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PRIVACY POLICY

(United Kingdom)

This version, drafted with reference to the UK GDPR and the Data Protection Act 2018, applies to users who select the United Kingdom as their country of residence in the App. A separate French version applies to users who select France.

Version dated 29 October 2026 — 2026-10-29-uk-v21 — effective date: 29 October 2026.

1. Who We Are and the Scope of this Policy

1.1 This Privacy Policy explains how KARIDO, a French société par actions simplifiée (SAS) with share capital of €6,800, whose registered office is at Lieu-Dit Autigeon, 558 Chemin de la Rivayrolle, 81500 Lavaur, France, registered with the Castres Trade and Companies Register under number 107 620 007 (SIREN 107 620 007) ("KARIDO", "we", "us" or "our"), processes personal data when you use the KARIDO mobile application (the "App"), its contact form or newsletter services.

1.2 KARIDO is the controller for the processing described in this Policy. You can contact our privacy team at contact@karido.io, by telephone at +33 7 67 08 45 58 or by post at KARIDO, a French société par actions simplifiée, Lieu-Dit Autigeon, 558 Chemin de la Rivayrolle, 81500 Lavaur, France. Following an assessment of our activities against the statutory criteria, we have not appointed a Data Protection Officer. The contact above is our privacy contact and is not a Data Protection Officer.

1.3 This Policy should be read with the applicable Terms and Conditions. A third party's own privacy policy or terms may also apply when you use Apple, Google, a third-party merchant or a Brevo-hosted form.

1.4 United Kingdom representative. Karido appointed Prighter Ltd as its UK representative under Article 27 UK GDPR by a letter signed on 9 October 2026. To contact the representative or exercise your rights through it, visit https://app.prighter.com/portal/15782771341. This appointment is separate from a Data Protection Officer.

2. Personal Data We Collect

2.1 Guest data and installation preferences stored locally. In guest mode, friends, events and gift ideas are stored locally on your device. The App also stores language, currency and shopping-market preferences, notification settings, versioned legal acceptance evidence, Analytics and Crashlytics choices, and the guest AI trial status and failed-attempt count for the day. The App also stores a local entry-completion marker and, after your explicit choice, a versioned OpenAI-sharing receipt. These are separate and tied to your technical identity on this installation; completing entry does not reactivate withdrawn agreement, and another Account's choice is not automatically adopted. A positive local receipt tied to your technical identifier and the age-policy version may permit strictly local offline use. It never authorises a server operation without the corresponding server-side check. This application data is not synchronised as Account data unless you sign in, subject to the temporary backend processing described below when you request AI generation and information transmitted when you use the contact form.

2.2 Account, authentication and age-check data. Your first name is required to create or complete an Account using email, Apple or Google. Your last name is optional from age fifteen through seventeen and required from age eighteen. For an existing Account, the App asks you to complete only the fields required for your age without deleting data already saved. You can edit these fields in Account settings; users aged fifteen to seventeen may also clear their last name. A name deliberately cleared is not automatically restored when signing in again with Apple or Google. This requirement does not apply to guest mode. During Account creation or a new account link, Apple or Google may supply a given name and a family name separately to prefill the fields; Karido never derives them from a full name or email address. These details are used for your Account profile and to personalise the interface. The two fields are stored in a private Cloud Firestore profile tied to your Account; Firebase Authentication also stores their combination as its display name. A local copy of these two fields, tied to your Account, stays on your device to restore the profile offline, including after synchronisation. A pending entry may also be retained so that saving can resume after the age check or when connectivity returns. The profile fields are not added to AI requests. The initial flow asks you to declare your date of birth in the email Account creation form or when completing entry after Apple or Google sign-in, in guest mode or when an existing Account first enters this flow. The date is sent to a protected function to check the fifteen-year threshold and, separately, the eighteen-year threshold for adult-only products. For an Account, the date of birth is stored in a private server-side document tied to the Account, so the same date can be restored on your devices and access can be recalculated when age thresholds are reached. It is read-only in settings; corrections go through support. It is not retained in local device preferences. For a guest, the date remains temporarily in memory for the check and, if needed, a retry; this input is not stored or hashed. On a compatible Apple device and with your agreement, an age range can supplement verification without replacing a date already tied to the Account. The date and declaration inputs are not sent to analytics or OpenAI. The eligibility evidence retains only positive decisions, thresholds, the method used, policy versions and a timestamp; a negative adult decision is not retained. Firebase Authentication creates an anonymous technical identifier without an email address for guest mode. For an Account, Firebase also processes your email address, sign-in provider, email-verification status and identity information supplied by that provider. Firebase stores passwords in hashed form; Karido cannot access the plain-text password.

2.3 Friend, event and gift data. Depending on what you enter, this may include a friend's first and last name, date of birth or other event dates, optional gender, relationship, preferences, things to avoid, an event-specific gift hint, minimum or maximum budget, and gift ideas with their status, estimated price, note or link. Preferences are optional. For friends under fifteen, “What they like” combines closed interest and characteristic choices, eight in total, while “Avoid” allows up to six closed choices. From age fifteen, these sections become a free-text portrait of up to 1,000 characters and an exclusion text of up to 300 characters. On reaching fifteen, the labels of existing choices may prefill an empty portrait and the exclusion text. Reminders are scheduled locally on the device.

2.4 Legal and eligibility evidence. We process the selected legal region, the Terms and Privacy Policy versions, displayed language, acceptance source, and client and server timestamps. We also retain the positive eligibility decision for people aged fifteen or over and, when obtained, a separate positive proof that the user is at least eighteen for regulated products, without including the declared age, date or received range bounds in that evidence; separate Account date-of-birth storage is described in clause 2.2. Legal evidence is local for a guest and is also recorded in Firestore after sign-in. App features remain unavailable until age eligibility and the applicable documents have been validated; adult-only products remain unavailable without a current 18+ proof.

2.5 Data processed for artificial intelligence. When you request gift generation, our backend reloads the canonical data and builds a provider request according to the friend's age. For a friend under fifteen, OpenAI may receive only an age band, a relationship category, optional gender, up to eight interest and characteristic categories in total, and six things-to-avoid categories selected from closed lists, the event type, required languages and market, minimum or maximum budget and currency, and existing-gift categories used to prevent duplicates. No free text about that friend is sent. For a friend aged fifteen or over, OpenAI may receive the same information plus the optional “What they like” portrait (up to 1,000 characters) and “Avoid” text (up to 300 characters), an “other” relationship label, the event's custom name and note, and up to thirty existing gift-idea titles, each limited to 120 characters. Those texts are transmitted to answer your request, so you must not enter sensitive, confidential or unnecessary information. For this gift-idea generation, OpenAI is not automatically given your name or email address, the friend's name or Karido identifier, contact details, date of birth, exact age or exact event date. It also receives a pseudonymous security identifier created with a server-held secret; this is neither the raw Firebase identifier nor a friend identifier. Inputs and outputs pass through moderation. Private context, job state and results are stored temporarily in Cloud Firestore during processing. Only suggestions you choose to save become persistent gift ideas in your user data. For an adult friend, an additional gift hint limited to 300 characters may also be sent. Continuation requests may reuse up to 150 bounded previously presented titles for deduplication; this differs from the thirty initial ideas.

2.6 Offer search and ranking. The App sends Karido's backend the search terms and friend identifier, or the reference of an existing server-side plan. A new plan sends OpenAI the complete technically normalised query, market and language; it does not automatically add the friend's name, date of birth, exact age or identifier. This path uses Responses without Moderation, and its structured output is validated locally. A separate ranking step sends OpenAI the friend's canonical age in completed years, the searched product (up to 48 characters for a generated idea or 120 for a manual search), its category and up to eight candidates reduced to the merchant title (160 characters), category and local number. Product-specific wording paths and their continuations also share minimised gift context: interest, style and exclusion categories, relationship and occasion type; from age fifteen, the optional “What they like” portrait (up to 1,000 characters) and “Avoid” text (up to 300 characters), event name and note, an ‘other’ relationship label and the reference idea's title and reason (160 and 500 characters); and for an adult, an additional hint of up to 300 characters. Language and search mode complete this context. This contextual path moderates input and output. None of these rankings automatically adds names, friend identifiers, dates of birth, prices, images or merchant links. You must not enter sensitive, confidential or unnecessary data in search terms or free-text fields. Typesense, self-hosted by Karido on OVHcloud infrastructure, receives the search terms and parameters needed: market, currency, a price ceiling compatible with that market and derived safety or audience filters. It does not automatically receive your Firebase UID or the friend's date of birth. If OpenAI classification fails, a raw search may be labelled as broader; a valid classification with no results is not automatically broadened. Offers may show a title, merchant, network, image, price and affiliate link. Loading an external image directly may send your device's IP address and technical connection information to its host before any click. A selected offer may be saved with the gift idea; other searches and results follow clause 8.

2.7 Optional transactional notifications. Event reminders are scheduled locally. The initial notification prompt offers reminders and, for an Account holder, search-completion notifications. Guest mode offers reminders only. Refusal does not block the App or automatically trigger another prompt; the two preferences can be changed separately afterwards. If an Account holder enables the notification that an AI selection is ready, we process their Firebase identifier, a random installation identifier, Firebase Cloud Messaging token, platform, locale and App version. The message sent to the device contains a technical job identifier and generic wording, without a friend's name or gift title. This function is not available in guest mode.

2.8 Optional Analytics data. Only if enabled, Google Analytics for Firebase receives a random app-instance identifier, technical device and App data, and a limited set of generic events: onboarding completion, access mode, creation of a friend or event, aggregate reminder coverage, generic AI-generation progress or outcome, guest-trial consumption, revealing further ideas, generic opening of a product link, saving an idea, Account creation and newsletter status. Karido does not send Analytics your Firebase UID, names, email addresses, dates, relationships, budgets, gift-context text, prompts, gift titles, merchants or product links.

2.9 Optional crash reports. Only if enabled, Firebase Crashlytics may receive crash traces, App and operating-system versions, device model, technical installation identifiers and data needed for diagnosis. Karido does not configure Crashlytics with your Firebase UID and does not intentionally attach names, email addresses, prompts or gift data.

2.10 Contact form. If you contact us through the App, including in guest mode, we process the message, optional subject, optional or prefilled reply email, locale, session mode, sign-in provider, authentication status and timestamp. The message is delivered to our Google Workspace mailbox and is not stored in Firestore. App Check also processes technical material needed to verify the App installation.

2.11 Newsletter. The new in-App subscription flow uses the Account's already verified email address, locale, consent source and notice version, an action identifier, status and corresponding dates. When registration is open, the dedicated button records your voluntary choice and the subscription becomes active after processing by Brevo, without a second confirmation email. Existing subscriptions awaiting confirmation keep their email confirmation flow. Website forms follow the information presented on each form. Verification of the Account email address does not, by itself, constitute newsletter consent.

2.12 Security data. Firebase, Google and attestation providers may process IP addresses, authentication logs, installation identifiers, App Check tokens and attestation material to secure services and prevent abuse.

2.13 We do not ask for special category data such as health, religion, ethnicity, sexual orientation or political opinions. You must not enter such information about yourself or another person.

3. Data About Other People

3.1 The App lets you record information about friends or family members who are not themselves Karido users. You must limit this to what is necessary for reminders and gift planning, have a legitimate reason for entering it, and ensure that the person would reasonably expect or has been informed of the use.

3.2 Karido does not use that information to contact those people, profile them for its own benefit or send them advertising. It is processed to provide the functions requested by the Account holder or guest user.

3.3 A person whose data has been entered may contact us to exercise their rights. We may need additional information to identify the relevant data without disclosing another User's information.

3.4 The User who enters the information is its source. Karido does not collect that person's email address, telephone number or other contact details and does not contact them. Giving each person this information individually would therefore be impossible in practice without collecting additional data solely for that purpose, which would undermine data minimisation. Karido accordingly makes this Policy publicly available as its Article 14 notice and relies on the exception for cases where individual provision is impossible or would involve disproportionate effort. As safeguards, Karido restricts the purposes as described in clause 3.2, minimises provider disclosures as described in clauses 2.5 and 2.6, prohibits sensitive data, applies limited retention periods and enables the person to exercise the rights in clause 9. The User should share this Policy with the other person where it is reasonable and appropriate to do so, but Karido does not treat the User as giving consent on that person's behalf.

4. Purposes and Legal Bases

4.1 Providing the App to you, including guest mode, Account management, import and synchronisation, friends, events and gifts, local reminders and product-offer search: performance of the Terms agreed with you (Article 6(1)(b) UK GDPR), but only where the processing is objectively necessary for that contract.

4.2 Processing information about friends and family members who are not Karido users: Karido relies on its and the User's legitimate interests in providing the requested private reminder and gift-planning service (Article 6(1)(f) UK GDPR). Karido has documented a legitimate-interests assessment covering the purpose, necessity, impact on the other person and balancing of interests. This processing is limited by data minimisation, private use, the safeguards in clause 3.4 and the rights and interests of the other person, with particular care where that person is a child. The User is not asked to, and cannot through the App, give data-protection consent on that person's behalf.

4.3 Generating AI suggestions, search plans or offer rankings, including the guest trial: your explicit, optional consent for data about you. The OpenAI box offered at entry is separate, initially unticked and optional. Leaving it unticked does not block friends, events, reminders or saved gift ideas. Searches using OpenAI remain blocked until you agree; the event page provides an explanation and a button to review and accept the proposed sharing. Agreement alone does not start a search. You may withdraw it in Settings, with the effects in clause 6.5. Your agreement is not consent on a friend's behalf. Minimised friend data described in clause 2.5 is processed on the documented legitimate interests in clause 4.2, with the safeguards applicable to their age.

4.4 Checking minimum ages and retaining positive eligibility evidence: steps necessary to perform the Terms and Karido's legitimate interests in enforcing its eligibility and safety policy, including preventing ineligible access to adult-only regulated products and demonstrating application of the fifteen- and eighteen-year thresholds. An Account holder's date of birth is retained to recalculate age thresholds and prevent conflicting declarations across devices. A guest's submitted date, declared age, received range bounds and negative decisions for the adult threshold are not retained. The separate child-specific assessment and safeguards remain subject to clause 10.2.

4.5 Keeping evidence of the Terms and privacy information presented: performance of the Terms, compliance with legal obligations and our legitimate interest in demonstrating applicable choices in the event of a dispute.

4.6 Measuring App usage with Analytics: your consent, offered as an optional choice during initial entry and separately changeable in Settings. Analytics remains disabled before a positive choice.

4.7 Receiving crash reports with Crashlytics: your optional choice, offered with Analytics during initial entry and separately changeable in Settings. Crashlytics remains disabled before a positive choice.

4.8 Managing the newsletter: your voluntary consent expressed through the dedicated button; existing flows and relevant forms may use double opt-in. Refusal does not affect Account creation or use of the App. You can unsubscribe at any time.

4.9 Responding to support messages: our legitimate interest in handling enquiries, or taking steps at your request depending on the message.

4.10 Notifying you when an AI selection is ready: your optional consent, expressed through the initial notification prompt or Settings, separate from Analytics and marketing communications. Search-completion notifications and reminders remain separately adjustable after that initial prompt. You may withdraw it at any time in Settings.

4.11 Securing the App, preventing fraud and abuse, and enforcing the Terms: our legitimate interests and, where relevant, legal obligations.

4.12 Complying with law and valid authority requests: compliance with legal obligations.

4.13 We do not sell or rent personal data and do not use it for third-party targeted advertising.

5. Recipients and Service Providers

5.1 We disclose data only to providers needed for the purposes described:

(a) Google Cloud and Firebase for authentication, including the anonymous technical identifier used for the guest trial, Cloud Firestore, backend functions, App Check, Remote Config, Firebase Cloud Messaging, Analytics and Crashlytics according to your choices;

(b) OpenAI through the Responses and Moderation APIs called exclusively by our backend, with Responses used to produce requested suggestions or classifications and Moderation used to check ordinary-generation inputs and outputs and the contextual paths described in clause 2.6;

(c) Apple and Google when you choose their authentication services, for app and device attestation needed to secure access and, depending on the platform, to deliver enabled transactional notifications;

(d) Awin (AWIN AG), Rakuten Advertising and Affilae, together with relevant merchants, depending on the offers displayed. Importing catalogues does not disclose your Account data or recipient profiles to them. Links retain the publisher, merchant, product or campaign references needed for affiliation; Karido does not automatically add your Firebase identifier, email address or a recipient’s gift context. When you open a link, its recipients may receive your IP address, browser or device information, the URL and, depending on the browser, the referring page, together with attribution or conversion data provided for by their service. Loading an external image may already disclose technical data to its host before you click;

(e) Brevo for newsletter registration, delivery and management, including double opt-in for the relevant flows;

(f) Google Workspace to receive and handle contact-form messages;

(g) OVHcloud to host and secure the catalogue pipeline and Typesense search engine. This infrastructure processes the search terms and parameters described in clause 2.6, merchant-offer catalogues and technical data needed for connections from our backend; and

(h) professional advisers or competent authorities where required by law or needed to establish, exercise or defend legal claims.

5.2 App stores, authentication providers, affiliate networks and merchants may process certain data for their own purposes. For affiliation, roles depend on the operation: Awin and Affilae publisher terms provide for cases of joint controllership for link tracking, conversion measurement and commission calculation. Karido retains its applicable obligations, including in these cases; you may exercise your rights by contacting us at contact@karido.io. Service-specific purposes, recipients, retention and choices are described in the Awin and Affilae notices, the Rakuten Advertising cookie and tracking information and the merchant’s privacy policy. Third-party attribution and retention periods are separate from Karido’s periods in clause 8. Merely opening a link does not constitute consent to non-essential tracking; prior consent is required where applicable. Karido’s Analytics, Crashlytics or OpenAI choices do not replace that choice.

Click and conversion data processed by Affilae is retained for twenty-five (25) months from the date of each click or conversion, then anonymised without further archiving. Backups are automatically erased no later than one hundred (100) days after their creation. These periods are specific to Affilae and separate from Karido's retention periods.

5.3 Karido uses OpenAI's Responses API with store=false and its Moderation API for ordinary generation. Sharing of model feedback, evaluation and training data, and inputs and outputs is disabled for the Karido organisation. The projects used are configured with “Global” residency and standard retention. Karido uses standard retention, without Zero Data Retention or Modified Abuse Monitoring. We therefore conservatively treat Responses abuse-monitoring logs as potentially containing requests, responses and metadata for up to thirty (30) days, or longer where required by law or reasonably necessary to protect OpenAI's services or a third party from harm. Karido uses the Moderation endpoint for ordinary generation inputs and outputs. The manual picker does not call Moderation for either its query or the structured JSON output from Responses. OpenAI documents no abuse-monitoring or application-state retention for the Moderation endpoint. The public Data Processing Addendum describes the commitments that apply when it is incorporated into the relevant services agreement. OpenAI may keep encrypted representations in a technical prompt cache on its computing equipment for up to twenty-four (24) hours, including when store=false disables response storage.

6. Artificial Intelligence Processing

6.1 Gift suggestions and AI-assisted product-search plans use only the provider data described in clauses 2.5 and 2.6. The App does not use them to take a significant decision about you based solely on automated processing; you decide whether to use a suggestion or open an offer.

6.2 AI-generated suggestions are identified as such before or when they are presented. Karido does not use friend information to train its own general-purpose model. The OpenAI settings that would allow Karido's API data to be used to improve or train OpenAI models are disabled.

6.3 The minimised ordinary-generation prompt and response pass through OpenAI's Moderation endpoint. For the manual picker, the full normalised query is sent directly to Responses without input or output moderation; Responses returns only categoryId and productType, after which the backend validates the strict JSON schema locally. Until a different verified retention control applies, Responses API abuse-monitoring logs follow clause 5.3. Karido does not place raw prompts or product-search terms in its technical logs.

6.4 You must avoid entering sensitive, confidential or unnecessary data. For a friend aged fifteen or over, relevant free text, including the “things to avoid” field, may be sent to OpenAI as described in clause 2.5 and must not be used for medical, religious or other special-category information. For a friend under fifteen, that free text is not sent and only closed categories are used.

6.5 Suggestions are stored persistently in your Karido user data only if you choose to save them. Context and unselected results remain temporarily in the Cloud Firestore job needed for processing and display, then follow clause 8.3 and the AI provider's rules. OpenAI sharing is optional both at entry and during use. Without current agreement you can use non-AI features; the event page provides an explanation and a button to review and accept the sharing before a search. The receipt is local, versioned and tied to your technical identity on this installation; another Account's choice is not automatically reused. Authorisations from the former mandatory flow are not reused for this new optional version. While a current receipt remains valid, a new search does not ask again. You may withdraw it in Settings. Refusal, dismissal or withdrawal blocks new OpenAI calls and leaves non-AI features available, including friends, events, reminders and saved gift ideas. Withdrawal does not restart the completed entry flow. A new offer search can still invoke OpenAI ranking with a saved plan and therefore also needs current agreement. Searches already started may finish. Withdrawal does not erase requests already processed or provider security logs still retained.

7. Locations and International Transfers

7.1 Guest data primarily remains on the device, subject to AI requests, the contact form and any telemetry you enable. The Cloud Firestore (default) database that contains synchronised data and temporary jobs is configured in the European eur3 multi-region. Backend functions principally run in europe-west1. Karido self-hosts its catalogue pipeline and Typesense search engine on a server supplied by OVH SAS (OVHcloud), 2 rue Kellermann, 59100 Roubaix, France, located in Gravelines, France, in the technical region os-gra6. Its Standard automated backup creates one daily copy retained for twenty-four (24) hours; the provider states that it is replicated in the same data centre on separate servers. The contract permits remote access needed for security and maintenance; the server location alone does not guarantee that all access takes place within the European Economic Area or the United Kingdom. This is not a Typesense Cloud service or a transfer to Typesense, Inc. Account, friend, event, gift, consent and application-job databases remain on Google Cloud and Firebase; catalogue backups and control metadata are also retained there. The catalogue migration therefore does not transfer all App data to OVHcloud.

7.2 Firebase Authentication is operated from data centres in the United States. Other Firebase services, OpenAI, Google Workspace, Brevo, Apple, Google and affiliate networks may process data outside the United Kingdom or European Economic Area. Apple states that its EU/EEA, UK and Swiss customers' personal data is stored in the United States. Its Privacy Policy describes its processing and the associated rights. Karido treats the documented OpenAI service as using “Global” residency and claims neither UK or European data residency nor Zero Data Retention.

7.3 Restricted transfers require a mechanism recognised under UK data protection law, such as applicable UK adequacy regulations, the UK International Data Transfer Agreement or Addendum, another approved safeguard or a valid exception. Google Cloud, Firebase and Google Workspace contracts provide service-specific transfer mechanisms. For data subject to UK law processed by OpenAI OpCo, LLC in the United States, OpenAI's Data Processing Addendum incorporates the Standard Contractual Clauses and UK Addendum. Affiliate network notices linked in clause 5.2 describe their processing. You may contact contact@karido.io for information about transfers and how to obtain a copy of applicable safeguards, subject to the protection of confidential information.

7.4 Brevo SAS, established in France, processes newsletter registrations on our behalf. For necessary maintenance and support access from India by Brevo CRM Solutions Private Limited, Brevo confirms the application of the European Commission's Standard Contractual Clauses, module 3, supplemented by the UK International Data Transfer Addendum. For access from the United States by Brevo, Inc., Brevo confirms reliance on the EU–US Data Privacy Framework, including its UK Extension, as well as the same Standard Contractual Clauses and UK Addendum. Transfers to Brevo SAS in France benefit from UK adequacy regulations. You may request information about these safeguards at contact@karido.io.

8. How Long We Keep Your Data

8.1 Guest data and local preferences: until deleted item by item in the App, successfully transferred to an Account, erased following confirmed Account deletion, the App's data is cleared or the App is uninstalled, subject to operating-system device backups. After a successful import, or after Account deletion is confirmed, the App erases friends, events and gift ideas from the previous guest database. Local legal evidence and installation-level preferences, including language, onboarding, currency and guest AI trial state, follow their respective reset mechanisms and may remain. The local OpenAI receipt is removed when App data is cleared or the App is uninstalled and, on a best-efforts basis, after successful Account deletion.

8.2 Account, friend, event, gift and synchronised consent data: while the Account remains open. The private date of birth follows this period and is deleted with the Account. The first and last names in the Firestore profile, their Firebase Authentication display name as well as their local copy and pending entries tied to the Account follow its deletion. Active deletion is initiated through the App after a recent sign-in and removes server data associated with the Account. Once deletion is confirmed, the App also erases any application data in the previous local guest database; if that local erasure fails technically, the App retries it on a later launch. Installation-level preferences described in clause 8.1 follow their respective reset mechanisms. Firebase states that certain authentication data and backup copies may take up to one hundred and eighty (180) days to be removed from live and backup systems. An unfinished deletion or necessary revocation has no automatic fence expiry. After a successful cleanup pass, the technical fence is set to expire ninety (90) days after that pass and a later successful pass can reset that date. Newsletter withdrawal follows clause 8.6; the seven-day limit does not apply to an undelivered opposition.

8.3 AI jobs and OpenAI processing. At admission, an active job and its private Cloud Firestore context receive an expiry timestamp two (2) days after admission. On a terminal transition, the job, private context and associated items receive an expiry timestamp twenty-four (24) hours after that transition. Firestore TTL deletion is asynchronous: Google states that deletion typically occurs within twenty-four hours after expiry, without an instantaneous-erasure guarantee or an absolute deadline. Relevant subdocument groups have their own TTL policies. Karido does not maintain an independent archive of raw prompts. In Production, Firestore recovery history covers seven (7) days and daily backups are retained for seven (7) days after creation; a record erased from active storage may therefore remain in an earlier copy. Pseudonymous quota and security counters may be retained for up to thirty-one (31) days. Gift ideas you choose to save follow the gift-data retention period. OpenAI retention is separate: store=false does not remove the technical cache or abuse-monitoring logs described in clause 5.3.

8.4 Analytics data: event data and user data are retained for fourteen (14) months in the relevant Production Google Analytics property. Resetting the user-data retention period on new activity is disabled. Analytics remains disabled until you enable it. Aggregated statistical reports that no longer reasonably identify an installation may be kept longer under an approved retention policy.

8.5 Crashlytics reports and associated identifiers: ninety (90) days before Firebase begins removing them from live and backup systems.

8.6 Newsletter data: we keep your email address and minimal evidence of registration during your subscription, for no more than three (3) years without relevant voluntary contact from you. Merely opening an email, a message sent by Karido or an administrative update does not extend this period. Your withdrawal immediately blocks email campaigns. Data no longer needed is cleaned up within thirty (30) days after an unconfirmed request or withdrawal, except where a documented need arises from an applicable obligation, a dispute or the defence of legal claims. We keep a separate minimal suppression record for at least three (3) years after withdrawal and then review whether it is still needed; it is used only to honour your choice and never causes automatic resubscription. Account deletion triggers withdrawal and does not erase that necessary record. The address needed to deliver withdrawal may remain in a protected outbox until transmission to Brevo is confirmed; an undelivered opposition is not automatically removed after seven days. A new subscription must follow a new voluntary request from you; importing contacts or an old consent indicator is not sufficient.

8.7 Support messages: ordinary enquiries are kept while they are handled and deleted no later than twelve (12) months after closure. Privacy requests, disputes, security incidents and records needed to establish, exercise or defend legal claims may be placed in a restricted-access intermediate archive for up to five (5) years after closure or resolution. A different period applies only where required by law or justified by ongoing proceedings, and access and retention are then limited to that purpose.

8.8 Security logs and provider technical data: according to the relevant service's own period. Firebase states that Authentication retains logged IP addresses for a few weeks. Firebase also states that App Check does not retain ordinary session tokens or attestation material; attestation material is subject to the attestation provider's terms. App Check may retain consumed tokens for up to thirty (30) days only when replay protection is used. Karido's current release configuration does not enable replay protection. The Google Cloud log buckets used retain ordinary logs for thirty (30) days and required audit logs for four hundred (400) days. They are not a prompt archive. Other providers apply their own service retention periods and criteria to their technical logs. For details about logs relating to your use of Karido, contact contact@karido.io.

8.9 Product searches and offers: search-job requests and results are scheduled to expire after twenty-four (24) hours, Account-linked search plans after thirty (30) days, and the shared cache of normalised offers after approximately five (5) minutes. Pseudonymous counters and reservations needed for quotas and security may be kept for up to thirty-one (31) days. Metadata for an offer you choose to save follows the period for the associated gift idea. An Account-, market- and product-specific display observation retains the last known state and its timestamp; it is refreshed no sooner than twenty-four (24) hours later and deleted with the Account. An Account-scoped local copy is also cleared when the Account is deleted.

8.10 Transactional-notification installations: the installation token is removed when you disable the setting, sign out, delete your Account or Firebase reports it as invalid. An inactive installation receives an expiry timestamp ninety (90) days after its last refresh, followed by asynchronous Firestore deletion. The opaque job identifier and technical delivery state receive a seven-day expiry timestamp followed by asynchronous Firestore deletion.

9. Your Rights and Choices

9.1 Subject to applicable conditions, you have rights to access, rectify or erase personal data, restrict or object to processing, receive data in a portable format and withdraw consent at any time without affecting earlier processing.

9.2 You may manage Analytics and Crashlytics, transactional notifications, the newsletter and Account deletion in Settings. Withdrawing Analytics consent disables collection and resets local Analytics data. Withdrawing Crashlytics consent disables collection and removes unsent reports; reports already sent remain subject to clause 8.5. Withdrawal of the separate OpenAI consent is explained in clause 6.5. Account deletion erases any application data remaining in the previous guest database; certain installation-level preferences described in clause 8.1 may remain.

9.3 To exercise a right, report data relating to a friend or make a data-protection complaint, email contact@karido.io or write to the postal address in clause 13. Please say that the message concerns privacy or a data-protection complaint. We may request information needed to verify identity or locate the data without requesting more than necessary. We generally respond to rights requests within one month, subject to extensions allowed by law.

9.4 We acknowledge a data-protection complaint within thirty (30) calendar days and investigate it without undue delay. If we need more time, we will explain the reason and the expected timetable. We communicate a reasoned outcome in writing, including any action taken or the reasons why no action is proposed. You may also complain to the Information Commissioner's Office at any time.

10. Children

10.1 The App is available only to people who are at least fifteen (15) years old. The check described in clause 2.2 takes place before App features or business-data synchronisation become available. A declaration indicating an age below fifteen blocks access without storing the declared age or received bounds. If we nevertheless learn that a child under fifteen has provided personal data through the App, we will take appropriate steps to delete it.

10.2 A person aged fifteen to seventeen is a child for UK data-protection purposes. Such a person may not access adult-only regulated products. That access requires separate positive proof that both the user and the relevant friend are at least eighteen; the merchant remains responsible for its own checks at purchase or delivery. The current free version permits users aged fifteen to seventeen to enter after the age check without a separate parental attestation. This access rule does not displace a parent’s or guardian’s legal powers or remove any permission required by law for a particular act.

11. Security

11.1 We use proportionate technical and organisational safeguards, including encryption in transit, password hashing by Firebase Authentication, App Check, Firestore access rules limited to the Account holder or authenticated owner of a temporary job, backend request validation and data minimisation for Analytics.

11.2 No system can guarantee absolute security. If a personal-data breach occurs, we will assess the risk and notify the ICO and affected individuals where required by law.

12. Changes to this Policy

12.1 We may update this Policy to reflect changes to the App, our providers or applicable law. The date and applicable version are identified in the App.

12.2 A material change may result in the Policy being presented again and, where necessary, a new acceptance of the Terms or a new consent choice. We will provide appropriate notice before the change takes effect where required by law.

13. Contact

13.1 For any question, request or complaint about this Policy or personal data:

By email: contact@karido.io

By telephone: +33 7 67 08 45 58

By post: KARIDO, a French société par actions simplifiée, Lieu-Dit Autigeon, 558 Chemin de la Rivayrolle, 81500 Lavaur, France

UK representative: Prighter Ltd — https://app.prighter.com/portal/15782771341.