Privacy
Policy.

Scope & who we are.

This Privacy Policy applies to the Kilo mobile applications (iOS and Android), our website at kilo.app, and any related online services (together, the "Services").

The data controller responsible for your personal data is:

Throughout this policy, "Kilo," "we," "us," and "our" refer to the entity above. "You" and "your" refer to the individual using our Services.

Definitions.

Personal Data

Any information that identifies you or could reasonably be used to identify you, either directly or in combination with other information.

Processing

Anything we do with Personal Data — collecting it, storing it, sharing it, deleting it, etc.

Processor

A third party that processes Personal Data on our behalf under our instructions (like Stripe or Firebase).

Services

The Kilo mobile apps, our website, and any related features or tools we provide.

Split

A shared expense inside Kilo — a subscription, bill, or other recurring cost that you and one or more other people pay into.

Information we collect.

3.1 Account & profile data

• Full name, username, and email address
• Phone number (used to match with friends and for account recovery)
• Password — we never store passwords in plain text. Authentication is handled by Firebase Authentication, which stores a salted scrypt-based hash.
• Profile photo, if you upload one (stored in Firebase Storage)
• Date your account was created
• Sign-in method (email + password or Sign in with Apple)

3.2 Financial & payment data

• Payment method metadata — card brand, last 4 digits, and expiration month/year. Your full card number is tokenized by Stripe and never reaches our servers.
• Billing address, if we're required to collect it for tax purposes
• Transaction history inside Kilo (amounts, dates, which split, which members)
• Your share allocation for each split
• If you're the organizer of a split, Stripe may share limited dispute or chargeback evidence with us if a member disputes a charge

3.3 Device & usage data

• Device model, operating system and version, app version
• IP address, and a coarse location derived from your IP (country / region — not GPS)
• Language and timezone
• Crash logs and performance metrics
• In-app events (screens viewed, features used) — used to improve the product
• Push notification token (APNs on iOS, FCM on Android)

3.4 Content you create in Kilo

• Splits and subscriptions you add (service name, cost, billing cycle, custom labels, notes)
• Receipt images you scan — stored encrypted in Firebase Storage. We run optical character recognition (OCR) on them to pre-fill line items. Images are retained for [RETENTION DAYS, e.g. 90 days] after the associated split is closed, then deleted.
• OCR output (extracted text from your receipts)
• Messages or notes you attach to a split (if applicable)

3.5 Contacts

When you tap "Find friends on Kilo," the app:

1. Reads phone numbers from your device after you grant permission
2. Normalizes them to E.164 format (e.g., +15551234567)
3. Hashes each number locally using SHA-256
4. Sends only the hashes to our servers to check for matches with existing Kilo users
5. Deletes any hash that didn't match within 24 hours
6. Stores only hashes for contacts you explicitly choose to invite (so we don't show invite suggestions you already dismissed)

Your contacts' raw names and phone numbers never leave your device.

3.6 Camera & photo library

• Camera: used only when you tap "Scan receipt." Captured images are processed as described in §3.4.
• Photo library: used only when you choose a profile photo, or select a receipt from your library instead of scanning one.
• Microphone: Kilo does not use the microphone.

3.7 Biometric data (Face ID / Touch ID / fingerprint)

If you enable biometric unlock, your fingerprint or face scan never leaves your device. Kilo does not see, collect, or store biometric data. We only receive a yes/no signal from your operating system indicating whether authentication succeeded.

3.8 Third-party sign-in

• Sign in with Apple: We receive your name (if you choose to share it) and either your real email address or Apple's relay email. We do not receive any other information from Apple.

3.9 Cookies & similar technologies (website only)

Our website uses a small number of cookies and similar technologies:

You can manage your preferences at any time through our cookie banner or in your browser settings. See our Cookie Policy for a full list of specific cookies.

How we collect it.

• Directly from you — when you sign up, edit your profile, add a split, or contact support.
• Automatically — device, usage, and crash data collected as you use the app.
• From third parties — Stripe (payment status), Apple (if you use Sign in with Apple), and push-notification providers (delivery status).
• From other users — if a friend invites you to Kilo, their device sends us a hashed version of your phone number so we can match you up when you join. If you never join, the hash is deleted after [30 days] of inactivity.
• Inferred — e.g., we may infer that you're the organizer of a split because you created it and added the payment method.

Why we use it.

Under the EU General Data Protection Regulation (GDPR), we must tell you the legal basis for each use. Here they are:

Who we share it with.

Our service providers (subprocessors)

We do not use advertising networks or attribution SDKs (e.g., Meta, TikTok, Branch, AppsFlyer). If that changes, we will update this policy and notify you.

Other users of Kilo

If you join a split, the other members of that split will see your display name, username, profile photo, and the amounts you owe or are owed within that split. They will not see your email, phone number, full payment details, or your activity in other splits.

Law enforcement & legal requests

We may disclose your information if we receive a valid legal process (subpoena, court order, warrant), or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others. Where legally permitted, we will notify you before we do so.

Business transfers

If Kilo is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will require the recipient to honor the commitments made in this Privacy Policy, and we will notify you (for example, by in-app banner or email) if your data becomes subject to a materially different privacy policy.

International data transfers.

Our primary infrastructure runs on Google Cloud's [REGION, e.g. us-central1] region in the United States. If you access Kilo from outside the United States, your Personal Data may be transferred to, stored, and processed in the U.S. or other countries where our service providers operate.

For transfers from the European Economic Area, the United Kingdom, or Switzerland to the United States, we rely on:

• the EU Standard Contractual Clauses (and the UK Addendum / Swiss supplement) with each of our U.S. processors; and
• the EU-U.S. Data Privacy Framework, the UK Extension, and the Swiss-U.S. Data Privacy Framework where our processors (including Google and Stripe) are certified.

You can request a copy of the safeguards we have in place by emailing privacy@getkilo.app.

Our EU representative (under GDPR Art. 27) is [EU REPRESENTATIVE NAME & ADDRESS, if you market to the EU]. Our UK representative is [UK REPRESENTATIVE NAME & ADDRESS, if you market to the UK].

How long we keep it.

When you delete your account, we remove or de-identify your Personal Data within 30 days, except for records we're legally required to retain (such as tax and financial records described above).

How we protect your data.

• In transit: All connections between your device and our servers are encrypted with TLS 1.2 or higher.
• At rest: Firebase Firestore and Firebase Storage encrypt data at rest by default using AES-256.
• Authentication: Passwords are hashed (scrypt) by Firebase Authentication and never stored or transmitted in plain text.
• Payments: Stripe is PCI-DSS Level 1 certified. Full card numbers never reach our servers.
• Access controls: Internal access to production data is limited to a small set of employees, logged, and requires multi-factor authentication.
• Optional in-app protections: You can enable biometric unlock and/or a 6-digit PIN inside the app.
• Incident response: If a data breach affects your Personal Data, we will notify affected users and the appropriate supervisory authority without undue delay — within 72 hours where required by GDPR.

No security program is perfect. We don't claim "military-grade" or "bank-level" security; we implement industry-standard safeguards and continuously improve them.

Your rights.

Rights available to everyone

• Access — ask what Personal Data we hold about you
• Correction — fix inaccurate or incomplete data
• Deletion — delete your account (in Settings → Account → Delete account, or by emailing us)
• Portability — export your data in a machine-readable format
• Withdraw consent — for anything you previously opted into
• Complain — lodge a complaint with your local data protection authority

To exercise these rights, email privacy@getkilo.app. We respond within 30 days. We may ask you to verify your identity before we act on your request.

EU & UK residents (GDPR / UK GDPR)

In addition to the rights above, you also have the right to:

• Restriction of processing — tell us to pause certain uses of your data
• Object — to processing we carry out based on legitimate interests, including marketing
• Not be subject to automated decisions with legal or similarly significant effects. Kilo does not make any such decisions about you.
• Lodge a complaint with your national data protection authority. In the UK, that's the Information Commissioner's Office (ico.org.uk); in Ireland, the Data Protection Commission (dataprotection.ie). A list of EU authorities is available here.

California residents (CCPA / CPRA)

If you are a California resident, you have the right to:

• Know the categories and specific pieces of Personal Information we have collected about you in the last 12 months, the sources, the business purpose, and the categories of third parties with whom we share it
• Delete Personal Information we have collected from you
• Correct inaccurate Personal Information
• Opt out of the "sale" or "sharing" of Personal Information
• Limit the use of Sensitive Personal Information
• Non-discrimination — we will not penalize you for exercising your rights
• Designate an authorized agent to make requests on your behalf (we'll verify the agent's authority before acting)

In the preceding 12 months, we have collected the categories of Personal Information described in §3. We do not use or disclose Sensitive Personal Information for purposes that would require a right-to-limit disclosure under CPRA §1798.121.

Other U.S. state privacy rights

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, or any other U.S. state with a comprehensive privacy law, you have rights substantially similar to those listed above. To exercise them, email privacy@getkilo.app. If we deny your request, you have the right to appeal; we will respond to appeals within 60 days.

Other regions

Residents of Québec (Law 25), Brazil (LGPD), and other jurisdictions with comprehensive privacy laws may have additional rights. Contact us and we'll handle your request in accordance with local law.

Children.

Kilo is a financial service intended for adults. Our Services are not directed to, nor do we knowingly collect Personal Information from, anyone under the age of 18. We age-gate at sign-up by requiring you to confirm you are at least 18.

We comply with the U.S. Children's Online Privacy Protection Act (COPPA) by not knowingly collecting data from children under 13. If you are a parent or guardian and believe your child has provided us with Personal Information, please contact privacy@getkilo.app and we will delete the information promptly.

Marketing communications.

• Email: every marketing email includes an unsubscribe link. You can also turn off marketing emails in Settings → Notifications.
• SMS (U.S.): reply STOP to opt out of marketing text messages, or HELP for help. Message & data rates may apply. Frequency varies. You can also manage SMS preferences in-app.
• Push notifications: manage from Settings → Notifications or from your device's system settings.
• Transactional messages (receipts, payment reminders, security alerts, changes to these terms) cannot be unsubscribed from while you have an active account.

Automated decisions & AI.

We use machine learning in two places:

• Receipt OCR — to turn a photo of a receipt into editable line items. You can always edit the results.
• Fraud & risk scoring — Stripe Radar evaluates payment attempts to detect fraud. A high-risk score may result in a payment being declined.

We do not make decisions that have a legal or similarly significant effect on you solely by automated means. If a payment is declined for risk reasons, you can contact support and we will review.

Third-party services & links.

Kilo helps you split the cost of third-party services, but Kilo is not affiliated with those services and does not manage your accounts with them. When you follow a link from Kilo to a third-party site (including the Apple App Store, Google Play, or the websites of services you're splitting), that third party's privacy policy — not ours — applies.

We encourage you to review the privacy practices of any third party before providing them with your data.

Do Not Track & Global Privacy Control.

Browsers can send a Do Not Track (DNT) signal. There is no industry consensus on how to interpret DNT, so we do not change our practices in response to it.

We do honor Global Privacy Control (GPC) signals as a valid opt-out of the "sale" or "sharing" of Personal Information under CCPA/CPRA. If our site detects a GPC signal from your browser, we treat it as an opt-out request for that browser / device.

Changes to this policy.

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top. For material changes — changes that expand how we use your data, add new categories of recipients, or otherwise affect your rights — we will notify you in advance by:

• an in-app banner the next time you open Kilo, and
• an email to the address on your account.

Previous versions of this policy are available on request. Your continued use of Kilo after the effective date constitutes acceptance of the updated policy.

Contact us.

We read every message our privacy team receives, and we respond within 30 days (usually much sooner).