Privacy Policy

Version 1.1. Last updated: 13 October 2026. (In the app, Kinu records which version of this policy you accepted, with the date. The website does not ask you to accept this policy; on the website your cookie choices are stored in your own browser.)

1. Who we are (Data Controller)

Ayesha Nazir (“Kinu”, “we”, “us”) is the controller of your personal data under the EU General Data Protection Regulation (GDPR). Kinu is currently operated byAyesha Nazir as an individual; company and registration details will be added here once it is incorporated.

• Address: Brennerstr. 90, 13187 Berlin, Germany
• Privacy enquiries: admin@kinuhealth.com

This policy covers both the Kinu mobile app and the Kinu website (https://kinuhealth.com).

2. The short version

• Kinu is a personal wellness and self-tracking app. It is not a medical device and gives no diagnosis, prediction, or medical advice.
• We collect the health information you choose to log and the minimum identity data needed to run your account.
• Your identity and your health data are stored separately, linked only by a random pseudonym, so your medical records carry no name or email.
• We process health data only with your explicit consent, which you can withdraw at any time.
• We do not sell your data, show ads, or run analytics or tracking inside the app.
• Your health data is stored in the EU (Frankfurt, Germany).
• You can delete your account and erase your health data from within the app.

3. The data we collect

3.1 Account and identity data

• Name (or preferred name), provided at sign-up.
• Email address, for sign-in and account communication.
• Date of birth / age, collected once as an eligibility check (Kinu is for users aged 16 and over, see section 12).
• Sign-in identifiers, depending on how you sign in: email and password, or an identifier from Sign in with Apple or Google Sign-In.
• Consent records: which consents you gave, the policy version, and the dates.

3.2 Health data (special category data, GDPR Article 9)

This is what you log in the app. It is stored under your pseudonym, not your name:

• Diagnoses and conditions you record.
• Symptoms and their severity (a 0 to 4 scale), with optional notes.
• Lab results you enter or scan, including the reference range printed on your own lab report and the test date.
• Medications and supplements, doses, and taken or missed logs.
• Activities, habits, and appointments you track.
• Body-weight measurements, where you log them.

3.3 Lab-report scanning (processed, not stored)

When you scan or upload a lab report, the file is sent to our secure cloud function and on to Google Document AI (EU) to read the text, in memory only. The report file is never written to storage and its contents are never logged. Only the values you review and confirm are saved, under your pseudonym. See section 7.

3.4 Technical and security data

• App Check attestation and sign-in tokens, used to confirm requests come from a genuine, unmodified copy of the app and from your account.
• Operational logs from our infrastructure provider (Google Firebase), which contain no health data.
• Crash reports, if the app crashes: what went wrong, your device model and system version, whether the device is jailbroken, the app version, and random identifiers for this installation. They contain no name, email, account identifier or health data. They are sent only after you have accepted the Terms and this policy, and are kept for 90 days. Provider: Google Firebase Crashlytics.
• Feature settings: when the app opens, and when you come back to it, it asks our provider which features are switched on. The request carries technical details about the app, including a random installation identifier and the app version, and your device's country, language, time zone and system version. It contains no account identifier or health data. Everyone receives the same settings. Provider: Google Firebase Remote Config.

3.5 What the app does not collect

• No advertising, analytics, or third-party tracking tools run in the app. The app does send crash reports and fetch feature settings, as described in 3.4. No analytics or advertising tools are built into the app.
• No location data.
• Symptom photos are not stored anywhere (any photo control is preview-only).
• Lab-report files are not retained (see 3.3).

3.6 Website data

Separately from the app, the website (https://kinuhealth.com) processes:

• Hosting and server logs: the site is hosted by Hetzner Online GmbH on servers in Germany (EU). For security and stable operation, the server records standard log data (IP address, date and time, the page requested, referrer, and browser and operating-system information). Legal basis: our legitimate interest in a secure website (Art. 6 (1)(f) GDPR).
• Fonts: served from our own server, not from any third-party network, so visiting the site does not share your data with a font provider.
• Waitlist form: if you join the waitlist, we process the name and email you submit to send the updates you asked for. Legal basis: your consent (Art. 6 (1)(a) GDPR). The form is hosted on our own site and passes your details to Brevo (Brevo SAS, EU) as our email processor.
• Contact form (Professionals page): if you send us a message, we process your name, email and message to reply and, where relevant, add you to our professionals contact list. Legal basis: our legitimate interest in responding to your enquiry (Art. 6 (1)(f) GDPR). Also handled by Brevo (Brevo SAS, EU).
• Cookies and analytics: we use Google Analytics 4 (provided by Google Ireland Limited) to understand, in aggregate, how the website is used so we can improve it. It runs only if and after you accept through our cookie banner, on the basis of your consent (Art. 6 (1)(a) GDPR), and you can withdraw at any time from our Cookie page. It sets analytics cookies (_ga and _ga_<id>, lasting up to two years) and processes usage data such as the pages you view, your device and browser, and an approximate location. Google Analytics is configured not to store your full IP address. This can involve a transfer to Google in the USA, covered by the EU-US Data Privacy Framework and standard contractual clauses. If you decline, no analytics cookies are set and no analytics data is sent.
• Marketing cookies: if you accept marketing through our cookie banner, we may set advertising cookies from the ad platforms we use (such as Google Ads, Meta, LinkedIn or TikTok) to measure how our campaigns perform and show more relevant ads. These run only if and after you accept, on the basis of your consent (Art. 6 (1)(a) GDPR), can involve transfers outside the EU under appropriate safeguards, and you can withdraw at any time from the cookie button on any page. If you decline, no marketing cookies are set.

4. Why we use your data, and our legal bases

Explicit consent for health data. Because your health information is special category data, we ask for separate, explicit consent to process it, distinct from your acceptance of the Terms. You give this at sign-up, and Kinu records the version and date. You can withdraw it at any time (section 8): withdrawal stops processing going forward and, in Kinu, erases your logged health data while keeping your account, so you can re-consent to start fresh.

5. How your data is structured (pseudonymisation)

Kinu is built around a deliberate split between your identity and your medical data:

• Your identity record (name, email, consent state) holds only a random pseudonym, never your medical data.
• Your medical data is stored under that pseudonym, never under your name or email.
• Access requires two independent checks to agree, and the pseudonym-to-account link is held in a create-once registry so it cannot be forged.

On their own, your health records are not directly identifying.

6. Who we share data with (processors)

We never sell your data, and we never share your health data for advertising. On the website only, advertising platforms are used to measure our ads if, and only if, you accept marketing cookies (see section 3.6). We work with a small number of vetted providers under GDPR Art. 28 data-processing agreements (advertising platforms may act as joint controllers for the data their cookies collect):

We may also disclose data where legally required, or to establish, exercise, or defend legal claims.

7. Automated processing and AI

Kinu is deliberately descriptive, not interpretive:

• The app's personalisation is rule-based and fixed. Features such as the “Common for you” symptom shortlist and the report ordering organise and rank your own logged data by transparent rules. They do not use machine learning, make no predictions, and produce no diagnosis.
• Where your result includes a reference range from your lab report, Kinu shows your value and that range side by side. For your latest result, it also draws the range as a band on a line, with a dot at your value's position. The band and the dot are always the same neutral colour, whatever the value. Kinu does not label the value, give a verdict on it, or tell you what it means. That is for you and your doctor.
• Lab-report scanning uses AI-based text recognition (Google Document AI) only to read a report you chose to scan. Extraction happens in memory, and you review and confirm every value before anything is saved, so a person (you) is always in the loop.
• We make no solely-automated decisions with legal or similarly significant effects about you (GDPR Art. 22). We do not profile you for advertising or marketing.

EU AI Act. Kinu deploys no high-risk AI systems. The only AI-based component is the lab-report text-recognition service above. Any future feature that could infer or predict a health outcome would be assessed separately and is not part of the current product.

8. Your rights

Under the GDPR you have the right to access (Art. 15), rectify (Art. 16), erase (Art. 17), restrict (Art. 18), data portability (Art. 20), object (Art. 21), withdraw consent at any time (Art. 7 (3)) without affecting prior lawful processing, not be subject to solely-automated decisions with legal effect (Art. 22, see section 7), and lodge a complaint with a supervisory authority (Art. 77).

How to exercise them:

• Erasure and account deletion: in the app, Settings then Delete account. This removes your health data, your pseudonym claim, your onboarding answers, and your account.
• Consent withdrawal: in the app, Settings then Withdraw consent. This erases your logged health data while keeping your account; you can re-consent to start a fresh diary.
• Data export (portability): in the app, Settings, then Legal & account, then Export my data. You get a ZIP file with your profile, your consents and their history, and what you have logged, as spreadsheets and a data file, with a plain-language guide to every column.
• Access, rectification, portability, restriction, or objection: contact admin@kinuhealth.com. We respond within one month (extendable by two further months for complex requests, Art. 12 (3)).

Supervisory authority. You may lodge a complaint with your local data-protection authority.

9. International data transfers

Your health data is stored in the EU (europe-west3, Frankfurt). One exception: the sign-in system (Firebase Authentication) stores basic login details such as your email on Google infrastructure that may be located in the United States. That transfer is limited to login data and relies on the European Commission's Standard Contractual Clauses as a safeguard, so we do not describe the app as fully EU-resident while this is the case. Crash reports and feature-setting requests are handled by global Google services that may process them outside the EU, including in the United States. Google LLC is certified under the EU-US Data Privacy Framework, and Google's data processing terms for these services provide for the European Commission's Standard Contractual Clauses where the Framework is not available. Apple and Google process sign-in data under their own transfer mechanisms. Copies of safeguards are available on request at admin@kinuhealth.com.

10. How long we keep your data

• Account and health data: kept until you delete your account or withdraw consent, then erased as in section 8.
• Lab-report files: not retained, processed in memory only.
• Backups: encrypted database backups with point-in-time recovery are kept on a rolling basis and fully replaced within about 14 weeks, so residual copies in backups fall away within that window.
• Website server logs: kept only as long as needed for security, then deleted.
• Consent records: kept as long as needed to demonstrate lawful processing.
• On-device cache: the app's local cache is cleared on the next launch after you sign out.

11. How we protect your data

• Pseudonymisation of all medical data (section 5).
• Encryption in transit and at rest.
• App Check attestation, so the backend only serves genuine copies of the app.
• Deny-by-default access rules; medical data requires two independent ownership checks to agree.
• No file storage, cloud file storage is disabled entirely.
• Least-privilege administrative access; production changes require sign-off.

No system is perfectly secure, but we apply measures appropriate to the sensitivity of health data (GDPR Art. 32).

12. Children

Kinu is intended for users aged 16 and over. We do not knowingly collect data from anyone under 16. If you believe a child has given us data, contactadmin@kinuhealth.com and we will delete it.

13. Changes to this policy

We may update this policy. Material changes to how we process your health data will require your renewed explicit consent; Kinu records the version and date you accepted. We will notify you of significant changes via the app or email.

14. Contact

Privacy enquiries and to exercise your rights: admin@kinuhealth.com.
Postal address: Ayesha Nazir, as listed in our Imprint.

Kinu Health. Last updated: 13 October 2026.