INKA Privacy Policy

Effective date: 2 July 2026

Last updated: 2 July 2026

This Privacy Policy explains how Votian Labs Limited ("Votian Labs," "INKA," "we," "us," or "our") collects, uses, shares, and protects your personal information when you use INKA (the "Service") through our website, mobile applications, and related services.

We are committed to protecting your privacy and being transparent about how INKA handles your data. INKA is a creator-marketing intelligence platform. Our service learns from your activity so that we can provide you with better predictions and recommendations. This document explains exactly what that means.

If you have any questions about this policy or your data, contact us at reachout@inkaviral.com.

1. Who We Are

INKA is a product of Votian Labs Limited, a company registered in Scotland.

• Business address: 5 South Charlotte Street, Edinburgh EH2 4AN
• Company number: SC891614
• Data controller contact: reachout@inkaviral.com

For users in the European Economic Area, the United Kingdom, and Switzerland, Votian Labs Limited is the data controller responsible for your personal information.

2. Information We Collect

We collect information you give us directly, information we collect automatically when you use the Service, and limited information from third parties when relevant.

2.1 Information you provide directly

When you create an INKA account and use the Service, you may give us:

• Account information: name, email address, password (hashed and salted, never stored in plain text), profile picture, country of residence
• Profile information: your niche, sub-niche, primary platforms, goals, posting frequency, brand voice preferences
• Content you submit for analysis: posts, captions, scripts, ideas, video descriptions, hashtags
• Images and media: images you upload for analysis (e.g., post thumbnails, content stills)
• Diary entries and notes: any notes you write in your INKA Twin or channel profiles
• Feedback: real-world performance data you report back to INKA (views, engagement, audience response, what worked, what flopped)
• Communications: support requests, feedback submissions, replies to in-app prompts

2.2 Information collected automatically

When you use INKA, we automatically collect:

• Device and connection information: IP address, browser type, operating system, device model, app version, language, time zone, referring URLs
• Usage information: which features you use, how often, what you click, how long you spend in each part of the Service, the path you take through the app
• Diagnostic information: crash reports, error logs, performance metrics (used to improve stability)
• Session information: authentication tokens, login timestamps, sign-out events

2.3 Information from third parties

If you choose to connect a social media account (Instagram, TikTok, YouTube, X, LinkedIn, Facebook) in a future version of INKA, we will collect — only with your explicit authorization — your account analytics, your post history, comments on your posts, and follower information. This is optional and you control it at all times.

2.4 What we DO NOT collect

• Payment card details: All payments are processed by Stripe (web), Apple (iOS in-app purchases), or Google (Android in-app purchases). We never see or store your card details.
• Biometric data: If you use Face ID, Touch ID, or fingerprint authentication, that information stays on your device. We never receive it.
• Precise location: We do not track your precise GPS location. Country and region are inferred from IP address only.

3. How We Use Your Information

We use the information described above to:

3.1 Provide and improve the Service

• Create and maintain your account
• Generate virality predictions, recommendations, and analyses on your posts
• Personalize your Twin (your private memory in INKA) so future predictions are sharper for you specifically
• Display trending content and platform-specific intelligence relevant to your niche
• Run our nightly learning cycles, research cycles, and collective intelligence mining (described in Section 4 below) so the system improves over time
• Communicate with you about updates, new features, and important service changes

3.2 Train and improve INKA's intelligence (this is the part most policies hide — we don't)

INKA is a learning system. When you submit a post for analysis, INKA records what was predicted. When you later report real-world performance back to INKA, the system uses that outcome to score the lessons that powered the prediction.

This is how INKA gets smarter for you AND for all other users. Patterns extracted from your data are used to refine the platform's collective intelligence. However, this is done in a privacy-preserving way:

• Your individual posts, diary entries, and personal profile remain private to your account. Other users never see your raw content.
• Cross-user pattern mining is fully anonymized. When the system identifies that "creators in fitness using sub-7-word hooks see higher save rates," it stores the pattern, not the people behind it. No user ID, no name, no email, no link back to you.
• You can delete your account at any time (see Section 8). When you do, all your personal information, content, and identifiers are permanently deleted. Anonymized patterns already derived from your data are retained as part of INKA's collective intelligence, because they no longer identify you.

3.3 Safety, compliance, and abuse prevention

• Detect and prevent misuse, fraud, spam, and policy violations
• Comply with applicable law, including responding to lawful requests from authorities
• Detect and report illegal content (specifically, child sexual abuse material is automatically detected and reported to the National Center for Missing & Exploited Children, as required by U.S. law)
• Maintain audit logs of authentication events (sign-in, sign-out, account deletion) for security and compliance

3.4 Marketing (only with your consent)

• Send product updates, tips, and feature announcements
• Offer relevant subscriptions or upgrades
• You can opt out of marketing communications at any time through your settings or by clicking "unsubscribe" in any email

We will never sell your personal data. We will never share your personal data for third parties to advertise to you outside INKA.

4. How INKA Learns From Your Data (The Honest Section)

We believe in being transparent about exactly how INKA works.

4.1 Your Twin

Every account has a private Twin — a memory of your posts, diary entries, questionnaire answers, feedback, and the analyses you've received. The Twin is yours. It's used only to make INKA's predictions for you more personalized over time.

4.2 Twin Agents (Premium feature)

If you subscribe to a Premium tier, you can create multiple "Twin Agents" — separate, isolated channels (for example, one for fitness content, one for ecommerce, one for personal brand). Each Twin Agent has its own memory and its own intelligence. They never contaminate each other. You can have one Twin Agent on the Standard tier; Premium tiers allow more.

4.3 The Hive

The Hive is INKA's central knowledge base. It learns three ways:

1. From explicit feedback — when you report whether a prediction was right or wrong
2. From autonomous web research — INKA identifies its own knowledge gaps and researches them via the public web, with a human reviewer approving all new knowledge before it enters the system
3. From anonymized cross-user pattern mining — patterns that hold across many creators in similar niches become lessons in the Hive

The Hive never stores raw personal content from users. It stores distilled, anonymized patterns and lessons.

4.4 Predictions and outputs

INKA's predictions, optimised content suggestions, and recommendations are generated by AI systems including large language models. These outputs are based on data analysis and may not always be accurate. INKA outputs are suggestions, not guarantees. We disclose AI use clearly throughout the Service.

5. How We Share Your Information

We share your information only in the limited circumstances described below.

5.1 Third-party service providers (data processors)

To run INKA, we use the following service providers. Each is contractually bound to handle your data only on our instructions and in compliance with applicable privacy law:

We do not share your information with third parties for their own marketing or advertising purposes.

5.2 Legal and safety

We may share your information when we believe in good faith that doing so is necessary to:

• Comply with applicable law, court order, or government request
• Protect the safety of any person, including you
• Investigate, prevent, or address fraud or abuse
• Enforce our Terms of Service

Specifically, suspected child sexual abuse material is reported to the National Center for Missing & Exploited Children as required by 18 U.S.C. § 2258A.

5.3 Business transfers

If Votian Labs is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be transferred as part of that transaction. We will notify you (by email and in-app notice) before your information is transferred and becomes subject to a different privacy policy.

5.4 With your consent

We share your information for any other purpose only with your explicit consent.

6. International Data Transfers

INKA is operated from the United Kingdom. Some of our service providers (listed in Section 5.1) are located in the United States and other countries. When your personal data is transferred outside the UK / European Economic Area, we rely on appropriate safeguards including:

• Standard Contractual Clauses approved by the European Commission and the UK Information Commissioner's Office
• Adequacy decisions where applicable
• Provider-specific certifications (SOC 2, ISO 27001, etc.) where relevant

You can request a copy of the safeguards we use by contacting reachout@inkaviral.com.

7. Data Retention

We keep your information only as long as necessary to provide the Service and comply with our legal obligations.

After the retention period, your data is either permanently deleted or anonymized so that it can no longer be linked to you.

8. Your Rights

Depending on your country of residence, you have the following rights regarding your personal data. We respect all of these rights, regardless of where you live.

8.1 Universal rights (we honour these for all users)

• Access: request a copy of all personal information we hold about you
• Correction: request that we correct any inaccurate information
• Deletion: request that we delete your account and personal data
• Export: request your data in a structured, machine-readable format (JSON)
• Withdraw consent: withdraw any consent you've given us at any time

8.2 How to exercise your rights

• In-app: Settings → Account → Data & Privacy
• Email: reachout@inkaviral.com
• We respond within 30 days (or sooner — usually within 7).

8.3 Account deletion specifically

When you delete your INKA account:

1. Your account is locked immediately and you are signed out of all devices
2. Within 24 hours: your profile, posts, Twin chunks, uploaded images, agents, and identifiable analytics are queued for deletion
3. Within 30 days: all of the above is permanently deleted from primary databases and backups
4. Anonymized patterns and lessons that INKA has already derived from your data are retained. These no longer identify you. This retention is what makes INKA's collective intelligence useful for all users.
5. You will receive a confirmation email when deletion is complete.

If you have specific concerns about deletion or want to confirm what is being retained, contact reachout@inkaviral.com before requesting deletion and we'll walk you through it.

8.4 Additional rights in the EEA, UK, and Switzerland (GDPR / UK GDPR)

• Object to processing: object to any processing based on legitimate interests
• Restrict processing: request that we temporarily stop processing your data
• Lodge a complaint: with your local data protection authority. For UK users, this is the Information Commissioner's Office (ico.org.uk).

8.5 Additional rights in California (CCPA / CPRA)

If you are a California resident:

• Right to know what personal information we collect, use, disclose, and sell (we do not sell)
• Right to delete your personal information
• Right to opt out of "sales" of personal information (we do not sell)
• Right to opt out of "sharing" for cross-context behavioural advertising (we do not share for this)
• Right to non-discrimination for exercising your rights

To exercise California-specific rights, email reachout@inkaviral.com with "California rights request" in the subject line.

8.6 Additional rights in Brazil (LGPD), Australia (Privacy Act), and elsewhere

We honour equivalent rights for users in all jurisdictions. Contact reachout@inkaviral.com.

9. Children's Privacy

INKA is intended for users 18 years of age or older. INKA is not directed at children, and we do not knowingly collect personal information from anyone under 18.

In the European Economic Area, the United Kingdom, and the United States (under COPPA), the minimum age for using a social-media-related service is 13. If we learn that we have collected personal information from a child under 13 (or the relevant minimum age in your jurisdiction), we will delete that information promptly and disable the account.

If you believe a child has provided us with personal information, contact reachout@inkaviral.com and we will take immediate action.

10. Cookies and Similar Technologies

INKA uses cookies and similar technologies for:

• Authentication: keeping you signed in
• Functionality: remembering your preferences (dark mode, language, etc.)
• Analytics: measuring how the Service is used so we can improve it

We do not use third-party advertising cookies or trackers.

You can control cookies through your browser settings. In the mobile app, we use App Tracking Transparency on iOS — if we ever ask you for ATT permission, we'll explain exactly what we want to track and why. Today, we do not run any third-party ad tracking SDKs.

11. Security

We take security seriously and implement industry-standard measures including:

• TLS encryption for all data in transit
• Encryption at rest for sensitive data
• Access controls and authentication for our team (only authorized personnel can access user data, and only when necessary)
• Audit logs for all administrative actions
• Regular security reviews of our infrastructure
• Vendor security review of all service providers

No system is 100% secure. If a security breach affects your personal data, we will notify you within 72 hours of becoming aware of it, as required by GDPR and equivalent laws.

To report a security issue, please email reachout@inkaviral.com.

12. AI-Specific Disclosures

INKA uses artificial intelligence to generate predictions, recommendations, and content suggestions. We disclose AI use clearly throughout the Service. Specifically:

• AI outputs are predictions, not guarantees. Real-world performance may vary.
• AI may occasionally be wrong. We continuously improve through feedback loops, but errors can occur.
• You retain ownership of your content. AI-generated suggestions are tools to help you, not works that replace your authorship.
• We don't train external public AI models on your private content. Patterns learned from your data stay within INKA's own systems.
• Image analysis uses computer vision. Uploaded images are analyzed by AI vision models (currently provided by xAI). These models receive your image temporarily during analysis. We retain the original image only as part of your account history; the third-party vision provider does not retain it past the API call.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other reasons. When we make a material change, we will:

• Update the "Last updated" date at the top of this page
• Notify you by email (for material changes affecting your rights)
• Provide an in-app notification

We encourage you to review this Policy periodically. Your continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

14. Contact Us

Questions, concerns, or requests about this Privacy Policy:

• Email: reachout@inkaviral.com
• Postal address: Votian Labs Limited, Scotland
• Data Protection Officer: reachout@inkaviral.com

For UK / EEA users, you have the right to lodge a complaint with your supervisory authority. For UK: Information Commissioner's Office, ico.org.uk.

INKA is built by creators, for creators. We respect your data because we are one of you. If anything in this policy is unclear, please ask — we'd rather explain than have you wonder.