Privacy Policy for getkorys.com

Privacy Policy for KORYS App and KORYS Junior

Last updated: October 11, 2026

1. Who we are and what this policy covers

KORYS App and KORYS Junior are operated by Intercept, Tapuitstraat 54C, 3083 WS Rotterdam, the Netherlands, Chamber of Commerce (KvK) number 75199955. Intercept is responsible for the personal data described here. Contact: [email protected].

This policy covers getkorys.com, korysapp.com and korysjunior.com, including exercises, reflections, AI coach conversations, voice interactions, support and WhatsApp interactions where offered. KORYS App is for adults aged 18 or older. KORYS Junior is intended for people aged 13 or older, particularly ages 13–17. This does not mean every feature is available to every age group or in every country. See section 3.

Personal data means information that identifies you or could be linked to you. A random device code, a phone number, a voice recording and a conversation can be personal data even without your name.

2. A short explanation for young users

  • The KORYS coaches are AI, not real people. An AI conversation involves sending what you say or write to the providers needed to generate a response.
  • Share only what is needed. Do not send passwords, payment card details, identity documents or detailed medical information. Avoid identifying other people.
  • Optional usage measurement is separate from conversations. You can refuse it. We do not send your name, email address, conversation content or reflection answers to Mixpanel.
  • A parent or school paying for KORYS does not automatically receive your private conversations.
  • Some choices require a parent or guardian. Some features have higher age limits. Ask us at [email protected] if something is unclear.
  • This policy explains data use. Reading it is not consent to optional tracking, recording, marketing or public sharing.

3. Ages, parents and different countries

KORYS Junior is not offered to children under 13. KORYS App is not offered to people under 18. If we learn that personal data has been collected contrary to these age rules or without required parental authorisation, we will investigate, restrict the affected processing and arrange deletion where appropriate, subject to lawful retention obligations.

The minimum age for using Junior, the age for independently consenting to data processing, and the age for entering a paid contract are different questions. Local law determines which permissions are necessary. In the Netherlands, a parent or legal guardian must give or authorise consent-based processing for a child under 16. For online services in the EU, national digital-consent thresholds vary between 13 and 16. Rules outside the EU may differ. A school subscription or an adult payment is not, by itself, valid parental consent for every purpose.

Where parental consent is required, the relevant feature or optional processing may be used only after that authorisation has been obtained and appropriately verified. Consent must be specific and can be withdrawn. It must not be bundled into acceptance of these terms or made a condition of unrelated features.

Third-party requirements also apply. ElevenLabs requires written approval for apps or experiences directed at people under 18. An ElevenLabs-powered Junior interaction must not be used by a person under 18 unless that approval covers the use and all applicable parental-consent and other requirements have been satisfied. Junior's general 13+ age does not override this restriction. WhatsApp has its own eligibility rules, which may vary by country and account type.

4. Information processed

The information depends on the features you actually use:

  • Account, contact and support information: information you submit, such as a name, email address, requests and correspondence. Visiting a page does not require you to provide a name or email address.
  • Exercises and preferences: selections, progress, language, theme and reflection answers where a feature stores or transmits them. Information kept only in your browser stays there unless a feature sends it to a service.
  • AI conversations: prompts, messages, responses and relevant conversation context. Voice interactions also involve microphone audio, speech recognition, generated speech, transcripts and technical session information. Audio recordings and conversation history may be retained when the relevant provider's recording or retention settings are enabled. Do not assume a call is unrecorded or immediately deleted.
  • WhatsApp: your phone number, profile information available in the interaction, messages, voice messages or attachments you send, and delivery or other message metadata made available to us. This applies when you actually contact KORYS through WhatsApp.
  • Transactions: purchaser contact details, order and invoice information, payment status and subscription identifiers where you buy a service. Payment card details are handled by the payment processor, rather than included in AI conversations.
  • Age and permission information: the age eligibility, country and parent or guardian information needed for a relevant permission, and records of choices and authorisations. We seek proportionate verification rather than unnecessary identity documents.
  • Technical information: IP address, device and browser information, request times, errors and security logs processed by the infrastructure needed to deliver and protect the service.
  • Optional analytics: a random device identifier, feature and button events, page or screen information and technical context, as described in section 6.

Your voice is personal data. Using audio for speech recognition does not, by itself, mean it is being used as a biometric identifier. KORYS does not offer identity verification through voice cloning.

5. Why information is used and the legal basis

Where the GDPR applies, we distinguish the following purposes:

  • Delivering the features, purchases and support you request: performance of a valid contract, or steps you request before a contract, for processing objectively necessary for that service. A parent's payment contract does not automatically provide a legal basis for all processing of a child's information.
  • Optional usage analytics, marketing where consent is required, and recording or other activities that require permission: consent, including parent or guardian authorisation where applicable. Refusing optional analytics does not prevent access to unrelated service features.
  • Keeping the service secure, investigating technical faults or abuse, handling complaints and protecting legal rights: legitimate interests in operating a secure and reliable service, assessed against your rights and with particular consideration for young users. This is not a substitute for consent where consent is required.
  • Accounting, tax obligations and valid legal requests: compliance with legal obligations.

A relevant collection screen must explain required information and what happens if you do not provide it. Without microphone access a voice call cannot work; you can choose not to start a call. Consent for optional analytics is separate from microphone access and any consent required for the conversation itself.

KORYS supports reflection and personal learning. Its AI responses are not decisions determining eligibility for education, employment, credit, healthcare or other similarly significant matters. We do not use private conversations for advertising, marketing testimonials or model training without a separate applicable legal basis and the required specific permission. Permission to have a conversation is not permission to publish it.

6. Cookies, browser storage and optional Mixpanel measurement

The apps use browser storage or similar technologies for choices such as language, theme and privacy preferences, and for features you request. Infrastructure may also process data necessary for delivery and security.

Where you permit optional usage measurement, we use Mixpanel to understand which screens, buttons and functions are used and improve the apps. We use a random device code, which is a pseudonymous personal identifier, not anonymous data. We do not include your name, email address, conversation text, audio or reflection answers in Mixpanel events. This measurement does not include session replay or recording what you type into conversations.

You can refuse optional measurement and change your choice in Settings, under privacy settings. Required parental consent also applies to this optional choice. Withdrawing consent stops future optional measurement on that device; it does not automatically erase previously collected events. Contact us to request deletion and, where available, provide the random identifier so we can locate the relevant data without asking for unnecessary identity details. Choices may need to be made separately on different devices or after clearing browser storage.

Our apps are configured to avoid IP-based location enrichment in their Mixpanel events. Hosting and network providers still need to handle network information to deliver requests. Refusing analytics does not prevent that necessary technical processing.

7. Providers and disclosure

Access is limited to what is necessary for the stated purpose. Providers include:

  • Hosting, delivery and technical infrastructure, including Cloudflare and the infrastructure supporting the KORYS websites.
  • ElevenLabs for AI voice and related conversation processing, together with the speech, language-model and other providers used in the selected configuration. Information needed for the interaction is transmitted to those services. Recording, retention and provider data-use arrangements depend on that configuration and the applicable business agreement. See ElevenLabs' privacy information.
  • Mixpanel for optional product analytics. See Mixpanel's privacy information.
  • WhatsApp/Meta for WhatsApp communications. WhatsApp also processes information for its own platform purposes under its own terms and privacy policy. Messaging encryption does not prevent the intended recipient and the systems handling the received message from processing its content. See WhatsApp's privacy information.
  • Stripe where it processes a KORYS payment, including its own legal and fraud-prevention functions. See Stripe's privacy information.

A provider's general privacy policy does not replace this policy or describe every setting in our business account. Providers acting on our instructions are subject to the applicable processing arrangements; some providers also act independently for their own platform or legal purposes.

Parents, schools, employers and other payers do not automatically gain access to private conversation content merely by paying. A legally valid request from a guardian, a safeguarding obligation or a lawful authority request is considered separately, taking account of the young person's rights and the applicable law. Do not treat KORYS as a service guaranteeing absolute secrecy.

We may disclose necessary information to professional advisers or authorities for a legal obligation, a substantiated safety issue or legal claims. A business transfer must respect applicable data-protection requirements; it is not permission to repurpose private conversations for unrelated advertising. Public use of a conversation, voice message, testimonial or podcast contribution requires a separate clear arrangement and the necessary permissions, including for minors. Ordinary coach calls are not consent to broadcast.

8. International processing

Providers and their subprocessors may process information outside your country, including in the United States and outside the EEA or UK. An EU analytics endpoint does not mean all processing stays in Europe.

Where required, transfers must use an applicable adequacy decision or contractual safeguards, such as the EU Standard Contractual Clauses and the applicable UK arrangements, with supplementary safeguards where necessary. You can contact us for information about the safeguards relevant to your data and a copy where available, with confidential information redacted. Accepting this policy is not blanket consent to an otherwise unlawful transfer.

9. Retention and deletion

We retain personal data only while it is needed for the stated purpose or a legal obligation. The criteria differ:

  • Account and progress information: while needed to provide the relationship or feature, followed only by information needed for an unresolved request, applicable obligation or legal claim.
  • Conversation audio, transcripts and history: according to the recording and retention settings of the actual conversation service and the need for providing the requested feature, addressing a specific support or safety issue, or a legal obligation. There is no promise that every call has zero retention. Contact us about a specific interaction and we will identify the applicable storage and deletion route.
  • Support correspondence and security logs: for resolving the matter, investigating faults or abuse and any necessary follow-up or applicable legal-claims period, rather than indefinitely for general training.
  • Optional analytics: only while needed to assess and improve feature use, subject to the relevant project retention controls, withdrawal and applicable deletion rights. Withdrawal stops future collection; existing identifiable events require the appropriate deletion process.
  • Invoices and tax records: the statutory period, generally seven years under Dutch rules, or ten years for records subject to applicable longer requirements such as the One Stop Shop VAT scheme. This does not justify keeping private conversations for the same period.
  • Permission records: as necessary to evidence the permission and meet the applicable legal or contractual obligation. ElevenAgents requires relevant consent evidence to be retained for at least five years, or longer if law requires; this is distinct from keeping the conversation itself.

After deletion, residual copies may remain temporarily in providers' backups until their normal deletion cycle completes, or where retention is legally required. We do not promise immediate erasure from every backup. Request-specific information about retention is available at [email protected].

10. Your choices and rights

Where applicable, you may request access and a copy, correction, deletion, restriction, portability, or object to processing based on legitimate interests. You may object to direct marketing and withdraw consent at any time. Withdrawal does not make earlier lawful processing unlawful. Some information may still need to be kept for a legal obligation or legal claim.

Send requests to [email protected], including which app and information your request concerns. We may ask for proportionate information to locate the data and verify your identity or parental authority. Do not email passwords, full identity documents or payment card details without an agreed secure and necessary process. Where the GDPR applies, we normally respond within one month; a lawful extension of up to two further months may apply, and we will explain it.

You can use Settings for the privacy choices available in the app, or contact us if you cannot find them. An account deletion request and cancellation of a subscription are separate matters; you may request both together. Information held by WhatsApp or another independently operated platform may also require a request to that provider.

You may complain to the Dutch Autoriteit Persoonsgegevens or the competent authority where you live or work. In the UK, this is the Information Commissioner's Office. Applicable local rights remain available; this policy does not claim that every country has identical rules.

11. Security and external services

We use appropriate measures proportionate to the processing and restrict access to the relevant operational purpose. No internet service can guarantee absolute security. Only share information you are comfortable including in an AI interaction, and use a trusted adult or appropriate professional for sensitive situations.

If you visit a KORYS social-media page, the platform's privacy practices also apply. For our Facebook page, Meta processes interactions and Page Insights under its applicable platform arrangements; this is separate from optional measurement inside the KORYS apps. A link to another service does not mean the service is operated by KORYS.

12. Changes and contact

We update this policy when the service or relevant processing changes and show the revision date above. Material changes requiring new permission must not be treated as accepted merely because this page was updated. Where required, we provide an appropriate notice before the change applies.

For privacy questions, rights requests or concerns about a young user's data, contact [email protected], or write to Intercept, Tapuitstraat 54C, 3083 WS Rotterdam, the Netherlands.