Privacy Policy

Controller

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website or use the Kalinio communication app. Personal data is any data with which you can be personally identified. For detailed information on the subject of data protection, please refer to the privacy policy below.

Who is responsible for the data processing?

The data processing on this website and – insofar as the operator has influence over this – in connection with the Kalinio app is carried out by the operator. You can find the operator's contact details in the section “Information on the controller” in this privacy policy.

How do we collect your data?

Your data is collected, on the one hand, by you providing it to us. This can be, for example, data that you send us by email or telephone, or that you send to us following an export of diagnostic information that you have explicitly triggered.

Other data is collected automatically or with your consent when you visit the website by the IT systems and service providers involved. This is mainly technical data, for example the internet browser, operating system, IP address or the time of the page view. This data is collected automatically as soon as you enter this website.

In the Kalinio app, camera and microphone data are only processed if you activate the corresponding functions and grant the operating system permissions. According to the current design, this processing takes place exclusively locally and in real time on your device.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipients and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time with effect for the future. In addition, under certain circumstances, you have the right to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

2. Hosting

GitHub Pages

This website is hosted externally via GitHub Pages. The provider is GitHub, Inc., 88 Colin P. Kelly Jr. Street, San Francisco, CA 94107, USA. For persons in the European Economic Area, GitHub also names GitHub B.V., Prins Bernhardplein 200, 1097 JB Amsterdam, Netherlands.

The external hosting is carried out in the interest of a secure, fast, stable and efficient provision of our online offering by a professional provider on the basis of Art. 6(1)(f) GDPR. Insofar as the use of the website serves to carry out pre-contractual measures or to fulfil a contract, the processing may additionally be based on Art. 6(1)(b) GDPR.

Data transfer to the USA and other third countries

In the case of the processing of personal data in the USA or other countries outside the European Union or the European Economic Area, a level of data protection deviating from that of the European Union may exist. GitHub states that it uses appropriate safeguards for international data transfers, in particular the standard contractual clauses of the European Commission, and, according to its own information, is certified under the EU-US Data Privacy Framework.

3. General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

We point out that data transmission over the internet, for example when communicating by email, can have security gaps. Complete protection of the data against access by third parties is not possible.

Information on the controller

Storage period

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a justified request for deletion or revoke consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data.

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged violation.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the browser's address line begins with “https://” and by the lock symbol in your browser line.

4. Data protection when using the Kalinio app

Principle of local processing

The processing required for the communication, camera, microphone, calibration and recognition functions is, according to the current design, carried out in principle exclusively locally on the device used. In particular, the following are not automatically transmitted by Kalinio to the operator or to Kalinio's own servers:

• written or selected communication content;
• images or image sequences captured by the camera;
• microphone or audio data;
• detected mouth movements or tongue-clicking sounds;
• calibration data and recognition profiles;
• individually stored words, menus and settings;
• measured values of the recognition diagnostics.

During normal recognition, audio and camera data are processed only transiently on the device and discarded after the respective evaluation. Kalinio does not store audio, photo or video recordings in this process and does not transmit such data to the operator. Only if you explicitly start a diagnostic function can Kalinio retain locally the time-limited diagnostic media described in this Privacy Policy.

Microphone and camera access

Kalinio uses the microphone for tongue-click recognition, the associated calibration and explicitly started audio diagnostics. The camera is used for control by mouth opening, smiling or the tongue movement, for “Camera as filter”, read-aloud acceleration and explicitly started camera diagnostics. Access only takes place if you activate the corresponding function and grant the permission requested by the operating system. You can revoke the permission at any time in your device's settings.

Local storage

Kalinio can store certain data locally on the device, in particular language settings, operating and speed settings, individually created words and menus, calibrations, microphone profiles, camera and recognition settings, as well as backups, insofar as you explicitly create them. You can remove locally stored data via the app functions or by deleting or resetting the app.

4a. Face Data: Processing, Storage, Sharing and Deletion

As face data, Kalinio temporarily processes the current front-camera image, locally derived face and lip landmarks, head-pose and quality values, numerical mouth-opening and smile values and – for tongue recognition – a normalized 128 × 128 pixel crop of the mouth area.

Kalinio uses neither Face ID nor the TrueDepth API. Face data is not used to identify a person, for advertising, marketing, profiling or analytics, or to create biometric identity profiles.

The sole purpose of this processing is the app function you directly request: mouth-opening or smile control, tongue control, the “Camera as filter” function, read-aloud acceleration and troubleshooting that you explicitly start.

During normal operation, full camera images, face and lip landmarks and mouth crops exist only transiently in memory. They are discarded after the respective evaluation, are not stored as photos or videos, and are not transmitted to the operator or any third party.

Personal camera calibrations store only numerical threshold, quality and pose values locally on your device – never camera images, face crops or mouth crops. These values remain until you reset the respective calibration, reset the app or uninstall the app. A backup you create may contain these numerical values but no images.

Only Quick Analysis, which you must enable beforehand, can temporarily retain already normalized 128 × 128 pixel mouth crops in memory for up to six seconds. The full camera frame, eyes and nose area are not stored. These image data are discarded when you close the analysis.

A file containing these mouth crops is created only if, after the analysis, you explicitly save the original recording for your own analysis. You then choose the storage destination yourself using the iOS dialog. Kalinio does not upload face data automatically and does not integrate an analytics, advertising or data-broker service for this purpose.

If you select an external service yourself in the iOS save or share dialog, the file is transferred to that provider solely because of your explicit choice and is stored or processed there under that provider’s privacy terms. The operator of Kalinio does not receive the file.

This camera diagnostic file is intended solely for your own local analysis and should not be sent to Kalinio Support. An export file you save to a destination of your choice remains there until you delete it yourself.

4b. Diagnostics and Support

Kalinio includes optional diagnostic features for investigating recognition problems. The measurements and temporary audio or camera data involved are initially processed exclusively and locally on the device.

Original audio and recordings of the mouth area are saved as a file only if you explicitly choose to do so. You decide where these files are saved. They are intended solely for your own analysis and are not part of the support process.

For a support request, you may voluntarily create a data-minimized text report and send it to Kalinio Support yourself. It contains technical measurements and settings, but no audio or image data, no mouth crops and no individual communication content. Exact times and persistent device identifiers are also removed automatically before export.

The app does not send diagnostic information automatically. A text report reaches Kalinio Support only if you send it yourself. The submitted report is used solely to handle your request and improve Kalinio’s stability and recognition features.

5. Apple App Store, StoreKit and optional subscription diagnostics

Kalinio is provided via the Apple App Store.

When downloading, purchasing, updating, managing a subscription or rating the app, Apple processes personal data under its own data-protection responsibility.

This may include in particular information about your Apple account, payment information, device information as well as download and purchase transactions.

The operator of Kalinio has no influence over this data processing.

In this respect, only Apple's data protection provisions apply.

Kalinio uses Apple StoreKit 2 directly to load subscription offers, verify entitlement, complete purchases and restore subscriptions. StoreKit processes the necessary purchase and transaction data under Apple's responsibility.

The app evaluates only current entitlements verified by Apple on the device. No transaction, Apple Account or payment identifiers are transmitted to the operator. The app stores locally only whether an active subscription was last confirmed, so that Kalinio is not incorrectly locked during a temporary network or store outage.

RevenueCat, Inc. is no longer used for purchases, activation or restoration during normal app operation. RevenueCat is contacted as an optional, read-only diagnostic comparison only if you expressly start the subscription diagnostics under “Diagnostics & Support”.

During this voluntary diagnostic request, a randomly generated anonymous RevenueCat App User ID, technical information such as device type and operating system, and purchase and subscription information including the Apple receipt, product, status and term may be transmitted to RevenueCat.

The processing is used exclusively for the technical comparison of StoreKit and RevenueCat information and for troubleshooting. The legal bases are Article 6(1)(b) and Article 6(1)(f) GDPR.

Kalinio does not transmit names or e-mail addresses, communication content, audio, image, mouth/face data, calibration data or diagnostic reports to RevenueCat. The data is not used for advertising or cross-app tracking.

RevenueCat processes data in the United States. Where required by data protection law, the EU Standard Contractual Clauses are used as the transfer mechanism. Further information:

https://www.revenuecat.com/privacy

https://www.revenuecat.com/dpa

Recipients of Personal Data

A transmission takes place exclusively:

• to RevenueCat only if you deliberately start the optional subscription diagnostics, and only for the diagnostic comparison described there,
• when you voluntarily send a diagnostic report,
• when you select an external service yourself as the destination in the iOS save or share dialog,
• when this is required by law, or
• insofar as this is necessary to process the support request you have expressly requested.

Storage period at RevenueCat

Data transmitted to RevenueCat when the voluntary subscription diagnostics are started is processed only for the diagnostic comparison and subsequently only as required by contractual or statutory retention obligations. It is deleted or returned in accordance with the data processing agreement.

6. Plugins, embedded content and analysis

In the future, this website may embed videos from YouTube as well as content from social networks (e.g. Instagram, Facebook). Insofar as legally required, such content is only loaded after your explicit consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). If platforms are merely linked via an external link, data is generally only transmitted after the link has been clicked.

Website analytics with Umami Cloud

We use Umami Cloud to statistically evaluate the use of this website and improve accessibility, usability and content. The provider is Umami Software, Inc., 28 Geary St, Suite 650 #243, San Francisco, California, USA. Where personal data is processed, we base this data-minimising audience measurement on our legitimate interest in improving our online service (Article 6(1)(f) GDPR).

The collected data includes page views, page paths and titles, referring pages (referrers), timestamps, browser language, screen size, browser, operating-system and device information, and an approximate location. The provider can see the IP address when a connection is made. According to Umami, it is used to derive location data and a pseudonymous visit identifier, but is not stored in the analytics data. Umami does not use cookies for this tracking.

In addition, we record as statistical events whether the App Store link, the help link or a contact option was clicked. Only the fixed event name and, for contact, the type of contact option (email or telephone) are transmitted. Content, entered data and individual identifiers are not transmitted as event data.

URL query parameters and fragments are excluded from collection, including in referrers. We do not send form contents or other user input and do not collect personal custom events. We do not use additional individual user identifiers, session recordings or heatmaps. An enabled Do Not Track setting in your browser is respected; in that case, no analytics data is sent.

The free Hobby plan we use retains analytics data for six months. Umami lists server locations in the EU and the USA, so processing in the USA is possible. Umami’s data processing agreement provides, in particular, for EU Standard Contractual Clauses where transfers to third countries require safeguards. You may object to processing under Article 21 GDPR on grounds relating to your particular situation by contacting info@kalinio.app. Further information from the provider:

https://umami.is/privacy

https://umami.is/dpa

7. Changes to this privacy policy

We reserve the right to adapt this privacy policy if the technical functions of Kalinio, the website, the service providers used, analysis methods, embedded content, social media offerings, distribution channels or legal requirements change. The version published on this website at any given time applies.