
            <h1>Privacy Policy</h1>
            <p>Last updated: October 22, 2026</p>

            <div>
                <p>This privacy policy ("<strong>Privacy Policy</strong>") governs how ITANU STUDIOS LTD ("<strong>ITANU</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 KolWrite via <a
                        href="https://www.kolwrite.com/">https://www.kolwrite.com/</a> (the "<strong>Websites</strong>")
                    or through our KolWrite applications, extensions and plug-ins for supported mobile, desktop, wearable
                    and web platforms (together, the "<strong>App</strong>"), or through our APIs and supported
                    integrations (the Websites, the App, APIs and integrations collectively, "<strong>KolWrite</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, KolWrite:
                        <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, AI credits or API Usage 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 record, upload, transcribe, translate or share content</li>
                            <li>When you interact with language model</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 KolWrite to you, to keep it secure, and as described
                            below. We do not sell your Personal Data, and KolWrite does not show ads.</li>
                        <li>When you use a cloud AI feature, the content needed for that request is sent to our processing infrastructure and contracted cloud-computing and AI-processing service providers, after you have given your consent in the App. The service terms for our managed AI processing restrict use of your content for model training without our permission, and we have not given that permission.</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> KolWrite and KolHive OS (available at <a
                            href="https://kolhive.com/">https://kolhive.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
                        KolHive Privacy Policy (<a
                            href="https://kolhive.com/privacy">https://kolhive.com/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 KolWrite or by email before the changes apply to you,
                    and we will ask for your consent where the law requires it. KolWrite 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@kolwrite.com">info@kolwrite.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 count visits and measure how fast our pages load</li>
                    <li>To administer the Website and fix faults</li>
                </ul>
                <p><strong>Third parties we share with:</strong> Contracted website-hosting, content-delivery and security service providers, including bot-prevention services that check sign-up forms, and cookie-free website analytics services that count visits and measure page speed. These services operate internationally as described in section 4.</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 our contracted authentication service 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, including
                        your choice about third-party AI processing</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, including watches and editing-software plug-ins</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> Our contracted authentication service, 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 KolWrite.</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> Our contracted business-email service provider, and the social-media or other platforms you choose to contact us on.</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</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</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> Contracted email-delivery and bot-prevention service providers, which deliver our emails and check that the sign-up is not made by a bot. These services operate internationally as described in section 4.</p>
                <p><strong>Consequences of not providing:</strong> Cannot send you marketing communications.</p>

                <h5><strong>When you provide billing information or make a purchase</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Billing contact name and email address</li>
                    <li>Company or organization name</li>
                    <li>Billing address and country</li>
                    <li>Tax identification number and purchase-order reference, where provided</li>
                    <li>Payment currency, package, price, tax, and credit details</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, AI credits or Usage 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> Payment processors such as PayPal, Apple and Google Play
                    (for purchases made through their stores), tax-document and accounting providers, and professional
                    advisers where required to complete the transaction, comply with law, prevent fraud, or maintain
                    financial records. 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 offer the requested billing
                    currency, calculate taxes, process the purchase or refund, or issue a required tax document.</p>

                <h5><strong>When you create, record, upload, attach, share or submit content for processing through
                        KolWrite</strong></h5>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Audio and video recordings, and relevant extracts</li>
                    <li>Transcript text, prompts, chat context, and selected text</li>
                    <li>Documents, images, audio, or video that you attach</li>
                    <li>Language and model selections, and technical request information</li>
                    <li>Other content you provide</li>
                </ul>
                <p><strong>How we collect it:</strong> We collect this information when you record content in
                    KolWrite, including on a watch, upload or attach a file, send media from a supported editing
                    application, enter or submit text, select existing content for processing, or otherwise request
                    that KolWrite process your content. We collect technical request information automatically when
                    the feature is used.</p>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To process and return the result you request</li>
                    <li>To store your content and keep it in sync across your devices</li>
                    <li>To operate, maintain, secure, troubleshoot, and support the Service</li>
                    <li>To measure your use of credits and storage</li>
                    <li>To prevent misuse and comply with legal obligations</li>
                    <li>To improve KolWrite 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, hosted by a contracted infrastructure provider in Germany, and with contracted file-storage service providers operating internationally. Processing that needs specialised hardware, such as speech recognition, speaker separation and video rendering, runs on GPU computers we operate ourselves in Israel or on contracted cloud GPU servers in other countries, using models we operate. AI features send the content needed for each request to the cloud-computing and AI-processing service providers described in "How AI features use your content" below. The processing locations are described in section 4. When you share content, the people you share it with receive it.</p>
                <p><strong>Consequences of not providing:</strong> We cannot process the request or provide the related
                    result.</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 KolWrite 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, KolWrite sends a few frames from the video and short parts of its transcript to the contracted AI-processing service provider for the selected model to find names that are said or shown, for example when someone introduces themselves or a name appears on screen. The AI provider is not asked to recognize anyone's face. This uses your AI credits.</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 meetings in KolWrite</strong></h5>
                <p>KolWrite lets you start, schedule and join audio and video meetings from your calendar. Meeting audio and video go directly between the participants' devices, encrypted. In larger meetings the device of one of the participants may pass the meeting on to the others. When a network does not allow a direct connection, the encrypted meeting may pass through a contracted network-relay service, which cannot decrypt it. We do not receive or store meeting audio or video.</p>
                <p><strong>Data we collect:</strong></p>
                <ul>
                    <li>Meeting details: title, scheduled time and length, settings (password, waiting room, guests)
                        and who hosts the meeting</li>
                    <li>Participants: the name each participant uses, whether they are signed in or a guest, their
                        type of device, and when they join and leave</li>
                    <li>IP addresses of participants, to connect them and to prevent abuse</li>
                    <li>Email addresses you enter to invite people</li>
                    <li>If meeting transcription is on: the transcript of what participants say, with their names, and,
                        if you turn on "Save recording", a recording of the meeting</li>
                </ul>
                <p><strong>How we collect it:</strong> From you and the other participants when you use meetings. A
                    meeting password is stored only in a coded (hashed) form.</p>
                <p><strong>Purpose:</strong></p>
                <ul>
                    <li>To run your meetings and let the people you invite, and guests, join</li>
                    <li>To send the invitations you ask for and add meetings to your calendar</li>
                    <li>To transcribe and summarize meetings when you ask</li>
                    <li>To keep meetings secure and to prevent abuse</li>
                </ul>
                <p><strong>Meeting transcription:</strong> Transcription is on by default for meetings you host and can be turned off at any time. Everyone in the meeting sees that it is being transcribed and by whom. When the free transcription model is installed on your device, the audio is transcribed on your device and does not leave it. Otherwise, short parts of the meeting audio, including other participants' voices, are sent to our contracted cloud AI-processing service provider to create the text, as described in the third-party AI consent, and this uses your AI credits. If you ask for a summary, the transcript is sent to the AI provider of the model you select. The transcript and summary are saved in your KolWrite account; a recording is saved only if you turned on "Save recording". You are responsible for telling participants and for getting any consent the law requires before you transcribe or record a meeting.</p>
                <p><strong>Third parties we share with:</strong> Invitation emails you ask us to send go through our
                    email provider and contain the meeting link. If your Google Calendar is connected, invitations can
                    also be sent through it (see Google Calendar). Anyone who has a meeting link (and its password, if
                    you set one) can join the meeting.</p>
                <p><strong>Consequences of not providing:</strong> You cannot use meetings. You can still record and
                    transcribe on your own.</p>

                <h5><strong>How AI features use your content</strong></h5>
                <p>The KolWrite assistant and other AI features are AI systems, not people. AI can make mistakes, so
                    check important information.</p>
                <p><strong>Your consent:</strong> Before KolWrite sends your content to third-party AI providers, it
                    asks for your explicit consent. You can withdraw it at any time in Privacy and AI settings.
                    Withdrawal stops future transfers to third-party AI providers and signs you out; it does not undo
                    processing that has already taken place.</p>
                <p><strong>What is sent and when:</strong> When you use a cloud AI feature, KolWrite sends the content
                    needed for that request, such as your recording or an extract of it, the relevant transcript or
                    conversation, files you attach or select, 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>Our processing infrastructure and contracted cloud-computing and AI-processing service providers run the models used for chat, transcription, summaries, translation, image generation, search within your content, and voice features.</li>
                    <li>Max uses advanced AI models, which may hand parts of a task to other models, on contracted cloud-computing infrastructure. Max is not available in every country.</li>
                    <li>Where a feature is configured to use a direct cloud AI API, the necessary request content is sent to that contracted AI-processing service provider.</li>
                </ul>
                <p><strong>No training on your content:</strong> We do not use your content to train AI models. Our managed cloud AI service terms restrict providers from using content to train or fine-tune AI models without our permission, or, for paid API processing, from using prompts or responses to improve their products. We have not given permission or opted into provider training.</p>
                <p><strong>What providers keep:</strong> These providers may keep content for a short time to run the service, including caches that speed up answers (up to 24 hours for a managed cloud AI cache), and logs to detect abuse of their services (up to 30 days for a direct cloud AI API), as their terms allow. We have not turned on optional logging of requests and answers in our managed cloud AI projects.</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>
                <p><strong>AI apps you connect:</strong> If you connect another AI app on your device to KolWrite, that app can read and act on your KolWrite content within the access you choose in Settings, and it sends what it reads to its own provider under your agreement with that provider. We do not control those apps or providers. You can remove an app's access at any time in Settings.</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 KolWrite to send one.
                    KolWrite cannot read your Gmail messages. Google Calendar is described under "Google Calendar"
                    above. 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 KolWrite 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> KolWrite'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 KolWrite and KolHive.</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 through public IP-geolocation services, and fetch weather forecasts for that approximate location from public weather-forecast services.</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. In the mobile and desktop apps this happens directly from your device. In the web app and the watch apps it goes through our servers, so those services see our servers rather than your device.</p>

                <h5><strong>Error reports and performance data</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. For every upload or download that fails, and for a small share of those that finish (at
                    most one in ten), the App also sends performance data: whether it was an upload or a download, what
                    kind of transfer it was, its size, how long it took, how many tries it needed and which route it
                    took. We add the country your request comes from. This data never includes file names, links or the
                    content of your files. We use it to find where transfers are slow and to make them faster. We keep
                    each record, linked to your account, for 7 days; after that only anonymous daily totals remain. You
                    can turn all of this off under Settings, Help, Diagnostics.</p>

                <h5><strong>Sharing with others</strong></h5>
                <p>When you share recordings, transcripts or files, 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.</p>

                <h5><strong>Notifications</strong></h5>
                <p>If you allow notifications, we deliver them through the push-notification service providers for your device platform, 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>

                <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 KolWrite under
                        our Terms of Use (account, content, features you request, sync, purchases and support); because
                        of our legitimate interests in keeping KolWrite secure, preventing misuse, fixing errors and
                        understanding how KolWrite is used (you can object to this); because the law requires it (tax,
                        accounting and legal requests); or with your consent (sending content to third-party AI
                        providers, 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>KolWrite connects to our servers over encrypted connections (HTTPS/TLS).</li>
                    <li>Files you store are kept in contracted cloud file storage that encrypts stored files with AES-256. Connected Google account authorizations and synced voice signatures are also encrypted in our database.</li>
                    <li>Your password is handled by our contracted authentication service, and full payment-card details by PayPal, Apple or Google. Neither is stored on our servers.</li>
                    <li>You can lock the App on your device with your device's biometrics or a code.</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> (recordings, transcripts, files and documents): 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>Upload and download performance records:</strong> 7 days, then only anonymous daily totals are kept.</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>Meetings:</strong> Meeting records (title, time and participants) are deleted from our servers 30 days after
                        the meeting ends. Meeting transcripts, summaries and recordings stay in your account until you
                        delete them.</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:</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, and of
                        your choice about third-party AI processing: 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, authentication, AI, email, network-relay, notification, security, analytics and payment service providers described in this Privacy Policy. We require them to use it only to provide their services to us and to protect it with the same or equal level of protection as described in this Privacy Policy and required by applicable law. Your account password and the card details you use to pay us do not reach our servers, so they are never sent to our cloud GPU or AI-processing service providers. 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@kolwrite.com">info@kolwrite.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. Contracted cloud-storage and content-delivery providers store files and deliver our Websites through global networks. Our managed cloud AI processing uses a global endpoint, which can route a request to any region where capacity is available. Contracted cloud GPU servers may be located in different countries. Some of our hosting, storage, authentication, AI, email, network-connection, notification, security and analytics service providers are based in the United States and process data internationally. You may request the current recipients of your Personal Data and information about their processing locations under section 3.6.</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@kolwrite.com">info@kolwrite.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@kolwrite.com">info@kolwrite.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@kolwrite.com">info@kolwrite.com</a> from
                    the email address of your account. Deleting your account deletes the shared account for both
                    KolWrite and KolHive, 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@kolwrite.com">info@kolwrite.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>KolWrite 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 KolWrite 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 (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>The KolWrite mobile, desktop and watch apps do not contain advertising trackers or third-party
                    analytics tools. The App sends the error reports and upload and download performance data described in section 1, and our servers keep the
                    technical logs needed to run KolWrite and keep it secure.</p>

                <h5><strong>Website analytics</strong></h5>
                <p>Our Websites and the KolWrite web app use a contracted website analytics service to count visits and measure how fast our pages load. It does not use cookies. The service operates internationally as described in section 4. You may request its identity and information about its processing locations under section 3.6.</p>

                <h5><strong>Google Analytics</strong></h5>
                <p>The legacy KolWrite web app at web.kolwrite.com uses a tool called "Google Analytics" to collect
                    information about use of that app, such as how often users visit, what pages they visit, and what
                    other websites they used before. We use this information to maintain and improve our products. We
                    do not combine the information collected through the use of Google Analytics with Personal
                    Information we collect.</p>
                <p>Google's ability to use and share information collected by Google Analytics about your visits is
                    restricted by the Google Analytics Terms of Service, and the Google Privacy Policy. You may learn
                    more about how Google collects and processes data specifically in connection with Google Analytics
                    at <a
                        href="https://www.google.com/policies/privacy/partners/">https://www.google.com/policies/privacy/partners/</a>.
                </p>
                <p>You may prevent your data from being used by Google Analytics by downloading and installing the
                    Google Analytics Opt-out Browser Add-on, available at <a
                        href="https://tools.google.com/dlpage/gaoptout/">https://tools.google.com/dlpage/gaoptout/</a>.
                </p>

                <h5><strong>Log Files</strong></h5>
                <p>We use log files to administer KolWrite, 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. To exercise the rights described in section 5, contact us
                    at <a href="mailto:info@kolwrite.com">info@kolwrite.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@kolwrite.com">info@kolwrite.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.</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@kolwrite.com">info@kolwrite.com</a>.</p>
            </div>
