Privacy Policy

At a glance

• Who we are: Kera is run by SPIN LLC, a company registered in Georgia. We’re responsible (the “controller”) for your personal data.
• What Kera is: a household shopping app. Members of a household add what they need, approve requests, record purchases and track budgets. There’s also an AI assistant, Kera, that you can type or talk to. You’re talking to an AI system, not a person, whenever you use the assistant, and its voice is computer-generated.
• What we collect: your account details, what you and your household put into the app, and technical data needed to run it. Some features need permissions you can refuse (camera, microphone, contacts, location, notifications).
• Who else sees it: the other members of your household, and service providers who run parts of Kera for us, including AI providers (OpenAI, Anthropic, Google, Replicate) and search providers (Brave, Shopify). Several of them are in the United States.
• What we don’t do: we don’t sell your data, we don’t share it for advertising, we don’t show ads, and the assistant never buys anything or spends money for you.
• Deleting your account: Settings → Privacy & data → Delete my data. You’re signed out at once, and your personal data is erased automatically after 30 days unless you sign back in to cancel.
• Your rights: you can ask for a copy of your data, correct it, delete it, object to some uses and withdraw consent. Email hello@spin.ge.

1. Who we are

Kera is operated by SPIN LLC (“we”, “us”), the controller of your personal data.

2. What this policy covers

This policy covers:

• the Kera mobile app (Android; an iOS version is in preparation). A link to this policy is shown when you create an account,
• the Kera web app at aikera.app,
• public gift pages that Kera users share with people outside their household (section 14),
• the Kera website at aikera.io, including its contact and early-access sign-up forms (section 3.1).

It doesn’t cover the websites and apps of shops you visit from Kera.

The admin console that SPIN LLC staff use to run Kera isn’t available to you, but section 8.4 explains what our staff can see.

3. The personal data we collect

3.1 Data you give us

3.2 Data other people give us about you

Kera is shared, so other people can enter data about you:

• another member may invite you, record a purchase you made, add a preference about you (for example an allergy), or create a gift occasion for you;
• a guest on a public gift page may leave their first name when they claim a gift (section 14).

If you put information about someone else into Kera (for example a family member’s allergy or a friend’s birthday), please make sure they’re happy for you to do so.

3.3 Data we collect automatically

3.4 Data we don’t collect

• Payment details: Kera doesn’t take payments and has no card or bank-login details.
• Bank connections: Kera doesn’t connect to your bank.
• Government ID.
• Precise location: we never store a precise GPS position.
• Your address book: see section 7.
• Date of birth: we ask you to confirm you’re an adult when you sign up, but we don’t keep your birth date.

4. How we use your data, and our legal bases

The table lists each purpose. The “legal basis” column applies under the EU and UK GDPR, the Law of Georgia on Personal Data Protection, and similar laws (see the supplements for other countries).

Our legitimate interests, in plain terms:

• Automatic AI helpers: keeping lists tidy and easy to scan. We only send the item name, not who added it.
• Security: keeping Kera and your account safe.
• Fixing errors: making the app work. Error reports carry a user ID, not your name or email.
• Improving Kera: learning which features people use. We look at this internally, don’t share it with advertisers, and don’t use it to make decisions about you.

We’ve weighed these interests against your rights and believe the processing is expected and low-impact. You can object at any time (section 12).

Do you have to give us your data? You need an email address, display name and password to create an account, and a household to use most features. Everything else is optional; if you don’t provide it, only the related feature won’t work.

What we don’t do: we don’t sell your personal data, share it for cross-context behavioural advertising, give it to data brokers, show ads, or use it for advertising profiles.

5. Allergy and dietary notes (health information)

Allergy and dietary notes (“no peanuts”, “gluten-free”, “Nino is lactose intolerant”) can reveal health information, which the law gives extra protection. We use them only so that Kera doesn’t suggest something unsafe and can respect your household’s needs.

• Consent: before you save your first allergy or dietary note, Kera asks for your explicit consent and explains that the note will be shared with the household and with our AI providers when the assistant is used.
• Notes about someone else: a note can be linked to another household member, including a child. Only add one if that person (or, for a child, their parent or guardian) agrees.
• Who sees them: members of your household, and the AI provider running the assistant when any household member uses it (section 6).
• Withdrawing consent: in Settings → Privacy & data → Health notes consent, withdraw the consent; the notes it covered are deleted. You can also delete a single note: its author or a household Admin can delete it. Once a note is deleted we stop using it.
• When your account is erased: notes you wrote, and notes about you, are deleted.

6. AI features

6.1 You’re talking to an AI

The assistant, Kera, is an AI system, not a person. Its replies are generated by AI models and can be wrong, so check anything important (especially prices and allergens) before relying on it. Kera’s voice is synthetic (AI-generated), not a recording of a real person. The app labels the assistant as AI in the chat and during voice calls.

6.2 What the assistant can and can’t do

The assistant can suggest items, answer questions about your list and budget, look things up on the web, and find product prices. It is advisory only:

• it never buys anything and never spends or moves money;
• anything it proposes (an item, a wish, a saved preference) is added only after a person taps to confirm;
• approvals, purchases and budget changes are always made by a household member.

Kera makes no decision based solely on automated processing that has legal or similarly significant effects on you. Budget warnings are simple arithmetic. Household “auto-approve” rules are set by your household’s Admin, not by AI.

6.3 What we send to which AI provider

We don’t send photos or voice audio to any AI provider other than those listed for that row.

How the AI providers may use your data. They act as our processors: they process the data to return a result to us. Under our agreements with them, they may not use it to train their models. Providers may keep data for a short period for abuse monitoring (OpenAI says up to 30 days). We ask OpenAI not to store assistant responses beyond that.

6.4 Your choices

• Most AI features run only when you use them. You can avoid them by not using the assistant, voice, or photo and link reading.
• Automatic AI helpers (category suggestions, duplicate checks, item pictures) run on item names when an item is added. To turn off AI processing for your household, email hello@spin.ge and we’ll switch it off.
• You can delete any assistant conversation from its history. To stop conversations being kept at all, email us and we’ll turn off conversation history for your household.

7. Device permissions

Every permission is optional, and you can turn it off at any time in your device settings. Turning one off only stops the related feature.

8. Who we share your data with

8.1 Inside your household

Kera is built for sharing. Members of your household can see what you add to it: your display name, requests, comments, reactions, photos and voice notes, purchases, wishes that you’ve made visible to the household, and preferences. What each member sees depends on their role; for example, children can’t see household money (section 13).

Household Admins and Buyers can export the household’s data, including every member’s display name, email address and role.

8.2 Service providers (processors)

These providers process personal data on our behalf, under contracts that require them to protect it and use it only to provide their service to us.

Notifications are handed by Expo to Apple (APNs) or Google (Firebase Cloud Messaging) to reach your device, including the notification text.

8.3 Other services our servers contact

These receive no personal data about you from us, or only what you asked us to look up:

• Barcode databases (Open Food Facts, Open Beauty Facts, Open Products Facts, Open Pet Food Facts, Open Library, UPCitemdb): the barcode number only.
• OpenStreetMap Nominatim and Overpass: the city and country you typed, or your rounded (~1 km) position, to find nearby shops.
• Exchange-rate services (Frankfurter/European Central Bank, Fawaz currency API): currency codes and dates only.
• Google favicon service: shop web addresses, to show shop logos.
• Shop websites: when you paste a link or watch a price, our servers visit that page. If the web address you pasted contains personal information, the shop’s site receives it.

Some features we’ve built aren’t active: we don’t currently use Amazon’s product API or any affiliate network, and we earn no affiliate commissions. If that changes, we’ll update this policy first and label affiliate links in the app.

8.4 Our staff

A small number of SPIN LLC staff can access Kera’s data through an admin console, to provide support, keep Kera running and handle privacy requests. Every staff action is logged. Children’s names and emails are hidden from staff by default; revealing them requires a senior role and is logged.

8.5 Other disclosures

We may disclose data if the law requires it, to respond to a valid legal request, to protect the rights, safety or property of our users, the public or us, or as part of a merger, acquisition or sale of assets. In that case, the buyer would have to honour this policy, and we would tell you where the law requires.

9. Where your data is processed

Our database and servers are in the European Union (Frankfurt). SPIN LLC is based in Georgia and staff access the data from there. Several providers in section 8.2 are in the United States or operate globally, so your data is also processed there.

Georgia and the United States don’t have the same data protection laws as the EU or UK, and Georgia does not have an EU adequacy decision. Where the law requires, we protect transfers with:

• the European Commission’s Standard Contractual Clauses (with the UK Addendum or Swiss amendments where relevant);
• an adequacy decision, where one applies, such as the EU–US Data Privacy Framework for US providers certified under it;
• safeguards required by Georgian law for transfers out of Georgia.

You can ask for a copy of these safeguards at hello@spin.ge.

10. How long we keep your data

We may keep specific data longer if we have to for legal reasons, for example to handle a dispute or comply with a legal order.

11. Deleting your account

How to delete: in the app, go to Settings → Privacy & data → Delete my data. You can also ask at https://aikera.io/account-deletion or email hello@spin.ge from your account’s email address.

What happens:

1. Straight away: your account is deactivated and you’re signed out on every device.
2. 30-day grace period: if you change your mind, sign back in within 30 days and the deletion is cancelled.
3. After 30 days: your personal data is erased automatically. We:
   • replace your email address, display name and password with meaningless placeholders, so the account can’t be used or linked to you;
   • delete your push tokens, notification settings, password-reset and email-change links, and assistant conversations;
   • delete your photos, voice notes and item pictures you uploaded (including the stored files);
   • delete your comments and reactions;
   • delete preferences you wrote and preferences about you;
   • delete the wishes you created;
   • remove your user ID from usage data;
   • remove your name and email from our staff audit log.

What stays, and why: records your household relies on, such as list items, purchases, budgets and settle-up entries, stay with the household so the other members’ history and totals are still correct. After erasure they show as added or bought by ”Removed member” and aren’t linked to you.

If you’re the only Admin of a household, Kera asks you to hand the Admin role to another member or delete the household before your account is deleted.

Data may remain in backups for the period in section 10.

12. Your rights

Depending on where you live, you have some or all of these rights:

In the app you can:

• export your household’s core data (Settings → Privacy & data → Export my data; Admins and Buyers). The export includes your account, household members, items, purchases, budgets and recurring items. For a complete copy of everything we hold about you, email us.
• change your email address, display name, items and preferences;
• turn usage analytics and crash reports on or off (Settings → Privacy & data);
• manage notifications, remove your location, delete conversations, and delete your account.

To exercise any right, email hello@spin.ge. We may ask you to confirm the request from your account’s email address or to answer questions to verify your identity; we won’t ask for more information than we need. You can use an authorised agent where your law allows; we’ll ask them for proof of authority. We reply within one month (sooner where local law requires, see the supplements), and tell you if we need more time and why. It’s free unless a request is clearly unfounded or excessive.

If we refuse a request, we’ll explain why and how to appeal or complain.

We won’t treat you differently (for example by charging more or offering a worse service) because you used your rights.

13. Children

Kera is for adults. We don’t currently offer new child accounts: an adult can’t add a child to a household, and nobody under 18 may create an account. When you sign up, we ask you to confirm you’re 18 or older. If we learn that someone under 18 has created an account, we’ll delete it.

Before we paused child accounts, a household could give a child a limited Requester account. If your household still has one, this is how we treat that child’s data:

• What a child’s account collects: their display name; the requests, notes, comments, reactions, wishes and preferences they add; photos and voice notes they attach; push token; usage data and error reports.
• What children can’t do: buy, approve requests, invite people, share gift pages, scan receipts, use snap-to-add photo recognition, import statements, use location, web search, the assistant, voice features or other AI features (such as meal planning and AI suggestions), or export data. They don’t see household money unless an Admin chooses to let them see budgets.
• Children’s data and AI: the name of an item a child adds goes to Anthropic for category and duplicate checks, with nothing that identifies the child. Items a child adds get a picture from our catalog, not from AI, and links a child pastes are read without AI. Item names are part of the household’s list, which the assistant’s AI provider sees when an adult in the household uses the assistant; allergy and dietary notes about a child are sent then too. A child’s photos, voice notes and comments are never sent to an AI provider. These providers act as our processors and may not use the data for their own purposes.
• No ads, no profiling: we never show ads to children, use their data for behavioural advertising, sell it, or build marketing profiles.
• Children’s files: photos and voice notes are stored like everyone else’s (section 16).
• Public gift pages: a child’s wishes, and occasions for a child, are never shown on a public gift page (section 14).
• Parents’ rights: a parent or guardian can remove the child from the household in the app. To review, correct or delete a child’s data, or to withdraw consent (which closes the child’s account and erases their data), email hello@spin.ge.

If you think a child has given us data without their parent’s consent, email hello@spin.ge and we’ll delete it.

14. Public gift pages and guests

An Admin or Buyer can create a public link to a gift occasion so friends and family outside Kera can see the wish list and claim a gift.

What the page shows: the occasion’s name, its next date and how many days away it is, the first name of the person who shared it, the wishes’ names and pictures, and (if the sharer chose) prices. It doesn’t show members’ emails, other household data, or who has claimed what.

What we collect from guests: if you claim a gift, just the first name you type. We don’t ask guests to create an account, and don’t set cookies. We use your name so the household knows the gift is taken (legitimate interests in making gift-giving work). We keep it for the time in section 10. To have it removed sooner, email hello@spin.ge. The page links to this policy.

Links expire after 90 days at most (30 by default) and can be turned off any time by the household.

15. Cookies and browser storage

The Kera web app doesn’t use cookies, advertising trackers or third-party analytics. It uses your browser’s local storage to:

• keep you signed in (your session token);
• remember your settings and dismissed tips;
• queue actions made offline until you’re back online.

These are needed for the features you ask for, so we don’t ask for consent. You can clear them in your browser at any time, which signs you out.

The mobile app stores your session token in your device’s secure storage.

16. Security

We protect your data with measures appropriate to the risk, including:

• encryption in transit (HTTPS/TLS) for all traffic;
• passwords stored only as salted bcrypt hashes;
• sessions that expire, and that we can end on all devices at once (for example after a password reset or deletion request);
• checks that you belong to a household, and your role, on every request;
• rate limits to slow down abuse;
• protections against our servers being tricked into fetching internal addresses, and checks on uploaded files;
• logging of every staff action in the admin console;
• encryption at rest provided by our database and storage providers.

Photos, voice notes and item pictures are stored at long, randomly generated web addresses that aren’t published or listed anywhere, so only someone who has the address can open one. We plan to restrict access further, so that only signed-in members of your household can open them.

No system is completely secure. If a breach puts your data at risk, we’ll notify the relevant authorities and you where the law requires (for example, within 72 hours under the GDPR and Georgian law).

17. Changes to this policy

We’ll update this policy as Kera changes. We’ll post the new version with its effective date. For important changes we’ll tell you in the app or by email before they take effect and, where the law requires, ask for your consent again. The previous version is at aikera.io/privacy/v1.0; older versions are available on request.

18. Contact

SPIN LLC · Ana Politkovskaia Street 22a, Floor 10, Apt 140, Vake District, Tbilisi 0186, Georgia Privacy: hello@spin.ge · Support: support@aikera.io

Regional supplements

These supplements add to the policy above for people in the listed places. If a supplement conflicts with the main policy, the supplement applies to you.

A. European Economic Area, United Kingdom and Switzerland

• Controller: SPIN LLC (section 1).
• Legal bases: section 4. Health information: explicit consent (GDPR Art. 9(2)(a)), section 5.
• Automated decisions: none with legal or similarly significant effects (GDPR Art. 22), section 6.2.
• Transfers: section 9.
• Rights: section 12, under GDPR Arts. 15–21. We reply within one month, extendable by two months for complex requests.
• Complaints: you can complain to the data protection authority where you live or work, or where the issue happened (in the EU, list at edpb.europa.eu). UK: Information Commissioner’s Office (ico.org.uk). You can also complain to us first and we’ll acknowledge it within 30 days. Switzerland: Federal Data Protection and Information Commissioner (FDPIC).
• AI transparency (EU AI Act Art. 50): section 6.1.
• Children: section 13.

B. Georgia

The Law of Georgia on Personal Data Protection (2023, in force since 1 March 2024) applies to our processing.

• Rights: to be informed, access, correction, update and completion, deletion or destruction, blocking (restriction), portability, withdraw consent, and to object to automated decisions.
• Response time: we reply within 10 working days, extendable where the law allows.
• Complaints: Personal Data Protection Service of Georgia (personaldata.ge).
• Minors: Kera is for adults and doesn’t currently offer new child accounts (section 13).
• Transfers out of Georgia: section 9.
• Breach notification: we notify the Personal Data Protection Service where required, within 72 hours.

C. United States

C.1 Children (COPPA)

Kera isn’t directed to children under 13 and doesn’t currently offer new child accounts (section 13). If we learn that we’ve collected personal information from a child under 13 without a parent’s consent, we’ll delete it. A parent or guardian can email hello@spin.ge to review or delete a child’s data, or to refuse further collection.

C.2 Your US state privacy rights

This part applies to residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and other states with comprehensive privacy laws, to the extent those laws apply to us.

Personal information we collected in the past 12 months:

We don’t sell or share personal information (including for cross-context behavioural advertising), and haven’t in the past 12 months. We don’t knowingly sell or share the personal information of consumers under 16. We use sensitive personal information only for purposes the law permits without a right to limit (providing the service you asked for, security and integrity), so we don’t offer a “limit the use” option.

Your rights: to know what we collect and disclose, access, correction, deletion, portability, and to opt out of sale, sharing, targeted advertising and profiling (which we don’t do). Where your state requires consent for sensitive data, we ask for it (section 5). Exercise them by emailing hello@spin.ge. We’ll verify your identity (section 12) and reply within 45 days, extendable once by 45 days. An authorised agent may act for you with written permission. If we deny your request, you can appeal by replying to our decision; we’ll respond within the time your state law sets and, if we deny the appeal, tell you how to contact your state Attorney General.

No discrimination: we won’t treat you differently for using your rights.

Retention: section 10.

C.3 Consumer health data (Washington, Nevada and similar laws)

Allergy and dietary notes can be “consumer health data” under Washington’s My Health My Data Act and similar laws. We collect them only with your consent (section 5), use them only to make Kera’s suggestions safe and relevant, share them only with household members and our processors (the AI providers in section 6.3), never sell them, and delete them when you ask. You can ask to access, delete or withdraw consent at hello@spin.ge.

D. Other countries