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Privacy policy

Effective as of: 1 September 2026

This policy describes how Kinema processes personal data when providing the Kinema service (the "Service"). It forms part of the contractual framework under Article 1.2 of the Terms of Service; in matters of personal data processing, it prevails. Capitalised terms have the meaning given in the Terms of Service.

1. Controller

The controller of personal data is Kinema AI Lab, s.r.o., with its registered office at Malostranské náměstí 262/9, 118 00 Prague 1, Czech Republic, Company ID (IČO): 24043362, e-mail: support@kinemalab.ai. We have not appointed a data protection officer; for all data protection matters, contact support@kinemalab.ai.

2. What Data We Process

2.1.

Account and identification: name, e-mail, password (in hashed form), billing details, account settings, versions of accepted terms and consents with timestamps.

2.2.

Payments: payment details are processed by Stripe as an independent controller/processor; we retain transaction identifiers, payment history and subscription status, not card numbers.

2.3.

Service consumption (metering): records of Credit consumption — account, type of operation, number of Credits, time. These records form the basis of billing (Article 6.5 of the Terms of Service).

2.4.

Your Content: Inputs, Outputs, Scripts, projects and Brand Documents, including any personal data contained in them. You are responsible for the legal basis for the data of third parties in Your Content (Article 8.2 of the Terms of Service).

2.5.

Likeness and voice (custom AI Actors): if you upload your likeness or voice to create a custom AI Actor, we process these recordings and data derived from them solely to provide that feature, on the basis of your express separate consent (see Article 5.3).

2.6.

Technical and operational data: IP address, device and browser type, access, error and operational event logs, performance data. We keep operational logs to the extent necessary to ensure operation, security and incident resolution.

2.7.

Communication: the content of communication with support and records of it.

2.8.

Cookies and similar technologies: governed by the separate Cookie Policy.

2.9.

Website usage data (only with your consent): pages you visit on kinemalab.ai and app.kinemalab.ai, the sections you scroll to and how long you stay, buttons you click, how you use videos (play, sound on, how far you watch), which plan cards you look at, the steps you take in the video brief and sign-up forms, device type, approximate location derived from your IP address, and the campaign or website that brought you. From the video brief we measure only its length and the options you pick, never the text you type.

2.10.

“Continue on desktop” link: when you ask us to e-mail you a link from your phone, we store your e-mail address (for sending), a random link identifier, the page and role you came from and the brief you started, so that the link can open your sign-up where you left off. If you allowed analytics, we also store your analytics identifier so we can tell that the visit on your computer continues the one on your phone.

3. Purposes and Legal Bases

PurposeDataLegal basis
Provision of the Service (account, generation, content storage, Workspaces)2.1, 2.4performance of a contract (Art. 6(1)(b) GDPR)
Billing and payments2.2, 2.3performance of a contract; compliance with a legal obligation (accounting and tax law)
Custom AI Actors2.5express consent (Art. 9(2)(a) GDPR)
Security, abuse prevention, enforcement of terms2.3, 2.6legitimate interest (protection of the Service and users)
Compliance with legal obligations (AI Act, consumer law, authority requests)as applicablecompliance with a legal obligation
Improvement of the Serviceanonymised/aggregated datalegitimate interest
Website analytics (Google Analytics 4)2.9consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via “Cookie settings”
Measuring the effect of our ads (Meta Pixel, LinkedIn Insight Tag)2.9consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via “Cookie settings”
Sending the “Continue on desktop” link2.10steps taken at your request prior to a contract (Art. 6(1)(b) GDPR); the analytics identifier only with consent
Marketing communications to existing customerse-maillegitimate interest with opt-out; otherwise consent
E-mails about Kinema: when you give us your e-mail address on the website (for example to send yourself a link or to sign up), we may send you e-mails related to using Kinema, such as the link you asked for, getting started, product updates and offers. Every e-mail includes an unsubscribe link.e-mail address, the page and button you usedlegitimate interest (Art. 6(1)(f) GDPR); you can object at any time via the unsubscribe link or by e-mail

4. What We Do NOT Do with Your Data

4.1.

We do not train on your content. We do not use Your Content (Inputs, Outputs, Scripts, Brand Documents) to train or fine-tune our AI models. From the model providers through which we generate Outputs, we contractually require the same and select providers who commit to no training (details in Article 6.2).

4.2.

We do not sell personal data to third parties.

4.3.

We do not carry out automated decision-making with legal or similarly significant effects on you.

4.4.

We do not use recordings of likeness and voice to identify, verify or authenticate persons; they serve solely to provide the feature you have requested.

5. Special Category: Likeness and Voice

5.1.

Creating a custom AI Actor requires the processing of recordings of your likeness and/or voice and of data derived from them, which may constitute biometric data.

5.2.

We carry out this processing solely on the basis of your express consent, granted in the product in a separate step before the first use of the feature, separately from the acceptance of the Terms of Service.

5.3.

You may withdraw the consent at any time in your account settings or by request to support@kinemalab.ai; upon withdrawal, the custom AI Actor and the source recordings will be deleted without undue delay. Withdrawal does not affect the lawfulness of processing before the withdrawal.

5.4.

If you upload the likeness or voice of another person, you are obliged to ensure their consent and information in accordance with legal regulations; this is your responsibility under Article 9.2 of the Terms of Service.

6. Recipients of Data

6.1.

Processors: infrastructure and AI model providers, our payment processor (Stripe), support and e-mailing tools. The current list of sub-processors is available upon request at support@kinemalab.ai. We have data processing agreements in place with our processors; subcontractors with access to Brand Documents are bound by confidentiality (Article 10 of the Terms of Service).

6.2.

AI model providers: to generate an Output, we transfer the necessary parts of your Inputs to the relevant model provider. We select providers with professional care so that their terms commit them not to use the transferred data to train their models, and we contractually require this commitment; we are not technically able to control the actual compliance of third parties with their commitments.

6.3.

Public authorities: to the extent of legal obligations or under Article 14.4 of the Terms of Service.

6.4.

Workspace members: content in a Workspace is visible to all its members and administrators (Article 4.2 of the Terms of Service).

6.5.

Transfers outside the EU/EEA take place only with safeguards under Chapter V of the GDPR (adequacy decisions, standard contractual clauses).

6.6.

Analytics and advertising providers, only if you allowed them: Google Ireland Limited (Google Analytics 4), Meta Platforms Ireland Limited (Meta Pixel) and LinkedIn Ireland Unlimited Company (Insight Tag). Their parent companies in the United States may process the data; these transfers rely on the EU–US Data Privacy Framework and standard contractual clauses. For the Meta Pixel and the LinkedIn Insight Tag we are joint controllers with the provider for the collection and transmission of the data (Art. 26 GDPR).

7. YouTube and Google Account Data

7.1.

Kinema uses YouTube API Services. When you choose to connect a YouTube channel, Google asks you to grant Kinema permission to upload videos to your YouTube channel (the youtube.upload scope). We use that permission for one purpose only: publishing the videos, titles, descriptions, tags, thumbnails, scheduled publish times and the altered-or-synthetic-content disclosure that you approve in the app. We do not read your channel's videos, subscribers, comments or analytics, and we never upload without your explicit action.

7.2.

We store an OAuth refresh token for each connected channel, encrypted at rest and never shown in the browser, together with the YouTube video IDs of uploads made through Kinema so the app can link to them. Google user data is not shared with third parties, not used for advertising, and not used to train AI models. People you invite to a channel can publish through its connection but cannot see or export the token.

7.3.

You can revoke access at any time in Channel Settings using Disconnect, which also revokes the token with Google, or from your Google account permissions page at https://myaccount.google.com/permissions. Deleting the channel or your account deletes the stored token. Use of YouTube features is also subject to the YouTube Terms of Service (https://www.youtube.com/t/terms) and the Google Privacy Policy (https://policies.google.com/privacy).

8. Retention Periods

CategoryPeriod
Account and Your Contentfor the duration of the account + a 60-day retention period after deletion (Article 17.6 of the Terms of Service), followed by permanent deletion from active systems
Recordings of likeness/voice (custom AI Actors)until withdrawal of consent or deletion of the avatar, at the latest until the end of the account retention period
Billing records, tax documentsas required by accounting and tax law (generally 10 years)
Records of consents and acceptance of termsfor the duration of the account + limitation periods
Website usage data (analytics)14 months in Google Analytics, then deleted; Kinema's own visit cookies 13 months
“Continue on desktop” link recordsthe link works for 30 days; the record is deleted after 12 months
Technical and operational logsfor a limited period necessary for operation, security and incident resolution, then deletion or anonymisation
Support communication2 years
Backupsfor the limited duration of the backup technology cycle, then overwritten
E-mail address given on the websiteuntil you unsubscribe or object, or 24 months after our last contact with you; then deleted

We may retain anonymised and aggregated data that does not identify you without limitation.

9. Your Rights

You have the right of access, rectification, erasure, restriction of processing, data portability, the right to object to processing based on legitimate interest, and the right to withdraw consent. Requests: support@kinemalab.ai. We will respond within one month. You have the right to lodge a complaint with the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů, www.uoou.gov.cz).

10. Security

We use technical and organisational measures appropriate to the risk: encryption in transit, access controls, environment separation, logging of access to production data. No transfer of data over the internet is entirely secure; you are responsible for the security of your login credentials.

11. Children

The Service is intended for persons aged 18 and over. We do not knowingly process children's data; if we discover such processing, we will delete the data.

12. Changes

We may update this policy; we will inform you of material changes by e-mail or in the product. The current version is always available at kinemalab.ai.

Contact: support@kinemalab.ai