1. Data Controller
The Data Controller is RevTech S.r.l., with registered office in Italy. For any communication regarding data protection, you can contact the Data Processor at: revtechcompany@icloud.com.
2. Data Collected and Cloud Synchronization (Supabase)
By virtue of the Local-First nature of the application, data collection is reduced to the bare minimum (Data Minimization):
- Chat Content: Conversation texts, history, and chat logs remain stored exclusively in the local memory of the user's device. RevTech has no access to, does not transmit, and does not store user chats on its servers.
- Cloud Gallery and Characters: Data relating to characters created or publicly shared by users consists exclusively of encrypted text strings and optimized JSON configurations (with an average weight of about 49 KB per file). This data is stored on secure SQL tables hosted on the Supabase cloud infrastructure.
- Authentication and License Data: Only the email address and access credentials necessary for account license validation and multi-device character synchronization are collected.
3. Monetization and Third-Party Tracking Tools
- Advertising Networks (Ads): Within the Basic Plan, the application integrates third-party advertising network SDKs (e.g., Google AdMob, Unity Ads) to deliver banners and ads. These networks may collect anonymous device identifiers for the sole purpose of optimizing ad delivery.
- Financial Transactions: All payment data (credit card numbers, billing information) is processed directly and exclusively by Stripe via encrypted protocols. RevTech never comes into possession of nor stores the user's financial data.
4. Protection of Minors and Age Verification (GDPR, COPPA, CCPA)
The use of Klie is strictly prohibited for individuals under the age of 13 (or under 16 within the European Economic Area, unless otherwise provided by national laws).
Verification Mechanism: At the time of first launch (Onboarding), the application requires passing an age verification block (Age Gate) based exclusively on the self-certification principle.
Exclusion of Biometric Tracking: In compliance with strict privacy policies, RevTech does not collect, request, or process biometric data, face scans, or official identity documents for age verification, ensuring the anonymity and security of its users' personal data.
5. Rights of Data Subjects (GDPR / CCPA Rights)
Users can exercise the rights guaranteed by the GDPR (Arts. 15-22) and the CCPA at any time, including:
- The right to access their cloud synchronization data.
- The right to request the immediate and permanent deletion of their account and all characters published in the Cloud Gallery.
- The right to object to advertising tracking through the native settings of their operating system (iOS, Android, Windows, macOS).
To exercise these rights, simply send a written request to: revtechcompany@icloud.com.
III. Jurisdiction
These Terms of Service are governed by and construed in accordance with the laws in force in Italy. Any dispute arising from the interpretation or execution of this contract shall be submitted to the exclusive jurisdiction of the Court indicated during the company incorporation phase.