Effective Date: [04.05.26] Last Updated: [July 23^th, 2026]

NEWEYES Pte. Ltd. (UEN: 202556859N) (“NEWEYES”, “we”, “us”, or “our”), with primary registration in 165B Telok Ayer Street, 068617, Singapore, company registration number 202556859N and its Affiliated Companies provide services that include access to and use of the NEWEYES mobile application (the “App”, KAION), our website at www.kaion.ai, and all associated subdomains (collectively, the “Services”). In providing the Services, we process personal data as data controller.  This Privacy Policy (“Privacy Policy”) describes how we collect, store, use, and share your personal data through our Services. References to “you” or “your” mean users of our Services who are 18 years of age or older.

This Privacy Policy is designed to comply with Singapore’s Personal Data Protection Act 2012 (PDPA). 

1. Introduction

We care about the protection and confidentiality of your personal data. When you use the KAION Services, you may provide your personal data. We process this information as described in this Privacy Policy, to allow you to have individualized interactions KAION, and allow us to perform and improve our core Services through learning from your interactions. Our App is an AI-powered neuro-tech platform designed to help you understand how your brain works and affects your behaviour and thoughts through personalised and conversational interactions.

 

KAION is not a medical device, healthcare service, or diagnostic tool, and it does not provide medical advice, diagnosis, treatment, or clinical recommendations. The information, insights, scores, and AI-generated responses provided by the app are intended solely for general informational and self-improvement purposes and should not be relied upon as a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of a qualified physician or other licensed healthcare professional regarding any medical condition or before making decisions about your health.

 

For the purposes of this policy, personal data has the meaning ascribed to it under PDPA. We may create anonymised and aggregated datasets from personal data for lawful business purposes, including the performance and improvement of the core functionalities of our Services. We adhere to all relevant regulations and guidelines to ensure that the data we handle is protected against unauthorized access, disclosure, alteration, and destruction. Our practices are designed to safeguard the confidentiality and integrity of your personal information, while enabling us to deliver the core Services.

 KAION Privacy policy does not apply to how third parties and their services define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

 

 

2. Personal Data We Collect

 

• Account Information: This includes your name, surname, data of birth, email address, password, phone number and unique identifiers that include country, time zone, type and ID of the device from which the account operates.

• Payments and transactions:When you make purchases through the Services, our third-party payment processors collect your payment information. We maintain a record of your purchases, the features you select, and the rewards you earn and use.
• Age verification: KAION is solely available to users older than 18 years of age. To ensure this, users go through a process of age verification. This implies face recognition. Data provided during the age verification process is processed by our partner  We do not store, record or retain internally any data processed through that service. For more information, please visit ComplyCube website: Security & Compliance Center | ComplyCube.
• Interests and Preferences:We also learn about your interests and your preferences over time through your use of the Services to personalize your conversations and the features of the Services.

 

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our core functionality of our Services or respond to requests you may have.

 

2.2 Information Collected Automatically

• Device and Network Information: This includes your device type, mobile device’s operating system, manufacturer and model, browser, IP address, device and cookie identifiers, language settings, mobile device carrier, and general location information such as city, state, or geographic area.
• Usage Data:  This includes information about how you use the Services, such as your interactions with the Services, the links and buttons you click, and page visits.
• Camera and Microphone Access:We request camera and microphone permissions to allow voice-based interaction, and to analyse voice patterns and facial expressions during conversations. Summaries & transcripts of voice interactions with the AI agent (both kept in audio and written form). Our models evaluate emotional signals across multiple captures; Only when an emotion is positively validated a single still image retained. That image is stored anonymously — linked to the type of emotion recognised
• Facial images captured during a session are used for emotion recognition processing.
• User behaviour:usage patterns, emotional state trends, cognitive game proficiency, behavioural trends.
• Health and Fitness Information: data relating to the health status of an individual, including data related to one’s physical condition, including activity, sleep, exercise, and other wellness metrics. These metrics are intended for general wellness and personal development purposes only and are not intended to diagnose, treat, cure, or prevent any disease or medical condition.
• Any other information: details such as the content of your communications with KAION, including interactions with customer support and contacts through social media channels

 

2.3 Sensitive data

Certain features of the Services require the collection and processing of voice recordings, facial images, and other personal information that may be used to deliver, personalize, maintain, improve, and secure the Services.

 

We encourage you not to share personal information that is not necessary for your use of the Services, including information relating to your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, or other sensitive matters. While your use of the Services may naturally involve personal topics, you remain responsible for the information you choose to share.

 

If you choose to include sensitive information in your messages despite this instruction, that information will be processed as part of your conversation data, including by third-party AI language model providers, solely to generate conversational responses and deliver core app functionality. We will not use your sensitive information — or any content of your conversations — for marketing or advertising purposes.

 

We apply the same data minimization, de-identification, and contractual protections to sensitive data as to all conversation data shared with third-party providers. If you have shared sensitive information and wish to have it deleted, you can request deletion as described by contacting us at privacy@kaion.ai.

 

2.3 Analytics and Tracking Data

We use the following third-party analytics services to understand how users interact with our App:

• Google Analytics 4:Collects IP address, device type, and usage patterns.
• Mixpanel:Collects device information and behavioural usage analytics.
• Google & Meta Ads:Used for user engagement and marketing attribution analysis.
• Age verification partner: Identity Verification, KYC & AML Compliance | ComplyCubethis provider helps us make sure users are above the age of 18.
• Consent Management Platform: https://usercentrics.com/is our dedicated CMP specifically designed to handle compliantly the requirements of data privacy laws. 
• Cognifit: comis our game provider. It receives a user id from KAION and collects the performance and usage behaviour of the user in the games. No personal and identifiable data crosses between Cognifit’s environment and KAION’s environment.

We use Cookies and Similar Technologies to understand and improve user’s experience when using our Services. Cookies help us ensure that our platform functions properly, remember your preferences, enhance security, analyse website performance, and better understand how visitors interact with our services. You can manage your cookie preferences through our Consent Management Platform (CMP) triggered at first time installation or in any major update afterwards.

You can use our website without submitting personal data. 

Every time our website is accessed, user data is transferred to us or our web hosts/IT service providers by your internet browser and stored in server log files. This stored data can include: name of the site page called up, date and time of the request, IP address, amount of data transferred, and the provider making the request. The processing is carried out on the basis of First Schedule, Part 3 of the PDPA due to our legitimate interests in ensuring the smooth operation of our website as well as improving our services.

 

3. How We Use Your Personal Data

 

 

Purpose	Why and how we process your personal data	Legal basis	Categories of information
Operating and administering the Services	Providing and maintaining the content and functionality of the Services. Carrying out obligations arising from our contract with you. Creating your account and profile. Facilitating payments and transactions, including for the purchase of Services, and managing your rewards. Responding to your inquiries, comments, feedback or questions, and troubleshooting. Managing our relationship with you, which includes sending administrative information to you relating to our Services. Verifying the age of registered users.	Necessary to perform our contractual obligations with you, such as providing you with the Services.	Account information. Age Information. Interests and preferences. Payments and transactions. Device and network data. Analytics and tracking data. User behaviour. Any other information.
Providing the core personalized functionality of the Apps	Providing you a personalized AI companion and allowing you to personalize your profile, interests, and AI companion interactions. Enabling you to have personalized interactions with the Services, including through the use of third-party AI language model providers that generate conversational responses. Allowing KAION to learn from your interactions to improve the delivery of the Services.	Necessary to perform our contractual obligations with you, such as providing you with the personalized features of the core Services, including the use of third-party AI language model providers, neuroplasticity score and cognitive training.	Account information. Interests and Preferences. Device and network data. Usage data. Camera & Microphone access. Facial Images. User behaviour. Health & Fitness information. Analytics and Tracking information.
Protecting the Services and performing corporate operations	Preventing fraud, criminal activity, and misuse of our Services, and ensuring the security of our IT systems, architecture and networks (including testing, system maintenance, support, and hosting of data), and performing activities that are functional to transfers of assets, branch of business, acquisitions, mergers, divisions or other corporate operations.	Necessary to pursue our legitimate interests, adequately balanced with your rights and interests, in ensuring the integrity, confidentiality, and availability of our digital infrastructure, detecting and responding to threats, and maintaining a safe and trustworthy environment for all users and performing corporate operations.	Account information. Age verification. Interests and Preferences. Payments and transactions. Device and network data. Usage data. Any other information. Analytics and Tracking data.
Analyzing trends in the use of the Services and anonymizing user interaction data to improve Service performance and safety	Aggregating, anonymizing, and deidentifying personal information. Analyzing the use and effectiveness of our Services. Improving and adding features to our Services. Developing our business and marketing strategies. This includes collecting and immediately anonymizing user feedback, and small portions of Messages and Content data to train our proprietary safety algorithms, enhance chatbot performance, prevent inappropriate outputs, and ensure compliance with safety standards.	Necessary to pursue our legitimate interests, adequately balanced with your rights and interests, in optimizing service performance, developing protective measures against harmful content, enhancing user experience, and informing strategic decisions to grow and tailor our offerings.	Account information. Age verification. Interests and preferences. Payments and transactions. Device and network data. User behaviour, Camera & Microphone access. Facial Images. Health & Fitness information. Usage data. Analytics and Tracking data. Any other information.
Marketing and advertising the Services	Sending you commercial information by email that we believe will be of interest to you, such as information about our Services, features, and surveys.	Your consent	Account information. Interests and Preferences. Device and network data. Usage data.
Enforcing our agreements, and defending against legal claims and disputes	Enforcing and complying with our terms and policies. Protect our and others’ rights, privacy, safety, or property. Ensuring the integrity of our Services. Defending against legal claims and disputes. Recovering payments due to us.	Necessary to pursue our legitimate interests, adequately balanced with your rights and interests, in safeguarding our legal position and rights, protecting our assets and users, and ensuring compliance with applicable laws and regulations.	Account information. Interests and preferences. Payments and transactions. Device and network data. Usage data.
Complying with legal obligations	Keeping records of transactions, and complying with the applicable laws, regulations, legal processes and authorities’ requests.	Necessary to comply with a Legal obligation	Account information. Age verification. Interests and preferences. Payments and transactions, and rewards. Device and network data. Usage data.

 

 

4. How We Share Your Personal Data

 

4.1 Third-Party Service Providers

We share your personal data with companies and individuals that provide services to us or on our behalf or help us operate the Services or our business (such as hosting, information technology, third-party artificial intelligence language models, customer support, email delivery, and website analytics services).

We share your data with the following categories of service providers who process data on our behalf: 

• AI Services:Conversational and analytical features are powered by a third-party AI service operated on a dedicated, isolated infrastructure under a corporate agreement. We transmit conversation content (prompts and system instructions) solely to generate responses. No directly identifying personal data is included in these transmissions. The provider acts as our data processor under a Data Processing Agreement and is solely responsible to comply in accordance with Singapore’s Personal Data Protection Act (PDPA).
• Payment Processing:In-app purchase processes all payment transactions. Your payment information is handled entirely by third-party payment providers and is not stored on our servers.
• Analytics Providers:Google Analytics 4, Mixpanel, and Google and Meta Ads receive usage and behavioural data to help us understand app performance and user engagement.
• Age Verification:Identity Verification, KYC & AML Compliance | ComplyCube provides biometric age verification services to ensure compliance with our age restrictions.
• CMP: https://usercentrics.com/provides a platform managing user consent across our services.

 

4.2 Anonymised and Aggregated data.

Where data has been irreversibly anonymised such that it no longer constitutes Personal Data under the Personal Data Protection Act 2012 (“PDPA”) or other applicable law, KAION may use, analyse, combine, create derivative datasets from, disclose, transfer, license, commercialise, or otherwise make available such anonymised and aggregated information for lawful business purposes.

 

These purposes may include, without limitation:

• statistical analysis and business intelligence;
• research and scientific study;
• product and service development, testing, validation and improvement;
• benchmarking, trend analysis and market intelligence;
• the development, evaluation, validation, testing and training of artificial intelligence and machine learning models;
• the creation of analytics, insights, predictive models, reports, indices and other data products;
• providing access to anonymised analytics, datasets, insights or AI-powered services through application programming interfaces (APIs), software development kits (SDKs), enterprise platforms, data licensing arrangements or other technology integration models; and
• licensing or providing anonymised datasets, analytics, models or insights to research institutions, commercial partners, technology providers, healthcare organisations, academic institutions and other third parties for lawful purposes.

 

KAION will implement all reasonable technical and organisational measures to assess and mitigate the risk of re-identification before any disclosure, licensing or commercialisation of anonymised or aggregated information, considering the nature of the data, the intended recipient, the intended use and available technologies.

 

4.3 Legal Requirements

We may disclose your personal data if required by law, regulation, legal process, or governmental request.

 

5. Data Security

Kaion is committed to treating all collected information with strict security measures, guaranteeing its confidentiality at all times, in accordance with the Protection Obligation of the PDPA. We implement appropriate technical and organisational measures to protect your personal data:

• Encryption:Data is encrypted both at rest and in transit
• Access Controls:Access to personal data is governed by the need-to-know principle
• Audit Logs:All access to personal data in our production database is logged
• Regular Security Reviews:We regularly assess and update our security practices

Despite our efforts, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data. We can only continuously update our technology to avoid damage, loss, alteration, destruction, or unauthorised use, access, or processing of your personal data.

 

6. Data Retention

6.1 Active Users

We retain your personal data, including conversation summaries, for 12 months following your last login to the App. This retention period is necessary to provide continuity of service.

6.2 Account Deletion

If you delete your account or request data deletion:

• All personal data will be deleted within 30 days of your request
• We retain only transactional data that cannot be used to identify you, as required for legal and accounting purposes
• Anonymised data used for AI training cannot be retrieved or deleted as it no longer contains personal identifiers

 

7. Your Rights Under Singapore’s PDPA

You have the following rights regarding your personal data:

7.1 Right to Access 

You can request a copy of the personal data we hold about you.

7.2 Right to Correction

You can request that we correct any inaccurate or incomplete personal data.

7.3 Right to Withdrawal of Consent

Where we process your data based on consent, you can withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before withdrawal.

7.4 Right to Data Portability

You can request your personal data in a structured, commonly used format.

7.5 Right to Deletion

You can request deletion of your personal data, subject to legal retention requirements.

7.6 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email:  policy@kaion.ai

We will respond to your request within 30 days as required under the PDPA.

 

8. Age Restrictions

Our App is intended for users aged 18 and older. We implement the following measures to prevent access by minors:

• Date of birth verification at registration
• Biometric age verification through our third-party provider 

If we learn that we have collected personal data from a person under 18, we will delete that information promptly.

 

9. International Data Transfers

We primarily serve users in Singapore. Your personal data is stored and processed in a regional service tenant via Microsoft Azure and/or Southeast Asia. When we transfer data to third-party service providers, we ensure appropriate safeguards are in place through Data Processing Agreements.

We only visualize your personal data from Singapore to our data processing facilities in Bulgaria (EEA member state) for core service processing, improvement and optimisations. All data transferred is anonymised and access control restricted. This transfer is done in compliance with the PDPA’s Transfer Limitation Obligation by:

• GDPR Adherence: Our Bulgarian data processor is subject to the stringent GDPR, which provides a comparable level of protection.
• Standard Contractual Clauses (SCCs): We execute a Data Processing Agreement (DPA) incorporating EU Standard Contractual Clauses (SCCs) to contractually guarantee data security.

 

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes:

• We will update the “Last Updated” date at the top of this policy
• We will notify registered users via email
• We encourage you to review this Privacy Policy periodically.

 

11. Cookies and Tracking Technologies

11.1 What We Use

Our App and website use cookies and similar technologies for:

• Essential functionality
• Analytics and performance monitoring
• User preferences

 

11.2 Your Choices

You can manage your cookie preferences through our Consent Management Platform (CMP) available in:

• App settings
• Our website cookie banner

Disabling certain cookies may limit your ability to use some features of the App.

 

12. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact:

NEWEYES PTE. LTD. 
165B Telok Ayer Street, 068617 
Singapore

Data Protection Officer: 
Katrien Meire

Email: policy@kaion.ai

 

13. Complaints

If you believe we have not handled your personal data in accordance with the PDPA, you have the right to lodge a complaint with:

Personal Data Protection Commission Singapore 
10 Pasir Panjang Road 
#03-01 Mapletree Business City 
Singapore 117438

Website: www.pdpc.gov.sg