Kilovoice Privacy Policy

Version: V1.0.0 Last Updated: August 5, 2026 Effective Date: August 5, 2026

Introduction

Top Stack Technology Co., Ltd. and the applicable entity operating Kilovoice ("we," "us," or "our") respect your privacy and the security of your personal data.

This Policy explains how we collect, use, store, share, transfer, and delete personal data when you use the Kilovoice iOS application and related cloud processing, account, subscription, and support services. It also explains your choices and rights.

For users in Mainland China, we will present this Policy and the Terms of Use before initializing non-essential SDKs, requesting system permissions, or processing non-essential personal data. We proceed only after you affirmatively agree. We do not use pre-checked boxes or infer consent merely from continued use.

If you do not agree, do not use features that require the relevant processing. Refusing optional processing will not prevent use of core features that do not depend on it.

1. Controller and Contact Details

Personal information handler/data controller:

If different entities provide the Services in different regions, we will identify each entity, its region, and responsibilities before release.

2. Scope

This Policy applies to:

  1. the Kilovoice iOS application;
  2. related recording upload, speech transcription, AI summarization, synchronization, account, and subscription services; and
  3. websites, customer support, and other services that expressly link to this Policy.

It does not govern third-party applications or websites you access through the system share sheet or external links. Those third parties process data under their own policies.

3. Personal Data We Process

We follow principles of lawfulness, fairness, transparency, purpose limitation, and data minimization. The data actually collected depends on the features you use, your permissions, and your region.

3.1 No Personal Data Collection Before Consent

For users in Mainland China, before you agree to this Policy, the App uses only static local resources included in the installation package to display the consent dialog. It does not collect personal data from the device or transmit it to a server, generate a user/device identifier, initialize non-essential analytics, attribution, or tracking SDKs, or request microphone, speech-recognition, notification, or App Tracking Transparency permission. The consent result is recorded only after you actively select an option.

3.2 Pseudonymous Identity, Account, and Sign-In Data

Signing in is not required for recording, importing, uploading, transcription, AI summaries, viewing data, or folder management. To distinguish signed-out users and associate data and benefits, we may process:

The device identity is stored in secure system storage and links the free allowance, membership benefits, recordings, imported files, and processing tasks while you are signed out. Because it persistently associates a device with content and transactions, it is a pseudonymous identifier rather than irreversibly anonymous information and may need to be declared as data linked to a user or device in the App Store privacy label. After sign-in, we may link the data and benefits to the signed-in account under the product rules.

3.3 Recordings, Imported Files, and User Content

When you actively use the relevant features, we may process:

Audio and transcripts may include voices, identities, conversations, locations, employment, education, health, financial, or other information about you or others. Some content may be sensitive personal data. Record, import, or upload content only when you have a lawful basis and have provided any required notice and obtained any required consent.

3.4 Subscription and Transaction Data

When you purchase a membership or restore a purchase, we may process:

Apple processes payment-card numbers, billing addresses, and other payment credentials. We do not receive your complete Apple ID password or complete payment-card details.

3.5 Device, Network, and Diagnostic Data

To provide, secure, and troubleshoot the Services, we may process:

If we release an Android version or a related SDK runs on Android, we may request or use the following permissions based on actual features:

The above fields and permissions are not all processed on every device simultaneously. Actual processing depends on operating system, device capabilities, SDK configuration, the features you use, and your authorization status. iOS does not provide IMEI, AndroidID, OAID, SIM IMSI, or other Android identifiers. We will not use device fingerprinting to bypass system permissions, ATT choices, or platform identification restrictions.

3.6 Usage and Product Analytics

Where we have obtained required consent or another lawful basis applies, we may record:

Analytics events are not intended to contain recording text, transcript text, summary text, or in-meeting note text. All production event fields must pass a pre-release data-inventory review.

3.7 Personal Data That Third-Party SDKs May Process

We are responsible for third-party code integrated into the App and require recipients of personal data to provide protection equal to or better than that described in this Policy and required by applicable law. After you agree to this Policy and use the relevant features, the following third-party SDKs or services may process device, network, app-usage, or diagnostic data on a minimum-necessary basis. Actual fields depend on the release platform, SDK version, final configuration, and the features you use; listing a field does not mean it is collected on every device.

3.7.1 Xuanhu SDK

3.7.2 Tencent Bugly SDK

3.7.3 Umeng+ SDK

3.7.4 Adjust SDK

3.7.5 Firebase SDK

3.7.6 Apple Services

3.7.7 Cloud Storage, Speech Recognition, and AI Services

For processing that requires consent or separate consent under applicable law, we will obtain your authorization before initializing the SDK or the relevant processing begins. Refusing non-essential analytics or attribution processing does not affect core features such as recording, playback, and viewing existing content.

Before release, the App and policy webpage will provide a complete inventory identifying at minimum each provider's full legal name, SDK or service name, purpose, fields, processing method, server region, privacy-policy link, and opt-out mechanism. Before adding or changing an SDK or third-party service, we will conduct a privacy and security review and update this Policy, the third-party inventory, iOS Privacy Manifest, and App Store privacy label.

3.8 Customer Support Data

When you contact us, we may process your email address, issue description, screenshots, device and App version, order identifier, and attachments you choose to provide. Do not send unrelated sensitive information or an Apple ID password.

3.9 Personal Data About Others

Recordings and imported files may include personal data about other people. You must ensure that you are legally permitted to provide it and have completed any notice, consent, or other lawful process required by applicable law.

4. System Permissions

The App may request the following iOS permissions:

  1. Microphone: to capture audio when you start a recording. If refused, recording is unavailable, but unrelated features remain available.
  2. Speech Recognition: when you actively enable live captions or a related system-recognition function. Refusal does not prevent audio recording or viewing existing content.
  3. Notifications: to notify you when audio upload, transcription, and summary generation have all completed while the App is not in the foreground. Refusal does not affect processing.
  4. App Tracking Transparency: with your permission, for attribution and campaign measurement. Refusal does not affect core functions or purchased benefits.
  5. File Access: through the system file picker, only to access audio files that you actively select for import.

You can manage permissions in iOS Settings. Withdrawing permission does not affect processing lawfully completed before withdrawal.

5. Purposes and Legal Bases

We may process personal data for the following purposes and legal bases.

5.1 Performing the Services Contract

This includes recording, saving, uploading, transcription, summary generation, playback, search, synchronization, sharing, account sign-in, benefit linkage, purchase validation, and support.

Under the GDPR or UK GDPR, the usual legal basis is performance of a contract or taking steps at your request before entering into a contract.

5.2 Your Consent

We rely on consent for microphone access, speech recognition, notifications, advertising tracking, processing sensitive data where separate or explicit consent is required, sharing personal data with another controller, and international transfers where required.

You can withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

5.3 Legal Obligations

We may process data for transaction records, consumer complaints, tax, lawful government requests, child protection, security-incident response, and other legal obligations.

5.4 Legitimate Interests and Security

Where permitted, we process data to prevent fraud, abuse, duplicate transactions, data loss, and cyberattacks, troubleshoot crashes, and improve performance.

Under the GDPR or UK GDPR, we rely on legitimate interests only where processing is necessary, those interests are not overridden by your rights and freedoms, and we have completed an appropriate balancing assessment.

5.5 Other Legal Bases in Mainland China

Where permitted by the Personal Information Protection Law, we may process information as necessary to enter into or perform a contract, fulfill legal duties or obligations, respond to a public-health emergency, protect life, health, or property in an emergency, or reasonably process information you have made public or that has otherwise been lawfully disclosed.

6. Sensitive Personal Data

Audio and transcripts may include biometric identifiers, health information, financial accounts, precise location, specific identity, religious beliefs, or information about children under 14, each of which may be sensitive personal information.

  1. We process sensitive data only for a specific purpose, where strictly necessary, and with enhanced safeguards.
  2. Where Mainland China law requires it, we explain the necessity and impact on individual rights and obtain separate consent.
  3. If audio contains another person's sensitive data, you must obtain separate consent or another lawful basis where required.
  4. Avoid recording or uploading sensitive data unrelated to the Service purpose.

7. AI and Automated Processing

  1. After you finish a recording or confirm an import, the App uploads audio under the feature workflow to disclosed cloud-storage/speech-recognition services to generate a transcript and speaker information. It then sends the transcript and context necessary for the feature to disclosed AI services to generate titles, summaries, and action items. Whether one provider supplies multiple stages, whether audio is sent directly to an AI provider, and deletion rules at each stage must be expressly disclosed before release based on the final architecture.
  2. Results may be inaccurate. AI output assists note-taking and is not used to make a solely automated decision that produces legal or similarly significant effects concerning you.
  3. Unless we separately and clearly notify you and obtain any consent required by law, we will not use identifiable private recordings or transcripts to train general-purpose AI models offered to the public.
  4. Final AI providers, processing regions, model-training settings, retention, and opt-out mechanisms must be verified and disclosed in the third-party inventory before release.

8. Sharing, Commissioned Processing, Transfers, and Disclosure

8.1 Service Providers and Commissioned Processing

We may engage cloud storage, speech recognition, AI, analytics, attribution, purchase-validation, and support providers to process necessary data. Contracts will limit purpose, term, method, data types, security, and return/deletion duties, and we will supervise their processing.

8.2 Sharing with Other Controllers

We do not disclose personal data to another controller except:

  1. after identifying the recipient, contact details, purpose, method, and data types, and obtaining separate consent where required;
  2. where necessary to complete a share, sign-in, purchase, or other instruction you initiate;
  3. where required by law or a lawful regulatory, judicial, or law-enforcement request;
  4. where necessary to protect life, property, or other vital rights and consent cannot reasonably be obtained; or
  5. in a merger, acquisition, reorganization, or asset transfer, provided that the successor continues to comply with this Policy and applicable law or obtains new consent where required.

8.3 Public Disclosure

We do not ordinarily make recordings, transcripts, or account data public. If public disclosure becomes necessary, we will provide notice and obtain separate consent where required, unless law provides otherwise.

8.4 Sale and Sharing for Targeted Advertising

We do not sell personal data for money.

If attribution processing is considered a "sale," "sharing," or targeted advertising under California or another applicable law, we will provide an applicable opt-out, honor legally valid preference signals such as Global Privacy Control, and respect your ATT choice.

9. International Transfers

Our overseas servers and main overseas service infrastructure are located in the United States. Therefore, when you use the Services from outside the United States, your personal data may be transferred to, stored in, and processed in the United States. Data protection laws in the United States may differ from those in your country or region.

  1. Transfer purposes: to provide account sign-in, recording upload and synchronization, speech transcription, AI content organization, subscription benefit validation, troubleshooting, security, and support.
  2. Possible data transferred: account and pseudonymous identity data, device and network data, usage and diagnostic data, subscription and transaction status, and audio, transcripts, summaries, action items, and other user content you actively upload or generate. Actual scope depends on the features you use and follows the minimum-necessary principle.
  3. Overseas recipients: may include our service infrastructure in the United States and providers that supply cloud storage, speech recognition, AI, analytics, attribution, security, and support services. Specific providers, purposes, data types, server regions, and privacy policies are disclosed in Section 3.7.
  4. European Economic Area, United Kingdom, and Switzerland: where data is transferred to the United States or another country without an adequacy decision, we will apply EU Standard Contractual Clauses, the UK International Data Transfer Addendum or Agreement, a Switzerland-approved mechanism, or another valid safeguard, supplemented where necessary by encryption, access controls, and transfer impact assessments.
  5. Other countries or regions: we will apply contractual, certification, consent, or other lawful transfer mechanisms required by local law and require recipients to process data only for agreed purposes with appropriate safeguards.

You may contact us at kilovoice@top-stack.com to learn about the transfer mechanisms applicable to your data or to request a copy of applicable safeguards to the extent permitted by law.

10. Storage and Retention

We retain personal data only for the shortest period necessary for the purposes described, unless law requires longer retention.

  1. Local recordings and drafts: until you delete them, remove the App, the device clears them, or feature rules provide otherwise. Whether removal of the App deletes data depends on iOS and backup settings.
  2. Cloud audio, transcripts, and AI content: until you delete the content or account and the legally required process is completed.
  3. Recently Deleted: an ordinarily deleted recording and its audio, transcript, summary, action items, in-meeting notes, folder association, and cloud copies remain together for 30 days. During that period they may be restored or permanently deleted. Voluntary permanent deletion or expiry starts the production-system deletion process.
  4. Account data: until account deletion is completed. Account deletion bypasses the Recently Deleted recovery period and deletes associated local/cloud audio, transcripts, summaries, action items, in-meeting notes, folders, identity, and benefit linkages. Production-system and isolated-backup deletion periods are [Insert before release]. Transaction evidence required for tax, consumer-protection, anti-fraud, or dispute purposes is isolated from operational data and deleted when the legal period expires.
  5. Device identity and signed-out data: until no longer used as a pseudonymous identity, account linkage is complete, or deletion is required. A signed-out user may use an in-App "Delete All Data" entry that must be implemented before release, or email kilovoice@top-stack.com with the current pseudonymous user ID, to request deletion of cloud audio, transcripts, summaries, action items, in-meeting notes, folders, usage allowance, and identifiers linked to that device identity. We will perform necessary verification. Valid transaction evidence may be isolated and retained for tax, consumer-protection, and dispute purposes.
  6. Transaction records: for periods required by applicable tax, accounting, consumer-protection, and anti-fraud laws.

When the purpose is fulfilled or the period expires, we delete, anonymize, or legally isolate the data.

11. Security

We use administrative, technical, and physical safeguards appropriate to risk, including:

  1. encryption in transit and appropriate encryption at rest;
  2. access controls, least privilege, authentication, and secure storage;
  3. access logging, anomaly monitoring, vulnerability remediation, and backups;
  4. provider security review and contractual controls;
  5. employee confidentiality, training, and access approval; and
  6. data-protection impact assessments and incident-response plans.

No online service can be absolutely secure. If personal data is or may be leaked, altered, or lost, we will promptly take remedial action and notify regulators and affected individuals as required by applicable law.

12. Your Rights and Choices

Depending on your location, you may have the right to:

  1. receive information and make decisions about processing;
  2. access and obtain a copy;
  3. correct or supplement data;
  4. delete data and your account;
  5. withdraw consent;
  6. restrict or refuse processing;
  7. data portability;
  8. object to legitimate-interest processing, direct marketing, or targeted advertising;
  9. not be subject to solely automated decisions producing legal or similarly significant effects;
  10. complain to a regulator; and
  11. receive non-discriminatory treatment for exercising privacy rights.

You can exercise choices by:

Deleting an account or signed-out identity does not automatically cancel an Apple subscription. You must cancel it separately in Apple ID subscription settings. Transaction evidence that law requires us to retain may remain isolated, but it will not be used to restore deleted recording content.

To protect account security, we may reasonably verify identity. We will respond within the period required by applicable law. If we deny a request, we will explain the reason and available appeal. An authorized agent must provide valid authorization and verification materials.

Withdrawing consent does not affect earlier lawful processing but may make a dependent feature unavailable.

13. Children

  1. The Services are not directed to children under 14 in Mainland China or children under 13 in the United States.
  2. Where law permits a minor to use the Services with guardian consent, we will obtain verifiable consent before collection and provide methods for access, correction, deletion, and stopping further processing.
  3. In Mainland China, information about a child under 14 is sensitive personal information. We will adopt specific rules and enhanced safeguards.
  4. If you believe we processed a child's data without valid consent, contact the privacy email. We will investigate and delete it or take other action as required by law.

14. Regional Disclosures

14.1 Mainland China

We process information under the Personal Information Protection Law, Cybersecurity Law, Data Security Law, Civil Code, Law on the Protection of Minors, Regulations on the Protection of Minors in Cyberspace, and other applicable rules.

Where required for sensitive personal information, disclosure to another handler, public disclosure, or an international transfer, we obtain separate consent and provide the required notice.

14.2 European Economic Area and United Kingdom

  1. Controller and representative details appear in Section 1 and must be completed before release.
  2. Legal bases include contract, consent, legal obligation, and appropriately balanced legitimate interests.
  3. You may complain to a data-protection authority in your habitual residence, workplace, or place of an alleged infringement.
  4. If processing is based on consent, you may withdraw it at any time. If based on legitimate interests, you may object.
  5. You may request information about applicable international-transfer safeguards.

14.3 California

In the preceding 12 months, we may have processed identifiers, customer records, commercial information, internet or electronic-network activity, audio information, inferences, and protected classifications or sensitive personal information contained in content users choose to provide.

Purposes and recipient categories are described in Sections 3, 5, and 8. We do not sell personal information for money. If applicable attribution activity constitutes "sharing" under the CCPA, we will provide a "Do Not Sell or Share My Personal Information" or equivalent mechanism and honor valid Global Privacy Control signals.

California residents may request to know, access, correct, delete, limit use or disclosure of sensitive personal information, opt out of sale/sharing, and receive non-discriminatory treatment. Specific rights depend on statutory thresholds and exceptions.

14.4 Other U.S. States

Where privacy laws in Colorado, Connecticut, Virginia, Utah, Texas, Oregon, or another state apply, we will provide applicable rights of access, correction, deletion, portability, opt-out of targeted advertising/sale/certain profiling, and appeal.

14.5 Brazil, Canada, Australia, Japan, South Korea, and Other Regions

Where local privacy law applies, we will comply with mandatory requirements concerning consent, transparency, international transfers, security, access, correction, deletion, complaints, and data-subject rights. This Policy does not limit rights available under applicable law.

15. Apple App Store Privacy Requirements

  1. A link to this Policy will be available in App Store Connect and in an easily accessible in-App location.
  2. We will individually disclose in App Store Connect the purposes, linkage to a user/device, and tracking status of audio data, other user content, name/email, user ID, device ID, purchases, product interaction, diagnostics, and data processed through Adjust and Firebase.
  3. Before release, we will aggregate and review the App's and all SDKs' `PrivacyInfo.xcprivacy` files and verify required-reason APIs, tracking domains, and privacy manifests/signatures for binary SDKs, so that App Store privacy labels, permission purpose strings, this Policy, code, and server behavior remain consistent.
  4. All tracking must comply with ATT. We will not manipulate, coerce, or bypass a user's choice through fingerprinting.
  5. Third-party providers must offer the same or an equivalent level of protection required by this Policy and Apple's rules.
  6. We will provide accessible methods to withdraw consent, delete data, and delete an account.

16. Cookies and Web Technologies

The App does not use browser cookies to store recordings. Websites associated with the Services may use necessary cookies or similar technologies for security and basic functionality. Analytics or advertising cookies will be subject to consent and preference controls where required. A website cookie inventory must be completed before the relevant site launches.

17. Changes to This Policy

We may update this Policy for changes in law, features, SDKs, providers, or data flows.

If a change materially affects processing purposes, data types, recipients, international transfers, or your rights, we will provide advance notice through a prominent in-App dialog, notification, email, or another reasonable method and obtain renewed consent where required.

The current last-updated and effective dates will appear at the top. We will not use previously collected data for an incompatible new purpose without required notice and consent.

18. Contact, Complaints, and Appeals

For questions, complaints, appeals, or privacy-right requests, contact:

Operator: Top Stack Technology Co., Ltd. Chinese legal name: 合肥栈顶信息科技有限公司 Privacy and support email: kilovoice@top-stack.com

After appropriate identity verification, we will respond within the period required by applicable law. You may also complain to a competent privacy, data-protection, or consumer-protection regulator where you live.