Privacy that protects
without hiding.

Welcome to KeepOn, mobile applications developed by InsularCode Ltd. that help guardians monitor children and elderly dependents by providing real-time updates on their safety, location, and device status. KeepOn is offered as two companion apps: KeepOn Guardian (installed on the guardian's device) and KeepOn Kids (installed on the dependent's device). This Privacy Policy outlines how we collect, use, disclose, and protect your information in compliance with the legal requirements of the United States (including the Children's Online Privacy Protection Act (COPPA)) and Europe (in accordance with the General Data Protection Regulation (GDPR)).

By using KeepOn, you agree to the collection and use of your data as described in this Privacy Policy. If you do not agree, please do not use the app.

We collect the following types of data depending on whether the app is being used by a guardian (KeepOn Guardian) or a dependent (KeepOn Kids):

In addition, the dependent's name and location labels (e.g., "Home," "School") are set by the guardian during the pairing process. Both apps also collect limited analytics and crash-diagnostic data - see Section 6, "Analytics and Crash Reporting," below.

We process your personal data based on your consent, as provided during the account creation process. By agreeing to this Privacy Policy and the associated terms, you consent to the collection, processing, and use of your personal data as described herein. You have the right to withdraw your consent at any time, and such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

We collect and process data for the following purposes:

• Providing core functionality of the KeepOn apps.
• Monitoring dependent device battery levels and location.
• Blocking apps based on predefined rules (e.g., low battery, excessive screen time).
• Web Filtering: Notifying the guardian when the dependent navigates to websites containing content such as pornography, drugs, violence, and other harmful topics.
• Safety Alerts (on-device capture, cloud-based analysis): Message content is captured on the dependent's device and sent to our servers, where it is analysed - including by a third-party AI provider (Anthropic), acting as our data processor - to classify safety risks (e.g., sex talk, love talk, bullying, suicide, or similar concerning topics) and alert the guardian.
• Push Notifications: Sending relevant notifications (e.g., when a dependent enters or leaves a location or their battery is low) via Firebase, using location labels rather than precise coordinates.
• Subscription Management: Processing Google Play purchase history to manage and validate guardian subscriptions.
• Analytics and Crash Reporting: Using Firebase Analytics and Firebase Crashlytics to understand app usage and to detect, diagnose, and fix crashes and stability issues. See Section 6 for details.
• Complying with legal obligations.
• Enhancing app performance and user experience.

We do not sell your personal data, and we do not share it with third parties for their own marketing, analytics, or advertising purposes. We do use the following third-party service providers, who process data strictly on our behalf and under our instructions, acting as data processors:

• Firebase (Google): Push notifications, Analytics, and Crashlytics. See Section 6 for details on the analytics and crash data collected.
• Anthropic: Cloud-based analysis of message content to classify safety risks, as described in Section 4, "Safety Alerts."

KeepOn does not collect or use an advertising identifier (e.g., Google Advertising ID). Advertising-ID collection is disabled, and the corresponding permission has been removed from both the KeepOn Guardian and KeepOn Kids apps. We do not use your data for advertising.

Both KeepOn Guardian and KeepOn Kids use the following Google Firebase services to help us understand how the apps are used and to keep them stable:

• Firebase Analytics (Google): Used to understand app usage and improve the apps. It collects a Firebase app-instance identifier, in-app events such as screen views and sessions, and an approximate, city-level location derived from your device's IP address.
• Firebase Crashlytics (Google): Used to detect and diagnose crashes and stability issues. When a crash occurs, it collects a crash report with diagnostic information, device state (e.g., device model and operating system version), a Crashlytics installation identifier, and may include the account's user identifier and a record of recent in-app navigation, to help us locate and fix the fault.

Google processes this data as a data processor on our behalf and under our instructions. This data is used solely to operate, maintain, and improve the apps - it is not used for advertising, and it is not shared with third parties for their own purposes.

KeepOn does not collect or use an advertising ID. Advertising-ID collection is disabled, and the corresponding permission has been removed from both apps.

We only retain the latest 25 records per dependent device. Older records are automatically deleted when new ones are added. If the guardian chooses to delete the dependent device from the app, all data associated with the dependent is permanently deleted. After the retention period, all personal data is securely deleted or anonymized.

As a user, you have the right to:

• Access: your personal data.
• Update: or correct your personal data (such as updating the dependent's name).
• Delete: your data (e.g., by removing the dependent's device from the app).
• Restrict: or object to the processing of your data.
• Data portability: Request a copy of your data in a machine-readable format.
• Withdraw consent: You have the right to withdraw your consent for data processing at any time. You can do this through the My Profile Page by clicking on Privacy Center and unchecking the consent checkboxes. By withdrawing consent, KeepOn will no longer process the personal data of the dependent's device, and the accounts of both the dependent and guardian will be permanently deleted.

To exercise these rights, please visit the "My Profile" page in the Support section of the app or contact us at support@keepon-app.com.

We take data protection seriously and have implemented the following security measures:

• Data is transmitted securely between the dependent's device, the server, and the guardian's device using a secured Web API with HTTPS.
• JWT authentication is used to ensure that only authorized users can access data.
• Guardian devices are protected with biometric authentication (e.g., fingerprint) or a PIN for accessing the app.

We comply with the Children's Online Privacy Protection Act (COPPA) in the U.S. and GDPR in Europe. Guardians must confirm they are 18 years of age or older during account creation and consent to the collection of their dependent's data by checking appropriate boxes during the account creation process. The app may collect information from children under the age of 13 (in the U.S.) or 16 (in Europe) when the guardian installs the app on their dependent's device. Guardians must pair their device with the dependent's device and manage their data accordingly.

We may update this Privacy Policy from time to time. When we do, we will notify you via the app or email of any significant changes. Please review the policy periodically to stay informed about how we are protecting your data.

If you have any questions or concerns regarding this Privacy Policy or wish to exercise your rights, please contact us at:

• Email: support@keepon-app.com
• Company: InsularCode Ltd.

If your data is transferred outside the European Union or the European Economic Area, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable laws.

In the event of a data breach that may affect your personal data, we will notify you without undue delay and in accordance with applicable laws.

If we use cookies or similar technologies, we will inform you about the types of cookies used, their purpose, and how you can manage your cookie preferences.

As a user of the KeepOn app, you are responsible for maintaining the confidentiality of your account information, including your email address, password, and any biometric data used for authentication. You agree to:

• Secure Your Account: Ensure that your password is strong and not easily guessable. Do not share your account credentials with anyone.
• Notify Us of Unauthorized Use: Immediately inform us if you suspect any unauthorized access or use of your account. We will take steps to investigate and address any reported issues.
• Log Out After Use: Always log out of your account when using shared or public devices to prevent unauthorized access.
• Keep Your Device Secure: Use device security measures (e.g., screen locks, biometric authentication) to prevent unauthorized access to your personal information and account.

We are not responsible for any unauthorized access to your account resulting from your failure to maintain the confidentiality of your account information.

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority.

This Privacy Policy is effective as of 9 August 2026. We will review and update this policy regularly to ensure compliance with legal requirements.