Privacy Policy

Section 01

Introduction

This Privacy Policy ("Policy") describes how Keeper ("Keeper", "we", "us", "our") collects, uses, stores, shares, and protects information about you ("User", "you", "your") when you use the Keeper mobile application and any related services (collectively, the "Service").

Keeper is a family storytelling application that sends one question per day to a designated storyteller (typically a parent or grandparent), who responds with a voice note that is preserved and made available to designated listeners within a private family group.

This Policy is incorporated by reference into our Terms of Service and constitutes a legally binding agreement. Where you use the Service on behalf of a minor or another person, you represent that you have all necessary authority and consents to do so.

Section 02

Who We Are (Data Controller)

For the purposes of applicable data protection laws, including the EU General Data Protection Regulation ("GDPR"), the Swiss Federal Act on Data Protection ("nDSG"), and any other applicable legislation, the data controller is:

EU/EEA Representative

Article 27 GDPR requires non-EU controllers offering services to EU/EEA residents to appoint an EU representative, unless the processing is occasional, does not involve large-scale processing of special category data, and is unlikely to result in a risk to the rights and freedoms of data subjects (Art. 27(2) GDPR). As a small, solo-operator side project, our current working position is that we may fall within this exemption. We recognise this is not a settled legal conclusion: because sending a daily prompt to storytellers is a core, recurring feature of the Service, a supervisory authority could reasonably take the view that our processing is not "occasional" in the strict sense Article 27(2) intends, notwithstanding our small scale. We are keeping this assessment under active review and will appoint an EU representative if our own analysis changes, or as our user base and processing activities grow.

Swiss FDPIC Notification

We are registered with and subject to the oversight of the Swiss Federal Data Protection and Information Commissioner (FDPIC) to the extent required under the revised nDSG effective 1 September 2023.

Section 03

Data We Collect

We collect only data that is strictly necessary to provide the Service ("data minimisation" principle). The categories below are exhaustive — we do not collect anything outside of this list without updating this Policy and providing fresh notice.

Voice Data — Special Category Notice

Voice recordings are processed as regular personal data under the legal bases described in Section 5 (consent and contract performance) — they are not used for voice recognition, speaker identification, or any form of biometric identification or verification of individuals, and are therefore not processed by us as special category biometric data under Article 9 GDPR. Notwithstanding this, we apply enhanced protection to voice recordings as a matter of policy: recordings are stored encrypted, accessible only to members of the specific private family group, and are never used for voice recognition, AI training, advertising targeting, or any purpose other than playback within the family group.

Section 04

Why We Process Your Data (Purposes)

Primary Purposes

• Service Delivery: Creating and managing your account; enabling voice note recording and playback; managing family group membership and invite flows; delivering daily questions to storytellers; storing and retrieving voice recordings for listening.
• Service Communication: Sending essential transactional emails (account creation, password reset, email verification). We do not send marketing emails without separate, explicit opt-in consent.
• Security & Integrity: Detecting and preventing fraud, abuse, or unauthorised access; maintaining Row Level Security so users can only access their own family's data; verifying account authenticity.
• Service Improvement: Understanding aggregated usage patterns (e.g., how many families are active) to improve the product. This is done on an anonymised/aggregated basis only and does not involve profiling individual users.
• Legal Compliance: Complying with our obligations under applicable law, responding to lawful requests from authorities, and enforcing our Terms of Service.

Expressly Excluded Purposes

We will never use your data for:

• Sale or transfer to third parties for commercial purposes
• Targeted advertising or ad network participation of any kind
• Training artificial intelligence or machine learning models
• Profiling or automated decision-making with legal or similarly significant effects
• Voice recognition, speaker identification, or biometric matching
• Data brokerage

Section 05

Legal Basis for Processing (GDPR / nDSG)

Under GDPR Article 6 and the Swiss nDSG, we must have a valid legal basis for each processing activity. Our bases are as follows:

Withdrawal of Consent

Where processing is based on your consent (Art. 6(1)(a)), you have the right to withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal. You may withdraw consent for microphone access via your device operating system settings at any time (iOS: Settings → Privacy → Microphone; Android: Settings → Apps → Keeper → Permissions). Withdrawal of microphone consent will prevent use of the core recording feature.

Section 06

Data Retention

We retain your data only for as long as necessary for the purposes for which it was collected, or as required by applicable law.

Account Deletion

You may request full account deletion at any time via the Settings screen in the app. Doing so schedules your account for deletion 30 days from your request, rather than deleting it immediately — this gives you a real window to change your mind. You can cancel a pending deletion at any time before then by returning to the Settings screen, where a banner shows the scheduled date and a "Keep my account" option. If you do not cancel, once the 30 days elapse: (a) your profile and account data are permanently deleted; (b) voice recordings you created are permanently deleted from storage; (c) family membership associations are removed. Note: if other family members have downloaded or saved copies of recordings (for example, via the app's data-export feature, described below), we cannot control their use of those local copies. You may also email privacy@keeperapp.website if you have trouble using the in-app flow.

If you would prefer not to wait — for example, to exercise your right to erasure without delay — the Settings screen also offers a separate, clearly-marked "Delete immediately instead" option. This skips the 30-day recovery window entirely: your account, recordings, and associated data are permanently deleted right away, with no way to undo it. Because this cannot be reversed, we recommend exporting your data first if you choose this option.

Exporting Your Data

Before deleting your account — or at any time — you can export your own data via Settings → Export my data. This generates a single file containing your profile information, group memberships, and every voice note you've recorded (including the actual audio, not just a link to it), along with your comments, reactions, and any custom questions you've sent, and hands it to your device's native share sheet so you can save or send it yourself. Because the file contains your actual recordings rather than time-limited download links, there is nothing that expires or that you need to remember to download before it's too late.

Section 07

Data Sharing & International Transfers

Third-Party Service Providers (Data Processors)

We engage the following third-party processors who act under our instruction and are contractually bound to protect your data:

For Apple, Google, and Expo, we rely on each provider's own published Standard Contractual Clauses, Data Processing Addendum, or equivalent GDPR-compliance framework, rather than a bespoke data processing agreement individually negotiated by us — consistent with how a small operator typically relies on the safeguards a major platform already publishes for developers using its services.

International Data Transfers (EEA/Switzerland → USA)

Your data is stored on Supabase infrastructure hosted on Amazon Web Services (AWS) in the United States. This constitutes a transfer of personal data to a third country for EEA and Swiss users. We rely on the following safeguards:

• Standard Contractual Clauses (SCCs): Supabase has executed the EU Standard Contractual Clauses (Commission Implementing Decision 2021/914) as the transfer mechanism for EEA users, providing GDPR-equivalent protections.
• Swiss SCCs: For Swiss users, transfers are governed by the equivalent Swiss standard data protection clauses recognised by the FDPIC under the revised nDSG.
• Supplementary Measures: Data is encrypted in transit (TLS 1.2+) and at rest (AES-256). Row Level Security (RLS) is enforced at the database level ensuring users can only access data belonging to their family group.

No Sale of Personal Data

Permitted Disclosures

We may disclose your data without your consent only in the following circumstances:

• Legal requirement: When compelled by a court order, subpoena, or other valid legal process issued by a competent authority with jurisdiction over us. We will, where legally permitted, notify you before complying.
• Protection of rights: To enforce our Terms of Service, protect the safety or security of our users, or protect our legal rights.
• Business transfer: In the event of a merger, acquisition, or sale of all or substantially all of our assets, personal data may be transferred to the successor entity. We will provide notice before your data is transferred and becomes subject to a different privacy policy.
• Aggregate data: We may share anonymised, aggregated, non-personally identifiable statistical information (e.g., "over 10,000 family stories recorded") publicly.

Section 08

Security Measures

We implement technical and organisational security measures appropriate to the risk. These include:

• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher.
• Encryption at rest: Voice recordings and database contents are encrypted at rest using AES-256 encryption on Supabase/AWS infrastructure.
• Access controls: Row Level Security (RLS) policies enforced at the PostgreSQL database level ensure that users can only read or write data within their authorised family group. No cross-family data access is possible.
• Signed URLs: Voice recordings are not publicly accessible. Access requires a time-limited signed URL (valid for 3,600 seconds) generated on-demand and scoped to authenticated users.
• Password security: Passwords are never stored in plain text. Authentication is handled by Supabase Auth using bcrypt hashing.
• Principle of least privilege: The application uses Supabase's anonymous public key (read-only for structure) with all write and read operations gated by authenticated session tokens and RLS policies.
• No third-party analytics SDKs: We do not include any analytics SDKs (such as Firebase Analytics, Mixpanel, or similar) that would transmit user data to third parties.

Section 09

Your Data Subject Rights

Depending on your jurisdiction, you have the following rights. We honour all of these rights equally regardless of jurisdiction, as a matter of principle.

How to Exercise Your Rights

Submit requests to privacy@keeperapp.website with the subject line "Data Subject Request". We will:

• Acknowledge your request within 72 hours
• Respond substantively within 30 days (extendable to 90 days for complex requests with notice)
• Verify your identity before processing the request (to prevent unauthorised access or deletion)
• Not charge a fee for reasonable requests (we may charge for manifestly unfounded or excessive requests)

Section 10

Children's Privacy

Keeper primarily operates in Switzerland and the European Union/EEA, and this Section is written with reference to that regulatory framework (in particular Article 8 GDPR) rather than the US COPPA regime, which is not the primary framework applicable to our operations.

Keeper is not directed at children under the age of 13, or under 16 in EU/EEA jurisdictions where the applicable age of digital consent is higher. We do not knowingly collect personal information directly from children under these age thresholds through our own account-registration flow.

Users must be at least 13 years of age to create their own account. Users between 13 and 16 in the EU/EEA require verifiable parental consent before we may lawfully process their personal data under GDPR Article 8.

Honest disclosure of our current process: we do not operate an automated age-verification or identity-verification mechanism. Age and parental-consent requirements are enforced through self-certification by the account holder at signup, and — where a family member is invited to a group rather than registering their own account — through self-certification by the inviting adult, who is responsible for confirming they have the appropriate authority or consent to include that person. We are reviewing whether a more robust verification mechanism is warranted as the Service grows.

If you are a parent or legal guardian and believe a child under the relevant age threshold has had personal information collected without appropriate consent, please contact us at privacy@keeperapp.website. Upon verification, we will delete the child's data from our systems.

The Keeper App Store listing is rated for ages 4+ (family-appropriate content), but account creation and data processing applies only to users 13 and over, subject to the self-certification process described above.

Section 11

Voice Recordings — Special Provisions

Voice recordings are the core data type processed by Keeper and warrant specific disclosure.

Microphone Permission

The app requests microphone access solely for the purpose of recording voice note responses to daily questions. The microphone is accessed only when you actively hold the record button within the app. We do not access the microphone in the background, while the app is closed, or for any purpose other than voice note recording initiated by you.

Recording Indicator

A visible recording indicator (animated record button in active state) is displayed within the app at all times during recording. Recordings cannot be initiated without the user's active, affirmative, sustained physical interaction (holding the record button). In-app notifications inform users when recording is in progress, consistent with GDPR Article 13 and applicable US state requirements.

Recording Ownership and Access

Recordings you create are stored in a private, access-controlled storage bucket. Access is restricted exclusively to members of your specific family group as defined within the app. No Keeper employee, contractor, or administrator can access your recordings for any purpose other than (a) resolving a specific technical support request you have initiated, (b) responding to a lawful legal request, or (c) security investigations in the event of a suspected breach.

AI / Machine Learning Prohibition

Your voice recordings will never be used to train artificial intelligence models, improve speech recognition systems, create voice profiles, or for any purpose beyond the Service's core function of family storytelling playback.

Recording by Non-Account Holders

If you invite a family member who is not a registered account holder to join a family group, you represent and warrant that you have obtained their informed consent to the collection and storage of their voice recordings under this Policy before they use the Service. You are solely responsible for obtaining and maintaining such consents.

Group-Wide Access (Current Product Behaviour)

Honest disclosure of how the Service currently works, and its actual limits today:

• In a family group: Listeners can access all voice notes shared to that group. Storytellers can access another storyteller's voice notes only if that storyteller has enabled the "share with other storytellers" preference described in Section 3 (off by default) — otherwise a storyteller's recordings are visible only to listeners, not to other storytellers.
• In a friends group: same-day answers to the shared daily question are hidden from other members until the viewer has recorded their own answer for that day. Once a member has answered, they can see that day's other answers, as they can any recording from a previous day.

Beyond these two gates, the Service does not currently provide per-recording access controls, and a member is not notified in-app when a new person joins their group and thereby gains access to previously recorded voice notes they're entitled to see under the rules above. If this matters to you, please bear it in mind before inviting new members to a group that contains recordings you consider sensitive. We may add finer-grained controls and notifications in the future.

Section 12

Cookies, Analytics & Tracking

The Keeper mobile application does not use cookies (which are a web browser technology). The app does not use any third-party advertising networks, tracking SDKs, or behavioural analytics platforms.

If you access a Keeper website (e.g., keeperapp.website or a privacy policy URL), that website may use essential cookies required for functionality. No third-party advertising or tracking cookies are used on any Keeper web properties. Where a cookie banner is displayed, your preferences will be respected.

We do not use Apple's IDFA (Identifier for Advertisers) or any equivalent advertising identifier. We do not check the Tracking Preference for advertising purposes because we do not serve advertising.

App Store analytics (aggregated, differential-privacy-protected data provided by Apple) may be used to understand general app performance. This data is provided by Apple in anonymised form and is subject to Apple's privacy protections; it does not identify individual users.

Section 13

California Residents (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with the following additional rights:

Right to Know

You have the right to request disclosure of: (a) the categories of personal information we have collected about you; (b) the categories of sources from which personal information is collected; (c) our business or commercial purpose for collecting or selling personal information; (d) the categories of third parties with whom we share personal information; and (e) the specific pieces of personal information we have collected about you.

Right to Delete

You have the right to request deletion of personal information we have collected from you, subject to certain exceptions.

Right to Correct

You have the right to request correction of inaccurate personal information.

Right to Opt-Out of Sale or Sharing

We do not sell or share personal information for cross-context behavioural advertising. There is nothing to opt out of. We confirm we have not sold or shared California consumers' personal information in the preceding 12 months.

Right to Limit Use of Sensitive Personal Information

Voice recordings may qualify as sensitive personal information under CPRA. We use voice recordings only for the purpose of providing the core Service (storage and playback within your family group). We do not use sensitive personal information for any purpose beyond providing the services you requested.

Right to Non-Discrimination

We will not discriminate against you for exercising your CCPA/CPRA rights. We will not deny you goods or services, charge you different prices, or provide you a different level or quality of service because you exercised your rights.

Exercising California Rights

Submit requests to privacy@keeperapp.website. We will respond within 45 days (extendable to 90 days with notice). You may designate an authorised agent to submit a request on your behalf.

Section 14

Swiss Users — nDSG (Revised Federal Data Protection Act)

The revised Swiss Federal Act on Data Protection (nDSG / LPD / DSG), in force since 1 September 2023, provides Swiss residents with data protection rights substantially equivalent to GDPR. The following provisions are of particular relevance:

• Right to information (Art. 25 nDSG): You may request information about data we hold about you, free of charge, at any time.
• Right to rectification (Art. 32 nDSG): You may request correction of inaccurate personal data.
• Right to erasure (Art. 32 nDSG): You may request erasure of your personal data subject to applicable retention obligations.
• Right to object (Art. 30 nDSG): You may object to certain types of data processing.
• Privacy by design and by default (Art. 7 nDSG): Our Service is built with privacy-protective defaults. Family data is private by default; no data is public-facing. Data collection is limited to what is necessary for the Service's functions.
• Cross-border transfer safeguards (Art. 16–17 nDSG): Transfers to the USA (Supabase/AWS) are governed by Swiss Standard Contractual Clauses, providing an adequate level of protection pursuant to the FDPIC's recognised safeguards list.
• Data Protection Impact Assessment: As explained in Section 3, we do not process voice recordings as special category biometric data under GDPR Article 9, because they are not used for voice recognition or identification. Separately, under the Swiss nDSG's broader definition of sensitive personal data — which can cover data revealing intimate or private-sphere information, not only the narrower GDPR Article 9 categories — voice recordings reflecting personal family stories may qualify as sensitive personal data under Swiss law even though they do not meet the GDPR Article 9 test. These are two distinct legal tests under two different regimes, not a contradictory position. Regardless of which categorisation applies, we have implemented technical and organisational measures (encryption, access controls, RLS policies) commensurate with the risk level.

Swiss residents may contact the Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch with complaints regarding our data processing.

Section 15

Limitation of Liability

No Warranty

THE SERVICE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT ANY WARRANTY OF ANY KIND, EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE. TO THE FULLEST EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES INCLUDING, WITHOUT LIMITATION: (A) IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT; (B) WARRANTIES THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE; (C) WARRANTIES REGARDING THE ACCURACY, RELIABILITY, OR COMPLETENESS OF ANY DATA; AND (D) WARRANTIES THAT ANY DEFECTS IN THE SERVICE WILL BE CORRECTED.

Exclusion of Consequential Damages

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, KEEPER AND ITS OPERATOR SHALL NOT BE LIABLE FOR ANY: (A) INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES; (B) LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR ANTICIPATED SAVINGS; (C) LOSS OF OR CORRUPTION OF DATA, INCLUDING VOICE RECORDINGS; (D) COSTS OF SUBSTITUTE SERVICES; OR (E) ANY OTHER PECUNIARY OR NON-PECUNIARY LOSS, WHETHER BASED ON CONTRACT, TORT, OR ANY OTHER THEORY, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Aggregate Liability Cap

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, OUR TOTAL AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATED TO THE SERVICE SHALL NOT EXCEED THE GREATER OF: (A) THE TOTAL AMOUNT YOU HAVE PAID TO US IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM; OR (B) ONE HUNDRED SWISS FRANCS (CHF 100). IF YOU HAVE NOT PAID US ANYTHING, OUR MAXIMUM LIABILITY IS CHF 100.

Data Loss

We are not liable for any loss, corruption, or unavailability of your voice recordings or other data arising from technical failures, server outages, data centre incidents, cyberattacks, or any other cause beyond our reasonable control. You are responsible for maintaining your own backup copies of recordings that are important to you, to the extent technically feasible through the app's features.

Force Majeure

We shall not be liable for any failure or delay in performance resulting from causes beyond our reasonable control, including but not limited to: acts of God, natural disasters, pandemic, war, government actions, internet infrastructure failures, third-party service provider outages (including Supabase or AWS), or cyberattacks.

Applicable Law Limitations on Exclusions

Some jurisdictions do not allow the exclusion of certain warranties or the limitation of certain types of damages. In such jurisdictions, our liability is limited to the greatest extent permitted by law. Nothing in this section limits liability for death or personal injury caused by our proven gross negligence or wilful misconduct, or for fraudulent misrepresentation.

Non-waivable rights: Nothing in this Policy limits, excludes, or waives any right that cannot be limited, excluded, or waived under applicable law, including without limitation the right to compensation for material or non-material damage arising from an infringement of the GDPR under Article 82 GDPR, and the equivalent right under the Swiss nDSG. The limitations of liability in this Policy apply only to the fullest extent that applicable law permits them to apply.

IP Infringement Disclaimer

We are not liable for any intellectual property infringement arising from: (a) user-generated content, including voice recordings; (b) questions answered by users that reference third-party materials; (c) any content shared or transmitted by users within family groups. Users are solely responsible for ensuring that content they upload or record does not infringe the intellectual property rights of any third party.

Section 16

User Indemnification

To the fullest extent permitted by applicable law, you agree to indemnify, defend, and hold harmless Keeper and its operator, affiliates, officers, directors, employees, agents, licensors, and service providers from and against any and all claims, liabilities, damages, judgments, awards, losses, costs, expenses, and fees (including reasonable legal fees) ("Claims") arising out of or relating to:

• (a) Your use of, or inability to use, the Service;
• (b) Your violation of this Policy or our Terms of Service;
• (c) Your violation of any applicable law, regulation, or third-party right, including any intellectual property right, privacy right, right of publicity, or other proprietary right;
• (d) Any content you upload, record, transmit, or otherwise make available through the Service, including voice recordings, custom questions, and profile information;
• (e) Any claim by a third party that your content infringes their intellectual property rights or other legal rights;
• (f) Any claim by an end user or third party arising from your use of the Service, including claims related to voice recordings of third parties;
• (g) Any misrepresentation made by you in connection with the Service;
• (h) Your failure to obtain legally required consents from third parties whose data you submit to the Service (including family members whose voice recordings you enable or invite);
• (i) Any claim related to your invitation of third parties to join a family group and the processing of their personal data in connection therewith.

This indemnification obligation survives termination of your use of the Service.

Section 17

User-Generated Content

The Service enables users to create, upload, and share voice recordings and other content ("User Content"). You retain ownership of your User Content. By using the Service, you grant us a limited, non-exclusive, royalty-free, worldwide licence to store, process, transmit, and make available your User Content solely to the extent necessary to provide the Service as described in this Policy.

Your Responsibilities

You are solely and exclusively responsible for all User Content you create, upload, transmit, or make available through the Service. You represent and warrant that:

• You own or have all necessary rights, licences, consents, and permissions to submit the User Content;
• Your User Content does not and will not infringe any intellectual property rights, privacy rights, or other rights of any third party;
• Your User Content does not contain any unlawful, harmful, threatening, abusive, harassing, defamatory, or otherwise objectionable material;
• You have obtained the informed consent of any person whose voice, likeness, or personal information is captured in your User Content.

Our Rights Regarding User Content

We reserve the right (but not the obligation) to remove any User Content that we determine, in our sole discretion, violates this Policy, our Terms of Service, or applicable law. We are not liable for any failure to remove User Content.

No Operator Liability for User Content

WE ARE NOT RESPONSIBLE OR LIABLE FOR ANY USER CONTENT OR FOR ANY CLAIMS, DAMAGES, OR LOSSES ARISING FROM OR RELATED TO USER CONTENT. USERS RELY ON USER CONTENT AT THEIR OWN RISK. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE EXPRESSLY DISCLAIM ALL LIABILITY IN CONNECTION WITH USER CONTENT.

Non-waivable rights: Nothing in this Section limits, excludes, or waives any right that cannot be limited, excluded, or waived under applicable law, including without limitation the right to compensation for material or non-material damage arising from an infringement of the GDPR under Article 82 GDPR, and the equivalent right under the Swiss nDSG. This disclaimer applies only to the fullest extent that applicable law permits it to apply.

Section 18

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will comply with our notification obligations as follows:

• Supervisory authority notification (GDPR Art. 33; nDSG Art. 24): We will notify the relevant supervisory authority (FDPIC for Swiss/EEA processing) within 72 hours of becoming aware of a breach that poses a risk to data subjects' rights and freedoms, unless the breach is unlikely to result in such a risk.
• User notification (GDPR Art. 34; nDSG Art. 24): We will notify affected users without undue delay when a breach is likely to result in a high risk to their rights and freedoms. Notification will be via email to the address on file and/or via in-app notification.
• US state breach laws: Where applicable (e.g., California, New York, and other US states), we will comply with applicable state breach notification laws, which may require notification within shorter timeframes.
• Breach notification content: Notifications will describe the nature of the breach, the categories and approximate number of individuals and records affected, the likely consequences of the breach, and the measures taken or proposed to address the breach.

Section 19

Changes to This Policy

We reserve the right to update or modify this Policy at any time. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Policy;
• Provide in-app notification of material changes;
• Send an email notification to your registered email address for changes that materially affect your rights or our data processing practices;
• Where legally required (e.g., for changes to processing purposes under GDPR), obtain fresh consent.

Your continued use of the Service after the effective date of a revised Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must cease using the Service and delete your account.

Prior versions of this Policy will be archived and available upon request.

Section 20

Contact, Complaints & Supervisory Authorities

Contact Us

Supervisory Authorities

You have the right to lodge a complaint with the relevant supervisory authority:

Governing Law

This Policy is governed by and construed in accordance with the laws of Switzerland, without regard to its conflict of law provisions. To the extent mandatory provisions of GDPR or other applicable laws apply to EU/EEA or US residents respectively, those mandatory protections shall apply regardless of this choice of law clause.

Dispute Resolution

Any dispute arising from this Policy or our data processing practices shall first be addressed through good-faith negotiation. If not resolved within 30 days, disputes shall be submitted to the exclusive jurisdiction of the courts of Geneva, Switzerland, subject to mandatory consumer protection laws that may grant users rights in their country of residence.

This Privacy Policy was last reviewed and updated on 11 September 2026. If you have read this far, thank you. Privacy matters — it's why Keeper stores your family's stories in a private, encrypted vault accessible only to your family. That's our promise.