Kini Privacy Policy
The short version
- We collect the minimum we need to run Kini: your email address, the workouts and activities you record, and limited technical data.
- Your Apple Health data, including step counts and recorded period days, never leaves your phone. We cannot see it. It is not synced, not backed up by us, and not sent to anyone.
- We use PostHog for product analytics to understand how people use the App and improve it. We rely on legitimate interests for this, and you can turn analytics off at any time in Settings.
- We do not sell your data or use it for cross-context behavioural advertising.
- You can delete your account and your data from within the App.
The rest of this page is the detail.
1. Who is responsible for your data
The joint controllers of your personal data are:
Amy Brumet and Nadia Kiamilev
Groninger Str. 37, 13347 Berlin, Germany
team@getkini.app
We operate Kini jointly. Either of us can answer a request about your data, and we have agreed between us that Amy Brumet is the first point of contact for privacy requests. Contacting either of us is enough to exercise your rights.
We have not appointed a Data Protection Officer, as we are not required to under Article 37 GDPR.
2. What we collect, why, and on what legal basis
2.1 Account data
What: your email address; your Supabase user ID; the sign-in method you used (Sign in with Apple or email code); account status; account creation and last sign-in timestamps. If you use Sign in with Apple and choose to hide your email, we receive only Apple's private relay address, not your real one. We never receive your Apple password.
Why: to create and secure your account, to sign you in, to link your data to you, and to contact you about the service.
Legal basis: performance of a contract with you, Article 6(1)(b) GDPR.
2.2 Training data
What: the workouts, plans, exercises, and one-off activities you record, including exercise names, sets, repetitions, weights, durations, dates and times, custom exercises you create, and any notes you add.
Why: to store your history, show it back to you, and sync it across your devices so you do not lose it when you change phones.
Legal basis: performance of a contract with you, Article 6(1)(b) GDPR.
Training records are personal data. Depending on what you enter, some entries may feel sensitive to you. We treat them with care and do not use them to infer health information.
2.3 Apple Health data (steps and recorded period days)
What: if, and only if, you grant permission, the App reads daily step counts and recorded menstrual flow days from Apple Health on your device.
Where it goes: nowhere. This data is read on your device, displayed on your device, and stored only on your device. It is not transmitted to us, not written to our servers, not included in sync, not included in any backup we hold, and not sent to any third party. We have no technical means of seeing it.
What we do not do: we do not predict periods, estimate cycle phases, infer ovulation or fertility, correlate your cycle with your performance, or use this data to change anything the App recommends or displays about your training.
Legal basis: your explicit consent, Articles 6(1)(a) and 9(2)(a) GDPR. Recorded menstrual flow is data concerning health and, in some readings, data concerning sex life, which is special category data under Article 9. We therefore ask for this separately and clearly, and you can use the rest of the App without enabling this feature.
Withdrawing consent: turn the feature off in the App under Profile at any time. Withdrawal takes effect immediately and does not affect the rest of the App. Because the data was only ever on your device, there is nothing for us to delete when you withdraw.
2.4 Technical and diagnostic data
What: when your device connects to our servers, our providers process technical information necessary to deliver the connection, including your IP address, request timestamps, and basic device and app version information. Our update provider receives your app version, platform, and device type when the App checks for an update.
Why: to deliver the service, keep it secure, detect abuse, and diagnose faults.
Legal basis: our legitimate interest in operating and securing the service, Article 6(1)(f) GDPR, and performance of a contract, Article 6(1)(b) GDPR.
We also use PostHog for product analytics. PostHog helps us understand how the App is used, which features are working, and where we can improve the experience.
We use analytics on the basis of our legitimate interests in improving and maintaining a simple product, fixing bugs, understanding basic usage trends, and making the App better over time. We keep analytics limited to what is reasonably necessary for those purposes.
We do not use PostHog for advertising, we do not sell analytics data, and we do not use it to make decisions about you that have legal or similarly significant effects.
You can turn off product analytics at any time in the App’s settings. If you turn it off, we will stop loading PostHog for your device going forward.
2.5 Support correspondence
What: if you email us, we hold your message, your email address, and our reply.
Why: to answer you and keep a record of the issue.
Legal basis: legitimate interest in providing support, Article 6(1)(f) GDPR, and where relevant, performance of a contract.
2.6 What we never collect
We do not collect: your precise or approximate location; your contacts; your photos or camera; your microphone; your browsing history; an advertising identifier; your name (unless you volunteer it in a support email or through Sign in with Apple); your date of birth; or any payment information, because the App is free and we take no payments.
3. Data stored only on your device
The following is written to a database on your phone and is never uploaded to us:
- Apple Health data, including steps and recorded period days
- workouts you are part way through, and unsaved set drafts
- your in-app settings and preferences, such as your units and step goal
- Live Activity display state
Deleting the App deletes this local data permanently. We cannot recover it.
4. Who we share data with
We do not sell your personal data. We do not share it for cross-context behavioural advertising. We do not disclose it to data brokers.
We use a small number of processors who handle data on our instructions and under a data processing agreement:
| Provider | What it does | Data involved | Where |
|---|---|---|---|
| Supabase | Database hosting, authentication, sync backend | Account data, training data, technical logs | European Union |
| Resend | Delivery of sign-in code emails | Email address, delivery metadata | United States |
| Expo / EAS | App builds and over-the-air updates | App version, platform, device type, IP address | United States |
| PostHog | Product analytics | App usage events, app version, device type, timestamps, and related event data | European Union |
| Apple | App Store distribution, Sign in with Apple, Apple Health framework | Account identifier; Apple Health data stays on device | United States and Ireland |
We may also disclose personal data where we are legally required to, for example in response to a valid order from a competent authority, or where necessary to establish, exercise, or defend legal claims. Where we are permitted to tell you, we will.
If we incorporate, restructure, or transfer the App to a company or successor, your data may transfer as part of that. We will tell you beforehand, and the new controller will remain bound by this policy or one no less protective.
5. International transfers
Some of our providers process data outside the European Economic Area, including in the United States. Where that happens, transfers are made under the European Commission's Standard Contractual Clauses, together with supplementary technical and organisational measures such as encryption in transit and at rest and access controls.
We configure PostHog to store analytics data in the European Union. However, some operational data relating to other providers may still be processed outside the EEA, including in the United States.
You can ask us for a copy of the relevant safeguards at team@getkini.app.
6. How long we keep data
| Data | Retention |
|---|---|
| Account data | For as long as your account exists |
| Training data | For as long as your account exists |
| Deleted account and its data | Erased from live systems within 30 days of your deletion request; purged from encrypted backups within a further 7 days |
| Server and security logs | Kept only for as long as our hosting provider retains them under our plan's standard log retention, which we do not extend. We do not copy them elsewhere or use them for any purpose beyond security and fault diagnosis. |
| Support emails | Up to 24 months after the issue is closed |
| Apple Health data | Never held by us; on your device until you delete the App or revoke access |
| Analytics event data | Kept only for as long as needed for product analytics and service improvement, and then deleted or anonymised according to our provider's retention settings |
We may keep a minimal record of a deletion (the fact that an account with a given identifier was deleted and when) where we need it to demonstrate compliance, on the basis of Article 6(1)(c) GDPR.
7. Security
We protect your data with measures appropriate to the risk, including:
- encryption in transit (TLS) for all traffic between the App and our servers;
- encryption at rest for our hosted database;
- row-level security so that an authenticated user can read only their own records, with no direct write access to database tables (all writes go through narrowly scoped, server-side procedures that validate ownership);
- session tokens held in the device's secure keystore (iOS Keychain via Expo SecureStore), not in general app storage;
- a separate on-device database file per account, so one person's data is not readable from another account on a shared device;
- access to production systems limited to the two of us, protected by multi-factor authentication;
- secrets and service keys held only in provider dashboards, never in the App or its published configuration.
No system is perfectly secure. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within 72 hours as required by Article 33 GDPR, and we will notify you directly without undue delay where Article 34 requires it.
8. Your rights under the GDPR
You have the right to:
- Access the personal data we hold about you, and receive a copy (Article 15).
- Rectification of inaccurate or incomplete data (Article 16).
- Erasure, the "right to be forgotten" (Article 17).
- Restriction of processing in certain circumstances (Article 18).
- Data portability: receive your data in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible (Article 20).
- Object to processing based on our legitimate interests, on grounds relating to your particular situation (Article 21).
- Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal (Article 7(3)). This applies to the Apple Health feature and, where relevant, to analytics.
- Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects (Article 22). We do not carry out any such processing.
How to exercise them. You can delete your account and its data yourself in the App under Settings. For anything else, email team@getkini.app. We will respond within one month, and will tell you if we need to extend that by up to two further months because the request is complex, as Article 12(3) permits. We do not charge for this.
We may ask you to confirm the email address on your account before we act on a request, so that we do not disclose your data to someone else.
Complaints. You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State where you live or work, or where the alleged infringement occurred (Article 77). Our lead supervisory authority is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin, https://www.datenschutz-berlin.de. We would appreciate the chance to resolve your concern first, but you are not required to come to us before going to them.
9. Your rights in the United States
If you live in a US state with applicable privacy law rights, you may have additional rights under that law.
We do not sell personal information, and we do not share it for cross-context behavioural advertising, as those terms are defined under the California Consumer Privacy Act. We have not done so in the preceding twelve months. We do not knowingly collect personal information from anyone under 18, so we do not sell or share the personal information of minors.
We do not process "sensitive personal information" for the purpose of inferring characteristics about you. Apple Health data, which would be sensitive if we held it, stays on your device and is never transmitted to us.
Use the same route as everyone else: delete in the App, or email team@getkini.app. We will verify your request against the email address on your account and respond within 45 days, extendable once by a further 45 days where permitted. If we decline a request, we will tell you why, and you may appeal by replying to our response with the word "Appeal"; we will decide the appeal within 45 days and tell you how to contact your state Attorney General if you disagree.
10. Deleting your account
You can delete your account and all data associated with it from the Profile section in the App.
When you do:
- your account record, and all workouts, activities, plans, and custom exercises stored on our servers, are deleted;
- the account database file on your device is removed;
- deletion is permanent and we cannot restore it;
- your data is removed from live systems within 30 days, and cycles out of our encrypted backups within a further 7 days.
Apple Health data does not need to be deleted by us, because we never receive it. To remove Kini's access to it, go to Profile > Apple Health and turn off access.
11. Children
Kini is not intended for anyone under 18, and we do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has given us personal data, contact team@getkini.app and we will delete it.
12. Automated decision-making and profiling
We do not carry out automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. The App displays your own records back to you; it does not score, rank, or make decisions about you.
13. Changes to this policy
We may update this policy. If a change materially affects how we handle your data, we will tell you in the App or by email before it takes effect, and, where the change relies on your consent, we will ask for that consent again.
The version number and effective date at the top of this page tell you which version is current. We keep previous versions available on request.
14. Contact
Amy Brumet and Nadia Kiamilev
Groninger Str. 37, 13347 Berlin, Germany
team@getkini.app