Privacy Policy
Effective as of October 10, 2026.
To view previous versions of this Privacy Policy, see its history on GitHub.
California Notice at Collection/State Privacy Rights Notice: See the State privacy rights notice section below for important information about your rights under applicable state privacy laws.
Kaiyu Hsu ("IdleBiz," "we," "us" or "our") provides IdleBiz, a retro RPG-style idle business sim for macOS in which every employee is a session of your own signed-in Claude Code or Codex CLI. This Privacy Policy describes how IdleBiz processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website at idlebiz.com and the IdleBiz desktop app for macOS) and the other activities described in this Privacy Policy (collectively, the "Service").
Notice to European users: Please see the Notice to European users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe", and "European" should be understood accordingly).
Index
- Personal information we collect
- Tracking & Other Technologies
- How we use your personal information
- Retention
- How we share your personal information
- Your choices
- Other sites and services
- Security
- International data transfer
- Children
- Changes to this Privacy Policy
- How to contact us
- State privacy rights notice
- Notice to European users
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your name and email address, when you email us.
- Communications data based on our exchanges with you, including when you email us, open an issue on our GitHub repository, contact us on social media, or otherwise.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your IP address and your browser's user agent (which names your browser and operating system), which our hosting provider records in short-lived request logs along with the page requested and when.
For more information concerning our automatic collection of data, please see the Tracking & Other Technologies section below.
Information the desktop app keeps on your Mac. The desktop app runs on your Mac and sends us nothing about you or your company. It has no telemetry and no crash reporting to us. Your company (its employees, tasks, memory, workspace files, orders and activity log) lives on your Mac under ~/.idlebiz. Your claude or codex CLI also keeps each run's transcript, prompts and tool results included, in ~/.claude/projects (in folders named after the ~/.idlebiz paths the runs work in) or ~/.codex/sessions. Stripe, Vercel and Printful keys you enter are stored in ~/.idlebiz, encrypted with the macOS Keychain whenever the Keychain is available (if it is not, they are kept there as plain text until it is), and are never handed to your employees. The app's logs stay on your Mac, in ~/Library/Logs/IdleBiz. If neither CLI is installed when you sign in during setup, the app downloads Anthropic's Claude Code installer from claude.ai and runs it, and signing a CLI in is that CLI's own sign-in with Anthropic or OpenAI. We do not receive any of this information; the services the app sends it to at your direction are described in How we share your personal information.
Data about others. If your company sells through Stripe payment links or Printful print listings, the desktop app reads your buyers' details from your Stripe account and keeps each paid order in your company's folder under ~/.idlebiz: the buyer's email address and, for a print, their name, phone number and shipping address. Your employees can read those orders to answer buyers, which sends them to your CLI's model provider, and for each paid print order the app sends Printful the buyer's name, email address, phone number and shipping address and the print files, so Printful can print and ship it. The same goes for any other information about people that you or your employees put in your company's files. All of this happens on your Mac and in your own accounts, and we never receive it: you, as the founder running the company, decide how your buyers' personal information is used and are responsible for it, including telling your buyers how you handle it. Please handle it as the laws that apply to you and to your buyers require.
Tracking & Other Technologies
Cookies and other technologies. Our website does not use cookies or other tracking technologies, and neither does the desktop app. In the usual categories of cookies, the Service uses:
- Essential: none. The website works without storing anything in your browser.
- Functionality / performance: none.
- Analytics: none. We use no analytics on the website or in the desktop app.
- Browser web storage: none. The website keeps nothing in your browser's local or session storage.
We do not use advertising or social media cookies, pixels or web beacons. The automatic data collection described above comes from the request logs our hosting provider keeps, not from anything stored in your browser. Sites our website sends you to, such as GitHub for the download, set their own cookies under their own privacy policies.
Chat and other artificial intelligence ("AI") technologies, such as those provided by Anthropic and OpenAI, that your own claude (Claude Code) or codex (Codex) CLI uses to operate the AI employee features that you can use to found, staff and run your company through the Service. Anthropic, OpenAI and other third parties may access and use the prompts the desktop app gives your employees, which it builds from your company's files and what you tell your team, and the files, web pages and tool results your employees read, including buyers' details they read to answer orders, to facilitate the provision of the Service. Each run goes to the model provider your CLI is signed in to (Anthropic or OpenAI, or a cloud provider or gateway you have set your CLI to use), under your account and that provider's terms, and none of it passes through us.
For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide and operate the Service, including the website and the desktop app's download;
- enable security features of the Service;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
- provide support for the Service, and respond to your requests, questions and feedback.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including analyzing and improving the Service and promoting our business.
Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.
Retention
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
Specifically:
- our hosting provider's request logs are short-lived, kept on its own schedule; and
- what the desktop app keeps stays on your Mac until you delete it, and we never receive it (see Your choices).
How we share your personal information
We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection). We do not sell your personal information or share it with advertisers.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business, such as hosting and email. Vercel hosts our website and keeps its request logs. GitHub hosts the desktop app's source code and releases: to point the download link at the latest release, our website asks GitHub's public API, which receives nothing about you, and your browser then downloads the .dmg straight from GitHub. The provider that hosts our email inbox receives the messages you send us.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. The desktop app also sends information straight from your Mac to the services you choose, using your own accounts and credentials, without it passing through us:
- your CLI's model provider (Anthropic or OpenAI, or the cloud provider or gateway your CLI is set to use) receives the prompts and files your employees work with, including the buyer emails and shipping addresses they read to answer orders;
- Vercel receives the files of each deploy you approve and the environment variables your team sets on a product's project, and answers the app's reads of your products' deployments and visitor counts;
- Stripe receives the payment links and print listings you approve, and answers the app's reads of your account's charges and checkout sessions, which carry your buyers' details; and
- Printful prices each print your team proposes to sell and, for each paid print order, receives the buyer's name, email address, phone number and shipping address and the print files, so it can print and ship it.
Each of these services handles that information under its own privacy policy and your settings with it.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in IdleBiz, financing of IdleBiz, or the sale, transfer or merger of all or part of IdleBiz or its assets). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of IdleBiz as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Your choices
In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states and Europe can find additional information about their rights below.
Access or update your information. The Service has no accounts, so there is nothing to log into. To see or correct the information we hold about you, such as the messages you have sent us, email kai@kyh.io.
Cookies and other technologies. Our website sets no cookies and stores nothing in your browser, so there is nothing to turn off on our side. Most browsers let you remove or reject cookies: to do this, follow the instructions in your browser settings. Doing so does not affect our website, but it can stop other sites from working.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals because the Service does not track you across other websites.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Delete your content. Everything the desktop app keeps is on your Mac, and you can delete it yourself at any time. Reset everything, in the app's Settings, switches off your company's live payment links at Stripe, then deletes ~/.idlebiz, with every company and stored key. Deleting the ~/.idlebiz folder yourself removes the same data but leaves any live payment links in place, so switch those off first. To remove what the CLIs kept of the runs, delete the runs' transcripts under ~/.claude/projects and ~/.codex/sessions; the app's logs are in ~/Library/Logs/IdleBiz. What the app made in your Vercel, Stripe and Printful accounts, such as deployments, payment links and print orders, stays there until you remove it in each service. To ask us to delete the messages you have sent us, email kai@kyh.io.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical and organizational safeguards designed to protect the personal information we collect, and rely on our service providers for the physical security of the systems they run for us. For example, the desktop app sends us nothing, and our website stores nothing in your browser. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are based in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should read the important information provided below about transfer of personal information outside of Europe.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
If you have questions about our practices or if you would like to exercise any privacy related right that may be available to you, please contact us via one of the methods listed below.
- Email: kai@kyh.io
- GitHub issues: github.com/kyh/idlebiz/issues, for bugs and other questions that involve no personal information. Issues are public, so please do not use them for privacy requests.
State privacy rights notice
Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the "State Privacy Laws").
This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states listed above, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. To confirm your identity, we will ask you to send your request from, or confirm it from, the email address you have used to contact us.
For purposes of this section, the term "Personal Information" has the meaning given to "personal data", "personal information" or other similar terms and "Sensitive Personal Information" has the meaning given to "sensitive personal information," "sensitive data", or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws.
Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.
Information. You can request the following information about how we have collected and used your Personal Information:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you.
Appeal. You can appeal our denial of any request validly submitted.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out.
- Opt-out of certain processing for targeted advertising purposes. We do not process your personal information for targeted advertising purposes.
- Opt-out of or appeal profiling/automated decision making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.
- Opt-out of other sales of personal data. We do not sell your Personal Information within the meaning of State Privacy Laws.
Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.
Sensitive Personal Information. We do not collect Sensitive Personal Information. The desktop app sends us nothing, and keeps the keys you enter in it on your Mac, sending each only to the service it belongs to.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.
Exercising your right to opt-out of the "sale" or "sharing" of your Personal Information. We do not sell your Personal Information or "share" it for cross-context behavioral advertising, as the State Privacy Laws define those terms, so there is nothing to opt out of. If that ever changes, we will update this Privacy Policy first, offer a way to opt out, and honor Global Privacy Control ("GPC") signals as valid opt-out requests, as required by applicable law.
Exercising other state privacy rights. You may submit requests to exercise any of the other state privacy rights listed above via email to kai@kyh.io.
Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.
Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
Information practices. The following describes our practices currently and during the past 12 months:
- Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described above in the Privacy Policy.
- Retention. The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
- Deidentification. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.
Personal information that we collect, use and disclose. We have summarized the Personal Information we collect, the purposes for which we collect it and the third parties to whom we may disclose it by reference below to both the categories defined in the "Personal information we collect" section of this Privacy Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). This chart describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in an email, may contain other categories of personal information not described below.
| Personal Information ("PI") we collect | CCPA statutory category | Purposes | Categories of third parties to whom we "disclose" PI for a business purpose | Categories of third parties to whom we "sell" or "share" PI |
|---|---|---|---|---|
| Contact data | Identifiers; California Customer Records | Service delivery and operations; Compliance and protection | Service providers; Professional advisors; Authorities and others; Business transferees | None |
| Communications data | Identifiers; California Customer Records | Service delivery and operations; Compliance and protection | Service providers; Professional advisors; Authorities and others; Business transferees | None |
| Device data | Identifiers; Internet or other electronic network activity information | Service delivery and operations; Compliance and protection | Service providers; Professional advisors; Authorities and others; Business transferees | None |
Additional information for California residents.
Shine the light law. Under California's Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. We do not disclose personal information to third parties for their own direct marketing purposes. You may send us requests for this information to kai@kyh.io. In your request, you must include the statement "Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email kai@kyh.io.
Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.
Notice to European users
General
Where this Notice to European users applies. The information provided in this "Notice to European users" section applies only to individuals in the United Kingdom and the European Economic Area (i.e., "Europe" as defined at the top of this Privacy Policy).
Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.
Controller. Kaiyu Hsu, who provides IdleBiz, is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called 'UK GDPR' (as and where applicable, the "GDPR")). See the 'How to contact us' section above for our contact details.
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed below.
- Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity").
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation ("Compliance with Law").
- Where we have your specific consent to carry out the processing for the Purpose in question ("Consent").
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see 'How we use your personal information'.
| Purpose | Categories of personal information involved | Legal basis |
|---|---|---|
| Service delivery and operations | Contact data; Communications data; Device data | Contractual Necessity |
| Security | Device data | Compliance with Law. Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks. |
| Compliance and protection | Contact data; Communications data; Device data | Compliance with Law. Legitimate Interests. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety. |
| Data sharing in the context of corporate events | Any and all data types relevant in the circumstances | Legitimate Interests. We and any relevant third parties have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations). However, we would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate. |
| To create aggregated, de-identified and/or anonymized data | Any and all data types relevant in the circumstances | Legitimate Interests. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Service operates as intended. |
| Further uses | Any and all data types relevant in the circumstances | The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected. |
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for Compliance and protection purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other info
No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide any sensitive personal information to us when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through the Service.
No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.
Your rights
General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
- Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising These Rights. You may submit these requests by email to kai@kyh.io. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
- For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://www.edpb.europa.eu/about-edpb/our-members_en
- For users in the UK – the contact information for the UK data protection regulator is below: The Information Commissioner's Office, Water Lane, Wycliffe House, Wilmslow – Cheshire SK9 5AF, Tel. +44 303 123 1113, Website: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe
We are based in the U.S. and many of our service providers, advisers or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
It is important to note that the U.S. is not the subject of a general 'adequacy decision' under the GDPR – the EU-U.S. Data Privacy Framework and its UK Extension cover only organizations certified under them, and we are not certified. Basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information transferred to us, which is equivalent to that provided by relevant European laws.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
- Transfers to territories without an adequacy decision. We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above). However, in these cases: we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or in limited circumstances, we may rely on an exception, or 'derogation', which permits us to transfer your personal information to such country despite the absence of an 'adequacy decision' or 'appropriate safeguards' – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at kai@kyh.io.
This template was prepared and made publicly available by General Legal, PC ("General Legal"). It is provided for general reference purposes only and does not constitute, and should not be construed as, legal advice, or an endorsement or review of any particular transaction in which it is used. Use of this template does not create an attorney-client relationship with General Legal. General Legal has not reviewed, and takes no position on, any modifications made to this document or the deal terms it is used to document.