Last updated August 14, 2026
This Privacy Policy explains how Palo Santo Consulting Pvt Ltd ("kioku", "we", "us", or "our") collects, uses, discloses, and protects your information when you use the kioku app and related services (the "Service"). It forms part of, and should be read with, our Terms & Conditions.
kioku is built to be private by design. Your document images, passwords, PINs, and attachments are encrypted on your device before they are uploaded, and we store only unreadable ciphertext for them — we cannot read, recover, or decrypt that content.
Palo Santo Consulting Pvt Ltd is the data fiduciary/controller responsible for your personal data processed through kioku. Registered office: Shilpa Ananya Tech Park, 1st Floor, Electronic City Phase 1, Bengaluru – 560100, Karnataka, India. You can reach us at info@palosantoconsulting.com or +91 99000 07586.
Account information: your email address and authentication details needed to create and secure your account.
Phone number: if you choose to add one in Settings, used only to send you reminders over WhatsApp. This is optional — you can add, change, or remove it at any time.
End-to-end encrypted content: the images, passwords, PINs, and file/audio/video attachments you add. These are encrypted on your device with a key derived from your password before upload. We store only ciphertext and cannot access the plaintext.
Scanned or imported document images: when you scan a document or import one from your device or a cloud storage app (see "How We Share Information"), the captured image is processed to extract details such as the document type and expiry date, before it is encrypted for storage in your vault.
Document metadata: information you enter to organize and be reminded about documents — such as titles, categories, expiry dates, repeat/recurrence settings, profiles, and reminder settings. We process this to provide lists, search, reminders, and calendar entries. It is protected by access controls but is not zero-knowledge encrypted, so it is technically accessible to us to operate the Service.
Device and usage information: device push-notification tokens, app version, device type/OS, and basic diagnostic or crash information used to deliver notifications and keep the app working.
Subscription information: your plan and purchase/renewal status. Payments are processed by the Apple App Store or Google Play; we and our subscription provider receive your entitlement status, not your full card details.
Family and nominee information: if you invite family members or designate a nominee, we process the identifiers (such as email addresses) needed to send invitations and enable shared or emergency access.
Support and assistant interactions: messages you send to our support team, and the questions you type into the in-app assistant, which are processed to answer you (see "How We Share Information").
We use your information to: create and secure your account; store and sync your content; generate expiry reminders and calendar entries; provide family sharing and nominee/emergency access; process and manage subscriptions; provide customer support and answer assistant queries; detect, prevent, and investigate fraud, abuse, and security incidents; comply with legal obligations; and maintain and improve the Service.
Where the DPDP Act applies, we process your personal data based on the consent you give when you use the Service and provide your information, and for legitimate uses permitted by law. Where the GDPR or similar law applies, our legal bases are performance of our contract with you, your consent, our legitimate interests in operating and securing the Service, and compliance with legal obligations.
You may withdraw consent at any time by deleting your account or contacting us; withdrawing consent does not affect processing already carried out, and some processing may be necessary to provide the Service or to meet legal duties.
Your document images, passwords, PINs, and attachments are end-to-end encrypted with a key derived from your password. We do not have your password or the keys to decrypt this content and cannot read it, produce it in plaintext, or recover it if you lose your password. This is an intentional privacy protection. Please keep your password safe and maintain your own backups of important documents.
We do not sell your personal data. We share information only as needed to run the Service, with service providers acting on our behalf under appropriate safeguards, including: cloud hosting, database, and authentication providers that store your (encrypted) content and account data; push-notification services (such as Apple Push Notification service and Firebase Cloud Messaging), an email delivery provider (Resend), and a WhatsApp messaging provider (MSG91, if you add a phone number) to deliver reminders; a subscription-management provider to verify your plan; an AI provider that processes document images you scan or import, solely to extract details like the document type and expiry date and return them to your device; and the provider that powers the in-app assistant, which processes the questions you type there to generate a response.
Because the assistant sends your typed questions to that provider, please do not enter passwords, PINs, card numbers, or other sensitive secrets into the assistant. Your encrypted vault content is never sent to it, and neither the assistant nor the scanning provider uses your data to train their models.
Importing a file uses your device's own file picker, which can show files from cloud storage apps you have installed (such as Google Drive, Dropbox, or iCloud). We do not connect to, authenticate with, or gain access to your account with those providers — we receive only the single file you choose to import.
We may disclose information if required by law or valid legal process, to enforce our Terms, or to protect the rights, safety, and security of our users, the public, or Palo Santo Consulting Pvt Ltd. Because your vault content is zero-knowledge encrypted, we cannot provide its plaintext in response to any such request. We may also transfer information in connection with a merger, acquisition, or sale of assets, subject to this Policy.
We retain your information for as long as your account is active or as needed to provide the Service. When you delete your account, we delete or de-identify your personal data within a reasonable period, except where we must retain certain information to comply with legal, tax, accounting, or security obligations, or as retained in routine backups for a limited time before they are overwritten.
We use technical and organizational measures designed to protect your information, including end-to-end encryption for vault content, encryption in transit, access controls, and biometric/passcode protection for sensitive items in the app. No method of transmission or storage is completely secure, and you are responsible for safeguarding your password, device, and device locks.
We and our service providers may store and process information on servers located outside your country, including outside India. Where required, we take steps to ensure appropriate safeguards for such transfers. Encrypted vault content remains unreadable to any provider that hosts it. If the Government of India restricts transfers to a particular country under the DPDP Act, we will comply with those restrictions.
Subject to applicable law, you may have the right to: access the personal data we hold about you; correct or update inaccurate data; request erasure of your data; withdraw consent; nominate a person to exercise your rights in the event of death or incapacity (as provided under the DPDP Act); and lodge a grievance or complaint. GDPR users may also have rights to restriction, objection, and data portability.
To exercise these rights, contact us at info@palosantoconsulting.com. Note that we cannot provide, correct, or export the plaintext of your zero-knowledge encrypted content, because we cannot access it — you control that content directly within the app. You can add, change, or remove your phone number (WhatsApp reminders) at any time in Settings.
If you have a grievance about how we handle your personal data, you may contact our Grievance Officer, Sumita Sriram, Palo Santo Consulting Pvt Ltd, Shilpa Ananya Tech Park, 1st Floor, Electronic City Phase 1, Bengaluru – 560100, Karnataka, India, at info@palosantoconsulting.com or +91 99000 07586. We will acknowledge and address grievances within the timelines required by applicable law, including the DPDP Act and, where relevant, the Consumer Protection (E-Commerce) Rules, 2020. If you are not satisfied with our response, you may have the right to escalate to the Data Protection Board of India or another competent authority.
The Service is intended for users aged 18 and over and is not directed to children. We do not knowingly collect personal data from children without the consent of a parent or lawful guardian as required by the DPDP Act. If you believe a child has provided us personal data, contact us and we will take appropriate steps to delete it.
The Service relies on third parties (such as the app stores, hosting providers, and notification services) that have their own privacy practices. This Policy does not cover those third parties, and we encourage you to review their policies. We are not responsible for the privacy practices of services we do not control.
We may update this Privacy Policy from time to time. If we make material changes, we will take reasonable steps to notify you, such as in-app notice or by updating the "Last updated" date below. Your continued use of the Service after changes take effect constitutes acceptance of the updated Policy.
For questions about this Privacy Policy or your personal data, contact Palo Santo Consulting Pvt Ltd at info@palosantoconsulting.com or +91 99000 07586. Registered office: Shilpa Ananya Tech Park, 1st Floor, Electronic City Phase 1, Bengaluru – 560100, Karnataka, India.