Privacy Policy
Effective Date: March 27, 2025 · Version 1.2
At Redak Code Inc., operating as Kinetic, we are committed to protecting your personal information. This Privacy Policy explains what data we collect, how we use it, with whom we share it, and your rights regarding your information. This policy applies to the Kinetic mobile application ("App") and all related services.
This policy is designed to comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Law 25, the EU General Data Protection Regulation (GDPR), and other applicable privacy laws.
1. INFORMATION WE COLLECT
1.1 Information You Provide Directly
- Account information: full name, email address, username, and profile photo
- Authentication credentials when registering with email and password
- Authentication data from social login providers (Google, Apple)
- Communications you send us, including support requests
1.2 Information Collected Automatically
- Device information: device type, OS version, unique identifiers
- Usage data: features used, predictions made, leagues entered, session duration
- Log data: IP address, access timestamps, error logs, and crash reports
- Country or region derived from your IP address (no precise GPS location)
1.3 Payment and Purchase Information
All in-app purchases are processed directly by Apple Inc. or Google LLC. Kinetic does not collect, store, or have access to your payment card information. We receive only transaction identifiers, purchase amounts, and subscription status.
2. HOW WE USE YOUR INFORMATION
- Create, verify, and manage your Kinetic account
- Provide, operate, and improve the App's features
- Process KineticCoin purchases, awards, and gift card redemptions
- Send account-related transactional notifications
- Send promotional communications (only with your consent per CASL)
- Analyze usage patterns to improve the platform
- Detect and prevent fraud and abuse
- Comply with applicable legal obligations
3. INFORMATION SHARING AND DISCLOSURE
We do not sell, rent, or trade your personal information to third parties. We may share your information with:
- Service Providers: RevenueCat (subscription management), Firebase (analytics, notifications), cloud infrastructure providers
- Legal Requirements: When required by applicable Canadian law, regulation, or court order
- Business Transfers: In the event of a merger or acquisition, with prior notice
4. DATA RETENTION
We retain your personal information for as long as your account is active. If you delete your account, we will delete or anonymize your personal information within 90 days. Financial and transaction records are retained for a minimum of 7 years to comply with Canadian tax and legal obligations.
5. YOUR PRIVACY RIGHTS
5.1 Rights Under PIPEDA (All Canadian Users)
- Access the personal information we hold about you
- Request correction of inaccurate information
- Withdraw consent to collection, use, or disclosure
- File a complaint with the Office of the Privacy Commissioner of Canada
5.2 Additional Rights for Quebec Residents (Law 25)
- Request deletion of your personal information
- Request that automated decision-making be reviewed by a person
- File a complaint with the Commission d'accès à l'information
5.3 Rights Under GDPR (European/UK Users)
- Right to Erasure, Restriction, Portability, and Object
- Right to lodge a complaint with your national supervisory authority
To exercise any rights, contact: privacy@kineticapp.ca
6. CONSENT AND CASL
We will only send you commercial electronic messages with your express or implied consent, as required by Canada's Anti-Spam Legislation. You may withdraw consent at any time.
7. CHILDREN'S PRIVACY
Kinetic is not directed to individuals under the age of 18 and does not knowingly collect personal information from minors. If we become aware that a child under 13 has provided us with personal information, we will delete it immediately.
8. APP TRACKING TRANSPARENCY (iOS)
On iOS devices, we may request permission to access your Advertising Identifier through Apple's ATT framework. We will always ask for explicit permission. You can manage this in your device settings.
9. DATA SECURITY
We implement industry-standard technical and organizational security measures including encryption in transit (TLS/HTTPS), encryption at rest, access controls, and regular security reviews. In the event of a data breach, we will notify affected users and the relevant authorities as required by law.
10. CROSS-BORDER DATA TRANSFERS
Your personal information may be stored and processed in Canada, the United States, or other countries where our service providers operate. We take steps to ensure comparable protection through contractual measures.
11. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. For material changes, we will provide at least 14 days' advance notice through the App or by email.
12. CONTACT US
Kinetic Privacy Officer
Email: privacy@kineticapp.ca
General Support: support@kineticapp.ca
Redak Code Inc., operating as Kinetic
Hamilton, Ontario, Canada
You also have the right to contact the Office of the Privacy Commissioner of Canada: www.priv.gc.ca · Toll-free: 1-800-282-1376