PRIVACY NOTICE

INTRODUCTION

Kordyan Editions LLC (“we,” “us,” “our,” or “Company”) operates the Kordyan Pets mobile application and associated web services (the “Service”). This Privacy Notice explains how we collect, use, disclose, and protect your personal information when you use the Service.

We are committed to transparency about our data practices. If you have questions about this Privacy Notice or our privacy practices, contact us at hello@kordyaneditions.com.

This Privacy Notice applies to all users of the Service. It describes our practices for personal data we collect and process about you.

DATA CONTROLLER AND PROCESSOR INFORMATION

Kordyan Editions LLC is the data controller. We decide what personal data to collect, how to use it, and what purposes it serves. Kordyan Editions is registered as an LLC in North Carolina and operates the consumer-facing Kordyan Pets Service.

Kordyan Labs LLC is our primary data processor. Kordyan Labs operates the technical platform and infrastructure that processes personal data on our behalf, per our instructions. Both entities are bound by data protection commitments.

Kordyan Editions is your primary point of contact for exercising privacy rights, though both entities may process your data.

INFORMATION WE COLLECT AND APPLICABLE RETENTION PERIODS

We collect personal data in several categories. Some data is provided by you directly; some is collected automatically through your use of the Service and your connected accounts. While we provide our typical retention periods in this section, we may retain certain information for longer than the listed periods where necessary to comply with legal obligations, resolve disputes, enforce our agreements, protect the security and integrity of our services, or navigate legal claims. Additionally, even if certain data is deleted from active systems, it may remain in our backup systems for up to an additional 30 days pending backup rotation schedules.

Account and Identity Information

• Name and email address (required for account creation)
• Password and authentication credentials
• Age verification (18+ confirmation)
• Profile information you add (optional: photo, bio, preferences)
• Contact information you provide (phone number, physical address if purchasing printed products)

Pet and Relationship Information

• Pet name, species, breed, age, and characteristics you provide
• Descriptions of your relationship with your pet
• Personal anecdotes and memories you share
• Journey type selection (e.g., Kordyan Pet Years, Kordyan Pet Memorial)
• Dates, milestones, and events you document

Photographs and Visual Content

• Photographs you upload of your pet and pet-related moments
• EXIF metadata embedded in photographs (location data, timestamps, camera information, device identifiers)
• Any other images or visual content you provide

AI-Generated Content

• AI-generated narrative text created from your pet information and content
• Customizations and edits you make to AI narratives
• Your interactions with AI-generated content (reading, sharing, exporting)
• AI Restrictions and Boundaries: Our AI creates narrative text only. It does not manipulate, alter, generate, or synthesize photographs or other visual content — the images you see in your keepsakes are your original photographs. We do not use your personal data, photographs, or AI-generated narratives to train AI models. We use existing AI capabilities from third-party providers to generate narratives for your specific use only.

All account information and content will be promptly removed but may be retained by us for up to 90 days after account deletion.

Gift Purchases and Recipient Information

If you choose to create a gift or arrange delivery to another individual, we may collect personal information about the recipient, such as their content you provide, as well as their name, mailing address, email address, telephone number, and any message you choose to include. We use this information solely to process and fulfill your request, provide related customer support, prevent fraud, and comply with legal obligations. We do not use recipient information for marketing purposes unless the recipient separately requests or consents to receive marketing communications.

By providing information about another individual, you represent that you are authorized to provide that information and that it is accurate to the best of your knowledge. Please be aware that if a gift recipient contacts us, they generally will be able to exercise any applicable privacy rights subject to legal exceptions.

We may retain provided data according to the same timelines provided in this Privacy Notice as it relates to the specific category of data in question.

Device and Usage Information

• Device identifiers (unique device ID, IDFA, Google Advertising ID where applicable) – may be retained by us for up to 12 months
• Device type, operating system, and browser information – may be retained by us for up to 12 months
• IP address and location information (where permitted) – may be retained by us for up to 30 days
• Usage patterns and analytics (features used, content uploaded, time spent, navigation paths) – may be retained by us for up to 24 months
• Session logs and timestamps of your activity, as well as crash reports and error logs – may be retained by us for up to 6 months

Payment and Transaction Information

• Payment method information (credit card, Apple Pay, Google Pay)
• Transaction history (subscription status, purchases, renewals, cancellations)
• Billing address and shipping address (for printed products)
• Refund and dispute information

We do not receive or retain your sensitive payment credentials. Regarding other payment/transaction information, we have a legitimate business interest in retaining certain data for purposes including tax, accounting, chargebacks, disputes, and recordkeeping. We may retain such records for as long as commercially reasonable or required for business and legal needs.

Communication and Support Information

• Messages and emails you send to our support team
• Customer support records and interactions
• Feedback, reviews, and survey responses
• Complaints and reports you submit

We have a legitimate business interest in retaining your communication and support information, in the event of consumer protection concerns or legal disputes. We may retain such records for as long as commercially reasonable or required for business and legal needs.

Metadata and Inferred Information

• EXIF metadata from photos: When you upload photos, we may temporarily extract and process location, timestamp, camera model, orientation, resolution, and device information to enhance contextual accuracy of AI narratives, organize your content chronologically, and identify photo clusters. We remove or de-identify nonessential metadata, including GPS location and device identifiers, as soon as reasonably practicable unless retention is necessary to provide a requested feature or comply with legal obligations. We may retain photo orientation/resolution metadata as long as the images are stored with us, and timestamp data is retained only so long as it supports the Service provided.
• Usage analytics metadata: Feature usage patterns, session frequency, content upload frequency, and engagement metrics. We use this to understand product adoption, identify trends, and improve feature design. Retained for up to 24 months for historical analysis.
• Device identifiers: Used for user identification across sessions, distinguishing multiple accounts, and preventing fraud. Retained as long as account is active plus up to 12 months for audit purposes.
• Location metadata: From IP address, device GPS (if enabled), and photo EXIF. Used to contextualize narrative generation (geographic relevance) and provide location-based features. Aggregated for geographic analytics. Precise location data is retained for no more than 90 days unless Services or legal obligations require a longer retention period, but no longer than the minimum retention period required. IP-derived location data and security logs are retained for no more than 6 months unless security investigations or legal obligations require a longer retention period, but no longer than the minimum retention period so required.

HOW WE USE YOUR INFORMATION

We process your personal data for the following lawful purposes:

Providing the Service

• Creating and maintaining your account
• Storing and displaying your photos and pet information
• Generating AI narrative text about your pet and relationship
• Creating, producing, and delivering printed keepsake products (books, calendars)
• Enabling sharing and collaboration features (if enabled)
• Processing payments and managing subscriptions

Improving and Personalizing the Service

• Analyzing usage patterns to understand user behavior and preferences
• Personalizing content and feature recommendations
• Testing new features and improvements
• Developing new products and journey types
• Optimizing app performance and user experience

Safety, Security, and Legal Compliance

• Detecting and preventing fraud, abuse, and unauthorized access
• Investigating violations of our Terms of Service
• Complying with legal obligations and court orders
• Protecting the rights and safety of our users and the Service
• Screening content for prohibited material (including animal abuse)

The reviews we perform by this section may use automated technologies, human reviewers, or both. When appropriate, we may remove content, suspend accounts, or disclose information to service providers or governmental authorities as permitted or required by law.

Customer Support and Communication

• Responding to your inquiries and support requests
• Sending service announcements and updates
• Notifying you of changes to our policies or Service
• Soliciting feedback to improve the Service

Marketing and Business Development

• Sending promotional emails and in-app messages (only with consent)
• Conducting surveys and market research
• Analyzing aggregate trends for business planning

Analytics and Research

• Aggregating and analyzing usage data to understand Service effectiveness
• Creating anonymized datasets for product research and optimization
• Benchmarking performance against industry standards

Analytics and research use aggregated or de-identified data to the extent practicable, minimizing personal data exposure.

PROCESSING YOUR INFORMATION

Our processing of personal data is only to the extent permitted by applicable laws. Whether the legal basis is based on a contract with you, your explicit consent, a legitimate business interest, or a legal obligation, we may process your personal data for account creation, marketing communications, security, and compliance.

DATA SHARING

We do not sell your personal data or share personal information for cross-context behavioral or targeted advertising. We do disclose your personal information only to service providers and business partners that need the information to provide products or services requested by you or to perform services on our behalf. Examples include payment processors, cloud hosting providers, shipping carriers, manufacturers and fulfillment partners, customer support providers, and technology vendors. We require these parties to protect personal information and to use it only for the purposes for which it was disclosed, unless otherwise permitted or required by law.

If we receive legal requests for your information, we will make commercially reasonable efforts to notify you of such requests.

Business Transfers

If Kordyan Editions LLC is acquired, merges with another entity, or enters bankruptcy, your personal data may be transferred as part of that transaction. We will notify you of such change and any privacy policy changes.

Aggregated and De-Identified Data

We may share aggregated or de-identified data that cannot reasonably identify you with business partners, researchers, and the public for marketing, analytics, and research purposes. This data does not include your personal information.

YOUR PRIVACY RIGHTS UNDER U.S. STATE PRIVACY LAWS

Depending on your jurisdiction, you may have the following rights regarding your personal data:

Right to Access

You have the right to request a copy of the personal data we hold about you as well as the personal data we have shared with third parties for their direct marketing purposes. Submit an access request to hello@kordyaneditions.com and we will provide your data in a structured, portable format.

Right to Correction/Rectification and Right to Limit

You can correct, update, or amend inaccurate or incomplete personal data. Use your account settings to edit profile information, or contact us for assistance. We use your Sensitive Personal Information as defined by law only for purposes permitted by the same. Accordingly, we do not offer a right to limit its use because we do not use it for purposes that trigger that right.

Right to Deletion/Erasure

You can request deletion of your account (or a sub-account, if using multiple aspects within the Service) and associated personal data. Upon deletion request:

• Your account is immediately disabled
• Your personal data is deleted
• Photos and content are permanently deleted
• AI-generated narratives are deleted
• Note that we retain certain data as required by law (e.g., tax records, legal holds)

Data in backup systems may take longer to delete due to technical backup cycles.

Right to Data Portability

You can request your personal data in a portable format (CSV, JSON, PDF) that you can transfer to another service. Submit a portability request to hello@kordyaneditions.com and we will provide your data according to your request.

Right to Opt-Out

You have the right to opt out of the following:

• Marketing. We will send marketing communications only if you have opted in. You can unsubscribe from marketing emails at any time via the unsubscribe link in the email or through your account settings. Opting out of marketing does not affect transactional emails or service communications.
• We do not share your data for cross-context behavioral advertising or targeted advertising, so you have no need for an opt-out right.

Right to Restrict Processing

You can request that we limit how we process your data in certain circumstances (e.g., while you dispute accuracy). Submit a restriction request and we will honor it except where necessary to provide the Service.

Right to Object or Appeal

You can object to processing based on a legitimate interest. We will respect your objection unless we have compelling reasons to continue processing. You also have the right to appeal any request denied by us.

Right to Withdraw Consent

If you’ve consented to certain processing (e.g., marketing), you can withdraw that consent at any time. Withdrawal doesn’t affect the legality of prior processing.

Right to Not Be Discriminated Against

We will not discriminate against you for exercising your privacy rights. You will not face denial of service, pricing differences, or quality reduction because you exercised your rights.

How to Submit Requests: To exercise any of these rights, contact us at hello@kordyaneditions.com with “Data Subject Request” in the subject line or via first class mail to the address listed at the end of this Privacy Notice. Include your account email and the specific right you’re exercising. We will verify your identity and respond within 45 days of the receipt of your request.

Financial Incentive Program

We may offer optional loyalty programs or promotions that involve collection of personal information in exchange for discounts or benefits. Participation is always optional and you can withdraw at any time.

INTERNATIONAL DATA TRANSFERS

We are a US-based company. Your personal data may be processed and stored primarily in the United States. However, your data may be transferred to other global jurisdictions where we or our service providers maintain facilities, including for processing, product fulfillment, and customer support. When your data is transferred, we implement appropriate safeguards as required by applicable law, including Standard Contractual Clauses or other approved transfer mechanisms.

By using the Service, you consent to the transfer of your personal data outside your country of residence, including to or from the United States, for processing as described in this Privacy Notice.

SECURITY MEASURES

HOW WE PROTECT YOUR DATA

We implement industry-standard security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

• Encryption in transit and at rest
• Access controls and role-based permissions
• Secure password requirements and authentication mechanisms
• Regular security audits and vulnerability assessments
• Firewalls and intrusion detection systems
• Limited employee access to personal data (need-to-know basis)
• Data backup and disaster response/recovery procedures

No Guarantee: While we use reasonable security measures, no security system is impenetrable. We cannot guarantee absolute security. You use the Service at your own risk.

If we discover a security breach involving your personal data, we will notify you without unreasonable delay, as required by law.

COOKIES AND TRACKING TECHNOLOGIES

We use cookies, pixels, and similar tracking technologies to enhance your experience and understand how you use the Service, including essential cookies; analytics cookies; preference cookies; marketing cookies; and third-party cookies.

Your Cookie Choices

Most browsers allow you to refuse cookies or alert you when cookies are being sent. You can manage cookie preferences in:

• Your browser settings (Safari, Chrome, Firefox, etc.)
• Your Kordyan Pets app settings (Analytics and Tracking toggles)

Please keep in mind that disabling essential cookies may impair Service functionality.

CHILDREN’S PRIVACY

The Service is not directed to individuals under 18 years of age. We do not knowingly collect personal data from minors. If we learn that a minor has created an account, we will delete the account and associated data promptly.

If you believe a minor is using the Service, please contact us at hello@kordyaneditions.com. Parents or guardians concerned about a minor’s use of the Service should contact us immediately.

For users in the US, the Children’s Online Privacy Protection Act (COPPA) restricts collection of data from children under 13. Our 18+ requirement exceeds COPPA protections.

“DO NOT TRACK” SIGNALS

Some browsers support “Do Not Track” (DNT) signals. We do not currently respond to DNT signals in a special way beyond standard privacy controls. You can control tracking via your account settings and browser preferences.

THIRD-PARTY LINKS AND SERVICES

The Service may contain links to third-party websites, apps, and services (e.g., social media, external retailers). We are not responsible for their privacy practices. Review their privacy policies before providing personal information. This Privacy Notice applies only to the Kordyan Pets Service.

UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the “Last Updated” date at the top
• Notify you via email or in-app notification (for material changes)
• Request your consent if required by law

Your continued use of the Service following notice of changes constitutes acceptance of the updated Privacy Notice. Review this notice periodically to stay informed.

If you have questions, concerns, or complaints about our privacy practices, contact us at:

Kordyan Editions LLC

Privacy Officer

14460 Falls of Neuse Rd, Ste 149-414

Raleigh, NC 27614

Email: hello@kordyaneditions.com

Web: https://kordyaneditions.com

Data Protection Authority Complaint: If you reside in the EEA or UK and believe we’ve violated your privacy rights, you have the right to lodge a complaint with your local data protection authority. Contact information for your jurisdiction’s DPA can be found at https://www.edpb.europa.eu/about-edpb/our-members_en.

END OF PRIVACY NOTICE