Kin Technology Limited Privacy Policy

Last Updated: July 27, 2025

Thank you for your interest in Kin Technology Limited ("Kin", "we", "our", or "us"). This Privacy Policy ("Policy") describes how we collect, use, disclose, and protect information in connection with your use of our various hardware, firmware, software, websites, applications, and services, including our smart pill dispenser (Kindo) and mobile application (collectively, the "Kin Technology Products and Services").

We are committed to protecting your privacy and ensuring transparency about how we handle your personal information.

This Policy covers:

• The types of information we collect from you.
• How we use this information.
• How we share or disclose this information.
• Your rights and choices regarding your information.
• The steps we take to protect your information.
• Data retention practices.
• International data transfers.
• How you can contact us.

1. Information We Collect

We collect various types of information to provide and improve the Kin Technology Products and Services. Some of this data may be considered personal information or personal data, meaning information that can identify or be reasonably linked to an individual.

1.1. Information You Provide Directly to Us:

• Account Information: When you create a KIN account, we collect your full name, email address (or phone number based on country), and password or authentication credentials. You may also choose to provide a profile photo, birthday, and other optional professional or personal details for your profile page. This information helps us identify you, provide personalized experiences, and secure your account.
• Contact Information: When you make a purchase, contact customer support, or sign up for updates, you may provide your name, email address, shipping and billing address, and phone number(s). This enables us to fulfill orders, respond to inquiries, and deliver support services.
• Payment Information: For purchases, you provide payment details such as credit/debit card information and billing address. Please note: Payments are processed via secure third-party payment processors. We do not store your full payment card details on our servers.
• Communications: When you contact us (e.g., via email, chat, phone), we collect information about your communication, including your contact details, the time, topic, and content of your messages.
• Feedback and Reviews: If you provide feedback, reviews, or ratings for our products or services, we collect this information to improve our offerings and understand customer satisfaction.
• Medication and Schedule Data: To enable the Kindo smart pill dispenser to function effectively, we collect medication names or types, dosage information, dispensing schedules, and frequency. This is sensitive health-related data, stored securely, and used solely to ensure accurate and timely medication dispensing.
• Photos and Audio Recordings:
• From Kindo Device: The Kindo device collects photos of medication within its dispense area (the cup that picks up dispensed meds). The camera's placement strictly limits its view, capturing only the dispense area and cannot see faces or the surrounding environment. These images are used for record-keeping and future recognition functions (e.g., for pill verification).
• From Mobile App: Our mobile application uses your device's camera to take pictures of prescriptions or canister IDs for OCR (Optical Character Recognition) processing. During this process, the image capture may incidentally include parts of your environment or face.
• Necessity & Storage: The collection of these photos and recordings is necessary for the functionality of the features we offer and is not optional for the use of these features. This data is stored both locally on the Kindo device/mobile app and online on our servers.

1.2. Information We Collect Automatically:

• Device-Related Information: When you activate or use Kindo, we collect device model, serial number, firmware version, status logs, and error reports. This helps us monitor device performance, provide customer support, and ensure accurate medication dispensing.
• Technical Information: When you visit our website or use our mobile applications, we collect data such as your IP address, browser type, operating system, device identifiers, and usage statistics. This helps us optimize performance and security.
• Location Information: We may collect location data from your mobile device to improve app functionality, such as setting time-based medication reminders, syncing time zones, or offering localized customer support. This data is only collected with your explicit permission and can be disabled in your device settings.
• Cookies and Similar Technologies: We use cookies and similar technologies on Kin websites and app to collect information, including personal data, from you. These small files enable certain features, functionality, and more relevant marketing. We do not use cookies to collect or store sensitive health information; this data is handled via secure, encrypted methods. Please see our separate Cookie Policy for more details.

2. How We Use the Information We Collect

We use the information we collect through Kin Technology Products and Services for the following purposes, in connection with operating our business, supporting our users, and improving our offerings. We process your data based on various legal grounds:

• To Provide and Operate Our Products and Services (Performance of Contract): We primarily use your account information, device information, medication schedule data, and technical information to operate the pill dispenser and app, manage user accounts, configure schedules and reminders, deliver customer support, and provide features based on your preferences. The processing of your data, including sensitive health data, is strictly necessary for fulfilling our service agreement with you and enabling the core functionalities of the Kin Technology Products and Services.
• For Personalizing Your Experience (Your Consent, or Legitimate Interests): We use account information, location information, and cookies to customize medication reminders, show relevant content or suggestions, and provide localized support. (Legal Basis: Your consent, or our legitimate interests to provide a tailored user experience.)
• For Improving Our Products and Services (Legitimate Interests): We analyze usage data (technical and device information) to understand user interaction, identify trends, improve design, functionality, and reliability, and develop new features. (Legal Basis: Our legitimate interests to enhance our products.)
• To Communicate with You (Performance of Contract, Legal Obligation, or Consent): We use your account and contact information to provide updates, send important safety or medication-related notifications, respond to inquiries, and offer promotions, surveys, or product information (with your consent if required by law). You can opt out of marketing communications at any time.
• To Ensure Safety, Security, and Compliance (Legitimate Interests, Legal Obligation): We use account, device, and technical information to detect and prevent fraud, abuse, or misuse; monitor device functionality and health compliance; respond to technical issues; and comply with applicable laws and regulations relevant to health-related or connected medical devices.
• To Generate Aggregated and Statistical Insights (Legitimate Interests): We combine and anonymize your personal data to produce aggregated insights (e.g., device usage trends, app performance metrics, anonymized medication adherence statistics). This type of information does not include any personally identifiable data and helps us improve services and develop health-focused innovations. (Legal Basis: Our legitimate interests for research and development, as anonymized data is no longer personal data.)

We do not use your information for automated decision-making or profiling that has legal or similarly significant effects on you.

3. When We Disclose Information

We respect your privacy and take data sharing seriously. We will not disclose your personal information except as described in this Policy or as disclosed to you at the time of collection.

We may share the information described in the "Information We Collect" section under the following circumstances:

• With Your Consent or Publicly Shared Content: If you choose to share content publicly (such as feedback or reviews) or give us explicit consent, that information may be visible to others. We do not currently provide public sharing platforms (e.g., forums), but if we introduce such features, we will provide clear options to control visibility.
• With Third-Party Service Providers: We engage trusted third-party companies to help us operate, provide, and improve our services. These partners may include:
• Payment processors
• Logistics and shipping providers
• Cloud storage and data hosting services
• Communication and marketing platforms

These third parties access your personal information only to perform services on our behalf and are bound by contractual obligations to keep your data confidential and secure.

• For Analytics and Advertising: We use cookies and similar tracking technologies to understand usage trends and personalize your experience. Some non-identifiable usage data may be shared with analytics or advertising partners. You can manage your preferences at any time via the "Cookie Preferences" section on our website.
• For Legal Reasons and Protection: We may disclose your information if required by applicable law or in good faith belief that such action is necessary to:
• Comply with legal obligations or governmental requests.
• Respond to subpoenas, court orders, or legal processes.
• Fulfill regulatory requirements applicable to health-related or connected medical devices.
• Prevent or investigate fraud, abuse, or security threats.
• Protect the safety, rights, or property of Kin, our users, or the public.
• Enforce our terms and conditions or other legal agreements.
• Pursue legal remedies or defend legal claims.
• In Business Transfers: In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be disclosed or transferred to the acquiring or successor entity. We will ensure such transfers are done in accordance with applicable laws and with continued protection of your data.
• Aggregated, Anonymized, or De-identified Information: We may share data that cannot reasonably be used to identify you with third parties for research and development, health and safety analysis, business intelligence, marketing, compliance, and reporting.

4. Your Rights and Choices

We are committed to giving you control over your personal data and value your security and privacy. You have specific rights regarding your personal information, which you can manage or exercise in the following ways:

• Right to Access and Rectification: You can access and modify your personal data, including account information, contact information, and health-related settings, at any time through the Kindo device or Kin App.
• With Third-Party Service Providers: We engage trusted third-party companies to help us operate, provide, and improve our services. These partners may include:
• For Analytics and Advertising: We use cookies and similar tracking technologies to understand usage trends and personalize your experience. Some non-identifiable usage data may be shared with analytics or advertising partners. You can manage your preferences at any time via the "Cookie Preferences" section on our website.
• For Legal Reasons and Protection: We may disclose your information if required by applicable law or in good faith belief that such action is necessary to:
• Right to Restriction of Processing: The right to request that we limit the ways we use your personal data.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to Object: The right to object to processing of your personal data in certain circumstances, including for direct marketing purposes.
• Rights related to Automated Decision-Making and Profiling: (As stated, we do not engage in automated decision-making or profiling that has legal or similarly significant effects on you.)

If you are unable to manage your data or exercise your rights through the App, you can contact our Data Protection Officer at hello@kintechnology.io to make an application. We will respond to your request within a reasonable time (generally no more than 30 days).

5. Data Retention

We retain your personal data for as long as necessary to provide you with the Kin Technology Products and Services, fulfill the purposes outlined in this Policy, and comply with our legal and regulatory obligations. This typically means we retain your data for the duration of your active use of our services plus a reasonable period thereafter to address any legal claims, conduct audits, or fulfill legitimate business purposes in accordance with applicable laws and common industry practices for health technology. When your data is no longer required, we will securely delete or anonymize it.

6. International Transfers of Personal Data

Your personal data may be stored and processed on regional servers tailored to your location. However, as our company is primarily based in Hong Kong, some data may also be stored and processed in Hong Kong. Depending on service delivery and our global operations, certain technical operations may occasionally require limited data transfers to other jurisdictions, including where our trusted third-party service providers are located.

When we transfer your personal data across borders, we implement appropriate safeguards to ensure your data remains protected in accordance with this Policy and applicable laws. These safeguards include:

• Utilizing Standard Contractual Clauses (SCCs) or other approved mechanisms for transfers from the EU to countries not deemed to offer adequate protection
• Ensuring compliance with specific requirements for cross-border data transfers under regulations such as China's PIPL (e.g., through security assessments or standard contracts), Japan's APPI, South Korea's PIPA, and Singapore's PDPA.
• We will never transfer your sensitive health data to countries without adequate data protection frameworks unless absolutely necessary for service delivery and with your explicit consent.

7. Changes and Updates to this Policy

We may update this Policy from time to time to reflect changes in our practices or legal obligations. If we modify this Policy, we will make it available on or through the Kin Products and Services and indicate the date of the latest revision. We will make reasonable efforts to notify you of significant changes, such as through in-app notifications or emails.

8. Cookie Policy

This section describes how we use cookies and similar technologies on our website and through our Kin Technology Products and Services.

8.1. What are Cookies? Cookies are small text files placed on your device when you visit our website or use our Kindo & App services. They help our systems recognize your device and remember preferences and usage patterns. Cookies enable essential functions like secure login, account management, and help us improve your experience by remembering settings and analyzing service usage. We specifically do not use cookies to collect or store sensitive health information like medication records or prescriptions, as this data is handled through more secure, encrypted methods.

8.2. Use of Cookies We use different types of cookies to provide and enhance our services:

• Essential Cookies: Necessary for basic website and app functionality, enabling secure login, device pairing, and reliable access to schedules.
• Preference Cookies: Remember your personal settings and choices, such as dosage units and alert tones, to deliver a personalized experience.
• Analytics Cookies: Help us understand service usage by collecting anonymous information about feature usage. This data is not traceable to individual users and helps improve functionality.
• Marketing Cookies: Used for relevant marketing.
• Third-Party Cookies: Certain features may involve cookies from carefully selected third-party providers for analytics, secure payment processing, and customer support systems.

8.3. Your Control & Consent We believe in putting you in control of your privacy:

• Website Users: Manage cookie preferences anytime via the Cookie Preference Center at the bottom of every page, enabling or disabling categories. Disabling essential cookies may affect functionality.
• App Users: Manage cookie-like technologies through your device settings (e.g., iOS: Settings > Privacy > Tracking; Android: Settings > Google > Ads). You can also disable analytics tracking in the Privacy section of your App Settings.
• You have the right to withdraw your consent to our use of cookies at any time by clearing browser cookies or resetting your app preferences. However, please be aware that some features may not work properly without certain cookies enabled.