Privacy Policy

Last updated: 21st September 2026

1) Who we are

Controller: PRODUCTSAVVY LIMITED, 19 Cairnbrook Avenue, Carrickmines, Dublin, D18FE06, Ireland. Contact: hello@kinclara.ie. This notice is for Kinclara.

2) What we process

• Account: name, email, password hash, login timestamps/IP (security logs).
• Care Circles: circle metadata, roles, membership, proxy confirmations.
• Health modules (optional): medications, wellness logs, notes (entered by you/your circle).
• Support: messages you send to us.
• Emails: product updates if you opt in.

3) Why we process (legal bases)

• Provide the service (accounts, circles, tasks): Contract (Art.6(1)(b)).
• Security & fraud: Legitimate interests (Art.6(1)(f)).
• Payments/tax (when enabled): Contract & legal obligation (Art.6(1)(c)).
• Health modules (medications/wellness/notes): Explicit consent (Art.6(1)(a) + Art.9(2)(a)). You can withdraw any time in Settings → Consent.
• Marketing emails: Consent (you can unsubscribe at any time).

4) Children & proxies

No direct accounts for users under 16 (IE/UK) in this beta. A parent/guardian or other lawful proxy may operate a Care Circle on a child’s behalf (with attestation). You may withdraw consent at any time.

5) Sharing & processors

• Google Firebase (EU region) – hosting, auth, database.
• Stripe Payments Europe – payments/subscriptions (V2).
• Databutton – platform/runtime services.
• MailerLite – product updates/transactional emails (opt‑in).

6) International transfers

We host in the EU (europe‑west) and do not make routine third‑country transfers. Some vendors may process support logs or metadata outside the EU; when that occurs we rely on valid transfer safeguards.

7) Retention

• Account data: life of account; security logs up to 24 months.
• Health entries: default 24 months after last activity or until you withdraw consent.
• Support/email preferences: until resolved or you unsubscribe.

8) Security

We use encryption in transit/at rest, role‑based access, audit logs, and least‑privilege controls appropriate to risk.

9) Your rights

You can request access, correction, deletion, restriction, portability, and withdrawal of consent at any time. You may also contact your data protection authority. We respond without undue delay within statutory timelines.

10) Professional contacts

If you are a health or community professional and we have contacted you about Kinclara, this section is for you. You did not give us your details yourself, so we are required to tell you the following — and we would want to anyway.

• Where we got your details: from a published professional or organisational source — an employer’s public website or directory, a professional register, or a public professional profile — or directly from a colleague who passed on your work contact details. We record the specific source and the date for every contact, and we will tell you which one applies to you if you ask.
• What we hold: your name, role and employer, a published or directly supplied work contact route, the source and date, a short note of publicly available professional context, and a record of any correspondence between us. We do not hold personal mobile numbers or home addresses. We hold nothing about the people you care for or the families you work with.
• Why: to ask professionals who work with families how relatives keep each other up to date, and whether information about Kinclara could be passed to families who might find it useful. Kinclara is free for families to use and is in private beta. We are not asking you to recommend or endorse it, and there is nothing for your service to buy.
• Legal basis: legitimate interests (Art.6(1)(f)) — our interest in approaching professionals, in their professional capacity, about something relevant to their field. We have weighed that against your rights and recorded the assessment; you can ask us for it. We contact you only at a work route, only about your professional work, once, with at most one short follow-up, and then we stop.
• How long we keep it: while the contact is live, and reviewed at the end of the pilot, when we decide whether it is still needed and record that decision. If you ask us not to contact you again, we keep a minimal record of that request indefinitely — it is the only reliable way to make sure we do not contact you again by mistake.
• How to stop it: reply to any message and we will not contact you again. You can also object to this processing, or ask for access, correction or erasure, at hello@kinclara.ie. If you are unhappy with how we have handled your details you can complain to the Data Protection Commission.

11) Changes

We will post updates here and, for material changes, provide in‑app or email notice.