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Privacy

Privacy Policy

PROVISIONAL Draft under review. Fields in square brackets are awaiting details from the data controller and legal advice. This is not a policy in force.

Last updated: [date]

> Prototype, 2026-10-18. The form and the chat on this site store the name, email, note and messages on the home server. Only the admin area reads them, and that is where they are deleted. They are not sent to a third party. The text below is still a draft: the fields in square brackets are not filled in.

1. Who we are

Kuia is an artificial intelligence (AI) assistant service. The controller of your personal data is [name of the controller], tax identification number (NIF) [NIF], registered office at [address]. For any privacy matter, write to [contact email].

[If applicable: Data Protection Officer: [name / contact].]

2. You are talking to an AI

When you use Kuia, you are interacting with an artificial intelligence system, not with a person. Answers are generated automatically and can contain mistakes. Check important information before you rely on it, especially on health, legal or financial matters.

3. What data we collect

  • Waitlist: your name, email and the optional note you write.
  • Using the service: what you write to Kuia (requests), the answers and the context memory linked to your account.
  • Account and API access: [email, account identifier, access keys — to be confirmed].
  • Technical data: [IP address, date and time of requests, error logs — to be confirmed].

Please do not include sensitive data in your requests (about health, ethnic origin, religion, etc.), or other people's data unless it is necessary.

4. What we use the data for and on what legal basis

PurposeLegal basis (GDPR)
Running the waitlist and contacting you about accessYour consent (Art. 6(1)(a))
Providing the service: answering requests and keeping context memoryPerformance of a contract (Art. 6(1)(b))
Security, abuse prevention and fixing errorsLegitimate interests (Art. 6(1)(f))
Meeting legal obligations (for example, invoicing)Legal obligation (Art. 6(1)(c))

Model improvement: [choose one option and confirm: "We do not use your requests to train or change the model." OR "We only use your requests to improve the model if you give explicit permission."]

5. Context memory

Kuia keeps the context of your work outside the model, so that the next task starts from what has already been done. The model does not change because of this memory. At the moment it is not yet possible to view, export or delete this memory directly in the app. You can ask for this by email (see section 8).

6. How we look after quality

Each new version of the model is tested and evaluated before it becomes available. This does not mean that each answer is checked individually. Answers can therefore contain mistakes.

7. Who we share data with

We do not sell your data. We share it only with service providers acting as our processors, under a data processing agreement (Art. 28 GDPR) and only on our documented instructions:

  • Hosting and servers: [hosting provider], [country/region].
  • [Email delivery: [provider]]
  • [Other processors: [list]]

Transfers outside the European Economic Area: [We do not make any. / We make them to [country], under [standard contractual clauses / an adequacy decision].]

We may also have to provide data to the authorities when the law requires it.

8. Your rights

As a data subject, you have the right of access, rectification, erasure, restriction of processing, data portability (a copy in a commonly used, machine-readable format) and to object, and you can withdraw your consent at any time (without affecting processing carried out before).

How to make a request: at the moment these requests cannot be made in the app. Write to [contact email] saying what you would like. We may ask you to confirm your identity. We reply within one month. That period can be extended by two further months for complex or numerous requests; if so, we will tell you within the first month.

If you believe your rights have not been respected, you can lodge a complaint with the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), at www.cnpd.pt.

9. How long we keep data

  • Waitlist: [period — e.g. until launch or until you ask to be removed].
  • Requests, answers and context memory: [period].
  • Technical logs: [period].
  • Invoicing data: the legal period ([10 years — to be confirmed]).

When the period ends, the data is deleted or anonymised.

10. Security

We use technical and organisational measures to protect your data, such as [access control / encryption — describe only what is in use]. No system is completely immune to failure. If there is a data breach that puts you at risk, we will notify the CNPD and, where the law requires it, you as well.

11. Cookies

[The site does not use analytics or advertising cookies. It only uses [none / strictly necessary technical storage] — to be confirmed.]

12. Minors

Kuia is not intended for anyone under [16].

13. Changes

We may update this policy. When the changes are significant, we will let you know by email or on the site.

Kuia · working prototype Privacy · English · 2026