Privacy Policy

Controller: Dawnbound Studio LLC, [ENTITY ADDRESS] ("kofy," "we," "us," or "our")

This Privacy Policy describes how kofy may collect, use, disclose, retain, and otherwise handle personal information through kofy.ai and related services. It is a notice, not a contract, and does not create rights beyond applicable law.

1. Two data commitments

1. Every model request will use a Zero Data Retention source under which the model-service provider does not retain request or response content or use that content for training.
2. kofy will not use User Content to train AI models.

Zero Data Retention applies to the model-service provider for a model request. It does not mean kofy stores nothing. kofy may store content, outputs, projects, run history, and related records for the purposes described below.

Except for these two commitments and duties imposed by applicable law, this notice does not promise a particular storage location, security method, retention period, vendor, workflow, or technical configuration.

2. Personal information kofy may handle

Depending on the features you use, kofy may handle:

• Identifiers and account data: name, email address, avatar, profile, language, account identifiers, authentication status, preferences, and account status;
• User Content: prompts, files, documents, projects, conversations, inputs, outputs, uploads, Skills, templates, examples, and related metadata;
• Commercial and activity data: purchases, subscriptions, credits, model and feature use, run history, publishing, reviews, referrals, Usage Earnings, payouts, disputes, and account actions;
• Device and network data: IP address, browser, device, Cookie or similar identifiers, timestamps, referring pages, request logs, error logs, and interaction data;
• Payment and tax data: transaction identifiers, purchase amounts, billing and tax-location data, payment status, tax forms, taxpayer identifiers, certifications, signatures, and legally required records;
• Payout and financial data: payout destination and status, account-holder and bank details, provider recipient identifiers, routing details, and account-number details needed to set up or process a payout;
• Communications and governance data: support messages, feedback, reports, complaints, review material, moderation decisions, enforcement records, and audit records; and
• Derived information: eligibility, risk, fraud, abuse, preference, and usage inferences produced from the information above.

Some payment, identity, tax, and payout information may be sensitive personal information under applicable law. kofy may transmit full details to a payment or payout provider even when kofy retains only a limited record.

3. Sources

kofy may obtain personal information:

• directly from you or an organization acting for you;
• automatically from your browser, device, and use of the Service;
• from sign-in, payment, tax, payout, hosting, analytics, security, and model-service providers;
• from other users, complainants, rights holders, or persons involved in a transaction or dispute; and
• from public sources, authorities, or other sources permitted by law.

4. Purposes and legal bases

kofy may handle personal information to:

• create, authenticate, secure, administer, and close accounts;
• provide, personalize, measure, charge for, support, change, and improve the Service;
• process model requests, content, purchases, subscriptions, credits, refunds, disputes, referrals, Usage Earnings, payouts, and taxes;
• publish, review, rank, restrict, remove, or enforce rules concerning Skills, templates, content, accounts, and transactions;
• detect, investigate, prevent, and respond to errors, fraud, abuse, security events, rights claims, prohibited conduct, and legal process;
• communicate with you and keep transaction, consent, tax, audit, and operational records;
• exercise or defend legal claims, enforce agreements, and protect kofy, users, third parties, and the Service; and
• conduct other compatible or disclosed purposes permitted by law.

Where a legal basis is required, kofy may rely on performance of a contract, steps requested before a contract, compliance with law, legitimate interests, consent, or another basis available under applicable law. Legitimate interests may include operating, securing, improving, commercializing, and defending the Service; preventing fraud and abuse; and protecting users and rights. Where processing relies on consent, you may withdraw it for future processing, but withdrawal does not affect prior lawful processing or processing supported by another basis.

5. AI model requests

A model request may include text, images, selected project material, Skill instructions, settings, and technical metadata needed to process the request. kofy may separately store inputs, outputs, conversations, run history, usage, cost, error, and safety records. The two commitments in Section 1 apply to model requests.

6. Disclosure and recipients

kofy may disclose personal information as reasonably needed for the purposes above to:

• hosting, storage, delivery, support, security, analytics, and other service providers;
• model-service providers processing model requests under Zero Data Retention;
• Google, Discord, or another sign-in provider you choose;
• Stripe, Wise, banks, payment networks, tax-service providers, and other payment or payout participants;
• other users or the public when you publish or share information or use a public feature;
• professional advisers, auditors, insurers, financing sources, and transaction counterparties;
• rights holders, complainants, affected persons, authorities, courts, and others where kofy believes disclosure is appropriate to comply with law, respond to process, enforce terms, investigate conduct, protect rights or safety, or defend claims; and
• an actual or proposed buyer, investor, lender, affiliate, successor, or other participant in a merger, financing, reorganization, asset transfer, insolvency, or similar transaction.

Some recipients, including sign-in, payment, payout, and model-service providers, may independently determine how they handle information under their own terms and privacy notices.

7. Browser and device storage

kofy may use session Cookies and similar technologies for authentication, security, preferences, referral attribution, analytics, and Service operation. kofy may use local browser storage, including localStorage and IndexedDB, for preferences, drafts, document caches, and recovery data. Your browser may allow you to block or delete this storage, but doing so may prevent features from working or remove locally stored material.

kofy does not currently respond to browser "Do Not Track" signals. The California disclosure in Section 11 explains kofy's current sale and sharing practices.

8. Retention, deletion, and account closure

kofy may retain each category of personal information for as long as reasonably necessary for the purposes for which it was collected or another compatible, disclosed, or legally permitted purpose. Relevant criteria include account and feature use, the nature and sensitivity of the information, transaction and tax requirements, payment or payout status, backup cycles, fraud and security needs, disputes, enforcement, legal holds, limitation periods, and other legal obligations.

Deletion of an account or item does not require deletion of information that kofy may lawfully retain, including transaction, tax, payout, consent, dispute, fraud-prevention, safety, moderation, audit, backup, and legal records. kofy may retain de-identified or aggregated information where permitted by law. In-product account closure is separate from a statutory privacy request and may have contractual conditions stated in the Published Rules.

9. International handling

kofy and its recipients may handle information in the United States and other countries whose laws differ from those where you live. Where applicable law requires a transfer mechanism, kofy may rely on an adequacy decision, Standard Contractual Clauses, another approved safeguard, or a lawful exception. You may request information about an applicable safeguard at .

10. Choices and privacy rights

Available account controls may let you update profile information, manage preferences, delete eligible content, cancel a subscription, or request account closure.

Depending on your location and subject to legal exceptions, you may have rights to know, access, correct, delete, or obtain a copy of personal information; restrict or object to processing; withdraw consent; opt out of certain sale, sharing, targeted advertising, or profiling; limit certain uses of sensitive information; appeal a request decision; or complain to a regulator. kofy may verify your identity, authority, and request before acting. kofy will honor these rights only to the extent and in the manner required by applicable law.

Submit a privacy request to . An authorized agent may submit a request where permitted by law, subject to verification of the agent's authority and the consumer's identity.

11. California disclosures

For the preceding 12 months, kofy may have collected the categories described in Section 2 from the sources in Section 3, used them for the purposes in Section 4, and disclosed them for business purposes to the categories of recipients in Section 6.

For the preceding 12 months, kofy did not sell personal information or share it for cross-context behavioral advertising as those terms are defined by the California Consumer Privacy Act. kofy did not knowingly sell or share personal information of consumers under 16. kofy does not use or disclose sensitive personal information for the purpose of inferring characteristics beyond purposes permitted without a right to limit under applicable law.

California consumers may have the rights listed in Section 10 and the right not to receive discriminatory treatment for exercising them. Because kofy does not currently sell or share personal information as defined by the CCPA, kofy does not currently provide a "Do Not Sell or Share My Personal Information" link. If these practices change, kofy may update this notice and provide any mechanism required by law.

12. Security

kofy may use technical, organizational, and contractual measures intended to protect personal information. No method of storage or transmission is completely secure, and kofy does not guarantee absolute security.

13. Age limit

The Service is intended only for people at least 18 years old. kofy may close an ineligible account and handle related information as permitted or required by law.

14. Changes

kofy may update this notice at any time. The current version and effective date will be posted on kofy.ai. kofy may provide additional notice where required by law.

15. Contact

Privacy questions and requests may be sent to:

Dawnbound Studio LLC

[ENTITY ADDRESS]