Legal

Privacy Policy

Last updated 13 September 2026 · Kiwaro for iPhone and kiwaro.app

Kiwaro records, transcribes and translates on your phone. Your recordings never reach us. This policy covers the little that is left.

1. Who we are

Sugori Goran Shutinovski, a sole trader registered in the Polish CEIDG, NIP 5214073677, REGON 528918841. Contact for anything in this policy: info@sugori.com.

2. What stays on your phone

Your recordings, transcripts, translations, markers, summaries and everything else the app produces are stored on the device. We never receive them. Transcription, translation and the AI features run on the phone itself, using Apple’s on-device model, no prompt and no audio leaves the handset.

Kiwaro has no account: no sign-in, no password, no email address on file. If you switch on Attach location, the coordinates are written into the app’s own database on the phone and are not transmitted. If you choose to keep a copy of recordings in iCloud Drive, those files go to your iCloud account under Apple’s terms — your storage, not ours. Choose a folder on the phone instead and nothing leaves at all. The name of the folder you chose is remembered in the device Keychain, on the device.

3. What we process, and why

Account and subscription. Nothing, in the ordinary case. There is no account to create and no login. Your subscription is held by Apple against your Apple Account, and we receive only the anonymised purchase status needed to unlock Pro. Legal basis: performance of a contract, Article 6(1)(b) GDPR.

Purchases. If you buy Pro, Apple processes the payment and gives us a transaction identifier, the plan and the storefront region. We never see your card details. Legal basis: performance of a contract, Article 6(1)(b) GDPR.

Invoices and tax records. Legal basis: legal obligation, Article 6(1)(c) GDPR.

Anything you email us. Legal basis: our legitimate interest in answering you, Article 6(1)(f).

4. Who else is involved

Apple, as an independent controller, for the purchase and for the App Store. Apple’s privacy policy governs that.

5. Transfers outside the EEA

None. Nothing we hold is transferred outside the European Economic Area.

6. Automated decision-making

None. Transcription and translation are automated, but they process a recording at your request; they make no decision about you and produce no profile within the meaning of Article 22 GDPR.

7. How long

Recordings stay on your phone until you delete them. Invoices are kept 5 years, as Polish tax law requires. Emails to support are kept up to 24 months.

8. Your rights

Access, rectification, erasure, restriction, portability, and objection to processing based on legitimate interest. Most of it you can do yourself — the data is on your phone and you can delete it at any time. For anything we hold, write to info@sugori.com.

You may complain to the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warszawa.

9. Do you have to give us anything

No. There is no account, so nothing is required to use the app.

10. Children

Kiwaro is rated 4+ and collects no personal data from anyone, children included.

11. Changes

Material changes are announced in the app before they take effect.

This policy describes our own practices. It is information, not legal advice, and we are not your legal advisor. Whether a particular recording is lawful where you are depends on your local law — see the Terms for how that responsibility sits.