PRIVACY POLICY

At Heho Solutions LLC (hereinafter, “Kiniely”), the privacy and security of your data are our priority. This policy describes how we collect, use, protect, and share your personal information when using our web platform and mobile application.

1. Data Controller

The owner and party responsible for the processing of your personal data is:

• Entity: Heho Solutions LLC.
• Headquarters: Miami, Florida, United States.
• Privacy Contact: support@kiniely.com

2. Information

We Collect For the proper functioning of Kiniely, we process the following categories of data:

• Identification Data: First name, last name, and email address.
• Account and Profile Data: Username, configuration preferences, and group participation (family, friends, or corporate).
• Technical and Usage Data: IP address, device type, operating system, unique device identifiers, and browsing data for security and analytics purposes.
• Transaction Data: Usage licenses are processed through certified payment providers (Stripe, Apple Pay, Google Pay). Kiniely does not store or have access to your full credit card or bank account details.

3. Purpose and Legal Basis for Processing 

We use your personal information based on the execution of the service contract and our legitimate interest to:

• Service Provision: Manage your account, process your predictions in real-time, and calculate standings.
• Technical Support: Attend to inquiries, resolve incidents, and improve the user experience.
• Security and Fraud Prevention: Monitor misuse of the platform and ensure the integrity of the tournaments.
• Communications: Send critical notifications about your account or ongoing tournaments, and commercial communications only if you have provided prior consent.

4. Data Retention 

Your personal data will be kept as long as you maintain an active account or as necessary to fulfill the purpose for which it was collected. After account cancellation, data may be kept blocked during legal periods to address potential administrative or judicial responsibilities. Subsequently, we will proceed with the final deletion or anonymization of the data.

5. Recipients and International 

Transfers Kiniely does not sell your personal information. However, for the operation of the platform, we share data in the following cases:

• Service Providers: We share data with essential data processors (cloud hosting, certified payment processors, analytics, and messaging services) under confidentiality agreements.
• Group Administrators and Commercial Partners: Kiniely shares data with commercial partners, companies, or individuals who create and manage groups within the platform. By joining a private or corporate group, the administrator of that group will have access to your username, predictions, and position in the standings for tournament management, incentive delivery, and internal communication purposes.
• Legal Requirements: We may disclose information if required by law or by competent authorities in compliance with judicial processes. Since our headquarters are in Miami, Florida, data from international users will be transferred and processed in the United States, with the necessary security guarantees.

6. Your Privacy Rights 

Regardless of your location, Kiniely guarantees the exercise of the following rights: Access, Rectification, Erasure (Right to be Forgotten), Restriction and Objection, and Portability. To exercise these rights, you can contact us through the app’s support channel or by sending an email to support@kiniely.com.

7. Cookies and Similar Technologies 

We use technical cookies and essential local storage to securely maintain your session, remember your viewing preferences, and ensure platform stability during high-traffic events.

8. Account Deletion Request 

At Kiniely, we respect your privacy and your right to control your personal data.

If you wish to delete your account and all associated data, please follow the steps below:

How to request account deletion:

• Send an email to: support@kiniely.com
• Use the subject: “Account Deletion Request”
• Include the email address associated with your Kiniely account

Once we receive your request, we will process the deletion within a maximum of 7 business days.

Data that will be deleted:

• User account information (email, user ID)
• Profile data
• Predictions and activity associated with your account
• Any stored preferences

Data that may be retained:

• Certain data may be retained for legal, security, or fraud prevention purposes, as required by applicable laws.
• Payment-related data may be retained by third-party providers (e.g., Stripe) according to their own policies.

Additional information:

• Once your account is deleted, the process cannot be reversed.
• You will lose access to all your data and history.

If you have any questions, contact us at support@kiniely.com

9. Updates to this Policy 

Heho Solutions LLC reserves the right to modify this Privacy Policy at any time. We will notify you of any relevant changes through the app or the email associated with your account.