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PRIVACY POLICY

Last updated June 10, 2026

This Privacy Notice for Kovy Inc. (doing business as Kovy), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • Download and use our mobile application (Kovy), or any other application of ours that links to this Privacy Notice,

  • Use Kovy: A collaborative travel and group trip planning platform that allows users to create shared itineraries, coordinate travel plans, manage group logistics, and communicate during trips.

  • Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@kovyapp.com.


SUMMARY OF KEY POINTS

  • What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

  • Do we process any sensitive personal information? Certain jurisdictions classify specific categories of data as "special" or "sensitive" (such as racial or ethnic origins, sexual orientation, or religious beliefs). Kovy does not collect, store, or process any such categories of data. Except for precise real-time geolocation data required to provide core mapping and group synchronization features, we do not process sensitive personal information.

  • Do we collect any information from third parties? We do not collect any information from third parties.

  • How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

  • In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties (such as essential mapping API platforms and foundational AI processing models necessary to calculate itineraries).

  • How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

  • What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

  • How do you exercise your rights? The easiest way to exercise your rights is by emailing us at privacy@kovyapp.com. We will consider and act upon any request in accordance with applicable data protection laws.


TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?

  2. HOW DO WE PROCESS YOUR INFORMATION?

  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

  5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

  6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

  7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

  8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

  9. HOW LONG DO WE KEEP YOUR INFORMATION?

  10. HOW DO WE KEEP YOUR INFORMATION SAFE?

  11. DO WE COLLECT INFORMATION FROM MINORS?

  12. WHAT ARE YOUR PRIVACY RIGHTS?

  13. CONTROLS FOR DO-NOT-TRACK FEATURES

  14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

  15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

  16. DO WE MAKE UPDATES TO THIS NOTICE?

  17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

  18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?


1. WHAT INFORMATION DO WE COLLECT?


Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • phone numbers

  • names

  • email addresses

  • usernames

  • passwords

  • contact preferences

  • Travel and Itinerary Data: Flight numbers, accommodation confirmations, destination addresses, group trip names, and calendar logistics voluntarily shared or inputted into a group itinerary.

  • Shared Content and Communications: Group chat messages, real-time communication logs, media uploads (photographs and shared albums), group poll votes, and expense tracking notes shared within the Services

  • Payment Data: Tokenized transaction records and generalized billing regions generated by third-party App Distributors (such as the Apple App Store or Google Play Store) when you purchase premium features. We do not directly ingest or store your raw debit or credit card numbers on our servers.

Sensitive Information. Except for precise real-time geolocation data required to provide core mapping and group synchronization features, we do not process sensitive personal information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.

  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, camera, contacts, microphone, storage, social media accounts, sensors, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.


Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements


2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver core collaborative travel and group planning features. We process your itinerary inputs, flight data, media assets, real-time communications, and group expense logs to synchronize trip coordination dashboards among your designated event group participants.

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "12. WHAT ARE YOUR PRIVACY RIGHTS? " below.

  • To deliver tailored contextual suggestions. We may process your travel parameters, general location coordinates, and destination selections strictly to display relevant, on-platform recommendations (such as local venues, dining options, or routing alerts) directly within your group itinerary dashboards.

  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.


3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

  • Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing and delivering the core collaborative travel planning features of the Services, managing your user account, and maintaining system stability.

  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

    • Send users information about special offers and discounts on our products and services

    • Develop and display personalized and relevant advertising content for our users

    • Analyze how our Services are used so we can improve them to engage and retain users

    • Understand how our users interact with the platform so we can continuously elevate the UI/UX design;

    • Analyze performance metrics to eliminate database latency and optimize app features; and

    • Maintain rigorous network security, platform data integrity, and fraud prevention protocols across user groups.

  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

  • For investigations and fraud detection and prevention

  • For business transactions provided certain conditions are met

  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

  • For identifying injured, ill, or deceased persons and communicating with next of kin

  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

  • If the collection is solely for journalistic, artistic, or literary purposes

  • If the information is publicly available and is specified by the regulations

  • We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments


4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

  • Cloud Computing Services

  • Data Storage Service Providers

  • Data Analytics Services

  • Artificial Intelligence (AI) and Machine Learning Models

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • When we use Third-Party Mapping and Geolocation APIs: We may share localized coordinates, destination addresses, or device-level location indicators with third-party mapping platforms (including but not limited to the Google Maps Platform API and Places API) to calculate routing metrics, pin itinerary destinations, and synchronize trip tracking maps across your group. You can modify or revoke geolocation access at any time through your mobile device’s native system settings. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.

  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.


5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. This includes all external travel transactions, accommodation reservations, flight bookings, or event purchases made via third-party web routing, which are processed exclusively by those respective providers under their own independent privacy parameters. We are not responsible for the content, privacy protections, or security practices of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.


6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (such as web beacons, pixels, and mobile device SDK identifier tokens) to gather operational information when you interact with our Services. Please note that while our desktop website endpoints utilize traditional browser cookies, our mobile application relies on native device sandboxes, local storage keys, and secure mobile tokens to preserve your login session, prevent crashes, and cache itinerary configurations.

We permit authorized third-party analytics and optimization service providers to deploy baseline tracking components across our platforms strictly to evaluate feature adoption trends, diagnose server-side API synchronization latency, map app crashes, and deliver context-aware local trip suggestions. We do not transmit tracking tokens or personal data payloads to external third-party data brokers for off-platform behavioral profiling or cross-site tracking across unrelated applications.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?".

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics We may share your information with Google Analytics to track and analyze the use of the Services. The telemetry data we leverage via Google Analytics is strictly limited to performance monitoring, session-duration tracking, and core feature-utilization analytics to optimize our platform's layout and system response times. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.


7. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies: We deliver our AI Products through secure API integrations with verified third-party service providers ("AI Service Providers"), including but not limited to OpenAI and other leading foundational industry model infrastructure platforms. When you interact with these smart features across our mobile or web applications, your explicit text prompts, destination choices, and itinerary parameters are processed by these providers strictly to render your requested travel outputs, as outlined in “2. HOW DO WE PROCESS YOUR INFORMATION?”.

In strict accordance with our enterprise infrastructure agreements, your unique inputs, group chat content, and travel logs are processed in isolated environments and are never utilized by third-party AI providers to train public models, nor are they shared with external advertising systems. You remain explicitly prohibited from utilizing our embedded AI prompt fields in any manner that violates the safety boundaries or acceptable use terms of our underlying AI Service Providers.

Our AI Products Our AI Products are designed for the following functions:

  • AI bots

  • AI insights

How We Process Your Data Using AI All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.


8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Meta or Google logins) across our mobile and web applications. If you choose to register via this method, we will receive specific public profile information about you from that social media provider. This information typically includes your name, email address, and public profile picture link, along with any other baseline information you explicitly choose to make public on that social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.


9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than twelve (12) months past the termination of the user's account.

If you choose to manually initiate account deletion via our in-app settings or web dashboard, our system architecture will immediately initiate a purging routine. This process completely deletes or permanently anonymizes your personal account identifiers, secure authentication tokens, and private profile parameters from our active production databases. Please note that collaborative group assets you contributed to an active shared trip (such as chat messages, shared album media, or group expenses) may be retained in an entirely anonymized profile state to maintain the structural integrity of the itinerary for the remaining group participants.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, 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.


10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

In the event of a confirmed security breach that risks significant harm to your personal data, we will notify you and relevant regulatory authorities directly via email and on-platform alerts without undue delay, in full compliance with applicable laws.


11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 13 years of age, and we require users between the ages of 13 and 17 to have parental or guardian consent.

We do not knowingly collect or solicit data from, market to, or allow the direct account creation of children under 13 years of age (or the equivalent minimum age of digital consent dictated by applicable regional jurisdiction laws). By registering for an account or navigating our web and mobile applications, you represent that you are at least 13 years of age.

In collaborative group travel scenarios, adult users or legal guardians may manually input baseline itinerary details or names regarding minors within a private trip coordination dashboard. Where this occurs, we process that information strictly as a data processor to render the functional trip dashboard for that specific group; we never utilize minor-related inputs for profiling, tracking, or marketing communication frameworks.

If you are between the ages of 13 and 17, you represent that your parent or legal guardian has reviewed and agreed to these terms and consents to your use of the Services. If we learn that personal information from users less than 13 years of age has been collected without verifiable parental consent, we will deactivate the account and take reasonable measures to promptly delete such data from our active databases. If you become aware of any data we may have collected from children under the age of 13, please contact us immediately at privacy@kovyapp.com.


12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.


Account Information

If you would at any time like to review or change the information in your account or terminate your account, you may leverage the following mechanisms :

  • Mobile & Web App Control Panels: Navigate directly to your profile screen or account settings panel inside either the native mobile application or desktop web application dashboard to manually update your profile details or trigger an immediate "Delete Account" routine.

Upon your request to terminate or delete your account, we will deactivate your profile and permanently delete or scrub all Personally Identifiable Information (PII) associated with your account from our active databases. This includes your name, phone number, email address, password, billing address, and tokenized transaction records, and payment history records. Because Kovy is a collaborative platform, any shared content or planning details you contributed to an event group—including but not limited to group chat messages, photos, shared expenses, poll votes, grocery lists, and packing lists—will remain active and visible to other trip participants to preserve the operational integrity of their travel plans. However, your personal identity will be completely detached from this data; your name will be removed and replaced with a generic "Deleted User" placeholder, ensuring your historical contributions are fully anonymized. If you are a Group Owner, the Travel and Itinerary Data (such as flight numbers, accommodation confirmations, destination addresses, group trip names, and calendar logistics) will remain active for the group, and the permissions you configured will remain locked for remaining group members. We may retain some minimized information in our files only as necessary to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and Mobile Tracking Technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. Removing or rejecting cookies could directly affect certain functionality or services of our Web Application dashboard. To control mobile-specific performance tracking or tokens on your device, you can adjust your native mobile operating system settings (such as iOS Privacy or Android Privacy menus) to manage your system-layer permissions.

If you have questions or comments about your privacy rights, you may email us at privacy@kovyapp.com.


13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to legacy browser DNT signals. However, our web application dashboards and platform endpoints are designed to recognize and automatically honor standardized Global Privacy Control (GPC) signals broadcast by your browser or tracking protection extension. When our web servers detect a valid GPC signal from your terminal, we treat it as an automated instruction to restrict opt-in tracking parameters for that browser session, in full alignment with local state statutes.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.


14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.


Categories of Personal Information We Collect

The list below shows the categories of personal information we have collected in the past twelve (12) months. For a comprehensive inventory of all personal information we process, please refer to the section "1. WHAT INFORMATION DO WE COLLECT?"

  • A. Identifiers: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

  • B. Personal information as defined in the California Customer Records statute: Name, contact information, education, employment, employment history, and financial information

  • C. Limited classification characteristics under state or federal law: Numerical age verification data collected solely to ensure compliance with minor-use regulations and guardian consent requirements. Kovy does not track, request, or process demographic vectors such as race, ethnicity, religion, marital status, or sexual orientation.

  • G. Geolocation data: Precise device location coordinates (GPS data) or generalized network-derived location parameters.

Sensitive Data Clarification: Precise location is utilized strictly to deliver core platform utilities, including mapping calculations, group proximity checks, and local destination recommendations. We do not leverage or process precise location matrices for secondary profile monetization.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;

  • Participation in customer surveys or contests; and

  • Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - For the duration of the active account and up to twelve (12) months post-termination, as detailed in Section 9

  • Category B - For the duration of the active account and up to twelve (12) months post-termination, as detailed in Section 9

  • Category C - For the duration of the active account and up to twelve (12) months post-termination, as detailed in Section 9

  • Category G - For the duration of the active account and up to twelve (12) months post-termination, as detailed in Section 9


Sources of Personal Information

Learn more about the sources of personal information we collect in "1. WHAT INFORMATION DO WE COLLECT?"


How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "2. HOW DO WE PROCESS YOUR INFORMATION?"

We collect and process your personal information through application performance tokens, internal configuration caching trackers, and secure Google Analytics telemetry used strictly to optimize feature performance and layout usability across our mobile and web applications.

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

Zero Sale or Sharing Disclosures: Kovy has not sold, leased, or shared personal information to third-party data brokers, ad networks, or external commercial profiling entities for business or commercial advertising purposes within the preceding twelve (12) months.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".


Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data

  • Right to access your personal data

  • Right to correct inaccuracies in your personal data

  • Right to request the deletion of your personal data

  • Right to obtain a copy of the personal data you previously shared with us

  • Right to non-discrimination for exercising your rights

  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

  • Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)

  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)

  • Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)

  • Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)

  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)


How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at privacy@kovyapp.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.


Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.


Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@kovyapp.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.


15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.


Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

  • offer you the products or services that you want

  • respond to or help with your requests

  • manage your account with us

  • confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.


Canada

We process and manage your personal datasets in strict compliance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) alongside applicable provincial privacy regulations (such as Alberta’s PIPA, British Columbia’s PIPA, and Quebec’s Law 25).

International Data Transmissions: To deliver cross-platform system functionality, real-time group itinerary updates, and secure AI processing loops, your personal data parameters may be transferred, processed, and securely stored on infrastructure systems located outside of your home province or outside of Canada (including within the United States). When data is transferred across international borders, it becomes subject to the regulatory frameworks of those host jurisdictions, which may allow foreign state authorities access to information under local security directives.

Data Privacy Officer Escalations: If you are a Canadian resident seeking a formalized review of your data file transfers, or if you feel our engineering frameworks have processed your information out of alignment with PIPEDA guidelines, you have an absolute statutory right to escalate a formal inquiry directly to the Office of the Privacy Commissioner of Canada (OPC) or your provincial Privacy Commissioner.


16. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.


17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our designated Data Privacy Officer (DPO) via email at privacy@kovyapp.com


18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable privacy statutes of your country, province, or state of residence (including Canada, the US, the UK, and the EEA), you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please submit your request directly via email to: privacy@kovyapp.com


To view our complete, transparent version history, visit the Kovy Public Legal Archive.



© 2026 Kovy Inc. All right reserved.

© 2026 Kovy Inc. All right reserved.