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Kidova Privacy Policy
Version [x.y], valid from [date]. German version: docs/legal/de/datenschutzerklaerung.md. [Counsel: decide which language version prevails.]
1. Who we are
The controller is [Company name, legal form], [street, postcode, city, Germany], email privacy@kidova.com, phone [number] ("Kidova", "we").
Data protection officer: [name or external DPO, contact] [or: counsel to confirm whether a DPO is required].
2. The short version
- Kidova is a VPN with kids protection and ad blocking. All our servers are in Germany.
- We do not store browsing history by default. We count blocked and allowed requests per category (for example "ads: 120 blocked"). We do not log which websites you or your children visit, destination IP addresses or DNS queries.
- Parents create the account. Children do not register and we do not ask for a child's name or birthdate. A nickname and an age band are enough.
- The child always sees that Kidova is active and what a parent can and cannot see.
- We do not sell data. We have no advertising or third-party analytics SDKs in our apps.
3. What we process, why, and on which legal basis
| Data | Purpose | Legal basis [counsel to confirm] | How long |
|---|---|---|---|
| Parent account: email, display name, role, language, passkey public keys | Account, login, security | Art. 6(1)(b) GDPR (contract) | Until account deletion |
| Family settings: family name, country, time zone | Provide the service, correct schedules and prices | Art. 6(1)(b) | Until account deletion |
| Child profiles: nickname, age band, protection settings, schedules, custom allow/block rules, app limits, approved video channels | Protect the child as instructed by the parent | [Art. 6(1)(b) and/or 6(1)(f); see DPIA §5.2] | Until the profile is deleted |
| Device data: platform, model, OS and app version, push token, last contact, protection state | Run the VPN, show protection status, send notifications | Art. 6(1)(b) | Until the device is removed |
| VPN data: device public key, tunnel IP addresses, time of last handshake, bytes per day | Run the VPN, show "protected", fair use and capacity | Art. 6(1)(b), 6(1)(f) | Key and tunnel IPs: until the device is removed; bytes per day: 90 days |
| Your device's public IP address | Needed to send VPN traffic back to your device | Art. 6(1)(b) | Kept in memory only, never written to disk |
| Activity counters: number of allowed/blocked/rewritten requests per profile, category and hour/day | Weekly reports for parents | [as for child profiles] | Hourly: 35 days. Daily: [13 months / per plan, see DPIA] |
| Detail mode (optional, off by default, Family Plus): blocked domain names with time and category | Lets parents see which blocked sites were requested | Art. 6(1)(a) (consent of the parent) | 7 days, then deleted automatically |
| Access requests and notes from the child, "wrong block" reports, bonus time | Let children ask for access, fix wrong blocks | [as for child profiles] | [retention to be set; proposal 30 days] |
| Tamper events (VPN switched off/on, permission removed) | Tell parents when protection stops | [as for child profiles] | 90 days |
| App usage minutes per app per day (child devices) | App limits, screen-time reports | [as for child profiles] | [to be set] |
| Billing: plan, status, amounts, provider references, invoices | Payment, invoices, legal accounting duties | Art. 6(1)(b), 6(1)(c) | Invoices and accounting records: [8/10 years, tax adviser to confirm] |
| Consents (type, version, time) | Prove consent | Art. 6(1)(c) with Art. 7(1) | [counsel] |
| Security logs, audit log (who changed what) | Security, preventing misuse, showing parents what changed | Art. 6(1)(f) | [proposal 13 months] |
| Support requests and diagnostics results (with your consent) | Help you | Art. 6(1)(b), 6(1)(a) for diagnostics | [proposal 2 years after last contact] |
| Crash reports (personal data removed on the device where possible) | Fix errors | Art. 6(1)(f) [or consent, counsel] | [proposal 90 days] |
| Website statistics (cookieless, aggregated) | Improve the website | Art. 6(1)(f) | See cookie statement |
What we do not do
- No logs of the websites or apps you use, of destination IP addresses, or of DNS queries (except detail mode above).
- No reading of messages, no screenshots, no keystroke logging, no location tracking.
- No decrypting of HTTPS traffic (no "TLS interception").
- No advertising profiles, no sale of data.
Honest limits
- Our "no logs" commitment is a technical and organisational rule of our service, enforced by how our software is built and who may access servers. Traffic passes through our servers, as with any VPN.
- If a law requires us to store or hand over data, we must comply.
[Counsel: current status of German IP-address retention, KIDOVA.md §9, §14.1.]We will update this policy and inform you before any such change takes effect, where the law allows.
4. Where the data is processed and who receives it
All Kidova servers, databases and backups are in data centers in Germany. Recipients:
| Recipient | Why | Location / safeguard |
|---|---|---|
| Contabo GmbH (hosting) | Our servers | Germany; data processing agreement (Art. 28 GDPR) |
[Backup provider] | Encrypted off-site backups | Germany; Art. 28 agreement |
[Email provider] | Login codes and reports by email | EU; Art. 28 agreement |
| Apple (App Store, push notifications), Google (Google Play, Firebase Cloud Messaging) | In-app purchases; push notifications | USA/worldwide; [EU–US Data Privacy Framework / standard contractual clauses, counsel to confirm] |
| RevenueCat | Manages app store subscriptions | [USA; safeguard] |
| Stripe | Web payments | [EU/USA; safeguard] |
[Tap, Whish, OMT, Areeba] (only if you pay with these, later markets) | Regional payments | [third country; safeguard] |
| Google (YouTube) | Curated video mode: our server searches channels for parents; the child's device plays videos in YouTube's embedded player (youtube-nocookie.com), which connects directly to Google | USA; [safeguard] |
| Authorities | Only when legally required | — |
Push notifications: we keep the content short and avoid sensitive details (for example "New request from Lina" rather than the website name). [Eng: implement, DPIA R-C9]
5. Children
Parents decide which protection their child gets. We designed Kidova so that:
- the child can always see that Kidova is active;
- the child app has a screen "What Kidova does" in the child's language, explaining what is blocked and what parents can see;
- older teens (16–17) see categories rather than websites unless detail mode is switched on, and then the teen is told.
More in our notice for parents:
docs/legal/en/children-notice.md.
6. How long we keep data
See the table in section 3. When you delete your account, we delete your data within [30] days. Encrypted backups are kept for up to 12 months and are deleted on a rolling schedule; deleted data is not restored into the live system from backups. Records we must keep by law (for example invoices) are kept for the legal period and then deleted.
7. Your rights
You have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), and to object to processing based on legitimate interests (Art. 21). You can withdraw consent at any time with effect for the future (Art. 7(3)), for example by switching off detail mode.
In the app and on app.kidova.com: Privacy center → Export data / Delete account. Or email privacy@kidova.com.
You can complain to a supervisory authority, in particular in your member state of residence or at our seat: [competent authority, address].
8. Security
Encryption in transit (WireGuard, TLS 1.3), encrypted storage and backups, access to servers only over a private management network with hardware security keys, audit logs, and regular security tests. [Counsel: keep this general.]
9. Automated decisions
We do not make decisions with legal or similarly significant effect based solely on automated processing (Art. 22). Blocking websites by category follows the settings the parent chooses.
10. Website
See our cookie and tracking statement (docs/legal/en/cookie-statement.md). Our website loads no third-party trackers and no Google Fonts.
11. Changes
We will announce material changes in the app and by email before they take effect.