Privacy Policy

Version 4.2 · Last updated September 27, 2026 · KuhlApps, LLC

In short

Questions or privacy requests: support@kuhlapps.com. Never send a password, one-time code, full payment-card number, or more private Pinch content than is needed to explain a request.


1. Scope and controller

This policy applies to the Pinchly mobile application and Pinchly websites that link to it. KuhlApps, LLC determines why and how personal data is processed and is the controller or business for applicable privacy law. A formal-notice address and current sub-processor list are available through the contact address above.


2. Eligibility and children

You must be at least 16 years old to create an account. We do not knowingly permit accounts for anyone under 16. If we learn that an under-16 account exists, we suspend and delete it through the verified deletion process, subject only to records lawfully required to be kept.

An adult may privately record a memory about another person, including a family member. That does not create an account for the other person. Do not record sensitive information about a child or other third party that you do not have a lawful reason to keep.


3. Data we collect and why

3.1 Information you provide

DataWhy we process it
Email address and authentication recordsCreate and secure your account, deliver sign-in codes and account notices, and send the product email described in section 3.5
Self-attested birth informationConfirm the 16+ rule; an exact birth year is discarded after the age check, while a coarse age band may be retained for age-safety and feature eligibility
Display name and profile settingsPresent your account and apply your choices
People, connections, Circles, Pinches, preference options, notes, reminders, gifts, gift lists, exchanges, claims, and visibility choicesProvide the private-memory, retrieval, reminder, gifting, and user-directed sharing service
Optional birthday month and dayProvide birthday visibility/reminders only when you turn that feature on; the year is not stored for this feature
Support messages and attachmentsInvestigate and answer your request

“You Added” content is private to the account that created it unless the creator explicitly chooses an available sharing scope. Another person's Official content remains controlled by that person. Linking an offline person to an Official Profile is viewer-local and does not merge ownership.

3.2 Information generated when you use Pinchly

DataWhy we process it
Consent and preference records, plan tier, limits, and subscription statusApply the versioned choices and product access that govern your account
Content-free milestone timestamps and coarse account-age/Pinch-count bucketsMeasure whether the product works without storing the question, answer, person, Pinch, or place
Structural product eventsUnderstand whether screens and workflows work; event payloads exclude names, notes, preference/item text, contact data, precise location, and raw voice
Crash/error records and device/app metadataDiagnose reliability and security problems; private content is scrubbed before transfer
Standard security logs such as IP address, time, route, and statusOperate, protect, rate-limit, and investigate abuse of the service
Push token and delivery state, when notifications are enabledDeliver the notifications you have turned on (section 3.5)
App Store transaction and entitlement recordsConfirm paid access, restore purchases, and keep required financial records
Links you open from PinchlyCount which links are used and reconcile commissions

3.3 AI-assisted capture and retrieval

AI-assisted structuring and retrieval are core parts of the Service. When you ask Pinchly to structure or retrieve a memory, the minimum text needed for that request may be sent to a contracted business/API provider. Pinchly does not send audio, your password, or a one-time authentication code. We contract for business processing rather than consumer-model training. The current provider, purpose, and transfer mechanism are available on request.

Pinchly may also use AI to draft gift ideas, for example before a date you have set for someone; the minimum text needed for that may be sent to the same provider.

Pinchly stores the structured Pinch you choose to save and the data needed to retrieve it. To measure and improve the quality of answers, Pinchly may also keep the text of an AI request and the answer it produced for up to 30 days, after which it is deleted. These records are used only for that purpose: never for advertising, never for cross-user patterns, and never to train a model.

3.4 Voice, contacts, places, and location

3.5 Email and notifications

Every account receives sign-in codes and account notices by email. In the United States we may also send product email—for example, short guides to using Pinchly. Every product email carries a one-tap unsubscribe link that works without signing in, and our postal address. In the European Economic Area, the United Kingdom, Switzerland, and other places whose law requires consent, we send product email only if you ask for it.

Notifications are one switch in the app, off until you turn them on. A notification may name the person it is about—for example, that a reminder you set for someone is due—so that it is useful on its own. You can turn notifications off at any time in the app or in your device settings.


4. How we do not use your content

Pinchly uses preference content only to provide, secure, support, structure, and retrieve the service you asked for. We do not use private preference content to create:

If we ever propose to do any of these things, we will publish a new version of this policy and of our Terms and ask for a separate, prospective opt-in that is not bundled with ordinary service acceptance. Continued use of the app alone is not consent to that different purpose.


5. Data we do not collect or use


PurposeLegal basis
Account, private-memory, retrieval, sharing chosen by the user, subscription access, and requested supportContract — GDPR/UK GDPR Article 6(1)(b)
Security, fraud/abuse prevention, and required recordsLegitimate interests — Article 6(1)(f), balanced against user rights
Product analytics, optional location bias, optional birthday visibility, and future marketingConsent — Article 6(1)(a), withdrawable at any time
Tax, accounting, lawful process, and regulatory dutiesLegal obligation — Article 6(1)(c)

We do not intentionally infer or analyze special-category data from private content. Do not place health, religion, politics, sexuality, biometric data, credentials, or other sensitive information in free-text notes.


7. Product analytics and your choice

Product analytics tells us whether screens and workflows work. Event payloads carry no names, notes, preference or item text, contact data, precise location, or raw voice.


8. Service providers and disclosures

We use providers only for the contracted functions needed to operate Pinchly. The categories may include:

Provider categoryData involved
Hosting, database, authentication, bot protection, storage, and email deliveryAccount and service data needed to operate Pinchly, and the email address and first name needed to deliver email
Business/API AI processingMinimum capture or retrieval text needed for the request
Place searchSearch text and optional approximate foreground location bias
Product analyticsStructural events without private content
Crash/error monitoringScrubbed technical diagnostics
Subscription management and AppleStore identifiers, receipts, plan, and entitlement state
Build and push infrastructureBuild inputs, device push token, and notification delivery payloads

Providers act on our instructions under their applicable data-processing terms. We may disclose data when lawfully required or to address an imminent safety or security threat, and we notify affected users where law permits.

Links you open from Pinchly, such as buy links on gift ideas, take you to other companies' sites, which follow their own privacy terms.


9. International transfers

Pinchly is operated from the United States and may use providers in the United States or other countries. Where required, transfers from the EEA, UK, or Switzerland rely on an adequacy mechanism, Standard Contractual Clauses, UK addendum, or another lawful transfer method plus appropriate safeguards. Current transfer details are available on request.


10. Retention and deletion

We keep personal data for as long as it is needed to provide and secure the Service, and for as long as applicable law requires or permits. In practice that means:

DataRetention rule
Account, people, Pinches, notes, Circles, reminders, gifts, gift lists, exchanges, claims, and settingsUntil deleted by the user or the account is deleted, subject to the recoverable/archive behavior shown in the product
Exact birth yearUsed for the age check and then discarded
Coarse age bandUntil account deletion
Optional birthday month/dayUntil the setting is turned off or the account is deleted
Consent and preference recordsAs needed to prove which version and choice governed processing, and as law requires
Security logs, crash reports, product analytics, and link countsAs long as needed to operate, secure, and improve the Service, and as law requires
AI request contentRequest and answer text may be kept for up to 30 days to measure and improve answer quality, then deleted; provider retention follows that provider's contracted term
Place searchNo user-linked query history; a cache may be used to return results
Content-free cost and operations recordsAs long as needed for billing, capacity, abuse prevention, and required records. These records never contain prompts, answers, voice, preference text, names, place queries or identity, precise location, or contact data
Subscription and financial recordsSubscription duration plus the period required for accounting, tax, disputes, and law
Support casesAs long as needed for the request, security, legal deadlines, and defensible records

We act on a verified account-deletion request within the time applicable law requires. We delete or de-identify account data and send required processor requests. A narrow record may be retained when law requires it, to prevent fraud or abuse, or to prove completion; it is isolated and not used for product or marketing purposes.


11. Your choices and rights

Subject to applicable law, you may request access, correction, a copy of your data, deletion, restriction, objection, or withdrawal of consent, and you may complain to a privacy regulator. California and other US-state residents may also exercise applicable rights concerning sale, sharing, targeted advertising, and profiling. Pinchly does not sell personal information or share it for cross-context behavioral advertising.

You can stop product email with the unsubscribe link in any such email. Where the law allows, a copy of your data does not include what other members have saved, even when it mentions you. You can delete your account and its data yourself in Settings → Account. For any other request, use the in-app controls where available or email support@kuhlapps.com. We verify identity before disclosing, changing, copying, or deleting account data. We do not ask for a password or one-time code, and we do not discriminate against a person for exercising a privacy right.


12. Security

Pinchly uses encrypted network connections, managed encryption at rest, server-enforced database access rules, least-privilege service access, content-minimized analytics payloads, and incident and deletion procedures. No security program eliminates all risk. Report a suspected vulnerability to support@kuhlapps.com without including unnecessary personal data or exploit details in an ordinary message.

If a personal-data breach is likely to risk individuals' rights, we notify affected people and regulators as required by applicable law.


13. Cookies and identifiers

The mobile app does not use browser cookies. Our websites use only cookies strictly necessary to serve and protect the pages. The app uses limited identifiers for authentication, consent, analytics where allowed, diagnostics, subscriptions, push delivery, and place-search sessions. Pinchly does not use those identifiers for third-party advertising or cross-context behavioral tracking.


14. Changes and prior versions

We version this policy. Before a material change takes effect, we provide notice and request new consent where law or the changed purpose requires it. Approved prior versions and their effective periods are archived through versioned publication records.


15. Contact

KuhlApps, LLC Email: support@kuhlapps.com

Use this address for general privacy questions, rights requests, a current sub-processor list, transfer safeguards, or the formal-notice address.