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.
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.
Account and identification: name, e-mail, password (in hashed form), billing details, account settings, versions of accepted terms and consents with timestamps.
Payments: payment details are processed by Stripe as an independent controller/processor; we retain transaction identifiers, payment history and subscription status, not card numbers.
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).
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).
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).
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.
Communication: the content of communication with support and records of it.
Cookies and similar technologies: governed by the separate Cookie Policy.
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).
We do not sell personal data to third parties.
We do not carry out automated decision-making with legal or similarly significant effects on you.
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.
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.
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.
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.
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.
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).
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.
Public authorities: to the extent of legal obligations or under Article 14.4 of the Terms of Service.
Workspace members: content in a Workspace is visible to all its members and administrators (Article 4.2 of the Terms of Service).
Transfers outside the EU/EEA take place only with safeguards under Chapter V of the GDPR (adequacy decisions, standard contractual clauses).
We may retain anonymised and aggregated data that does not identify you without limitation.
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).
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.
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.
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