Privacy Policy
Last updated: 9 October 2026
1. Introduction
This Privacy Policy explains how KochiKochi (kochikochi.app), operated by MO, a sole trader trading as KochiKochi(“we”, “us”, “our”), collects, uses, stores, and protects your personal data. We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Some data is processed as soon as you visit or sign in: error reports (Sentry), cookieless aggregated page analytics (Vercel Analytics) and product analytics (PostHog), which stores nothing on your device. Your profile data is collected when you complete onboarding and accept this Privacy Policy.
Data Controller:
MO, trading as KochiKochi
456 Apple Lane
Email: support@kochikochi.app
2. Data We Collect
2.1 Data you provide directly
When you create an account and complete onboarding, we collect:
- Display name: chosen by you during registration
- Email address: provided by your Google account
- Date of birth: to verify you are 18 or older
- Gender: used for the same-gender matching feature
- Country: suggested from your IP address by our hosting provider at the network edge (your IP is not sent to any other service for this); you can change it at any time in Settings
- Native language and learning language: used for matching you with appropriate conversation partners
- Profile avatar: provided by your Google account
- Matching preferences: such as same-gender matching preference
2.2 Data collected automatically
Each time you sign in or use the Service, we automatically collect:
- IP address: logged on every sign-in for security and moderation purposes
- Device fingerprint: a unique identifier generated from your browser properties (screen resolution, installed fonts, GPU, and other non-personal browser characteristics) using FingerprintJS. This is collected on every sign-in for moderation and ban evasion detection.
- User agent: your browser type and version, collected on every sign-in
- Call activity: records of calls you participate in, including partner ID, start time, end time, duration, and room ID. Stored in our database.
- Ratings: any thumbs up or thumbs down ratings you give or receive after calls, including optional reason tags
- Usage analytics: how you use the Service (pages viewed and product actions such as starting a match, call duration, toggling features, or upgrading), together with device and browser information, linked to your account ID. Collected via PostHog and hosted in the European Union. PostHog keeps nothing on your device (no cookies or local storage). The content of your conversations (audio, video, chat messages, captions) is never included in analytics data. You can object at any time (see Section 8).
- Page analytics: anonymous, aggregated page-view counts via Vercel Analytics. No cookies are set and nothing is linked to your account.
- Error reports: if something breaks, a report with the error, stack trace, device and browser information and your account ID is sent to Sentry so we can fix it.
2.3 Data processed in real time but not stored
During calls, the following data is processed in real time by third-party services but is not stored by KochiKochi:
- Audio (speech-to-text): When live captions are enabled by either participant in a call, audio from both participants is streamed to Deepgram (a third-party speech-to-text provider) for real-time transcription. This occurs even if only one participant has captions enabled. The audio is processed in real time and is not recorded or stored by us or by Deepgram beyond the duration of the processing.
- Video frames (content moderation): During calls, video frames from bothparticipants’ cameras are periodically captured and analysed for nudity detection using NSFWJS. Each participant’s device analyses its own outgoing video andthe other participant’s incoming video, so frames of your video are analysed on your call partner’s device, and this happens regardless of any settings or modifications on your own device. This initial analysis runs locally in the browser and no frame is sent anywhere for it. Sampling typically occurs every 1–30 seconds, depending on how long the call has been running and on account-level trust signals (such as account age), and temporarily speeds up after a potential violation is detected. Only frames flagged by the local analysis are sent to Sightengine (a third-party content moderation service) for confirmation, from either participant’s device. All other frames are discarded immediately. Frames are checked and discarded, never stored by us. A confirmed violation is recorded as a moderation log entry (scores and metadata only, no images). In addition, while you are in a call your device sends a periodic moderation heartbeat to our servers containing only status flags and numeric detection scores (never images or audio); calls whose heartbeat is lost are ended automatically.
- Caption text (translation):When you use the tap-to-translate feature, caption text is sent to Anthropic’s Claude API for translation. The text is processed in real time and is not stored by us or by Anthropic beyond the duration of the request.
2.4 Payment data
If you subscribe to KochiKochi Premium, payment is processed by Stripe. We do not collect, store, or have access to your full card number. Stripe provides us with:
- Last four digits of your card
- Card brand (Visa, Mastercard, etc.)
- Billing email
- Subscription status and billing dates
For Stripe’s data practices, refer to Stripe’s Privacy Policy at https://stripe.com/privacy.
2.5 AI Practice Partner data
If you use the AI Practice Partner feature, your spoken audio is streamed to ElevenLabs for real-time processing (speech-to-text, AI response generation via Claude, and text-to-speech). Conversation content is processed in real time and is not stored by us. ElevenLabs may retain data in accordance with their own privacy policy.
3. How We Use Your Data
We use your data for the following purposes:
| Purpose | Legal Basis (UK GDPR) |
|---|---|
| Providing the Service (matching, calls, captions, translation) | Performance of contract (Article 6(1)(b)) |
| Age verification | Legal obligation (Article 6(1)(c)) |
| Content moderation (automated and manual) | Legitimate interest: user safety (Article 6(1)(f)) |
| Ban evasion detection (IP, device fingerprint) | Legitimate interest: platform integrity (Article 6(1)(f)) |
| Honour score calculation from post-call ratings | Legitimate interest: moderation and abuse prevention (Article 6(1)(f)) |
| Processing payments | Performance of contract (Article 6(1)(b)) |
| Sending transactional emails (welcome, ban, deletion) | Performance of contract (Article 6(1)(b)) |
| Product analytics: understanding how features are used to improve the Service | Legitimate interest: service improvement (Article 6(1)(f)); you may object, see Section 8 |
| Complying with legal obligations (CSAM reporting) | Legal obligation (Article 6(1)(c)) |
4. Data Sharing
We share your data with the following third-party services, solely for the purposes described:
| Service | Data Shared | Purpose |
|---|---|---|
| Email, name, avatar (via OAuth) | Authentication | |
| Supabase | All profile and activity data | Database hosting and user management |
| LiveKit | Audio and video streams | Real-time video communication |
| Deepgram | Audio streams during calls | Speech-to-text for live captions |
| Anthropic (Claude) | Caption text | Translation and AI conversation |
| ElevenLabs | Audio streams (AI Partner only) | AI conversation voice synthesis |
| Sightengine | Video frames flagged by local analysis only | Nudity and content moderation confirmation |
| Stripe | Payment and billing data | Subscription payment processing |
| Resend | Email address, display name and the content of the email | Delivering account emails (welcome, suspension notices, account deletion, support replies) |
| Vercel | Request data needed to serve the site (IP address, user agent); aggregated page-view counts | Hosting and cookieless page analytics |
| FingerprintJS | Browser properties | Device fingerprint generation (client-side only, no data sent to FingerprintJS servers on the open-source version) |
| PostHog | Usage events, device and browser information, account ID | Product analytics (EU-hosted; no conversation content; nothing stored on your device) |
| Sentry | Error reports: stack traces, device and browser information, account ID | Application error monitoring (no conversation content) |
We do not sell your personal data to any third party. We do not share your data with advertisers. We do not use your data for targeted advertising.
5. Data Retention
| Data Type | Retention Period |
|---|---|
| Profile data | Until you delete your account |
| Call logs and ratings | For the life of your account (they feed your reputation score); deleted with your account |
| IP addresses and device fingerprints | 12 months from collection (purged automatically), or for as long as a suspension on the account is active |
| Reports and moderation logs | Retained for safety and legal purposes; your account ID is removed from them when you delete your account |
| Ban records | Until the account is deleted (see below) |
| Payment records | As required by UK tax law (typically 6 years) |
When you delete your account, your profile, call logs, ratings, sign-in logs and any ban record are deleted. Reports and moderation logs involving your account are kept with your account ID removed. A suspended account cannot be deleted while the suspension is active; contact support instead. We keep the suspension record and the related device and IP sign-in evidence to prevent ban evasion (legitimate interest).
6. Data Storage and Security
Your data is stored on servers operated by Supabase (cloud infrastructure). Data is encrypted in transit (TLS/HTTPS) and at rest. We implement the following security measures:
- Row Level Security on all database tables ensuring users can only access their own data
- API keys and secrets stored as environment variables, never committed to source code
- Two-factor authentication on all service provider accounts
- Regular backups with point-in-time recovery
- HTTPS enforced across the entire platform
Despite these measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.
7. International Data Transfers
Your data may be processed by third-party services located outside the United Kingdom, including in the United States. Where data is transferred outside the UK, we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses approved by the UK Information Commissioner's Office
- Adequacy decisions where applicable
- The third party's compliance with equivalent data protection standards
8. Your Rights
Under UK GDPR, you have the following rights:
- Right of access: request a copy of the personal data we hold about you
- Right to rectification: request correction of inaccurate data. You can update your display name, country, and preferences directly in Settings.
- Right to erasure: request deletion of your account and personal data. You can delete your account through the Settings page. Some data may be retained as described in Section 5.
- Right to restrict processing: request that we limit how we use your data in certain circumstances
- Right to data portability: request your data in a structured, machine-readable format
- Right to object: object to processing based on legitimate interests. To be excluded from product analytics, email support and we will switch it off for your account. Note that objecting to moderation-related processing may result in inability to use the Service, as moderation is essential to user safety.
- Right to withdraw consent: where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, contact us at support@kochikochi.app. We will respond within 30 days.
We send only account and support emails (for example a welcome message, a suspension notice, or a reply to your support request). We send no marketing email, so there is nothing to unsubscribe from; to stop account emails, delete your account.
9. Children's Privacy
KochiKochi is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children. If we become aware that a user is under 18, we will immediately suspend their account and delete their personal data.
If you believe a user on the platform may be under 18, please report them using the in-app reporting feature and select “Suspected underage user.” Such reports are treated with the highest priority.
10. Cookies, Local Storage and Analytics
KochiKochi uses only essential cookies: one to keep you signed in and one to remember your language. We set no analytics or advertising cookies, which is why there is no cookie banner. PostHog keeps its analytics state in memory for the page you are on and writes nothing to your device; Vercel Analytics counts page views without cookies. We do not track you across other websites.
| Cookie/Storage | Type | Purpose | Duration |
|---|---|---|---|
| Supabase auth token | Essential | Maintaining your logged-in session | Session |
| Language preference (NEXT_LOCALE) | Essential | Remembering your chosen display language | 1 year |
| PostHog analytics | None | Runs without cookies or local storage; signed-in users are recognised by their account, not their browser | Not stored |
We use PostHog, a product analytics platform, to measure how features are used: for example which pages are visited, whether a match succeeds, and which features are used during calls. Analytics events are linked to your account ID so we can understand usage per user, and are hosted by PostHog in the European Union. Analytics data never includes the content of your conversations (audio, video, chat messages, captions, or translations), and is not shared with advertisers or used for targeted advertising.
11. Automated Decision-Making
KochiKochi uses automated systems that may affect your experience:
- Content moderation: Automated nudity detection may result in your call being ended or your account being suspended. You may appeal any automated moderation decision by contacting support@kochikochi.app.
- Ban evasion detection: If your device fingerprint or IP address matches that of a previously banned account, you may be blocked from using the Service. You may appeal by contacting support@kochikochi.app.
You have the right to request human review of any significant automated decision that affects your access to the Service.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Material changes will be communicated to registered users via email or an in-app notification. The “Last updated” date at the top of this page reflects the most recent revision.
Continued use of the Service after changes take effect constitutes acceptance of the updated Privacy Policy.
13. Complaints
If you are not satisfied with how we handle your data, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):
14. Contact
For any questions, concerns, or requests regarding this Privacy Policy or your personal data, contact us at:
Email: support@kochikochi.app
Website: https://kochikochi.app