Privacy Policy

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

• Account information: full name, email address, username, and profile photo
• Date of birth, collected at registration to verify the 18+ eligibility requirement set out in our Terms of Service. The date of birth is stored and not displayed publicly.
• Authentication credentials when registering with email and password
• Authentication data from social login providers (Google, Apple)
• Gift card delivery information you provide when redeeming a reward (typically your account email address, used to deliver the digital gift card code)
• Communications you send us, including support requests

1.2 Information Collected Automatically

• Device information: device type, OS version, unique identifiers
• A non-reversible device fingerprint derived from device and browser characteristics, used only to prevent referral abuse (e.g. same-device self-referral). We store a hash; the raw values are not retained.
• A salted hash of your IP address at referral time, used only to detect referral abuse across shared networks. The raw IP is not stored alongside the referral record.
• Usage data: features used, predictions made, leagues entered, session duration
• Log data: IP address, access timestamps, error logs, and crash reports
• Diagnostic data: stack traces, performance metrics, and non-fatal errors collected via Sentry for crash and error monitoring
• Push notification tokens issued by Apple Push Notification service (APNs) and Firebase Cloud Messaging (FCM) via Expo
• Country or region derived from your IP address (no precise GPS location)

1.3 Information Stored Only on Your Device

Biometric data (Face ID / Touch ID / fingerprint) used to unlock the App never leaves your device. Kinetic only receives a yes/no authentication result from the operating system — we never see, store, or transmit biometric templates or images.

1.4 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 and in-app purchase management), Firebase (analytics and push notification delivery), Expo (push notification delivery via APNs and FCM), Sentry (crash reporting and error monitoring), Amazon Web Services (cloud infrastructure, Canada region), and MongoDB Atlas (database hosting)
• Gift Card Fulfillment Partners: When you redeem KineticCoins for a digital gift card, we share the minimum information required to deliver the reward (typically your email address, the redemption amount, and the gift card brand) with the third-party fulfillment provider responsible for issuing the gift card code. The current provider is disclosed in-App at the moment of redemption and may change over time.
• Fraud Prevention: We maintain internal audit logs of account, payment, redemption, and administrative actions for fraud detection, financial reconciliation, and chargeback investigation. These logs are accessed only by authorized Kinetic personnel and are retained as part of our transaction records under Section 4.
• 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