the purchase or refund,
                    calculate taxes, or issue a required tax document.</p>

                <h5><strong>When you create, record, upload, attach, share or submit content for processing through
                        KolHive</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Input (as defined in our Terms of Use)</li>
                    <li>Audio</li>
                    <li>Video</li>
                    <li>Images</li>
                    <li>Prompts, chat messages, instructions, and workspace context</li>
                    <li>Files, documents, app specifications, workflow instructions, generated artifacts, and code</li>
                    <li>Language, model and settings choices, and technical request information</li>
                    <li>Account Information</li>
                    <li>Other information you provide</li>
                </ul>
                <p><strong>How we collect it:</strong> 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.</p>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To process your request and return the result</li>
                    <li>To store your content and keep it in sync across your devices</li>
                    <li>To operate, maintain, secure, troubleshoot, and support KolHive</li>
                    <li>To measure your use of AI credits and storage</li>
                    <li>To prevent misuse and comply with legal obligations</li>
                    <li>To improve KolHive using information about how it is used, such as usage counts and error
                        reports</li>
                </ul>
                <p><strong>Third parties we share with:</strong> Your content is stored on our servers, which are
                    hosted by Hetzner in Germany, and in file storage provided by Cloudflare (R2). Processing that needs
                    specialised hardware, such as speech recognition, speaker separation and video rendering, runs on
                    GPU computers we operate ourselves or on cloud GPU servers provided by RunPod, using models we
                    operate. AI features send the content needed for each request to the AI providers described in
                    "How AI features use your content" below. When you share content, the people you share it with
                    receive it.</p>
                <p><strong>Consequences of not providing:</strong> Cannot provide you with the Outputs, generated artifacts, app-building features, or workspace functionality.</p>

                <h5><strong>When you play online with other people in KolHive apps</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Your display name (or the name you choose in the app) and a game-specific player ID</li>
                    <li>Presence details the app shares, such as whether you are in a game</li>
                    <li>Game messages and shared game state sent by the apps in the room</li>
                    <li>Invite codes (stored only in a one-way scrambled form) and which rooms you may rejoin</li>
                    <li>IP address and network connection information</li>
                    <li>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</li>
                </ul>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To let you play and work together with other people in real time</li>
                    <li>To deliver game messages and keep a game's shared state so players can continue later</li>
                    <li>To keep online play secure and to prevent abuse</li>
                </ul>
                <p><strong>Third parties we share with:</strong> 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 connection services
                    (currently Cloudflare and Google) see it while the connection is set up. You can turn direct
                    connections off in Settings; games then run only through our servers.</p>
                <p><strong>Voice chat and video:</strong> 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.</p>
                <p><strong>Voice commands in apps:</strong> 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.</p>
                <p><strong>Retention:</strong> 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.</p>
                <p><strong>Consequences of not providing:</strong> Cannot play online with other people. Turning off
                    direct connections keeps online play available through our servers.</p>

                <h5><strong>How AI features use your content</strong></h5>
                <p>The KolHive assistant and other AI features are AI systems, not people. AI can make mistakes, so
                    check important information.</p>
                <p><strong>What is sent and when:</strong> 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.</p>
                <p><strong>Who processes it:</strong></p>
                <ul>
                    <li>Google Cloud (Vertex AI) runs Google's Gemini models for chat, transcription, summaries,
                        translation, image generation, search within your content, and voice features.</li>
                    <li>Max uses Anthropic's Claude models (Claude Opus, which may hand parts of a task to Claude
                        Sonnet), which Google Cloud runs for us on Vertex AI. Anthropic states that data handling for
                        Claude on Google Cloud is governed by Google Cloud. Max is not available in every country.</li>
                    <li>Where a feature is configured to use them, requests may instead be processed through
                        Google's Gemini API or the OpenAI API.</li>
                </ul>
                <p><strong>No training on your content:</strong> We do not use your content to train AI models.
                    Google's terms for Vertex AI state that Google will not use your content to train or fine-tune AI
                    models without our permission, and we have not given that permission. When we use the paid Gemini
                    API, Google's terms state that Google does not use prompts or responses to improve its products.
                    OpenAI states that data sent to its API is not used to train its models unless the customer opts
                    in, and we have not opted in.</p>
                <p><strong>What providers keep:</strong> These providers may keep content for a short time to run
                    the service, for example in a cache that speeds up answers (Google keeps such a cache for up to 24
                    hours), and they may keep logs to detect abuse of their services, as their terms allow (OpenAI
                    states up to 30 days). We have not turned on the optional logging that would store your requests
                    and answers in our Google Cloud projects.</p>
                <p><strong>"Help improve KolWrite and KolHive":</strong> 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.</p>
                <p><strong>Providers you choose:</strong> 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.</p>

                <h5><strong>When you connect your Google account</strong></h5>
                <p><strong>Data we collect:</strong> 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.</p>
                <p><strong>Purpose:</strong> 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.</p>
                <p><strong>Google API data:</strong> KolHive's use and transfer to any other app of information
                    received from Google APIs will adhere to the <a
                        href="https://developers.google.com/terms/api-services-user-data-policy">Google API Services
                        User Data Policy</a>, 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.</p>
                <p><strong>Third parties we share with:</strong> Google, and the AI providers described above if you
                    let the assistant use your other Google data.</p>
                <p><strong>Consequences of not providing:</strong> 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.</p>

                <h5><strong>Approximate location, language and weather</strong></h5>
                <p>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 using ipwho.is
                    or ipapi.co, and fetch weather forecasts for that approximate location from Open-Meteo.</p>

                <h5><strong>Web search and web pages</strong></h5>
                <p>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, such as DuckDuckGo, Brave Search, Bing,
                    Mojeek, Wikipedia and GitHub. 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.</p>

                <h5><strong>Error reports</strong></h5>
                <p>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. You can turn this off under Settings, Help, Diagnostics.</p>

                <h5><strong>Sharing and publishing</strong></h5>
                <p>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.</p>

                <h5><strong>Notifications</strong></h5>
                <p>If you allow notifications, we deliver them through Google Firebase Cloud Messaging and Apple's
                    push notification service, using an identifier for your device.</p>

                <h5><strong>When you interact with us on social media</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Social Media Account</li>
                    <li>Content of interaction (text, images, etc.), including metadata (for example, timestamp)
                    </li>
                </ul>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To process and answer questions</li>
                    <li>To provide support</li>
                    <li>To review our services</li>
                    <li>To process your feedback</li>
                </ul>
                <p><strong>Third parties we share with:</strong> The 3rd party social media platforms may have access to
                    the data communicated.</p>
                <p><strong>Consequences of not providing:</strong> Cannot contact with you on social media.</p>

                <h5><strong>Google Calendar</strong></h5>
                <p>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.</p>
                <p>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.</p>
                <p>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.</p>

                <h5><strong>When you turn on speaker recognition</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Voice signatures: numbers calculated from short samples of a speaker's voice in your recordings</li>
                    <li>Face signatures: numbers calculated from a speaker's face in frames of your video recordings</li>
                    <li>The names and pictures you give to the speakers you save</li>
                    <li>Which speakers in your recordings match the speakers you saved</li>
                </ul>
                <p><strong>How we collect it:</strong> 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.</p>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To show who is speaking in your recordings and suggest names and pictures for them</li>
                    <li>To keep the speakers you saved available on all your devices</li>
                </ul>
                <p>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.</p>
                <p><strong>Third parties we share with:</strong> 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 AI provider of the selected model (Google
                    Gemini by default) 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.</p>
                <p><strong>Consequences of not providing:</strong> Speakers are not recognized automatically. You can
                    still name them yourself.</p>

                <h5><strong>When you use KolChat messages and calls</strong></h5>
                <p>KolChat messages, voice messages, photos, videos, files, reactions and calls are end-to-end
                    encrypted. They are encrypted on the sender's device and can be decrypted only on the devices
                    of the people in that chat or call. We cannot read, watch or listen to them, and we cannot give
                    them to anyone.</p>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Your KolChat profile: display name, "about" text, profile photo and your privacy choices</li>
                    <li>Your phone number, if you add it</li>
                    <li>The KolChat accounts you save as contacts, so we can apply your "my contacts" privacy
                        choices</li>
                    <li>Information about your devices that is needed to deliver messages: device identifiers,
                        platform, public encryption keys and push-notification tokens</li>
                    <li>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; who
                        joined a call or meeting and when; when you are online and when you were last seen</li>
                    <li>Encrypted messages and encrypted files while they wait to be delivered</li>
                    <li>If you join a meeting as a guest without an account: the name you type and your IP
                        address</li>
                    <li>Accounts you block, and reports you send, including any messages you choose to add to a
                        report</li>
                </ul>
                <p><strong>How we collect it:</strong> 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 Google Firebase. 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.</p>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To deliver your messages, files and calls to the right people and devices</li>
                    <li>To let people who have your phone number, email address or invite link find you, according
                        to your settings</li>
                    <li>To notify you about new messages and incoming calls</li>
                    <li>To show your profile, online status and last seen according to your privacy choices</li>
                    <li>To prevent spam and abuse and to keep accounts secure</li>
                </ul>
                <p><strong>Third parties we share with:</strong> Notifications are delivered through Google Firebase
                    Cloud Messaging and the Apple Push Notification service; 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 devices when possible, which lets the devices see each other's IP address. In larger group calls, the device of one of the participants may pass the call on to the others; that device receives the call like any participant. If someone transcribes a call or meeting, everyone in it sees a notice. When a network does not
                    allow a direct connection, the encrypted call passes through a relay operated by Cloudflare, which
                    cannot decrypt it. 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 Cloudflare. 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.</p>
                <p><strong>Voice message transcripts:</strong> When you tap Transcribe on a voice message, your device
                    decrypts it and sends the audio to Google Gemini 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.</p>
                <p><strong>Consequences of not providing:</strong> 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.</p>

                <blockquote>
                    <p><strong>Additional Uses:</strong> 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.</p>
                </blockquote>

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

                <blockquote>
                    <p><strong>Legal bases (European Economic Area and United Kingdom):</strong> 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.</p>
                </blockquote>

                <h4><strong>2. HOW WE PROTECT AND RETAIN YOUR INFORMATION</strong></h4>

                <h5><strong>2.1. Security</strong></h5>
                <p>We have implemented appropriate technical, organizational and security measures designed to protect
                    your Personal Data, including:</p>
                <ul>
                    <li>KolHive connects to our servers over encrypted connections (HTTPS/TLS).</li>
                    <li>Files you store are kept in Cloudflare R2, which encrypts stored files with AES-256. Connected
                        Google account authorizations and synced voice signatures are also encrypted in our database.</li>
                    <li>Your password is handled by Google Firebase Authentication, and full payment-card details by
                        PayPal, Apple or Google. Neither is stored on our servers.</li>
                    <li>You can lock the App on your device with your device's biometrics or a code.</li>
                    <li>Our servers are hosted by Hetzner in Germany, in data centers that Hetzner states are certified
                        to ISO/IEC 27001. Google lists Generative AI on Vertex AI and Firebase Authentication within the
                        scope of its ISO/IEC 27001 certification and SOC 2 reports, and RunPod states that it holds
                        ISO/IEC 27001 certification and has completed SOC 2 Type II examinations. These certifications
                        belong to those providers, not to the Company.</li>
                </ul>
                <p>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.</p>

                <h5><strong>2.2. Retention of your Personal Data</strong></h5>
                <p>We keep Personal Data only as long as we need it for the purposes in this Privacy Policy:</p>
                <ul>
                    <li><strong>Account information:</strong> while your account exists.</li>
                    <li><strong>Your content</strong> (files, recordings, transcripts, documents and apps): until you
                        delete it or your account.</li>
                    <li><strong>Chats with the assistant:</strong> 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.</li>
                    <li><strong>Records of AI requests</strong> (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.</li>
                    <li><strong>Usage records</strong> (which model was used, token counts and credits, without the
                        content of your requests): while your account exists.</li>
                    <li><strong>Purchase records:</strong> for as long as tax and accounting laws require, including
                        after you delete your account.</li>
                    <li><strong>Error reports and technical logs:</strong> 7 to 90 days, depending on how serious the
                        error is.</li>
                    <li><strong>Voice and face signatures of a saved speaker:</strong> 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.</li>
                    <li><strong>KolChat:</strong> KolChat 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. 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.</li>
                    <li><strong>Age band:</strong> 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.</li>
                    <li><strong>Support requests:</strong> as long as needed to handle your request and keep a record
                        of it.</li>
                    <li><strong>Mailing list and waitlist:</strong> until you unsubscribe. We keep a record of your
                        consent and unsubscription.</li>
                    <li><strong>Records of your acceptance</strong> 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.</li>
                </ul>
                <p>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:</p>
                <ul>
                    <li><strong>(i)</strong> where we are required to do so in accordance with legal, regulatory, tax or
                        accounting requirements</li>
                    <li><strong>(ii)</strong> for us to have an accurate record of your dealings with us in the event of
                        any complaints or challenges</li>
                    <li><strong>(iii)</strong> if we reasonably believe there is a prospect of litigation relating to
                        your Personal Data or dealings</li>
                </ul>

                <h4><strong>3. HOW WE SHARE YOUR PERSONAL DATA</strong></h4>
                <p>In addition to the recipients described above, we may share your Personal Data as follows:
                </p>
                <ul>
                    <li><strong>3.1.</strong> With service providers that process Personal Data on our behalf, such as
                        the hosting, storage, AI, email and payment providers named 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.</li>
                    <li><strong>3.2.</strong> 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.</li>
                    <li><strong>3.3.</strong> 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.
                    </li>
                    <li><strong>3.4.</strong> 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.</li>
                    <li><strong>3.5.</strong> 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.</li>
                </ul>
                <p>We do not sell your Personal Data, and we do not share it with third parties for their own
                    advertising or marketing.</p>
                <p><strong>3.6.</strong> If you want to receive the list of the current recipients of your Personal
                    Data, please make your request by contacting us to <a href="mailto:info@kolhive.com">info@kolhive.com</a>.
                </p>

                <h4><strong>4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA</strong></h4>
                <p><strong>4.1.</strong> 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. Cloudflare stores files and
                    delivers our Websites from its global network. Google processes AI requests through Vertex AI's
                    global endpoint, which can route a request to any region where capacity is available. RunPod's GPU
                    servers may be located in different countries. Some of our providers are based in the United
                    States.</p>
                <p><strong>4.2.</strong> 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 <a
                        href="mailto:info@kolhive.com">info@kolhive.com</a>.</p>

                <h4><strong>5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT</strong></h4>

                <h5><strong>5.1. Rights</strong></h5>
                <p><strong>5.1.1.</strong> Depending on the law that applies to you, you have some or all of the
                    following rights:</p>
                <ul>
                    <li><strong>a.</strong> 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.</li>
                    <li><strong>b.</strong> You have the right to request that we rectify or erase any Personal Data we
                        hold that is inaccurate or misleading.</li>
                    <li><strong>c.</strong> 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.</li>
                    <li><strong>d.</strong> You have the right to receive Personal Data you gave us in a portable format.</li>
                    <li><strong>e.</strong> Where we rely on your consent, you have the right to withdraw it at any
                        time.</li>
                    <li><strong>f.</strong> 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.</li>
                </ul>

                <p><strong>5.2.</strong> You can exercise your rights by contacting us at <a href="mailto:info@kolhive.com">info@kolhive.com</a>. 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.</p>

                <p>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.</p>

                <p><strong>5.3. Deleting your account:</strong> You can delete your account in the App under Settings,
                    Security, Delete account, or by emailing <a href="mailto:info@kolhive.com">info@kolhive.com</a> 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.</p>

                <p><strong>5.4. Marketing emails – opt-out:</strong> You may choose not to receive marketing email of
                    this type by sending a single email with the subject "BLOCK" to <a href="mailto:info@kolhive.com">info@kolhive.com</a>.
                    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.
                </p>

                <h4><strong>6. CHILDREN AND TEENS</strong></h4>
                <p>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.</p>
                <p><strong>Age range from your device.</strong> 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.</p>

                <h4><strong>7. INTERACTION WITH THIRD PARTY PRODUCTS</strong></h4>
                <p>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 "<strong>Third Party Service</strong>"). 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.</p>

                <h4><strong>8. ANALYTIC TOOLS</strong></h4>
                <p>KolHive's apps and Websites do not contain advertising trackers or third-party analytics tools. The
                    App sends the error reports described in section 1, and our servers keep the technical logs needed
                    to run KolHive and keep it secure.</p>

                <h5><strong>Log Files</strong></h5>
                <p>We use log files to administer KolHive, keep it secure, and find and fix problems.</p>

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

                <h4><strong>9. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW</strong></h4>

                <p>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 <a
                        href="mailto:info@kolhive.com">info@kolhive.com</a>. We will not discriminate against you for
                    exercising them.</p>

                <p><strong>9.1. California Privacy Rights:</strong> 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 <a href="mailto:info@kolhive.com">info@kolhive.com</a>. Please note that
                    we are only required to respond to one request per customer each year.</p>

                <p><strong>9.2. Our California Do Not Track Notice:</strong> 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.</p>

                <p><strong>9.3. Deletion of Content from California Residents:</strong> 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.</p>

                <h4><strong>10. CONTACT US</strong></h4>
                <p>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 <a href="mailto:info@kolhive.com">info@kolhive.com</a>.</p>
            </div>