Privacy notice
Draft for review by a qualified UK solicitor. This notice is not yet in force, and the words in square brackets still need filling in.
Last updated: [EFFECTIVE DATE]
The short version
Kur8 works on your phone. Your settings, your limits, the time you spend and, in parent mode, the activity summary all stay on your phone. We can't see them, and we don't sell or share them.
Kur8 never sees, keeps or sends your passwords or sign-in details for Instagram, Facebook, TikTok, YouTube, X or Snapchat. The only login we keep is your Kur8 account.
The information that reaches us is your Kur8 account (your email address, your password, your first name if you give it, and which messages you're happy to get), a random identifier for each of the two phones your subscription covers, what you choose to send us, such as an email to support, and limited purchase information from Apple, which RevenueCat checks for us. In parent mode the account is the parent's. Nothing about the child reaches us: only a random identifier for their profile and for their phone.
Who we are
Kur8 is made by [COMPANY NAME], registered in England and Wales under company number [COMPANY NUMBER], at [REGISTERED ADDRESS]. For information we receive, we're the controller under UK data protection law. We're registered with the Information Commissioner's Office under number [ICO REGISTRATION NUMBER].
For any privacy question or request, email hello@getkur8.app.
What Kur8 keeps on your phone
Kur8 stores these things on your phone so it can work. They never leave the phone, and we don't receive them.
- Your sign-in to Kur8, and a copy of your account details so Kur8 opens without the internet. These are kept in your iPhone's Keychain. Your password isn't kept on the phone.
- Your choices: whether Kur8 is for you or your child, your limits, your filters, your daily allowance and how Kur8 looks.
- Your time and counts: minutes used, posts or videos seen, and posts hidden, for each channel. Daily totals are kept for 14 days, then deleted.
- Posts already counted: short identifiers for posts you've seen today, so a post isn't counted twice. These are cleared each day.
- Accounts you've chosen: the names of accounts you've asked Kur8 to hide or always show.
- Which terms you agreed to, and when.
- This phone's identifier: a random code Kur8 makes the first time it opens, kept in your iPhone's Keychain. It says nothing about the phone. A copy is kept with your Kur8 account so a subscription covers just two phones (see below).
- Your subscription: whether Kur8 is paid for, which plan and when it renews, as Apple and RevenueCat report it, so Kur8 opens without the internet.
- Filter rules: the lists of labels and page parts Kur8 hides. These aren't about you.
In parent mode, Kur8 also keeps:
- Which account the child's profile belongs to. The Kur8 account is the parent's, and the child's profile is held under it. The child doesn't have a Kur8 account of their own.
- Your child's first name, if you give it (it stays on the phone and isn't sent with the account), and the age you chose (13 to 17), to suggest starting limits.
- The parent PIN and recovery code, stored only as scrambled versions (hashes) in your iPhone's Keychain. Nobody, including us, can read the PIN back from them.
- The activity summary: totals of time and counts, which part of the day the time was used, limits reached, attempts to open a paused channel, more time given, settings changes, wrong PIN attempts and, once Screen Time is added, if its access was removed. Entries are kept for 14 days. The summary never records which accounts, posts, comments or messages were involved.
What Kur8 looks at but doesn't keep
To hide posts, Kur8's code reads the labels and text of the posts on your screen, such as "Paid partnership", "AI info", hashtags or an account name, and decides there and then whether to show each one. This happens on your phone. Apart from the counts and the accounts list above, nothing it reads is stored or sent anywhere.
Kur8's code doesn't run on the platforms' sign-in, account, password or message pages. It doesn't read what you type, and it never reads your messages. Snapchat's website is its chat, so there Kur8 only hides the parts you switch off, such as Spotlight, by how Snapchat's page names them, without reading anything on the page.
The camera and microphone
Kur8 asks for your camera and microphone so you can film a story or a snap on a platform's page inside Kur8. Your iPhone asks you first, and you can say no, or turn either off later in iPhone Settings. What you film goes straight from your phone to the platform, under its privacy policy. Kur8 doesn't see, hear, keep or send it. On a child's phone, the platforms' pages can't use the camera or microphone unless the parent turns this on in parent controls.
The platforms
When you open a channel, you're using that platform's own website, for example Instagram's, inside Kur8. You sign in on the platform's own page, and the platform collects information about you as it would in a web browser, under its own privacy policy. Kur8 never sees, keeps or sends your passwords or sign-in details for Instagram, Facebook, TikTok, YouTube, X or Snapchat. You sign in to those on their own pages. The only login Kur8 keeps is your Kur8 account. Kur8's code switches itself off on sign-in pages and on any page with a password box, and never reads what you type. The platform sets its own cookies and sign-in details on your phone, inside Kur8. Kur8 doesn't read, copy or send them, and they're deleted when you delete Kur8.
Kur8 doesn't add tracking to the platforms' pages, doesn't send them anything about you, and doesn't receive anything from them about you.
Read the platforms' own privacy policies to find out what they do: Meta for Instagram and Facebook, TikTok, Google for YouTube, X Corp. for X, and Snap for Snapchat.
Screen Time
Once Screen Time features are added, Kur8 uses Apple's Screen Time (Family Controls) to limit the platforms' own apps on your phone. You give permission on your phone, and you can take it away in iPhone Settings. Apple keeps the details of which apps you use on your phone. Kur8 is only given the apps you pick, in a form it can't read, and the time limits it needs to apply. The time it shows comes from Apple's report on your phone, and isn't sent to us.
What we receive
When you contact us
If you email us, we receive your email address, your message and anything you attach. We use it to reply and to put things right. Our lawful basis is our legitimate interest in answering you. We keep these emails for [24 months] after we last hear from you, then delete them, unless we need them for a legal claim.
The waitlist
If you join the waitlist on our website, getkur8.app, we keep your email address and the date you joined, so we can email you when Kur8 is in the App Store. Our lawful basis is your consent, and you can take it back at any time by emailing hello@getkur8.app or with the unsubscribe link in our email. The list is held by Supabase, our account provider, on its servers in London, and is kept apart from Kur8 accounts. We delete your address once we've told you Kur8 is out, or within [12 months] if it isn't, and we never use it for anything else or share it.
When you subscribe
Apple handles your payment. We don't receive your name, card details or Apple Account details. Apple tells us that a subscription is active, which plan it is, the country of purchase and the transaction details we need to confirm it and keep tax records. Our lawful basis is the contract with you, and for tax records our legal obligation. We keep transaction records for 6 years, as tax law requires.
We use RevenueCat, Inc. to check subscriptions for us. It receives the purchase information from Apple and your Kur8 account's random identifier, which isn't your name or email. It acts only on our instructions. RevenueCat is based in the United States, and holds this information there. [TRANSFER SAFEGUARD, FOR EXAMPLE THE UK ADDENDUM TO THE EU STANDARD CONTRACTUAL CLAUSES IN REVENUECAT'S DATA PROCESSING AGREEMENT.]
Information Apple shares with developers
If you've chosen in iPhone Settings to share analytics or crash reports with app developers, Apple may give us crash reports and statistics such as the number of downloads. Apple doesn't give us your name or contact details with these. You can turn sharing off in Settings, then Privacy and Security, then Analytics and Improvements.
Filter rule updates
[OPTIONAL: KEEP IF REMOTE RULES ARE SWITCHED ON] So filters keep working when the platforms change their pages, Kur8 may download updated filter rules from [RULES HOST]. As with any download, this reveals your phone's internet address to that server. Kur8 doesn't send anything else, and the server's logs are deleted after [30 days]. Our lawful basis is our legitimate interest in keeping Kur8 working.
Your Kur8 account
Your Kur8 account is the only login we keep. When you create one, we keep:
- your email address
- your password, which our account provider stores only as a scrambled version (a hash), so nobody, including us, can read it back
- your first name, if you give it
- which messages you're happy to get from us (see below)
- when the account was made, and a record of sign-ins (the time, internet address and device type) to keep it secure, kept for [SIGN-IN LOG PERIOD]
- if you use Sign in with Apple, the email address Apple gives us (this can be a private relay address that hides your real one), and your first name if you choose to share it
In parent mode the account is the parent's. We also keep a random identifier for the child's profile, so the child's phone can show it belongs to the parent's account. We never receive the child's name, age, limits, time or activity.
A subscription covers one phone for you and one for your child. To keep to that, Kur8 makes a random identifier on each phone and we keep it with your account, marked as yours or your child's. It says nothing about the phone itself. When you sign out, the identifier is removed.
We use this to give you your account and keep it secure. Our lawful basis is the contract with you, and for security, our legitimate interest in protecting your account. We send marketing messages only with your consent.
Our account provider is Supabase, Inc., which acts only on our instructions. Your account is held on its servers in London, United Kingdom [CONFIRM REGION]. Supabase is a US company, and its staff may sometimes reach the information from outside the UK to run and support the service. [TRANSFER SAFEGUARD, FOR EXAMPLE THE UK ADDENDUM TO THE EU STANDARD CONTRACTUAL CLAUSES IN SUPABASE'S DATA PROCESSING AGREEMENT.] Emails with sign-in codes are sent by [EMAIL PROVIDER].
Your account is kept until you delete it. Deleting your account in Kur8's Settings removes it from our servers straight away. Copies in backups are overwritten within [BACKUP PERIOD]. If an account isn't used for [INACTIVE PERIOD], we may email to ask whether to keep it, and delete it if we don't hear back.
Messages from us
We always send account and security emails, such as the code to confirm your address, a code to reset your password, or a note that your password changed. Product news, tips and invitations to give feedback start switched off, and we'll only send them if you switch them on in Kur8's account settings. You can switch them off again at any time there, or with the unsubscribe link in each email. We never send messages to a child.
What we don't do
- We don't keep a record of how you use Kur8. Only your Kur8 account is held online.
- We don't use advertising, analytics or tracking in Kur8.
- We don't sell or share information about you.
- We don't ask for your contacts, location or access to your photo library. When you add a photo or video to a post, your iPhone lets you pick just that one, and it goes straight to the platform.
- We don't make decisions about you that have legal or similarly significant effects. Kur8's filters decide which posts to show, but only following the settings you chose.
Children
Kur8 isn't for children under 13. Young people aged 13 to 17 can use Kur8 when a parent or guardian sets it up in parent mode. We've designed Kur8 to follow the ICO's Age Appropriate Design Code (the Children's Code): the child has no account, the child's information stays on their phone, the activity summary is totals only, and the child is always told that a parent set Kur8 up and what the parent can see.
There's a shorter notice written for young people, called "Your privacy in Kur8". Parents, please read it with your child.
For information in parent mode, our lawful basis is legitimate interests: the parent's and the child's interest in healthy, safe use of social media. We've weighed this against the child's interests and limited what's kept to totals only, held only on the child's phone.
Keeping information safe
The information on your phone is protected by your phone's passcode and Apple's encryption. The parent PIN is stored as a salted hash in the Keychain, and wrong attempts lock the keypad for longer each time. Your Kur8 account travels over encrypted connections, your password is stored only as a hash, each account can reach only its own information, and our account provider limits repeated sign-in attempts. Information you send us is kept in a secure email account, with access limited to the people who need it.
How long things are kept
Information on your phone stays until Kur8 deletes it, as described above, you delete your Kur8 account in Settings, or you delete Kur8. Deleting your Kur8 account removes it from our servers and removes everything Kur8 keeps on the phone, including a child's profile and the activity summary. Deleting Kur8 removes its settings, history and the platforms' sign-ins, but not your Kur8 account, so you can sign in again later. To remove the account, delete it in Settings, or email hello@getkur8.app. Your iPhone may keep the parent PIN record in its Keychain after Kur8 is deleted. It's only a scrambled version and can't be read, and if you set up parent mode again, Kur8 will ask for a new PIN.
Your rights
You have the right to:
- ask for a copy of information we hold about you
- ask us to correct it if it's wrong
- ask us to delete it
- ask us to limit how we use it, or object to how we use it
- ask for information you gave us in a format you can move to another service
Because almost everything stays on your phone, we usually hold nothing about you except your Kur8 account (with its two phone identifiers), emails you've sent us and purchase records. You can change your account details in Kur8's settings, and delete your account there at any time.
To use your rights, email hello@getkur8.app. We'll reply within one month. A parent can make a request for a child, and a young person can make their own.
Complaints
If you're unhappy with how we've handled information, please tell us first at hello@getkur8.app, and we'll do our best to sort it out. You can also complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint, or by calling 0303 123 1113.
Changes to this notice
If we change how Kur8 handles information, we'll update this notice and tell you in the app before the change applies. If Kur8 ever needs to send information off your phone, we'll explain what and why first, and ask you where the law requires it.