KINDRED

Privacy Policy

This document is clearly labelled as a Privacy Policy. It names Melco Technology PLC as the operator of the Kindred application and describes how personal data is handled in the first release of Kindred (v0.0.1).

It describes only the features that are actually available in this release so that it matches the app and its Google Play Data Safety declaration.

It is written to satisfy the requirements of the Google Play Console (User Data policy and Data Safety), the Personal Data Protection Proclamation No. 1321/2024 of Ethiopia, and international data-protection best practice.

1. Introduction

Kindred is a digital professional-identity and contact-management application that helps people create, manage, share, and exchange professional contact information. Kindred is developed and operated by Melco Technology PLC ("Melco", "Kindred", "we", "us", or "our"), a company established in Addis Ababa, Ethiopia.

This Privacy Policy explains what personal data we collect, why we collect it, the legal basis on which we rely, how we use, store, protect, and share it, and the rights you have over it.

Kindred is built around a simple principle:

Your identity belongs to you. You decide what professional information you share, and with whom.

We comply with the Personal Data Protection Proclamation No. 1321/2024 of the Federal Democratic Republic of Ethiopia (the "Proclamation" or "PDPP 2024"), together with other applicable Ethiopian laws concerning electronic transactions, cybersecurity, computer crime, and consumer protection.

Where our users are located outside Ethiopia, we also apply the core principles of leading international frameworks such as the EU General Data Protection Regulation (GDPR) as a matter of best practice.

This Policy is written for the first release of Kindred (v0.0.1). As Kindred introduces new features that involve new or materially different processing of personal data, we will update this Policy before those features are launched.

2. Who We Are and Scope of This Policy

Data Controller. For the purposes of the Proclamation, Melco Technology PLC is the data controller that determines the purposes and means of processing personal data through Kindred.

This Policy applies to individuals who:

• create, verify, or log into a Kindred account;
• complete onboarding;
• create, manage, or share a Kindred Card;
• create and manage contacts;
• use the limited scanning feature where available;
• adjust app settings; or
• otherwise communicate with Kindred.

This Policy does not govern third-party services you may reach through information contained in a Kindred Card. Those services operate independently under their own privacy policies.

3. What Kindred Does in This Release

The first release of Kindred focuses on digital professional identity and contact management.

Available features

• Onboarding — a short guided setup, including selecting your preferred language.
• Account creation and authentication — registering, verifying your email, receiving OTPs, logging in, resetting your password, and accepting legal terms.
• Kindred Card — creating, editing, and managing a digital professional card.
• Card sharing — sharing your Kindred Card through QR code, shareable link, text, email, and add-to-wallet.
• Contacts — creating, viewing, editing, filtering, and managing professional contacts.
• Settings — managing theme, language/locale, and account preferences.

Limited features being finalised

• Card scanning — scanner available but not yet part of the complete end-to-end flow.
• Receiving/importing contacts — still being completed.
• Subscriptions and plans — plan options exist, but the paid subscription flow is not yet active.

Not included in this release

The following features are not operational in v0.0.1:

• professional notes;
• community and opportunities;
• events;
• enterprise identity;
• proximity/radar or location-based discovery;
• NFC tap-to-share.

These features will undergo privacy review before launch.

4. Personal Data We Collect

We collect only the personal data necessary to provide, secure, and improve Kindred.

4.1 Email address

An email address is required to create and verify a Kindred account.

We strongly recommend using your professional (work or business) email address rather than a personal email address when creating your account and when adding an email to your Kindred Card.

Your login email is not automatically displayed on your Kindred Card.

4.2 Sensitive personal data

Kindred v0.0.1 is not designed to collect sensitive personal data, government-issued identification documents, or perform KYC verification.

If future features require such processing, we will review the legal requirements and update this Policy.

5. App Permissions

You may deny permissions through your device settings, although related features may not function.

6. How We Use Personal Data

We process personal data for lawful purposes including:

• creating and maintaining your account;
• verifying your email and authenticating access;
• recording acceptance of legal terms;
• creating and sharing your Kindred Card;
• managing contacts;
• applying preferences;
• operating the limited scanner;
• maintaining subscription status;
• protecting accounts and preventing abuse;
• responding to support requests;
• complying with legal obligations.

Where processing is based on consent, you may withdraw your consent at any time.

7. Public Card vs Private Account Data

Creating a Kindred account does not make your account information public.

Your login email remains private unless you explicitly choose to include an email address on your Kindred Card.

Only information you choose to share becomes available to others.

8. Information You Choose to Share

When you share your Kindred Card, the information on that card may become available to the recipient.

Once information has been shared, recipients may save or retain it independently of Kindred.

We recommend including your professional email address when sharing your card.

9. Card Scanning

Card scanning is still being finalised in this release.

Where used, the camera is accessed only to read a business card or Kindred Card so that you can save contact information.

Information read from a card is not used for unrelated marketing or profiling.

10. Automatically Collected Information

Kindred automatically collects limited technical and security information to:

• operate the service;
• authenticate users;
• detect errors;
• prevent abuse;
• investigate security incidents;
• improve reliability.

11. Subscriptions and Plans

Paid subscription plans are being introduced.

Where subscriptions become available:

• payments will be handled by authorised third-party providers;
• Kindred will not collect or store card numbers, PINs, or bank passwords;
• Kindred may receive limited subscription and transaction information for account administration.

12. How We Share Personal Data

We do not sell your personal data.

We may share personal data with:

• trusted service providers;
• other users when you share your Kindred Card;
• competent authorities where required by law;
• successor organisations in the event of a business transfer;
• other parties with your explicit consent.

13. International Data Transfers

Some technology providers may process data outside Ethiopia.

Where this occurs, transfers will be made in accordance with Ethiopian law and appropriate safeguards.

14. Data Retention

We retain personal data only as long as necessary.

Examples include:

• account information while your account remains active;
• OTP data for authentication and security;
• transaction records where legally required;
• security logs for protecting the service;
• temporary backup copies before permanent deletion.

15. Account Deletion

You may delete your Kindred account:

• In the app: Settings → Account → Delete Account
• On the web: submit a deletion request through the published account deletion page or contact the privacy email.

Following deletion, we will delete or anonymise your personal data except where retention is required by law, security, fraud prevention, or legitimate legal purposes.

16. Data Security

We use reasonable technical and organisational safeguards including:

• secure authentication;
• encryption where appropriate;
• access controls;
• security logging;
• backups;
• vulnerability management;
• incident response procedures.

No online service can guarantee absolute security.

Never share your Kindred OTP or password with anyone.

17. Your Rights

Subject to applicable law, you may have the right to:

• be informed;
• access your personal data;
• correct inaccurate data;
• request deletion;
• restrict certain processing;
• object to certain processing;
• receive portable data where applicable;
• withdraw consent;
• request human review of certain automated decisions;
• lodge a complaint with the Ethiopian Communications Authority.

Exercising your rights

Contact us using the details below. We may verify your identity before acting on your request.

18. Children and Minors

Kindred is intended for professional use by adults.

We do not knowingly process a minor's personal data without the legally required consent.

19. Cookies and Similar Technologies

Where applicable, cookies or similar technologies may be used for:

• maintaining login sessions;
• authentication;
• security;
• remembering preferences;
• diagnostics;
• improving the service.

20. Governing Law

This Policy is governed by the laws of the Federal Democratic Republic of Ethiopia.

The supervisory authority is the Ethiopian Communications Authority (ECA).

21. Contact Us

Please provide enough information for us to understand your request.

Do not send identification documents or other sensitive information by ordinary email unless we specifically request them through a secure process.

22. Changes to This Privacy Policy

We may update this Policy when:

• the law changes;
• the service changes;
• new features introduce new processing;
• third-party services change;
• our privacy or security practices improve.

Where a material change significantly affects how we process personal data, we will provide appropriate notice and obtain consent where required by law.

The version and effective date at the top of this document identify the applicable version.

© 2026 Melco Technology PLC. Kindred. All rights reserved.