Effective Date: 22 January 2026

Last Updated: 9 March 2026

KLYNE PRIVACY POLICY Effective Date: 22 January 2026 Last Updated: 9 March 2026

Klyne NEDA LLC (“Klyne”, “we”, “us”, or “our”) operates a private, individual-use digital reflection and personal insight application, including the Klyne mobile application, website, APIs, and related services (collectively, the “Service”). This Privacy Policy describes how we collect, use, store, disclose, and protect personal data when individuals access or use the Service.

What Klyne Is, and What It Is Not

Klyne is a consumer-facing product intended solely for private, personal use.

Klyne does not sell personal data, ever. It does not show advertisements or share data with advertising networks, ever. It does not make personal data available to employers, organisations, managers, HR platforms, or any third party with an interest in the user. It does not integrate with workplace monitoring systems, analytics tools, or any external dashboard. It does not provide any employer, organisation, or third party with visibility into individual user data.

These are not aspirational commitments. They are structural features of how Klyne is built and operated. They distinguish Klyne from the majority of consumer wellness and mental health applications on the market.

For purposes of applicable data protection laws, including the Swiss Federal Act on Data Protection (nFADP), the EU General Data Protection Regulation (GDPR), the UK GDPR, and applicable United States state privacy laws, Klyne acts as the data controller.

By accessing or using the Service, you acknowledge and agree to the practices described in this Privacy Policy.

Nature and Purpose of the Service

The Service is designed as a private self-reflection and awareness tool. Users may voluntarily log self-selected emotional labels, contextual tags, and related information for personal insight. The Service operates exclusively within the boundaries of user interaction with the application and relies only on information explicitly provided by the user and the timestamps of those entries.

Klyne does not monitor users in the workplace or elsewhere, does not observe behaviour outside the Service, and does not infer personal attributes beyond what a user explicitly chooses to log. The Service does not generate evaluations, judgments, diagnoses, or decisions about individuals and does not predict future emotional states or outcomes.

The Service is not a medical device, diagnostic tool, therapeutic service, psychological or psychiatric service, or a substitute for professional medical, psychological, legal, or financial advice. Information displayed by the Service is descriptive and informational only. Users remain solely responsible for how they interpret and act upon any information presented.

Klyne describes patterns in user-logged data. Klyne does not describe the user as a person, does not assess health status, and does not predict future emotional states.

Categories of Personal Data

We process only personal data reasonably necessary to operate, secure, and improve the Service.

Account and identification data may include name, email address, authentication credentials, and language or regional preferences.

User-provided data may include emotion labels selected by the user, scenario or context tags selected by the user, and timestamps of logged entries. The Service does not include a free-text notes feature. Users log structured, self-selected inputs only. Using the Newtonian Emotional Dynamics Algorithm (NEDA) and AI-assisted processing described below, Klyne generates derived informational outputs from user-selected labels and logged entries, including frequency, recurrence, persistence, and intensity indicators. Klyne does not infer medical, psychological, or mental health conditions.

Technical and usage data may include device type, operating system, application version, log files, timestamps, error diagnostics, and security-related metadata. This information is used solely for security, stability, abuse prevention, and service improvement.

Website analytics data: Klyne uses limited analytics tools on its website only, not within the mobile application, to understand aggregate traffic patterns and improve the website experience. Website analytics data is not linked to individual user accounts or emotional logs and is not used for advertising purposes.

Communications data may include support requests, correspondence, feedback, and incident or security reports initiated by users.

Sensitive and Health-Adjacent Data

The Service is not designed to diagnose, assess, or process health or mental health conditions. However, users may choose to log emotions or reflections that could be considered sensitive in some jurisdictions. Klyne treats such content as sensitive and applies enhanced safeguards.

Such inputs are processed only to generate descriptive summaries of logged data and are not used to infer conditions, assess health status, or make medical or psychological determinations. Users are instructed not to submit medical or diagnostic information.

Legal Bases for Processing

Where applicable, Klyne processes personal data on the basis of contractual necessity to provide and operate the Service; user consent for voluntary inputs and optional features; legitimate interests to ensure security, prevent misuse, maintain reliability, and improve functionality; and legal obligation where processing is required by law.

Where user-entered emotional logs may be considered sensitive data under applicable law, Klyne relies on explicit user consent for processing those inputs. Users must accept this Privacy Policy to create an account and use the Service.

Algorithms, Automation, and AI

Klyne uses a two-layer system to generate the informational outputs displayed to users.

The first layer is NEDA (Newtonian Emotional Dynamics Algorithm), a proprietary, rule-based computational framework that calculates escalation classifications, emotional force indicators, and pattern thresholds. NEDA determines the structure and classification of all outputs. It is not adaptive machine learning.

The second layer uses OpenAI’s API to phrase those pre-computed NEDA outputs into readable, contextually appropriate language. To produce responses that reflect a user’s recent emotional patterns, a limited window of that user’s own recent log entries is included alongside the NEDA outputs in the request sent to OpenAI.

What is transmitted to OpenAI: when a user logs a new check-in, the following data from that user’s own logs may be transmitted to OpenAI: emotion labels selected by the user, scenario or context tags selected by the user, and timestamps of logged entries from the preceding 7 days, alongside a structured prompt. No generated insights, escalation classifications, or NEDA-computed outputs are transmitted to OpenAI. Only entries from the preceding 7 days are included. No data from other users is ever included in any request. The Service does not include a free-text notes feature, so no free-text content is transmitted to OpenAI.

Processed outputs such as insights, escalation levels, and recommendations are stored on Klyne’s own backend infrastructure. They are not retained by OpenAI beyond any abuse-monitoring logs described in OpenAI’s published data retention policies.

What OpenAI does not do: OpenAI’s role is limited to language rendering. OpenAI does not determine escalation classifications or emotional force scores, as those are computed exclusively by NEDA. It does not generate independent assessments, diagnoses, or predictions about users. Based on OpenAI’s published API data usage policies, it does not use data submitted via Klyne’s API to train its models.

In-app disclosure: Klyne discloses within the application that AI-assisted language rendering is used to phrase certain outputs, in compliance with applicable App Store guidelines and as a matter of transparency. This disclosure is presented during account creation and remains accessible in application settings at any time.

The Service does not perform automated decision-making that produces legal or similarly significant effects within the meaning of Article 22 GDPR. It does not generate outcomes with authority over the user and does not replace human judgment or professional advice.

OpenAI is the only third-party AI provider used by Klyne at this time.

What Klyne Does Not Do With Your Data

Klyne does not sell personal data. It does not share personal data with advertising networks. It does not permit third-party advertising or profiling of users. It does not provide employers, organisations, or third parties with access to individual user data. It does not use emotional logs to train any AI model. It does not share data with any party for commercial purposes beyond those strictly necessary to operate the Service.

Third-Party Service Providers

Klyne may engage third-party service providers for cloud infrastructure and hosting, security and fraud prevention, website analytics (website only, not linked to emotional data or user accounts), customer support tooling, AI-assisted language rendering (OpenAI, as described above), and payment processing (Stripe).

Payment processing: Klyne uses Stripe to process subscription and one-time payments. Klyne does not store full payment card details on its own servers. Stripe’s processing of payment data is subject to Stripe’s own privacy policy at stripe.com/privacy.

All such providers act solely as data processors, are bound by contractual obligations consistent with applicable data protection law, and may process personal data only on Klyne’s instructions and for the purposes described in this Policy. A current list of categories of third-party processors is available upon request at privacy@klyne.app.

Data Retention

Personal data is retained only for as long as necessary to provide the Service, maintain account functionality, comply with legal obligations, and ensure security and abuse prevention. User logs are retained until the user deletes them or deletes their account, except where limited retention is required for backup, security, or legal purposes. Website analytics data is retained in accordance with the applicable provider’s standard retention settings and is not linked to individual user accounts.

Data Security

Klyne implements appropriate technical and organisational security measures, including encryption in transit and at rest where appropriate, access controls based on least-privilege principles, security monitoring, and regular review of security practices. Access to user content is restricted to the user and authorised personnel on a need-to-know basis for support and security purposes only.

International Data Transfers

Where personal data is transferred outside Switzerland, the European Union, or the United Kingdom, Klyne relies on lawful transfer mechanisms including adequacy decisions, standard contractual clauses, or equivalent safeguards. Where OpenAI is used for language rendering, processing locations depend on OpenAI’s infrastructure configuration. Klyne limits transmitted data to the structured fields described in the Algorithms section above.

User Rights

Depending on jurisdiction, users may have rights to access, correct, delete, restrict, or object to processing of their personal data; request data portability; withdraw consent where applicable; and lodge a complaint with a competent supervisory authority. Requests may be submitted to privacy@klyne.app. Klyne responds within legally mandated timeframes.

Age

The Service is not intended for individuals below the minimum eligible age in their jurisdiction. Where no specific local requirement applies, the minimum age is sixteen (16) years. In jurisdictions where a higher minimum age applies to digital services or health-adjacent applications, that higher age governs. Klyne does not knowingly collect personal data from individuals below the applicable minimum age. Where Klyne becomes aware that such data has been collected, it will be deleted promptly.

Changes to This Policy

Klyne may update this Privacy Policy from time to time. Material changes will be communicated through the Service or other appropriate means. The revised Last Updated date at the top of this document will reflect any changes.

Contact

privacy@klyne.app | legal@klyne.app

© 2026 Klyne NEDA LLC. All rights reserved.