Privacy Policy

Last updated: 24 August 2026

1. Introduction

This Privacy Policy explains how KochiKochi (kochikochi.app), operated by [Your Legal Entity Name] (“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.

By creating an account and accepting this Privacy Policy during onboarding, you consent to the data practices described below. No personal data is collected or stored until you complete the onboarding process and provide your consent.

Data Controller:

[Your Legal Entity Name]
[Registered Address]
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 — auto-detected from your IP address, editable by you
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. The content of your conversations — audio, video, chat messages, captions — is never included in analytics data.

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.
Caption text (audio moderation):For premium users with captions enabled, transcribed text may be periodically sent to Google’s Perspective API for toxicity analysis. The text is processed in real time and is not stored.

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 ratings	Legitimate interest — matching quality (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))
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
Google	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
Google (Perspective API)	Transcribed text	Audio/text toxicity analysis
Stripe	Payment and billing data	Subscription payment processing
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)
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	12 months, then automatically deleted
Ratings	12 months, then automatically deleted
IP addresses and device fingerprints	12 months from date of collection
Reports	Retained indefinitely for safety and legal purposes
Ban records	Retained indefinitely for safety and legal purposes
Moderation logs	Retained indefinitely for safety and legal purposes
Payment records	As required by UK tax law (typically 6 years)

When you delete your account, your profile data, call logs, and ratings are deleted. Ban records, moderation logs, and reports involving your account may be retained for safety and legal compliance.

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. 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.

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 essential cookies for authentication and session management, and first-party analytics storage to understand how the Service is used. We do not use advertising cookies, and we do not track you across other websites.

Cookie/Storage	Purpose	Duration
Supabase auth token	Maintaining your logged-in session	Session
Theme preference	Remembering your display settings	Persistent
Language preference (NEXT_LOCALE)	Remembering your chosen display language	Persistent
PostHog analytics (ph_* cookie/local storage)	Recognising your browser across visits so product usage can be analysed	Persistent

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 and text toxicity analysis may result in your call being ended or your account being suspended. You may appeal any automated moderation decision by contacting support@kochikochi.app.
Matching: Your honour score (calculated from post-call ratings) influences which users you are matched with. Users with low honour scores may be matched with other low-scoring users.
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):

Information Commissioner’s Office

Website: https://ico.org.uk

Helpline: 0303 123 1113

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