Last Updated: May 2026
When using the Konstruct mobile application or website (the "Service(s)"), we ("Konstruct", "We", "Our ") may collect and process your personal data.
The purpose of this Privacy Policy (the "Privacy Policy") is to inform the users of the Services ("User(s)", "You", "Your") of the means used to collect and process Your personal data (“Personal Data”), in compliance with the applicable legislation, including Regulation (EU) No. 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR") and Directive 2002/58/EC of 12 July 2002 as amended by Directive 2009/136/EC ("ePrivacy Directive"), and any national transposition text or any subsequent text that may follow them, as well as any other data protection law applicable to Our Services (together, "Applicable Regulations").
It is very important to us to respect your privacy and protect your personal data.
By accessing and/or using the Services, You are informed that Your personal data will be collected and processed under the terms and conditions set forth below. If You do not agree to this Policy, You shall cease all use of the Services.
The Privacy Policy is an integral part of the Terms of Use ("TOU") and must be read together with such TOU.
We may amend the Privacy Policy, in order to comply with any legislative, regulatory, jurisprudential, editorial or technical changes under the conditions described in the TOU. Therefore, before browsing, You should refer to the latest version of the Privacy Policy.
The controller of Users’ Personal Data collected on the Services is Konstruct Labs SA, with registered offices at Cours des Bastions 13, c/o ExpertFid & Audit SA, 1205 Genève, Switzerland. Email: support@konstructapp.com.
During the collection of Personal Data, the User will be informed if certain Personal Data must be provided or if they are optional. If Personal Data that is required is not provided, access to certain features of the Services, such as the account creation, and the use of such Services by the User will be impossible.
In particular, We collect the following categories of Personal Data relating to the User:
· Identity / account information: title, surname, first names, username, postal address, telephone number, e-mail address, date of birth;
· Identifiers and encrypted password;
· User profile data: confidence IQ responses, self-assessment results, challenge completions, reflections and written inputs, progress data, avatar customization data;
· Payment data: payment confirmation (payment processed by third party service providers), country/region;
· Commercial relationship data: purchases made or in progress, services subscribed and their status, User preferences, User reviews and any problems encountered or reported by the User in the provision of Services;
· Invoice payment data: terms of payment, payments received, payments due, reminders, balances, billing address;
· Contact data: messages sent to the Services via contact forms or online chats, correspondence that may be sent to Us, AI conversation data, including metadata;
· Interests declared via a form or deduced from the use of the Services;
· Technical navigation, usage and interaction data: device type, operating system, app version, use statistics, IP address, log data, session duration, interaction patterns, cookies, crash reports;
· Location data.
The Service is not a healthcare or mental health service and does not provide medical advice, diagnosis, or treatment.
The Service is designed in a way that does not require, request, or actively solicit the provision of sensitive personal data (including health-related data) from Users at any stage of the user journey.
However, in the course of using the Services, Users may choose to voluntarily share information relating to their personal experiences, reflections, or progress (for example, relating to confidence, emotions, relationships, or stress). Depending on the context, such information may qualify as sensitive personal data under Applicable Regulations.
Where such data is provided by Users on their own initiative, it is processed on the basis of the User’s explicit consent, which is collected at the time of account creation.
Users remain free not to disclose any such information and can use the Service without providing sensitive personal data.
Personal Data that You provide to Us, as well as data that is collected and/or processed in connection with Your use of the Services, is processed for the following purposes:
· Under the contract between You and Us(TOU and this Privacy Policy), and with Your consent for any sensitive data You voluntarily decide to provide, we process Your data to: provide You with the Services, ensure their proper functioning, process Your requests, and allow You to create an account; as well as for user relationship management, account management, and payment management.
· Based on Our legitimate interest in improving Our Services, we: analyze the usage of the Services, including interactions with AI features, in order to improve performance, accuracy, User experience and AI performance; and improve the Services, in particular, to optimize or offer new features to the Services, correct any technical errors.
· Based on Our legitimate interest in offering You services and offers that correspond to Your preferences and interests, we: adapt and optimize the display of the content of Services and promotional offers, parameters or preferences, appetites and interests, proven, assumed or deduced, of the User, which may result from Your use of the Services, information You enter, Your navigation and Your interactions with the Services; and promote Our services and propose You with offers and news.
· With Your consent to receive offers and news from Our partners, we: inform You of Our offers and news, unless You object; and inform You of offers and news from Our partners, if You have provided Your consent.
· With Your consent to activate the geolocation function, we process Your data for optimizing the Services using the geolocation function, such as adapting content or functionalities based on Your approximate location.
· With Your consent for non-essential cookies, we store and/or access information on Your device (cookies or similar technologies) to ensure the proper functioning of the Services, measure audience and performance, improve the Services, and, where applicable, personalize content and features.
· Based on Our legitimate interest in ensuring the security and proper use of the Services, we detect, prevent and address misuse of the Services, including violations of the TOU, or security incidents.
· Finally, based on compliance with legal obligations and Our legitimate interest in ensuring Our legal defense, we comply with applicable legal and regulatory requirements, respond to lawful requests from authorities, and manage potential disputes.
In certain instances, We may anonymize or de-identify Your Personal Data so that it cannot reasonably be reidentified by Us or by another person, and We may use this deidentified or anonymized data for any reason permitted by Applicable Regulations. If We deidentify or anonymize information that was originally based on Personal Data, We maintain and use that information in deidentified or anonymized form and will not attempt to reidentify the data, except as otherwise permitted or required under Applicable Regulations.
Your Personal Data is strictly confidential. We take all the necessary precautions and organizational and technical measures in order to preserve the security, integrity and confidentiality of Personal Data, and, in particular, to prevent such data from being distorted or damaged, or unauthorized third parties having access thereto. We do not sell Your Personal Data.
In accordance with the regulations in force, Your Personal Data may be disclosed to competent authorities, public bodies, courts, law enforcement agencies, ministerial officer, or authorized third parties, , where such disclosure is required by law or is necessary to comply with a legal obligation, to respond to lawful requests, or to establish, exercise or defend Our legal claims.
Your Personal Data may be disclosed by Us to following third parties, for the purposes described above:
· Our personnel and Our service providers;
· Our affiliates;
· Our business partners;
· Social networks: if You choose to subscribe / access the Services via a social network account, certain information (such as Your name, username or profile picture) may be shared with Us by the relevant social network in accordance with its terms. Conversely, limited information relating to Your use of the Services may be shared with that social network. You can manage these exchanges through Your social network account settings;
· Corporate transactions: in the event of a merger, acquisition, restructuring, financing, transfer of assets, or similar transaction, Your Personal Data may be transferred to or accessed by the relevant third parties;
· Professional advisors: including legal, financial, or accounting advisors, where necessary to protect Our rights or comply with Our legal obligations.
Konstruct’s infrastructure, including AI model hosting, is located in Switzerland. User data and AI conversation data are processed on secure servers operated in Switzerland. Switzerland is recognized by the European Commission as providing an adequate level of data protection.
The User's Personal Data may be processed outside the European Union and Switzerland, including via remote access. We undertake not to carry out any transfer of Personal Data outside the European Union without implementing the appropriate safeguards in accordance with the Applicable Regulations.
In accordance with the Applicable Regulations, subject to an express request, You have the right to access to Your Personal Data, as well as the right to rectification, a right to object, right to restriction of processing, and a right to erasure, under the conditions set out in the Applicable Regulations.
When the processing of Your Personal Data is based on Your consent, You have the right to withdraw Your consent at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.
You also have the right to data portability, allowing You to receive, in a structured, commonly used and machine-readable format, the Personal Data You have provided to Us, and to transmit it to another controller where technically feasible. This right applies only to Personal Data processed on the basis of Your consent or the performance of a contract, and does not include data that We have generated ourselves.
You may also to provide Us with instructions regarding the retention, deletion and communication of Your Personal Data after Your death.
To exercise the rights mentioned in this Article, You may contact Us at support@konstructapp.com. We will respond to Your request in accordance with the Applicable Regulations.
If You consider that the processing of Your Personal Data infringes the Applicable Regulations, You also have the right to lodge a complaint with the competent supervisory authority, in particular in the Member State of Your habitual residence, place of work, or place of the alleged infringement.
We do not to retain Your Personal Data for longer than is strictly necessary for the purposes for which it was collected, in accordance with the Applicable Regulations. We anonymize or delete Your Personal Data once the relevant purpose has been fulfilled and/or the applicable retention period has expired.
However, certain Personal Data may be retained for a longer period where necessary to comply with legal or regulatory obligations, or for the establishment, exercise or defence of legal claims. In such cases, the Personal Data is archived with restricted access and will no longer be actively used for operational purposes. It is stored securely and separately, and may only be accessed on a need-to-know basis.
The following maximum retention periods apply:
· Audience measurement and Service customization, Management of cookies and other trackers, User preferences, Personal Data processed as part of promotional operations, offers and communications, AI interaction data (e.g. User inputs and generated responses), · Technical logs and security data (e.g. connection logs, IP addresses, error logs): Until account deletion or expiry.
Expiry is defined as inactivity of the user after a period of three years. Once a year (by end June of evey year) we will review user activity and delete accounts that have been inactive for a period of 3 years.
· Personal Data relating to the management of requests for the exercise of rights: duration of the processing of the request, then archived for up to 3 years for evidentiary purposes.
· Other information relating to the contractual relationship and account data; until the expiry / deletion of the User account, plus 5 years for the data necessary for establishment and defense of Our legal rights
· Information relating to subscriptions (billing): 10 years from the date of the last purchase or the last full payment of the last service provided
The Services are not intended for individuals below the minimum age required under Applicable Regulations to create an account and give consent (which is 16 years old in the European Union, or such higher or lower age as may apply in Your jurisdiction).
We do not knowingly collect or process Personal Data relating to individuals below this age. Users who do not meet this age requirement are not permitted to create an account or use the Services.
We implement appropriate technical and organizational measures to ensure a level of security of Your Personal Data that is appropriate to the risks, taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing.
In particular, We implement measures designed to protect Personal Data against unauthorized access, disclosure, alteration or destruction.
We use automated processing, including AI-based systems, to provide and personalize the Services, such as generating responses, adapting content, and suggesting features based on Your interactions.
These processing activities do not result in decisions based solely on automated processing that produce legal effects concerning You or similarly significantly affect You within the meaning of Applicable Regulations.
If You live within the United States, You may have certain rights regarding Our processing of Your Personal Data under applicable local state law. If Our processing of Your Personal Data is governed by such laws, the following provisions apply to Our processing of Your Personal Data, whether collected online or offline. These provisions supplement the information provided in Sections 1-10. If You are a resident of Nevada or Washington, please refer to our Consumer Health Privacy Policy regarding the processing of data that may relate to Your health.
Depending on where You reside, and subject to certain exceptions, You may have the rights described in Section 6. In addition to those rights, You also may have the right to right to appeal a refusal to take action on Your request. If You choose to exercise any of Your rights, You have the right to not receive unlawful discriminatory treatment by Us.
