Legal & help · English
Privacy Notice
Status and introduction
Unpublished English working draft. Legal, territory and release approval are required before production use. This Privacy Notice for Lost Meteor LLC (doing business as Lost Meteor Software) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you: Visit our website at https://kintwined.com or any website of ours that links to this Privacy Notice Download and use our mobile application (Kintwined), or any other application of ours that links to this Privacy Notice Use Kintwined. Kintwined is a web, iOS, and Android application for adults aged 18 and over to preserve personal and family stories, answer optional questions, conduct consented interviews, build private relationship trees, and store and selectively share photographs, audio, video, and other files. Family content is encrypted on the user’s device before cloud storage; account, authorization, billing, and network metadata are processed separately. Optional speech recognition and translation use supported local models. Free and recurring paid plans are available. Adults may maintain managed records about other people, including children; children and teenagers cannot create self-service accounts. Engage with us in other related ways, including any marketing or events Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: names email addresses job titles usernames passwords contact preferences contact or authentication data optional encrypted profile facts, dates of birth, family and chosen-family relationships, education and work history, personal stories, question answers and revisions, photographs, audio, video, files, captions, and user-selected contact names Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information: information revealing race or ethnic origin information revealing political opinions information revealing religious or philosophical beliefs permitted optional family stories and records about children/non-users may reveal sensitive characteristics. health information, intimate sexual details, biometric identification data, id numbers and financial credentials are prohibited in content, but may still be processed if supplied contrary to these rules; content is not automatically screened. Payment credentials are entered into the purchasing Apple App Store or Google Play. Web purchases are disabled. Kintwined does not receive full card numbers or card security codes. It receives an opaque account-scoped customer identifier and product, purchase, entitlement, refund/cancellation and renewal metadata. Family names, stories and keys are not sent as RevenueCat billing attributes. Provider privacy notices: https://www.apple.com/legal/privacy/ ; https://policies.google.com/privacy ; https://www.revenuecat.com/privacy . The operator confirms accepted standard provider terms; the applicable controller/processor roles and service-specific DPA/transfer coverage still require verification. Identity login uses explicitly connected Apple or Google accounts; see HOW DO WE HANDLE YOUR SOCIAL LOGINS? Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission: Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, microphone, storage, user-selected photos/files and contact names through system pickers; supported on-device speech recognition; optional os biometric unlock (no biometric templates received); opt-in local notification scheduling (no remote push-token service), and other features. If you wish to change our access or permissions, you may do so in your device's settings. Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed. The implemented collection is limited to service, security, update and vendor metadata described below; this is not advertising analytics or cross-site tracking. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Information automatically collected In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. Collection is limited to the service, security, update and vendor metadata described below; no advertising analytics or session replay is implemented. The web app uses essential browser storage as described in DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? The information we collect includes: Service, network, security, and update metadata. HTTP requests expose IP address, browser/user-agent and request time to hosting and service providers. The backend uses bounded anti-abuse counters, authentication/session records, public device and encryption identifiers, authorization/routing metadata, object sizes and transfer timing, quotas, and purchase/entitlement records. Native update checks and model downloads expose platform/runtime, language/model, and request metadata to their vendors; SDK diagnostics depend on the vendor. We do not request GPS/location permission or operate advertising analytics, session replay, or family-content telemetry. Google API Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. Information collected from other sources Other authorized family members, interviewers and managers can contribute stories or records about you. Selected contact/file imports and archives can contain third-party information. Explicitly connected Apple/Google services supply identity authorization information; the purchasing stores and RevenueCat supply transaction/entitlement information. We do not purchase data-broker lists, scrape public profiles or enrich advertising profiles. Apple/Google authentication is not a request for Facebook/X profiles or social friends lists. You may contact us about information concerning you even without an account; verification, others’ rights and encryption limits must be assessed.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent. We process your personal information for a variety of reasons, depending on how you interact with our Services, including: To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. (Retention period: While needed to operate the account, until account deletion and completion of queued cleanup. Verification/reset capabilities expire after 30 minutes; sessions expire or are revoked. Minimized deletion and delivery status may remain; final production schedules require approval before launch.) To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. (Retention period: Encrypted content is retained until the user deletes it or the account, subject to synchronized cleanup. Service backup retention is configurable from 1 to 28 days (default 7); outages can delay cleanup. Offline devices, local exports, and independent recipient copies can retain data.) To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. (Retention period: Only as needed to answer and resolve the inquiry and meet applicable legal obligations. Support-case retention and exceptional legal-hold schedules are not yet finalized and require approval before public release; do not send private vault content or recovery secrets.) To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. (Retention period: Transactional email payloads are removed after provider acceptance, permanent failure, or a maximum 23-hour outbox expiry; verification/reset messages expire after 30 minutes. Opaque delivery status may remain. Cloudflare Email Sending and recipient mailbox retention are separate.) To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. (Retention period: While needed to administer the subscription and resolve pending transactions. Processed backend billing events become eligible for cleanup after 30 days; unresolved events remain until resolved. Store/payment-provider and legally required accounting retention are separate and must be finalized before launch.) To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user. (Retention period: Until the authorized contribution, invitation, membership, or account is removed or expires, subject to synchronized cleanup. Removing access cannot recall a recipient’s prior export, screenshot, or independent copy.) To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. (Retention period: For the security task and relevant expiry period: anti-abuse rate-counter windows are at most one hour, replay nonces at most ten minutes, and retired identity hashes thirty minutes. Cleanup may be delayed. Provider request-log retention must be verified before production.) To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent. Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you. Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to: Diagnose problems and/or prevent fraudulent activities Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way For investigations and fraud detection and prevention For business transactions provided certain conditions are met If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim For identifying injured, ill, or deceased persons and communicating with next of kin If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced If the collection is solely for journalistic, artistic, or literary purposes If the information is publicly available and is specified by the regulations We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments Permitted sensitive processing requires an additional valid legal condition where applicable, such as the affected person’s explicit consent; a contract or legitimate interest alone is not an Article 9 condition. A contributor’s permission is not permission from everyone described.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Cloudflare provides web/API hosting, D1 account/authorization/billing indexes, Durable Objects coordination, and private R2 encrypted storage/backups. Apple supplies optional sign-in and App Store purchases. Google supplies optional sign-in and Google Play purchases. Storage currently uses Kintwined’s first-party Cloudflare implementation; Google Drive and private iCloud/CloudKit storage providers are disabled. Cloudflare Email Sending delivers transactional account messages and short-lived verification/reset codes; it does not receive stories or vault recovery keys. RevenueCat handles opaque billing identifiers, native-store transactions and entitlements. Purchases are available only through the iOS and Android stores; web purchases are disabled and Stripe is not used. Expo/EAS distributes native app updates. Apple, Google/ML Kit and the browser vendor supply optional local-model delivery and vendor diagnostics. Story speech/translation processing runs locally. Only authorized recipients receive shared family content. Disclosure for a legally required request, protection of rights, or a business transfer must have a valid basis and appropriate safeguards; encryption limits what can be provided. No private-story marketing, sale or publicity license is granted. New answers default to Only me unless the author explicitly sets another default. Authors can choose selected favorites or permitted tree audiences and separately restrict export/clone. An optional onboarding name uses the audience disclosed beside its field. Tree ownership and payment do not grant another author’s private answers. Managers have defined access to unclaimed records; a claimed contributor controls their future private answers. Narrowing access limits future authorization but cannot retract prior screenshots, exports or independent copies. You can skip prompts, change relevant settings, stop speech, revoke OS permissions, remove models, restrict audiences, revoke devices/invitations, export permitted records and request deletion.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
The web app uses IndexedDB and limited local/session storage for the encrypted vault, account-registration/deletion progress, selected language, pending invitation and secure sign-in/storage-connection handoffs. It is not accurate to describe these as advertising cookies. Checkout and identity-provider technologies require separate inspection. No advertising or analytics consent mechanism has been qualified; no GPC handler is implemented. The app does not change behavior in response to legacy DNT. Before release, necessary storage must be classified and any non-exempt technology must obtain the consent or other treatment required by applicable law. See Cookies and Browser Storage in the app’s legal documents. No production banner or public policy link is claimed.
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
Dictation and translation use supported installed on-device capabilities and have no cloud fallback. Review draft outputs before saving or sharing; originals are not automatically replaced. Model acquisition and SDK/OS diagnostics may use the network and require exact-release review. Family content is not used for AI training. Biometric quick unlock uses the device OS and device-only authenticated storage; we do not receive face/fingerprint templates. Reminders use local OS scheduling, not an app remote push-token service.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
Apple and Google are the supported third-party identity logins. We receive the account subject and identity information needed for the chosen login, including the email/name fields supplied by that provider. This does not request Facebook/X accounts or social friends lists. We use this information for the purposes described in this notice. The identity provider’s own handling is governed by its privacy notice.
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
Lost Meteor LLC is in the United States. Its Cloudflare, RevenueCat, Expo, Apple Developer and Google Play/API accounts and acceptance of current standard terms are operator-confirmed. Applicable standard agreements may incorporate DPAs, EU Standard Contractual Clauses, UK addenda and Swiss adaptations. Coverage depends on the actual provider role, service and transfer; this draft does not certify every flow. Where a restricted transfer requires safeguards, use the applicable valid mechanism and required assessment/supplementary measures. A provider’s valid scoped adequacy/DPF route can be an alternative to SCCs; Lost Meteor does not claim its own DPF certification or BCR approval. Actual provider/subprocessor locations and remote access remain to be verified. There is no EU-only or country-separated storage guarantee. No EEA, UK or Swiss representative has been appointed; required appointments and final contact details must be completed before the affected launch. An internal privacy lead, DPO-threshold assessment and Swiss-specific representation assessment remain outstanding.
9. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). If you are located in the EU or UK, see section "HOW DO WE PROCESS YOUR INFORMATION?" for our retention periods by purpose. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
Encryption, signed authorization, access controls and segregated credential storage are implemented safeguards, not a guarantee or certification. Independent penetration/cryptographic review and real-device/provider qualification remain pending. Encryption does not protect an unlocked compromised device, all metadata or a recipient’s saved copy. Lost Meteor has no vault decryption override. You need a trusted device or saved recovery code; provider login, password reset and purchase restore cannot decrypt lost content. Keep recovery material secure and separately protect readable exports.
11. DO WE COLLECT INFORMATION FROM MINORS?
Accounts and independent use require age 18 or over and legal capacity. Parent or guardian permission does not permit a minor account. We do not target child or teen accounts. Adults may maintain authorized managed records about children and other non-users; these records can contain children’s personal information. Managers must have appropriate authority and respect applicable custody, consent, privacy and notice requirements. Contact [email protected] about an underage account or a represented child’s information.
12. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence. In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the UK and are unhappy with how we have handled your personal information, you can make a complaint directly to us. This is in addition to the rights you have under the UK General Data Protection Regulation and the Data Protection Act 2018. How to contact us: Email: [email protected] Post: See "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" What happens after you complain We will acknowledge your complaint within 30 days of receiving it. We will investigate without unjustifiable or excessive delay. We will keep you informed of progress and explain the outcome. If you are not happy with our final response, you can refer your complaint to the Information Commissioner's Office, the UK supervisory authority. Website: ico.org.uk/make-a-complaint Helpline: 0303 123 1113 Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner. Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Account Information Use the available account export/deletion and content controls in Settings, or email [email protected]. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. If you have questions or comments about your privacy rights, you may email us at [email protected].
13. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below. Categories of personal information — intended service inventory Identifiers: account/email/public device IDs/IP and optional names. Customer-record/demographic data: optional profile facts, birth dates, family and work/education narratives. Commercial data: subscriptions and entitlements. Internet/electronic activity: bounded service/security/SDK/update metadata, not cross-site advertising history. Audio/visual data: chosen media and recordings. Sensitive data: necessary account-authentication credentials, permitted optional stories revealing sensitive characteristics, represented-child records, and prohibited details if users nevertheless supply them. Prohibiting health information in content does not establish that no such data is processed. Biometric templates, device-location tracking, institution-maintained FERPA education records and consumer-profiling inferences are not implemented collection features. Ordinary personal education memories remain content. Disclosure is to the scoped providers and chosen audiences described above, not sale or advertising sharing. Each category follows the relevant purpose-specific retention criteria, not an invented single retention period. Actual prior-twelve-month collection/disclosure must be verified before a live California notice is issued. We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you. We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: Receiving help through our customer support channels; Requests concerning account, privacy or billing; and Facilitation in the delivery of our Services and to respond to your inquiries. We will use and retain the collected personal information as needed to provide the Services or for: Category A - For the applicable purposes and periods in How Long Do We Keep Your Information; subject to deletion, expiry, queued cleanup, and limited legal retention. Category B - Only for the applicable purposes and periods described in How Long Do We Keep Your Information, including deletion/expiry and backup cleanup; not an indefinite blanket retention period. Category C - For the applicable purposes and periods in How Long Do We Keep Your Information, including user-controlled deletion, synchronization, and backup cleanup. Category D - For subscription administration and pending transaction resolution as detailed in How Long Do We Keep Your Information. Processed backend billing events become eligible for cleanup after 30 days; unresolved events, provider records, and necessary accounting/legal records have separate retention criteria. Category F - Limited service/request, security, billing-SDK, and update metadata only; not cross-site browsing or advertising profiles. Retained for the applicable operational/security periods described above; final provider log and diagnostic schedules require pre-release verification. Category H - User-selected photos, audio, and video are encrypted content retained until deletion with synchronized and backup cleanup as described above. Authorized recipients may retain independent copies. No thermal or olfactory sensing is used. Category I - Optional encrypted work-history answers follow the content deletion, synchronization, and backup criteria in How Long Do We Keep Your Information. This service does not evaluate employment eligibility or process job applications as part of its family-story features. Category L - Only for the applicable authentication or user-requested encrypted content purpose, with withdrawal/deletion and synchronized backup cleanup as described above. Optional stories may reveal these characteristics; they are not used for advertising or eligibility profiling. Sources of Personal Information Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?" How We Use and Share Personal Information Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?" We collect and share your personal information through: Service-provider API requests for hosting, account authentication, encrypted storage, transactional email, billing, and updates; user-directed private sharing. No advertising trackers, data sales, or cross-context behavioral advertising. Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information. This is an intended prelaunch inventory, not an attestation of the previous twelve months. The service does not implement sale or cross-context advertising sharing. Intended service disclosures and recipient categories are described in WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? Your Rights You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include: Right to know whether or not we are processing your personal data Right to access your personal data Right to correct inaccuracies in your personal data Right to request the deletion of your personal data Right to obtain a copy of the personal data you previously shared with us Right to non-discrimination for exercising your rights Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling") Depending upon the state where you live, you may also have the following rights: Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota) Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland) Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon) Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut) Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota) Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California) Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida) How to Exercise Your Rights To exercise these rights, email [email protected] or write to: Lost Meteor LLC, 8 The Green, Ste B, Dover, DE 19901, United States. Please mark correspondence “Privacy Request.” Account holders can also use the authenticated account export and deletion controls in Settings. We may verify identity or authority without requesting vault recovery codes or private content keys., or by referring to the contact details at the bottom of this document. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws. Request Verification Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf. Appeals Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general. California "Shine The Light" Law California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in. Australia and New Zealand We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act). This working draft describes information, sources, purposes and recipients; final regional notice and operational compliance require qualified approval before launch. If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular: offer you the products or services that you want respond to or help with your requests manage your account with us confirm your identity and protect your account At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?" If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner. Republic of South Africa At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?" If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are: The Information Regulator (South Africa) General enquiries: [email protected] Complaints (complete POPIA/PAIA form 5): [email protected] & [email protected]
16. FAMILY RECORDS, ENCRYPTION AND CONTENT RESTRICTIONS
Accounts and independent use are for adults aged 18 or over with legal capacity. Adults may maintain authorized records about children and other non-users; the restriction on child accounts does not mean these records contain no children’s data. Contributors must respect other people’s privacy, authority and consent requirements. Stories, media and recovery snapshots are encrypted on the device before cloud transfer. Private content keys remain on user devices; account, routing, security and billing metadata remain service-visible. Support cannot decrypt a vault or remove independent recipient copies. Do not enter or upload health information about yourself or anyone else, including diagnoses, symptoms, treatments, medications, disability details, mental health, reproductive health, medical records or genetic data. Keep intimate sexual details, biometric identification data, government ID numbers, passwords, recovery codes and financial account or payment credentials out of stories, family questions, recordings, attachments and imports. General beliefs, political views and everyday family memories remain optional. Skip questions that would reveal prohibited details. These rules do not automatically screen, block or erase prohibited information, including older revisions and backups. For removal help, contact [email protected] without sending the content or recovery secrets. Beliefs, politics and family narratives may still reveal sensitive information; applicable legal protections remain. Other sources are authorized family contributors, selected imports and connected identity/payment/storage providers, not data brokers or marketing lists. Identity login uses Apple or Google. Speech and translation run on supported local capabilities without cloud fallback; model downloads and vendor diagnostics may use the network. No GPS collection, advertising analytics, session replay, facial recognition or voiceprint identification is implemented.
17. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
18. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact us by post at: Lost Meteor LLC 8 The Green, Ste B Dover, DE 19901 United States
19. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, email [email protected]. Account holders can also use the account export/deletion controls in Settings; do not send recovery codes or private content keys.