Privacy Policy for Cominilab

Effective Date: October 1st, 2025
Last Updated:  October 1st, 2025

1. Introduction

Welcome to CominiLab, a math learning companion designed to help young children develop their mathematical skills. We are committed to protecting your privacy and the privacy of your child. This Privacy Policy explains how we collect, use, and protect information when you use our app.

2. Information We Collect

Personal Information

• Child's First Name: We collect your child's first name (or a name they choose to use) to personalize their learning experience

• Child's Age: We collect your child's age to provide age-appropriate math content and activities

• Parent's Name: We collect the parent or guardian's name (or a name they choose to use) for account management and communication purposes

Usage Information

• Learning progress and performance data

• Time spent using the app

• Areas of difficulty and improvement

• Device information (device type, operating system)

• App usage analytics (features used, session duration)

Information We Do Not Collect

• Last names or full legal names

• Email addresses from children

• Phone numbers

• Physical addresses

• Social security numbers

• Photos or videos of children

• Location data

3. How We Use Information

We use the collected information to:

• Personalize math lessons and activities for your child

• Track learning progress and identify areas for improvement

• Communicate with parents about their child's progress and app updates

• Provide customer support and respond to inquiries

• Improve our app's educational content and features

• Ensure the app functions properly on your device

We will never sell your data. Your personal information and your child's information will never be sold, rented, or traded to third parties for commercial purposes.

4. Information Sharing and Disclosure

We will never sell your data. We do not and will never sell, trade, or rent your personal information or your child's personal information to third parties.

We may share information only in the following limited circumstances:

• With your consent: When you explicitly agree to sharing

• Service providers: With trusted third-party services that help us operate the app (these providers are bound by strict confidentiality agreements)

• Legal requirements: When required by law or to protect safety and security

• Business transfers: In the event of a merger or acquisition (users will be notified in advance)

5. Children's Privacy (COPPA Compliance)

RIPPLES is designed for children and complies with the Children's Online Privacy Protection Act (COPPA):

• We collect minimal personal information from children

• We do not require children to provide more information than necessary to use the app

• Parents can review, delete, or refuse further collection of their child's information

• We do not enable children to publicly post personal information

• We implement reasonable security measures to protect children's information

Parental Rights

Parents and guardians have the right to:

• Review their child's personal information and their own information

• Delete their child's personal information and their own information

• Refuse further collection of their child's information

• Receive information about how their child's data is being used

• Contact us with questions about our privacy practices

To exercise these rights, contact us at sai@comini.in

6. Data Security

We implement appropriate technical and organizational security measures to protect your information, including:

• Encryption of data in transit and at rest

• Secure servers and databases hosted in India with international security standards

• Regular security assessments and audits

• Limited access to personal information on a need-to-know basis

• Compliance with Indian cybersecurity frameworks and international best practices

We follow industry-standard security practices and comply with applicable data protection laws in India and internationally.

7. Data Retention

We retain your child's information only as long as necessary to provide our services or as required by law. Learning progress data is typically retained to maintain continuity in your child's educational experience. You may request deletion of your child's data at any time.

8. Third-Party Services

Our app may use third-party services for analytics, crash reporting, or other functionality. These services have their own privacy policies, and we encourage you to review them. We only work with service providers who maintain appropriate privacy protections for children's data.

9. International Data Transfers

CominiLab is developed and operated from India.

Service Availability: CominiLab is not available to users in the European Union or United Kingdom. If you are located in the EU or UK, please do not use this app.

For users in other countries, please note that your information may be transferred to and processed in India where our servers and operations are located. We ensure appropriate safeguards are in place for such transfers and comply with applicable data protection laws in your jurisdiction.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify users of any material changes by:

• Posting the updated policy in the app

• Sending an email notification (if we have parent contact information)

• Displaying a prominent notice in the app

Continued use of the app after changes become effective constitutes acceptance of the updated policy.

11. Your Choices and Controls

You can:

• Delete the app and all associated data at any time

• Contact us to request deletion of your child's data

• Disable certain app features that collect usage data

• Use the app without providing optional information

12. Future Paid Features

RIPPLES is currently free to use. If we introduce paid features in the future:

• We will update this privacy policy accordingly

• Any payment processing will be handled by secure third-party payment processors

• We will not store payment card information

• Users will be clearly notified before any charges occur

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your child's information, please contact us:

Email: sai@comini.in
Company: Comini Learning Private Limited
Address: Mayflower 2nd Floor, Off new Kantwadi, Bandra West, 400050, Mumbai, India

We are committed to addressing your concerns promptly and transparently. We will respond to privacy requests within the timeframes required by applicable law (typically 30 days, or 45 days for complex requests).

14. Additional Information for Residents of Certain Jurisdictions

United States Residents

California (CCPA/CPRA): California residents have additional rights under the California Consumer Privacy Act, including the right to know what personal information we collect, the right to delete personal information, and the right to opt-out of the sale of personal information (note: we do not sell personal information).

Other US States: Residents of states with comprehensive privacy laws (such as Virginia, Colorado, Connecticut, and Utah) have similar rights to access, delete, and correct their personal information.

Canada Residents

Canadian residents have rights under applicable provincial privacy laws, including the right to access and correct personal information we hold about them.

Australia/New Zealand Residents

Residents have rights under the Privacy Act 1988 (Australia) and Privacy Act 2020 (New Zealand), including the right to access and correct personal information.

India Residents

As we are based in India, we comply with the Information Technology Act, 2000 and associated rules, as well as emerging data protection regulations including the Digital Personal Data Protection Act, 2023.

Note: CominiLab is not available to residents of the European Union or United Kingdom.