KALEIDOSCOPE LOCAL PRODUCT PRIVACY NOTICE REVIEW DRAFT - NOT FOR PRODUCTION USE Last updated: August 22, 2026 This draft describes the intended privacy boundary for the local Kaleidoscope product. Production account features and publication must remain disabled until the data controller's exact legal identity and contact, processors, jurisdiction-specific disclosures, retention schedule, and rights-request process are completed and reviewed. 1. SCOPE This notice applies to the Kaleidoscope local manager, proprietary local engine, optional product-account features, documentation site, and product support. It does not apply to a separately contracted hosted-memory or synchronization service, or to third-party services governed by their own notices. 2. LOCAL MEMORY DATA The local engine is designed to keep memory content, prompts, queries, selected results, graph data, memory identifiers, workspace/principal/journal coordinates, local paths, and vault files on devices controlled by the user. Installing or using the local engine does not authorize Kleos Research to upload, sync, inspect, sell, train on, or delete that local memory data. Local vault deletion is a separate user-initiated operation. Users are responsible for access controls, lawful content, backups, exports, and deletion on their devices. 3. DATA PROCESSED BY OPTIONAL ACCOUNT FEATURES If a user chooses to activate a production account feature, the public manager may process only the bounded account and device data needed for that feature, such as: - email address and account identifiers; - identity-provider name and opaque external identity identifiers; - device identifier, user-supplied device label, platform, and last-seen time; - authorization state, session family identifiers, and security audit events; - authentication and revocation timestamps; and - ordinary network metadata such as IP address, user agent, and request status recorded by the identity provider, hosting provider, or account service. Refresh credentials are intended to remain in the operating-system credential store. Agent configuration, profiles, and local vaults must not contain those credentials. Account requests must exclude memory content, queries, results, vault coordinates, profile identity fields, provider secrets, and absolute local paths. Production login is not available until the exact fields, provider, endpoints, credential behavior, and data flows are verified and published. 4. DOCUMENTATION SITE, PURCHASES, AND SUPPORT A static documentation host may process ordinary delivery and security logs. The production site must publish its hosting provider, cookie/local-storage inventory, and retention before analytics, personalization, or non-essential cookies are enabled. If purchases are offered, payment providers may process billing and payment information under their own notices. Kaleidoscope should receive only the billing records needed to provide the product, prevent fraud, and meet legal obligations. Support processes may receive contact details, correspondence, account/device identifiers, and diagnostics a user chooses to submit. Users must review and redact diagnostics and must not submit credentials, private keys, raw memory content, prompts, or confidential local paths unless specifically requested through an approved secure channel. 5. PURPOSES AND LEGAL BASES Subject to the law that applies to the production data controller, account and support data may be processed to: - provide requested account, device, entitlement, purchase, and support functions; - authenticate users and protect accounts, releases, and services; - diagnose failures and maintain compatibility; - comply with law and enforce product terms; and - improve the product using aggregated or de-identified information. Before production, the controller must map each purpose and data category to an applicable legal basis, including contract, legitimate interests, consent, or legal obligation as required. Consent must be freely given and withdrawable where it is the selected basis. 6. TELEMETRY AND TRAINING The local engine contract declares no required network connection, external model call, or production telemetry. Non-account manager operations are designed to run offline. Kaleidoscope does not sell local memory data or use it for targeted advertising. No production feature may use local memory data, prompts, queries, or results to train a model unless a separate, explicit, informed opt-in and applicable contract identify the data, purpose, recipient, retention, and withdrawal consequences. Any future telemetry must be documented field by field, default state, destination, purpose, legal basis, retention, and opt-out behavior before it is enabled. 7. SHARING Production data may be disclosed only as needed to: - contracted processors that provide identity, hosting, payment, email, customer-support, or security services; - professional advisers under confidentiality obligations; - authorities or other parties when required by law or reasonably necessary to protect rights, users, or service security; or - a successor in a merger, financing, reorganization, or sale, subject to appropriate notice and safeguards. A production notice must name or categorize material processors and provide required cross-border transfer disclosures. Processors may not use product data for their own advertising or model training unless the user separately agrees. 8. RETENTION AND DELETION Data must be kept only for the shortest period needed for the stated purpose, security, dispute resolution, and legal obligations. Before production, the following proposed schedule must be validated against system behavior and law: - active account records: while the account is active; - deleted-account records: delete or de-identify within 30 days, except records that must be retained for security, fraud, tax, or legal claims; - authentication and security audit events: 90 days unless an active investigation or law requires longer; - support cases: 24 months after closure unless a user or contract requires a shorter period; - service backups containing account data: expire within 35 days; and - local memory data: controlled and deleted locally by the user, not retained by the account service. A production release must confirm these periods, backup behavior, legal holds, and account-deletion verification. A local logout or account deletion must not silently delete a local vault. 9. SECURITY Kaleidoscope uses measures intended to separate local memory, account traffic, credentials, package integrity, and support diagnostics. No method is perfectly secure. Users should protect devices and credentials, install verified updates, use least privilege, and report suspected vulnerabilities through the published security channel. 10. INTERNATIONAL TRANSFERS If account or support data crosses borders, the production controller must use a valid transfer mechanism and publish the relevant countries and safeguards. No claim about an adequacy decision, standard contractual clauses, or data residency is made in this draft. 11. PRIVACY RIGHTS Depending on location, a user may have rights to access, correct, delete, restrict, object to, or port personal data; withdraw consent; and complain to a regulator. Identity verification may be required before fulfilling a request. A production release must provide an exact request channel, controller identity, response timeline, appeal method where required, and regulator details. 12. CHILDREN Kaleidoscope is not directed to children under 16, and account features should not knowingly collect their personal data. The production controller must adjust this threshold and consent process where local law requires. 13. CHANGES Material changes should be announced before they take effect when practicable. The notice must show its effective date and preserve prior versions. A change does not retroactively authorize a new use of local memory data. 14. CONTACT Before production, insert the data controller's exact legal name, postal address, privacy email or request portal, data-protection representative where required, and data protection officer contact where applicable. END OF REVIEW DRAFT