Privacy Policy

LF-Softwaresolutions OG, 4050 Traun, Austria
Data protection contact: support@kinkybot.ai

Account and verification: Email address, name, password hash for password accounts, profile image and provider identifier when supplied through Google sign-in, email verification status, age confirmation, and timestamps and versions of acceptance of the Terms and consents.

Usage and content data: Chats, prompts, summaries and conversation memories used for personalization, created characters, settings, favorites, uploaded or generated images, speech-generation text and generated speech. The current voice feature synthesizes speech; no microphone-recording or audio-transcription workflow is implemented in the current application. Account-linked counters record use of messages, Coins and features.

Technical data: IP address, session identifier, timestamps, browser/device information, and security and error logs.

Communications and promotions: Support requests and replies, feedback and review results, email verification, newsletter consent and subscription status, raffle enrollment and draw records, and in-app announcement recipients, read/open status and CTA click timestamps.

Guest use: Session-linked age and consent status, guest chats and usage limits may be processed before an account is created. If guest conversations are transferred to your account, they become account-linked content.

Payments: Checkout, subscriptions, and coin purchases are currently disabled.

Account provision, chat, and image and voice features are provided for the performance of a contract or to take steps at your request prior to entering into a contract (Art. 6(1)(b) GDPR). Security, abuse prevention, and error logs are based on legitimate interests in maintaining a safe and stable service (Art. 6(1)(f) GDPR). Statutory retention is based on Art. 6(1)(c) GDPR.

Optional browser storage and newsletter delivery are based on consent (Art. 6(1)(a) GDPR). Optional AI review of feedback also requires a separate opt-in; ordinary feedback is not automatically submitted for AI review. Consent may be withdrawn at any time with effect for the future. Raffle administration and requested rewards are processed to administer your participation (Art. 6(1)(b) GDPR); abuse prevention and necessary staff audit trails rely on the legitimate interest in administering a safe service (Art. 6(1)(f) GDPR).

Internal operational statistics use existing account, usage and transaction records to understand service activity, costs and reliability. They are distinct from optional third-party browser analytics; the current cookie integration does not load a third-party analytics or advertising provider. Any legitimate-interest processing remains subject to necessity, balancing and your right to object. Sensitive content is subject to the separate safeguards in section 4.

Staff moderation: Authorized staff may review generated images and their associated prompts, including content from private chats and custom characters, where necessary for content moderation, investigating suspected abuse, preventing misuse or enforcing the Content and Usage Rules. Access is restricted to authorized staff and audited without copying images or prompt contents into audit logs. Staff must respect confidentiality and use reviewed content only for these purposes; this does not make it visible to other users.

Such review does not remove your GDPR rights. Sensitive content remains subject to the applicable Article 9 safeguards and the explicit-consent requirements described here. Content described as “private” is not exempt from authorized moderation, and the service does not promise absolute confidentiality against such review.

Intimate chats, prompts, or images that you enter freely may contain information about sex life, sexual orientation, health, or other specially protected areas. Where Art. 9 GDPR applies, we process this data on the basis of your separate explicit consent under Art. 9(2)(a) GDPR.

This processing may include disclosures to the AI and infrastructure providers described in section 5. Generated images are sent to OpenAI for content moderation before storage. The current workflow does not use Runware age classification. Moderation acceptance must not be understood as verification that an image depicts adults.

Consent is voluntary, but is required for features that process such content. You can request withdrawal without deleting your account by contacting support@kinkybot.ai. After withdrawal, affected chat, image, voice or personalization features may no longer be available. Account deletion is a separate option. The lawfulness of earlier processing is unaffected. A dedicated in-account withdrawal control is not currently provided.

Application diagnostics contain only restricted operational metadata, not emails, chat content, generated prompts or media URLs. They are held in a bounded memory buffer for at most 24 hours and are not persisted to hosting console logs. Historical hosting logs and independent provider logs are governed by their respective retention and deletion controls. This is not end-to-end encrypted processing.

Depending on the features used, data is disclosed to service providers only to the extent necessary. Based on the current technical setup, the following categories and services are used in particular:

• Replit: application hosting, runtime logs and object storage for media.
• Neon: database storage for account, content, usage, consent and operational records.
• Resend: transactional email delivery and newsletter subscription administration, including email address and necessary delivery/subscription metadata.
• Google, if you choose Google sign-in: authentication and the identity/profile fields returned for account creation or login. Google also processes the sign-in interaction under its own applicable privacy terms.
• OpenRouter and the downstream model providers used for the selected model: chat generation, conversation processing, image-prompt construction, voice-text preparation, character creation and optional feedback review. Necessary input and contextual excerpts are sent to the model provider.
• Runware: image generation, including the final image prompt and any reference image needed for the requested generation.
• OpenAI: content moderation, including text and images needed for the moderation check.
• ElevenLabs: speech synthesis, including the text to speak, selected voice and necessary generation settings.

Verified legal entities, privacy notices, processing locations and contractual roles: Replit, Inc., 1001 E Hillsdale Blvd, Suite 400, Foster City, CA 94404, USA – processor – hosting and deployment of the web app, storage of uploaded and generated media (Replit Object Storage), server logs.

The list reflects the current application paths, not proof that processing agreements or provider retention settings have been verified. Historical Xavira/fal integrations are not represented as current image processing. Before enabling another provider, its data flow must be disclosed and reviewed. OpenRouter may route to different inference providers; the actual downstream recipients and their retention/training settings must be identified rather than assumed from a model name.

The aim is not to disclose direct contact details to AI models unless they are necessary for the feature.

Some providers may process data outside the European Economic Area. Transfers require a valid mechanism, such as an applicable adequacy decision or appropriate safeguards including EU Standard Contractual Clauses, and any necessary supplementary measures. A statutory derogation must not be assumed to authorize routine provider transfers. General consent to intimate-content processing is not, by itself, a transfer safeguard.

Actual countries, recipient-specific mechanisms and access to safeguards: Replit (USA): EU Standard Contractual Clauses (Module 2) incorporated in Replit's Data Processing Agreement; Replit is not certified under the EU-US Data Privacy Framework.. Information and copies of applicable safeguards can be requested through the data protection contact. The mechanisms cannot be confirmed from application code alone.

Retention must be limited to the relevant purpose. Account data and private content are generally tied to account use or content deletion; separate periods are needed for operational records, providers and backups. A seven-year retention obligation for certain business records is not a general requirement to keep chats or all personal data for seven years.

• Accounts, chats, memories and media: For as long as your account exists. When you delete your account, your profile, chats, characters (including public ones) and generated images are deleted immediately. Payment and invoice records are kept in de-identified form for 7 years to meet Austrian tax law (§ 132 BAO).
• Support and feedback: Up to 2 years after the request is closed, then deleted.
• Newsletter subscription, raffle enrollment and draw records: Newsletter data until you unsubscribe. Raffle entries are kept until the draw ends, and winners' data for up to 12 months for prize handling and questions. Data relevant to tax law is kept longer if required.
• Announcement delivery/open/click records and staff audits: In-app messages for as long as your account exists. Admin audit logs for up to 12 months.
• Application-managed diagnostic logs: at most 24 hours in memory. Historical hosting and independent provider logs: Server and security logs for up to 30 days, unless they are needed longer to investigate a specific security incident.
• Backups and external provider copies: Database backups are automatically overwritten after at most 14 days. If a backup is restored, previously requested deletions are carried out again.
• Consent and legal-acceptance evidence: For as long as the consent is valid, plus 3 years after it is withdrawn or expires, so that we can prove consent was given.

Account deletion removes account-linked personal data, chats, generated media, voice files, feedback, notifications and all custom characters, including public profiles. Other users’ chat histories remain under an anonymous “Deleted character” placeholder, without the deleted character’s profile or media. Only de-identified payment records needed for statutory retention, minimal erasure audit records and keyed deletion hashes with deletion dates remain. A separate hash-only ledger is used to reapply erasure after database backup restoration. Interrupted storage or provider erasures are retried; an incomplete erasure is not reported as successful.

Deletion requests cannot override statutory retention obligations, the defense of legal claims, or technically limited backup cycles retroactively. Any remaining data that is restricted may only be used for the relevant exception purpose.

Technically necessary cookies and browser storage enable sessions, security, age access, and guest features. Optional categories are activated only after consent. Details and withdrawal options are provided in the Cookie Information.

AI processes prompts, conversation context and memories to generate personalized responses and media; automated moderation may block content. With your separate opt-in, submitted feedback is sent via OpenRouter for an automated assessment of whether it is concrete, relevant and safe. Approval can trigger a one-time 20-Coin credit; rejection does not, and uncertain cases may require staff review. The result and reason are recorded. Do not include private chat transcripts, intimate details or other sensitive data in feedback.

AI can make mistakes. You can contact support or the data protection contact to question a result and request human review. Whether a particular automated restriction or decision produces legal or similarly significant effects under Art. 22 GDPR must be assessed for that decision; this notice does not categorically exclude Art. 22 safeguards.

Newsletter consent is distinct from account registration and can be withdrawn through the newsletter unsubscribe option or the data protection contact. Raffle eligibility checks the current subscription status; unsubscribing can end eligibility without cancelling the account. Enrollment, eligible participant records, draws and awards are processed to administer the raffle. Winner details are not automatically published to other users by the raffle interface.

Staff can send in-app messages to one account, all accounts or a plan-based audience, immediately or on a schedule. The system records delivery/recipient status, first open/read and CTA-click timestamps, and staff audit details. These data support inbox unread state, delivery reporting and administration. An open count is not proof that someone read all content. The MVP does not send these announcements by email; promotional in-app messages still require an appropriate legal basis and review of applicable marketing rules.

Data subjects have the rights, in accordance with the GDPR, to access, rectification, erasure, restriction of processing, data portability, and objection. Consent may be withdrawn at any time with effect for the future. You may object to processing based on legitimate interests on grounds relating to your particular situation, and to processing for direct marketing at any time. You also have the right to lodge a complaint with the Austrian Data Protection Authority, Barichgasse 40–42, 1030 Vienna, dsb.gv.at, or another competent supervisory authority.

Send requests to support@kinkybot.ai. Requests generally receive a response within one month; a permitted extension of up to two additional months requires timely notice and reasons. Proportionate identity verification may be needed. The downloadable basic export below contains selected account fields and a conversation overview, not a complete copy of chat messages, media, feedback and all other personal data. Request a complete access response separately.

After signing in, a basic export and account deletion are available directly on this page. You may also request a complete access response via the data protection email address.

Data marked as required is necessary to create an account. An account cannot be provided without an email address, age confirmation, acceptance of the Terms of Service, and the required explicit consent. KinkyBot is intended exclusively for people aged 18 and over and does not knowingly process account data belonging to minors.

Technical and organizational measures appropriate to the risk are implemented. Absolute security cannot be guaranteed. This notice will be updated if features, providers, or the legal situation change. Appropriate notice will be given in the event of material changes.