Kinzoo Together Privacy Policy

Effective Date: May 11, 2026

Last Updated: April 2026

Introduction and Scope
Who We Are
What Data We Collect
How We Use Your Data
Advertising on Kinzoo Together
Children's Privacy (COPPA — US)
GDPR and GDPR-K — EU and UK Users
Canadian Users — PIPEDA and Quebec Law 25
California Users — CCPA/CPRA
How We Share Your Information
International Data Transfers
Data Retention
Your Rights
Security
Third-Party Links and Services
Changes to This Policy
Contact Us
Version History

1. Introduction and Scope

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Welcome to Kinzoo Together ("Together," "we," "our," or "us").

Kinzoo Together is a video calling app designed to connect families across generations — grandparents and grandchildren, parents and cousins, aunts and uncles. It is a place for real connection. Our core promise: we will never manipulate children, build profiles on them, or collect information we don't need.

This Privacy Policy applies specifically to Kinzoo Together. It is a standalone document, separate from the privacy policies for other Kinzoo products.

This policy applies to:

Adults who use Together as participants or account holders
Children who participate in calls through an account set up by an adult
Everyone who uses the Together iOS app, Android app, or any web-based interface we may offer

By using Kinzoo Together, you agree to the practices described in this Privacy Policy. If you are setting up or managing an account that a child will use, you are agreeing on their behalf.

2. Who We Are

Kinzoo Technologies Inc. is the company behind Kinzoo Together. We are incorporated in Canada and operate globally.

Kinzoo Technologies, Inc.

1066 – 999 W Hastings St

Vancouver, BC V6C 2W2

Tel: (604) 868-9719

Or use our online form to get in touch

For Data Subjects in the EU/UK:

We value your data subject rights under GDPR and therefore appointed GDPR-Rep.eu as representative according to Art 27 GDPR and provide you with an easy way to submit us privacy related request like a requests to access or erase your personal data. If you want to make use of your data subject rights, please visit: https://gdpr-rep.eu/q/15974644

3. What Data We Collect

We collect as little as possible. Here is exactly what we collect and why.

3.1 Adult Users

When an adult creates an account or participates in Together, we collect:

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Data	Why We Collect It
Name	Account personalization
Email address	Account creation, login, and communications
Password (encrypted)	Account security
Country or region	To apply correct legal protections
Profile type selection (Adult or Kid)	Set by you at sign-up to establish account role
Payment information	If you subscribe to a paid plan — processed by our payment provider; we do not store card numbers
Device type and operating system	To deliver the app
App version	For troubleshooting
Call metadata (duration, timestamp, participants)	To provide the service and for safety
IP address	Network routing and fraud prevention; not retained beyond session

3.2 Child Users

Children join Together by selecting"Kid" as their profile type at sign-up, or by being invited into a call by an adult account holder. We collect the minimum possible from child users.

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Data	Why We Collect It
First name	To identify them in calls
Profile type (Kid)	Set by user at sign-up

That is all we collect from child users. We do not collect:

Email addresses from children
Date of birth or age
Location data
Behavioral data or usage profiles
Advertising identifiers linked to child profiles
Any data used to profile or target children

3.3 Video Call Data

Kinzoo Together does not record, store, or retain the content of video or audio calls. Calls are transmitted between participants in real time and are not retained on our servers.

We do not collect or retain:

Video footage or recordings
Audio recordings
Face geometry, face recognition data, or any biometric identifiers
Images from video streams

This means there is no biometric data collection. If this ever changes, we will update this policy, notify users, and obtain consent where required.

3.4 Automatically Collected Technical Data

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Data	Why We Collect It
Crash logs and error reports	To fix bugs
App usage patterns (screens visited, features used)	To improve the app
Network type	To optimize call quality
Advertising identifier (adult users only)	For contextual ad delivery — see Section 5

Kinzoo Together does not record, store, or retain the content of video or audio calls. Calls are transmitted between participants in real time and are not retained on our servers.

We do not link advertising identifiers to child profiles. Child users' device data is not used for any advertising purpose.

4. How We Use Your Data

We use data only for the purposes listed below. We do not sell personal data to third parties.

4.1 Purposes and Legal Bases

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Purpose	Legal Basis (GDPR Art. 6)	Applies To
Providing the video calling service	Performance of contract (Art. 6(1)(b))	All Users
Account creation and management	Performance of contract (Art. 6(1)(b))	Adult Users
Child safety and abuse prevention	Legitimate interests (Art. 6(1)(f))	All Users
Improving app performance	Legitimate interests (Art. 6(1)(f))	All Users
Processing payments	Performance of contract (Art. 6(1)(b))	Paying Subscribers
Service communications (account notices)	Performance of contract (Art. 6(1)(b))	Adult account holders
Marketing communications	Consent (Art. 6(1)(a))	Adult users who opt in
Legal obligations	Legal obligation (Art. 6(1)(c))	All Users
Contextual advertising to adult users	Legitimate interests (Art. 6(1)(f))	Adult users on free tier
Contextual advertising to child users	See ⚠️ flag in Section 5	Child users on free tier

4.2 Purposes and Legal Bases

For child users, we process only what is strictly necessary to provide the service:

We do not build behavioral profiles of children
We do not use children's data for advertising targeting
We do not share children's data with advertising partners
Children see contextual-only ads based on the general app context — not based on any data about them personally (see Section 5)

5. Advertising on Kinzoo Together

5.1 Our Advertising Model

Kinzoo Together uses contextual advertising only. This means:

Ads are matched to the general context of the app (for example, a "family video calling app" category) — not to your personal profile, browsing history, or behavior
No behavioral targeting. We do not build profiles of any user — adult or child — for advertising purposes
No interest-based advertising. We do not track users across apps or websites to serve targeted ads
No user profiling for ads. Neither adult nor child user data is used to construct an advertising profile

This policy applies to all users. It is not limited to children.

5.2 Who Sees Ads

Adult users on the free tier: Will see contextual ads
Child users on the free tier: Will see contextual ads
Subscribers (paid tier): No ads

5.3 What We Commit To — All Users

Regardless of advertising model:

No behavioral targeting for any user
No user profiling for any user
No interest-based ads for any user
No cross-app tracking for advertising purposes
No child data used for any advertising purpose beyond context —the contextual signal is the app category, not anything about the child
All ads are clearly labeled as advertisements
No manipulative advertising techniques (countdown timers, false urgency, dark patterns)

5.4 How Contextual Ads Work on Together

Contextual ads are served based on:

The general category of the app (family/video calling)
General, non-personal signals such as device type and approximate region

Contextual ads do not use:

Your name, age, or any profile data
Your call history or behavior in the app
Children's first names or any child account data
Any persistent advertising identifier linked to a child user profile

5.5 Ad Partners

Kinzoo Together works with the following third-party advertising partners to deliver contextual ads within the app:

Google AdSense (Google LLC)
Google AdMob (Google LLC)
Kidoz (Kidoz Ltd.)

Ads are selected based solely on contextual signals (e.g., content category, general app context) —never based on user profiles, browsing history, or cross-app tracking.

5.6 Ad-Free Option

Subscribers to a paid individual plan see no advertising. Subscriptions are individual — there is no family subscription. Each adult account holder manages their own subscription.

5.7 Your Choices

Subscribe: Upgrade to a paid individual plan to remove all advertising.
Global Privacy Control (GPC): We honor GPC signals from supported browsers as an opt-out of sale/sharing of personal information under CCPA/CPRA.
Opt out of ad personalization on your device: You can reset or limit your device advertising identifier through your iOS or Android device settings. This has no effect on contextual ad delivery, which does not rely on advertising identifiers.

6. Children's Privacy (COPPA — US)

This section addresses our obligations under the U.S. Children's Online Privacy Protection Act (COPPA), which protects children under 13.

6.1 How Together Works With Children

Kinzoo Together is a mixed-age platform — adults and children participate in the same product. It is not directed solely at children, but children under 13 do use it. We comply with COPPA in full.

6.2 Account Setup for Child Users

When a child uses Kinzoo Together, they select "Kid" as their profile type at sign-up. We collect only their first name. No email address, date of birth, location, or other personal information is collected from child users.

The adult who creates the call session (for example, a grandparent) is the account holder. Children join via invite from that adult.

6.3 What We Collect From Children

As described in Section 3.2, we collect only:

First name (for display in calls)
Profile type (Kid) — set by the user at sign-up

We do not collect children's email addresses, precise location data, behavioral data, date of birth, or any information used for advertising targeting.

6.4 Parental Rights Under COPPA

Parents and guardians have the right to:

Review the information stored about their child (first name, profile type, and call participation logs)
Delete their child's account and all associated data
Refuse further collection or use of their child's information

To exercise these rights, contact us at privacy@kinzoo.com. We will respond to verified parental requests within 30 days.

6.5 No Behavioral Advertising to Children

We do not behaviorally target children. We do not build advertising profiles of children. We do not share child user data with advertising partners. Children on the free tier see contextual ads only —see the ⚠️ compliance note in Section 5.2.

This section applies to users in the European Economic Area (EEA), the EU, and the United Kingdom (UK).

7.1 Legal Basis for Processing

Our legal bases for processing personal data are set out in Section 4.1. Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of prior processing.

7.2 Children and Age of Digital Consent (GDPR-K)

Under GDPR Article 8, the age at which a child can consent to online services without parental involvement varies by EU member state:

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Age of Digital Consent	Member States
13	Belgium, Denmark, Estonia, Finland, Latvia, Malta, Portugal, Sweden
14	Austria, Bulgaria, Cyprus, Lithuania, Spain
15	Czech Republic, France, Greece, Slovakia, Slovenia
16	Croatia, Germany, Hungary, Ireland, Italy, Luxembourg, Netherlands, Poland, Romania

For children below the applicable age of digital consent in their country, GDPR requires verifiable parental consent before processing their personal data and — under GDPR-K guidance — before showing them advertising.

7.3 EU/UK Representative

Kinzoo has appointed a representative in the EU and UK as required under GDPR Article 27 and UK GDPR. Contact information:

7.4 Your Rights Under GDPR

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Right	What It Means
Right of access	Request a copy of personal data we hold about you
Right to rectification	Ask us to correct inaccurate data
Right to erasure	Ask us to delete your data (subject to legal exceptions)
Right to restrict processing	Ask us to pause processing your data
Right to data portability	Request your data in a portable format
Right to object	Object to processing based on legitimate interests
Rights re: automated decision-making	We do not make automated decisions with legal or significant effects on users

Contact us at privacy@kinzoo.com to exercise any of these rights. We respond within 30 days (or one month under GDPR, extendable to three months for complex requests). We may ask you to verify your identity.

You also have the right to lodge a complaint with your local data protection authority (DPA) — for example, the Data Protection Commission (Ireland), the ICO (UK), or the CNIL (France).

8. Canadian Users — PIPEDA and Quebec Law 25

8.1 PIPEDA

Kinzoo Technologies Inc. is a Canadian company and complies with the Personal Information Protection and Electronic Documents Act (PIPEDA).

Under PIPEDA, you have the right to:

Access the personal information we hold about you
Challenge the accuracy or completeness of your information
Withdraw consent to the collection, use, or disclosure of your information (subject to legal or contractual limitations)

Contact us at privacy@kinzoo.com to exercise these rights. We will respond within 30 days. If you are not satisfied, you may contact the Office of the Privacy Commissioner of Canada (OPC).

8.2 Quebec — Law 25

Privacy by default: We apply the most privacy-protective settings by default, particularly for child users.
Privacy Impact Assessments (PIAs): We conduct PIAs before launching new features or partnering with new technology providers.
We collect only what is necessary. Data minimization: We collect only whatis necessary.
Breach notification: We notify affected individuals and the Commission d'accès à l'information (CAI) of privacy breaches that present a risk of serious injury.
Right to portability and de-indexation: Quebec residents may request that we cease disseminating their personal information or de-index identifying content in applicable circumstances.

9. California Users — CCPA/CPRA

This section applies to California residents under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

9.1 Your Rights

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Right	What It Means
Right to know	What personal information we collect, use, and share
Right to delete	Ask us to delete your personal information
Right to correct	Ask us to correct inaccurate personal information
Right to opt out of sale/sharing	Opt out of sale or sharing for cross-context behavioral advertising
Right to limit sensitive personal information	Limit certain sensitive information uses
Right to non-discrimination	We won't discriminate against you for exercising your rights

9.2 Do We Sell Personal Information?

We do not sell personal information as defined under the CCPA. We use contextual advertising only and do not share personal data with ad partners for behavioral advertising purposes. Sharing data with contextual ad partners for non-profiling, non-behavioral purposes does not constitute "selling or sharing" under CPRA.

9.3 Global Privacy Control (GPC)

We honor GPC signals. If your browser or device sends a GPC signal, we treat this as an opt-out of sale and sharing of personal information for cross-context behavioral advertising. No additional action is required from you.

9.4 How to Exercise Your Rights

Contact us at privacy@kinzoo.com. We respond to verifiable consumer requests within 45 days (extendable by 45 days where necessary).

9.5 Children Under 16 — Law 25

We do not sell or share the personal information of users we know to be under 16. Children are excluded from behavioral advertising. Child user data is not shared with advertising partners under any circumstances.

We do not sell personal information. We share data only as follows:

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Recipient	What Is Shared	Purpose
Service providers (hosting, infrastructure)	Account and technical data	Delivering the service
Payment processors	Payment information	Processing subscriptions
Contextual ad partners	General app context signal only; no user profile data	Delivering contextual ads to adult users and child users on free tier
Safety and law enforcement	Data required by law or necessary to prevent harm	Legal compliance, child safety
Business successors	Account data in event of merger/acquisition (with notice to users)	Business continuity

We never share children's personal data (first name, profile data, call logs) with advertising partners. Contextual ad delivery does not require sharing any child personal data — it is based on app-level context only.

We require all service providers and ad partners to maintain appropriate data protection standards and to use data only for the specific purposes we authorize.

11. International Data Transfers

Kinzoo Technologies Inc. operates from Canada. Your data may be processed in Canada, the United States, or other countries where our service providers operate.

For EU/EEA and UK users: When we transfer personal data outside the EEA or UK, we use appropriate safeguards including:

Standard Contractual Clauses (SCCs) approved by the European Commission
The UK International Data Transfer Agreement (IDTA), as applicable
EU adequacy decisions where applicable (Canada is recognized as adequate by the EU Commission for PIPEDA-governed transfers)

We do not transfer children's personal data internationally beyond what is necessary to deliver the service, and any such transfers are subject to the same protective safeguards.

12. Data Retention

We retain personal data only as long as necessary for the purposes for which it was collected, or as required by law.

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Data Type	Retention Period
Adult account information	Duration of account + 2 years for legal compliance
Child profile data (first name, profile type)	Until account is closed or user deletes account
Call metadata (timestamps, participants)	90 days, then deleted
Video/audio call content	Not retained — calls are not recorded or stored
Payment records	7 years (legal/tax requirements)
Crash logs and app diagnostics	90 days

When an account is deleted, we delete or anonymize personal data within 30 days, unless retention is required by law.

13. Your Rights

A summary of privacy rights by jurisdiction:

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Right	Canada (PIPEDA)	US (CCPA)	EU/UK (GDPR)
Access your data	✓	✓ (CA residents)	✓
Correct your data	✓	✓ (CA residents)	✓
Delete your data	✓	✓	✓
Data portability	Limited	✓ (CA residents)	✓
Opt out of advertising	N/A (contextual only)	✓	✓ (consent withdrawal)
Lodge a complaint with regulator	OPC	State AG / FTC	Local DPA
Parental rights for child accounts	✓	✓ (COPPA)	✓

To exercise any of these rights, contact us at privacy@kinzoo.com.

14. Security

Our security measures include:

End-to-end encryption for all video calls
Encryption at rest for stored personal data
Access controls — only authorized personnel access personal data, on a need-to-know basis
Regular security assessments and penetration testing
Vendor security reviews — we require third-party providers to maintain appropriate security standards

If you suspect unauthorized access to your account, contact us immediately at support@kinzoo.com.

Data breach notification: If a breach occurs that poses a risk to your rights and freedoms, we will notify affected users and relevant regulatory authorities as required by applicable law.

15. Third-Party Links and Services

Kinzoo Together may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to read their privacy policies before providing them with any information.

We do not knowingly direct child users to third-party websites or services that do not comply with applicable children's privacy laws.

16. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes — especially changes that affect how we handle children's data or advertising practices — we will:

Notify account holders by email or in-app notification
Update the "Last Updated" date at the top of this policy
For material changes affecting children's data, obtain fresh parental consent where required

Your continued use of Kinzoo Together after any change constitutes acceptance of the updated policy (except where consent is legally required).

17. Contact Us

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please email us at privacy@kinzoo.com or use our online form to get in touch. Please note that your communications with us may not necessarily be secure. Therefore, please do not include credit card information and/or other sensitive information in your communications with us.

Any comments, questions, concerns or complaints regarding your personal information or our privacy practices may be sent to our Privacy Officer as follows:

Attention: Privacy Officer, Kinzoo Technologies, Inc.