Privacy Policy — Kina (Android)

Company / Controller: HippolyteDev (France)

Effective Date: 1st January 2026

Applies to: the Kina Android application and our website at: https://www.jely-studio.com/home (together, the “Services”).

1. Scope and roles

1.1 What this Privacy Policy covers

This Privacy Policy explains how HippolyteDev (“HippolyteDev”, “we”, “us”) collects, uses, shares, and protects information when you use the Services, and the choices and rights available to you.

1.2 Data controller

For the purposes of the EU General Data Protection Regulation (“GDPR”) and other applicable data protection laws, HippolyteDev is the data controller of the personal data processed under this Privacy Policy, unless expressly stated otherwise.

1.3 Contact

You may contact us about privacy matters at:
Email: hdev-contact@jely-studio.com

If you are in the EU/EEA, you also have the right to lodge a complaint with your local supervisory authority (in France, the CNIL).

2. Key definitions

For clarity in this Privacy Policy:

• “Personal Data” means information that identifies or can reasonably be linked to an identifiable individual.

• “User Content” means content you choose to create, record, upload, transmit, or store through the Services (including images, recordings, and other media).

• "Processor” means a service provider that processes Personal Data on our behalf under contract.

• “Device Data” means data about the device and how the Services are accessed and used.

3. Who the Services are for (18+)

The Services are intended for adults aged 18 and over. We do not knowingly collect Personal Data from anyone under 18. If you believe a minor has provided Personal Data to us, please contact us and we will take appropriate steps to delete it.

4. Personal data we collect

We collect Personal Data in three main ways: (a) data you provide, (b) data collected automatically from your device and use of the Services, and (c) data received via third parties when necessary to provide core functionality.

4.1 Data you provide to us

Depending on how you use Kina, you may provide:

(a) Account data

• Email address

• User ID (or account identifier created by the Services)

(b) User Content and communications

• Images, audio, recordings, or other content you create/record/upload through your device camera, microphone, or media storage when you choose to do so

• Any messages, prompts, or other information you submit in-app (if applicable to features)

Important note on User Content: User Content may contain information about you or others, including potentially sensitive information depending on what you choose to capture or upload. Please do not upload content you are not permitted to share.

4.2 Data we collect automatically

When you use the Services, we may automatically collect:

(a) Device and usage information

• Device language and device country/region (e.g., from device settings)

• App activity and usage signals necessary to operate and secure the Services (e.g., feature interactions, basic diagnostics)

(b) Push notification identifiers

• A push token or similar identifier used to deliver notifications to your device (e.g., via Android push services)

4.3 Purchases and subscriptions (Google Play Billing)

If you purchase paid features or subscriptions, transactions are processed through Google Play Billing. We typically receive limited purchase information necessary to enable your purchase and provide support, such as:

• Purchase status, product identifier, subscription status, and purchase/transaction tokens or receipts
  We do not receive or store your full payment card details from Google Play.

4.4 Information we do not intentionally collect

Unless your use of the Services necessarily involves it, we do not intentionally collect:

• Government IDs

• Precise GPS location (unless a feature clearly requires it and you expressly permit it)

If this changes, we will update this Privacy Policy and, where required, provide additional notices or obtain consent.

5. Permissions and device access (camera, microphone, storage, notifications)

5.1 Camera / microphone / media storage

Kina may request access to:

• Camera (to capture images or video)

• Microphone (to record audio)

• Device media storage (to upload or save media)

We request these permissions only to enable user-initiated features, such as when you press a capture/record button or choose to upload content. You may refuse or revoke these permissions at any time in your device settings, but some features may not function without them.

5.2 Notifications

If you enable notifications, we use notification permissions and push identifiers to deliver app-related messages (such as feature updates, account/service messages, and other operational notifications). You can disable notifications in your device settings.

6. How we use personal data (purposes)

We use Personal Data for the following purposes:

6.1 To provide and operate the Services

• Create and manage your account

• Enable core functionality, including features requiring User Content

• Provide language translation features (where applicable)

• Process and validate in-app purchases and subscriptions (via Google Play Billing metadata)

6.2 To secure, maintain, and improve the Services

• Monitor performance, reliability, and stability

• Detect, prevent, and respond to fraud, abuse, and security incidents

• Debug and fix errors, and improve features and user experience

6.3 To communicate with you

• Send essential service communications (e.g., operational notices)

• Respond to your support requests and inquiries

6.4 To comply with legal obligations

• Meet legal, regulatory, and tax requirements (where applicable)

• Enforce our rights and resolve disputes

7. Legal bases for processing (GDPR)

Where GDPR applies, we process your Personal Data under the following legal bases:

7.1 Contract (Article 6(1)(b))

Processing necessary to provide the Services you request, including account creation, enabling features, and providing purchased functionality.

7.2 Legitimate interests (Article 6(1)(f))

Processing necessary for our legitimate interests in operating, securing, and improving the Services (e.g., fraud prevention, service integrity, basic diagnostics), provided those interests are not overridden by your rights.

7.3 Consent (Article 6(1)(a))

Where required, we rely on your consent—such as for optional notifications or any feature that requires consent under local law. You can withdraw consent at any time (withdrawal does not affect processing already carried out).

7.4 Legal obligation (Article 6(1)(c))

Processing necessary to comply with applicable laws.

8. How we share personal data

We do not sell your Personal Data. We share Personal Data only as described below:

8.1 Service providers (processors)

We use third-party service providers to support core functionality, including:

• Backend infrastructure and hosting

• Database hosting

• Real-time communication (if features require it)

• Language translation services

• Push notification delivery services

• Customer support tooling (if applicable)

These providers process Personal Data on our behalf under contractual obligations designed to protect it and limit use to providing services to us.

8.2 Google Play Billing

Google processes payments for purchases/subscriptions and provides us limited transaction metadata necessary to enable your purchase and provide support.

8.3 Legal and safety disclosures

We may disclose Personal Data where we believe it is reasonably necessary to:

• Comply with law, regulation, legal process, or governmental request

• Protect the rights, safety, and security of users, the public, or HippolyteDev

• Investigate and help prevent security issues, fraud, or abuse

8.4 Business transfers

If we are involved in a merger, acquisition, restructuring, or sale of assets, we may transfer Personal Data as part of that transaction, subject to appropriate confidentiality and notice where required by law.

9. International data transfers

Because the Services are available worldwide and we use service providers that may operate globally, your Personal Data may be processed in countries outside your country of residence, including outside the EU/EEA.

Where GDPR applies and Personal Data is transferred outside the EU/EEA, we will use appropriate safeguards, such as:

• European Commission adequacy decisions (where applicable), and/or

• Standard Contractual Clauses (SCCs) and, where necessary, supplementary measures.

You may request information about transfer safeguards by contacting us.

10. Data retention

10.1 General approach

We keep Personal Data only as long as necessary for the purposes described in this Privacy Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements.

10.2 Account closure and deletion timeline (your stated process)

• Deletion requests: may be submitted within 7 days of account closure.

• Completion: once requested, we will permanently delete Personal Data associated with your account within a maximum of 30 days, subject to the limitations below.

10.3 Limited exceptions

We may retain certain data for longer where necessary to:

• Comply with legal obligations (e.g., accounting, tax, regulatory)

• Maintain security, prevent fraud, and protect against abuse

• Maintain limited records of consent, requests, and compliance actions

• Maintain logs and backup copies for a limited period as part of routine operations

If retained, data will be limited, protected, and kept only for the period required.

11. Your rights and choices

11.1 GDPR rights (EU/EEA/UK and similar regimes)

Subject to applicable law and verification of identity, you may have the right to:

• Access your Personal Data

• Rectify inaccurate or incomplete Personal Data

• Delete your Personal Data

• Restrict or object to certain processing

• Data portability (where processing is based on contract or consent and carried out by automated means)

• Withdraw consent at any time (where processing is based on consent)

To exercise rights, contact us using the details in Section 1.3. We may request information needed to verify your identity and process your request.

11.2 Notification controls

You can enable/disable notifications in device settings.

11.3 Device permissions

You can manage camera, microphone, and storage permissions within Android settings. Disabling permissions may limit certain features.

11.4 Account deletion

If Kina provides an in-app deletion mechanism, you can use it. Otherwise, you may request deletion through the contact method in Section 1.3, consistent with the timeline in Section 10.2.

12. California and certain U.S. state disclosures (if applicable)

This section applies only to the extent applicable under U.S. state privacy laws (e.g., California CCPA/CPRA).

12.1 Categories of personal information collected

We may collect the following categories:

• Identifiers (email, user ID, push token)

• Internet or electronic network activity information (app interactions and basic diagnostics)

• User content (images/audio/media you upload)

12.2 Purposes

Purposes are described in Section 6.

12.3 “Sale” / “Share”

We do not sell Personal Data for money. We do not share Personal Data for cross-context behavioral advertising as those terms are commonly defined under certain U.S. state laws.

If our practices change (e.g., we introduce targeted advertising), we will update this Privacy Policy and provide required opt-out mechanisms.

12.4 Your rights

Depending on your state of residence, you may have rights to access, delete, correct, and obtain information about our processing, and to opt out of certain types of processing. Contact us via Section 1.3.

13. Security

We implement appropriate technical and organizational measures designed to protect Personal Data against unauthorized access, loss, misuse, alteration, and disclosure. However, no system can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your credentials and securing your device.

14. Third-party links and services

The Services may link to or integrate with third-party services (for example, app store pages or external tools). Their privacy practices are governed by their own policies. We encourage you to review third-party privacy policies before using those services.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the Services, legal requirements, or our practices. We will post the updated version with a revised “Last Updated” date. Where required by law, we will provide additional notice or obtain consent.

16. How to contact us

For privacy questions, requests, or complaints, contact:
HippolyteDev
Email: hdev-contact@jely-studio.com