Privacy Policy

Last updated: June 19, 2026

KLUBB PRIVACY POLICY

Last updated: June 19, 2026

1. INTRODUCTION

This Privacy Policy (hereinafter, the "Policy") describes how KAI VENTURES S.A.S. (hereinafter, "Klubb", "we" or "our") collects, uses, stores, shares and protects the personal data of users of the Klubb mobile application and any associated services (collectively, the "Service").

This Policy supplements the Klubb Terms and Conditions of Use (the "Terms") and is governed by Argentine Personal Data Protection Law No. 25,326 and other applicable regulations.

By downloading, accessing, registering for or using Klubb, the User accepts the practices described in this Policy. If you do not agree, you must not use the Service.

2. DATA CONTROLLER

Controller: KAI VENTURES S.A.S.

Registered address: City of Buenos Aires, Argentine Republic

Privacy contact: support@klubbai.com

3. DATA WE COLLECT

3.1. Data provided by the User

Registration data: name, email address, age-of-majority confirmation, acceptance of the Terms and Privacy Policy, and data provided by identity providers (Google, Apple or others enabled by Klubb).
Profile data: profile picture, personal description, interests, preferences and any other information the User voluntarily chooses to add.
User-generated content: plan descriptions, titles, categories, tags, messages in chats and communities, and in later stages, images or multimedia.
Subscription data: information related to Pro plan subscriptions, processed on iOS through the App Store and on Android through Google Play, including product identifiers, transaction identifiers, receipts, purchase tokens and subscription status needed to validate and administer the purchase.
AI chat queries: the content of queries made by the User to the artificial intelligence assistant within the Platform.
Communications: messages sent to support@klubbai.com or through other enabled contact channels.

3.2. Data collected automatically

Device data: model, operating system, app version, language, unique device identifiers.
Usage data: features used, plans viewed, likes, social interactions, frequency and duration of use, screens visited.
Location data: precise device location (GPS), only while the app is in use (foreground), as set forth in Section 12 of the Terms.
Technical log data: IP address, date and time of access, app errors, performance data.
Analytics, performance and campaign measurement data: technical and interaction information needed to understand Service usage, diagnose errors, measure stability, improve features and measure the performance of app acquisition or promotion campaigns. This may include app install, app open, registration, onboarding completion and general feature interaction events, technical app/device information and identifiers available depending on the platform, permissions granted by the User and system settings.

3.3. Data provided by third parties

Identity providers: when the User registers through Google, Apple or another provider, we may receive basic profile data (name, email address, profile picture) according to the permissions granted by the User to that provider.
App stores: data related to subscription status and payment, provided by the App Store or Google Play, depending on the platform used by the User.

4. PURPOSES OF PROCESSING AND LEGAL BASES

Klubb processes the User's personal data on the following bases, as applicable:

4.1. Performance of the contract (acceptance of the Terms)

Create and manage the User's account.
Provide the Service: display plans, enable social features (friends, followers, likes, communities, chats), process Swipe and recommendations.
Personalize the User's experience: plan suggestions, content ordering and relevant communities.
Process the AI chat feature, including sending User queries to AI service providers (currently OpenAI) for response generation. Klubb may send relevant context data (such as location, interests and preferences) to improve response quality.
Send operational communications related to the Service, including push notifications within the app and to the User's device.
Manage Pro plan subscriptions, process payments and administer renewals and cancellations.
Verify Venue accounts pursuant to the verification process set forth in the Terms.

Send commercial and promotional communications, including promotional push notifications, where applicable.
Access the precise location of the User's device.

The User may revoke consent at any time through the app settings or by contacting support@klubbai.com, without affecting the lawfulness of processing prior to revocation.

4.3. Legitimate interest of Klubb

Compile aggregated and anonymized statistics on Service usage.
Improve the Service, including development of new features and optimization of existing ones.
Prevent fraud, abusive use and violations of the Terms.
Ensure the security and integrity of the Platform and Klubb's systems.
Moderate content in accordance with the Terms.

4.4. Compliance with legal obligations

Retain and disclose information when required by legal or regulatory obligation, court order or request from a competent authority, pursuant to Section 10 of the Terms.
Cooperate with public authorities in criminal, administrative or civil investigations.

Klubb may share the User's personal data with the following recipients, exclusively for the purposes described in this Policy:

5.1. Service providers (data processors)

Supabase: infrastructure and database provider. Data is stored on servers managed by Supabase, which may be located outside the Argentine Republic.
OpenAI: artificial intelligence service provider. User queries to the AI chat and context data necessary to generate responses are processed by OpenAI in accordance with its data processing policies. Klubb does not authorize OpenAI to use User data to train its models.
Google Maps/Places: mapping, geocoding and geolocation services needed to display and search plans by location.
Push notification services: push messaging service providers (such as Apple Push Notification service, Expo Notifications, Firebase Cloud Messaging or others) for sending notifications to the User's device.
App Store / Apple: provider for processing and administering in-app purchases on iOS. Klubb does not store credit card data or sensitive financial information; these are processed directly by Apple.
Google Play / Google: provider for processing and administering in-app purchases on Android. Klubb does not store credit card data or sensitive financial information; these are processed directly by Google Play.
Meta / Facebook: provider of advertising measurement and app event analytics tools, through Meta App Events SDK, to measure installs, registrations, onboarding completion and campaign performance. Klubb does not share chat content, private messages, profile pictures, precise location, User-generated content or sensitive data with Meta for this purpose.

5.2. Other Users of the Platform

The User's profile information (name, photo, description, interests) is visible to other Users according to the profile's privacy settings.
Venue accounts with enabled features may view personal data of Users who interact with their plans (such as name, profile picture and profile information), according to the subscribed plan and as detailed in Section 14 of the Terms.
Messages in open communities are visible to any User of the Platform. Messages in private communities are visible only to their members.

5.3. Commercial partners (anonymized data)

Klubb may share aggregated and anonymized statistics with commercial partners, without individually identifying the User. Such data does not allow the direct or indirect identification of the User.

5.4. Authorities and legal compliance

Klubb may disclose personal data when it reasonably and in good faith considers it necessary for the purposes set forth in Section 10 of the Terms (Cooperation with Authorities and Information Retention).

5.5. Corporate transactions

In the event of a merger, acquisition, assignment or total or partial transfer of the Service or of KAI VENTURES S.A.S.'s assets, personal data may be transferred to the acquirer or successor, who shall be bound by the obligations of this Policy.

6. INTERNATIONAL DATA TRANSFERS

Personal data collected by Klubb may be stored and processed on servers located outside the Argentine Republic, including in jurisdictions where our service providers operate (Supabase, OpenAI, Google, among others).

Klubb will adopt reasonable measures to protect personal data transferred internationally, including the selection of providers that offer adequate data protection guarantees, in accordance with applicable law.

7. DATA RETENTION

Klubb will retain the User's personal data for as long as the account remains active and, thereafter, for the period necessary to:

(a) Comply with legal, regulatory or tax obligations.

(b) Preserve evidence in connection with disputes, claims or legal proceedings, whether ongoing or reasonably foreseeable.

(d) Maintain technical backup copies in accordance with Klubb's regular deletion cycles.

Anonymized or aggregated data may be retained indefinitely for statistical purposes or Service improvement.

When the User requests the deletion of their account or content, Klubb will proceed in accordance with Sections 8.4 and 17.3 of the Terms.

8. USER RIGHTS

Under Law No. 25,326 and other applicable regulations, the User has the right to:

(a) Access: request information about the personal data Klubb holds about the User.

(b) Rectification: request the correction of inaccurate or incomplete data.

(c) Update: request the update of outdated data.

(d) Deletion: request the deletion of personal data when it is no longer necessary for the purposes for which it was collected, subject to the exceptions set forth in Section 8.4 of the Terms and Section 7 of this Policy.

(e) Withdrawal of consent: withdraw consent granted for data processing, without affecting the lawfulness of processing prior to withdrawal.

To exercise these rights, the User may contact Klubb at support@klubbai.com. Klubb will respond within a reasonable period in accordance with applicable law.

The NATIONAL DIRECTORATE FOR PERSONAL DATA PROTECTION (Direccion Nacional de Proteccion de Datos Personales), the supervisory authority under Law No. 25,326, has the power to receive complaints and claims filed in connection with compliance with personal data protection regulations.

9. DATA SECURITY

Klubb implements reasonable technical and organizational measures to protect personal data against unauthorized access, loss, alteration, destruction or misuse, including:

Encryption of data in transit and at rest.
Role-based access controls.
System access monitoring and logging.
Periodic review of security measures.

However, no data storage or transmission system is completely secure. Klubb cannot guarantee the absolute security of personal data, but is committed to acting diligently to protect it in accordance with industry standards.

10. MINORS

The Service is intended exclusively for persons over eighteen (18) years of age. Klubb does not intentionally collect personal data from minors. If we become aware that data from a minor has been collected, Klubb will proceed to delete it as soon as possible.

If you are a parent or guardian and believe that a minor has provided personal data to Klubb, please contact us at support@klubbai.com so we can take appropriate action.

11. USE OF ARTIFICIAL INTELLIGENCE AND EXTERNAL PROVIDERS

Klubb uses artificial intelligence services provided by third parties (currently OpenAI) to power the Platform's assisted chat feature and recommendation systems.

When the User uses the AI chat, the content of their query and relevant context data (such as approximate location, interests and preferences configured in their profile) may be sent to the AI provider's servers to generate the response.

Klubb selects AI providers that offer adequate guarantees regarding data processing and commits to not authorizing such providers to use User data to train their own models, unless the User expressly consents to it.

Results generated by AI are for guidance purposes only and do not constitute professional advice of any kind, as set forth in Section 5.3 of the Terms.

12. ANALYTICS AND TRACKING TECHNOLOGIES

Klubb may collect technical analytics and interaction data to understand how Users use the Service, improve the user experience, diagnose errors, measure stability, optimize features and measure the performance of app acquisition or promotion campaigns.

Klubb uses Meta App Events SDK to record certain app events, such as app install or app open, completed registration, onboarding completion and other technical or interaction events needed to measure campaigns and understand Service performance. These events may include technical app and device information, available identifiers and limited event parameters. Klubb configures this measurement in accordance with the permissions granted by the User and the rules of iOS, Android, the App Store and Google Play.

Klubb does not share with Meta or advertising networks the content of private messages, chats, closed communities, AI assistant queries, profile pictures, precise location, financial data or User-generated content to create external advertising profiles.

On iOS, Klubb does not use the IDFA advertising identifier or perform advertising tracking across third-party apps or websites unless the User grants the corresponding permission through Apple's App Tracking Transparency framework and Klubb technically enables it in a future version. On Android, the use of advertising identifiers or equivalent identifiers, if available, is carried out in accordance with device settings, applicable permissions and Google Play rules.

Since Klubb operates primarily as a mobile application, it does not use cookies inside the app. The landing website may use technical technologies necessary for functionality, security, performance or basic measurement. If Klubb introduces advertising, sponsored content or additional tracking technologies in the future, it will update this Policy and request any consents required by applicable law and app store rules.