1. Introduction

Kinara Ltd. ("we", "our", "us") is committed to protecting your personal data and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application Kinara (the "App"). This policy applies worldwide as we respect the privacy rights of all our users, including those protected by the GDPR, Tanzania's Personal Data Protection Act, and other applicable regulations.

2. Information We Collect

We collect the following categories of data to provide and improve our services:

Data Type	Examples	Category
Account Information	Name, email address, date of birth, school/institution	Essential
Usage Data	Quiz scores, battle results, streak counts, XP earned, features used	Essential
Device Information	Device model, OS version, app version, unique device ID	Analytics
Performance Data	App crash logs, load times, error reports	Analytics
Communication Data	Support tickets, feedback messages, survey responses	Optional
Location Data	Country/region (approximate, for content localization)	Optional

3. How We Use Your Data

We use your information for the following purposes:

• Core Services: Provide, operate, and maintain the App's learning features, battles, leaderboards, and streak systems.
• Personalization: Tailor quiz difficulty, content recommendations, and study paths to your level and progress.
• Gamification: Track XP, achievements, streaks, and leaderboard rankings tied to your account.
• Communication: Send push notifications for streaks, battle results, and leaderboard updates; respond to support inquiries.
• Analytics & Improvement: Analyze usage patterns to improve features, fix bugs, and enhance user experience.
• Security: Detect and prevent fraud, cheating, or unauthorized access to accounts.

4. Legal Basis for Processing

We process your data based on the following legal grounds:

• Contractual necessity: To provide the App services you requested.
• Legitimate interest: To improve our services, ensure security, and prevent abuse.
• Consent: For optional data collection (e.g., location, marketing notifications). You may withdraw consent at any time.
• Legal obligation: To comply with applicable laws and regulations.

5. Data Sharing & Third Parties

We do NOT sell your personal data. We may share data only with:

• Cloud infrastructure providers (hosting, data storage) operating under strict data processing agreements.
• Analytics providers (anonymized/aggregated data only) to help us understand usage trends.
• App stores (Apple App Store, Google Play) for account verification and pass purchases.
• Law enforcement when required by law or to protect the safety of our users.

6. International Data Transfers

Your data may be processed on servers located outside your country of residence. We ensure appropriate safeguards are in place, including Standard Contractual Clauses and data processing agreements, to protect your data in compliance with applicable data protection laws.

7. Data Retention

We retain your personal data for as long as your account is active or as needed to provide services. Upon account deletion:

• Account data and personal information are deleted within 90 days.
• Anonymized usage data (leaderboard history, aggregated analytics) may be retained indefinitely as it no longer identifies you.
• Backup copies are purged within 180 days.

8. Your Rights

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

• Access: Request a copy of your personal data.
• Rectification: Correct inaccurate or incomplete data.
• Erasure: Request deletion of your data ("right to be forgotten").
• Portability: Receive your data in a structured, machine-readable format.
• Restriction: Limit how we process your data.
• Objection: Object to processing based on legitimate interest.
• Withdraw consent: Revoke previously given consent for optional data processing.

To exercise any right, contact us at privacy@kinaraapp.co.tz. We will respond within 90 days.

9. Data Security

We implement industry-standard technical and organizational measures to protect your data:

• Encryption: All data in transit is encrypted via TLS 1.3; sensitive data at rest is encrypted using AES-256.
• Access controls: Strict role-based access to user data within our organization.
• Regular audits: Security assessments and penetration testing conducted quarterly.

While we strive to protect your data, no system is completely secure. We encourage you to use strong passwords and protect your device.

10. Children's Privacy

Kinara is available to users aged 13 and above. For users aged 13-17:

• We require parental or guardian consent before collecting personal data.
• We do not display full names or contact details publicly on leaderboards or in battles.
• Parents may contact us to review, modify, or delete their child's data at parents@kinaraapp.co.tz.

11. Cookies & Tracking

The App does not use traditional browser cookies. However, we may use:

• Device identifiers for analytics and fraud prevention.
• Push notification tokens to send you streak reminders and battle invitations.
• In-app analytics to measure feature usage and performance (via Firebase Analytics or similar).

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes via App notification or email at least 15 days before they take effect. Continued use of the App after changes constitutes acceptance.

13. Contact Us

For any privacy-related questions, data requests, or concerns:

• Data Protection Officer: dpo@kinaraapp.co.tz
• General inquiries: privacy@kinaraapp.co.tz
• Postal address: Kinara App Ltd., Dodoma, Tanzania