Privacy Policy

Welcome to Kumi, operated by Kumiai Inc. ("we," "us," or "our"). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and services (collectively, the "Service").

By using Kumi, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use the Service.

This Privacy Policy applies to all users of the Kumi website and the Kumi mobile application distributed via the Apple App Store.

2.1 Information You Provide

• Account Information: Name, email address, username, password, and profile information
• Learning Data: Your progress, performance, preferences, study goals, and interactions with learning content
• Communication: Information you provide when contacting us for support, feedback, or inquiries
• Payment Information: Subscription and billing information is processed by Apple via in-app purchases or by third-party payment processors, depending on platform. We do not store or process full payment card information on our servers.

2.2 Information Collected Automatically

• Usage Data: Pages visited, features used, time spent, and interaction patterns
• Device Information: Device type, operating system, browser type, IP address, and unique device identifiers
• Analytics: We use PostHog to understand how users interact with the Service. When you are signed in, PostHog receives a stable internal account identifier (your user id) and usage events; we do not send your email or display name to PostHog. Dictionary search analytics use aggregated fingerprints (not the raw characters you typed).
• Cookies: We use cookies and similar tracking technologies (see Section 8)

We do not use personal data for cross-app tracking, targeted advertising, or data brokering, and we do not participate in Apple's App Tracking Transparency (ATT) tracking.

We use your information to:

• Provide, maintain, and improve the Service
• Personalize your learning experience using adaptive systems based on your interactions and progress
• Track your progress and adapt content to your proficiency level
• Process subscriptions and manage access to paid features
• Send service-related updates, notifications, and educational content
• Respond to comments, questions, and support requests
• Analyze usage patterns to improve our systems and learning models
• Detect, prevent, and address technical issues, abuse, and fraudulent activity
• Comply with legal and regulatory obligations

We do not sell your personal information.

We may share your information only in the following circumstances:

• Service Providers: Third-party vendors who perform services on our behalf (hosting, analytics, payment processing, customer support)
• Legal Requirements: When required by law, subpoena, court order, or legal process
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: When you explicitly authorize us to share information
• Aggregate Data: Anonymized or aggregated data that cannot reasonably identify you

We retain personal information for as long as necessary to provide the Service and fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

When you delete your account, we deactivate it and revoke access immediately. Your data may be retained in a deactivated state for legal, analytics, accounting, fraud prevention, or security purposes. If you would like your data to be permanently erased from our systems, please contact us at privacy@kumi.app, and we will process your request in accordance with applicable law.

Depending on your jurisdiction, you may have the following rights:

• Access: Request access to your personal information
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal information
• Portability: Request a copy of your data in a portable format
• Opt-Out: Opt out of marketing communications
• Objection: Object to certain types of processing

Users may delete their account at any time from within the Kumi app settings. If you are unable to access the app, you may request account deletion by contacting privacy@kumi.app.

We implement appropriate technical and organizational safeguards to protect personal information, including:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security reviews and updates
• Secure cloud infrastructure and hosting providers

However, no method of transmission over the internet or electronic storage is completely secure. While we take reasonable steps to protect your information, we cannot guarantee absolute security.

We use cookies, web beacons, and similar technologies to operate and improve the Service.

Types of cookies we use include:

• Essential Cookies: Required for core functionality
• Analytics Cookies: Help us understand how users interact with the Service
• Preference Cookies: Remember your settings and preferences

You may manage or disable non-essential cookies through your browser settings. Disabling cookies may limit certain features of the Service.

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

Third-party services we use may include:

• PostHog (analytics)
• Apple In-App Purchases and payment processors
• Cloud hosting providers
• Email and notification service providers

We do not use analytics data for advertising purposes or sell analytics data to third parties.

The Service is intended for users aged 13 and older. It is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13.

If you believe we may have collected personal information from a child under 13, please contact us at privacy@kumi.app, and we will take appropriate steps to delete the information.

Your information may be transferred to and processed in countries other than your country of residence, including the United States.

Where required by law, we implement appropriate safeguards, such as standard contractual clauses, to protect personal data during international transfers.

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

• The right to know what personal information we collect and how it is used
• The right to request deletion of personal information
• The right to opt out of the sale of personal information (we do not sell personal information)
• The right to non-discrimination for exercising your privacy rights

If you are located in the European Economic Area (EEA) or the United Kingdom, you have rights under the General Data Protection Regulation (GDPR), including those listed in Section 6.

Our legal bases for processing personal data include:

• Performance of a contract (providing the Service)
• Legitimate interests (improving the Service, security, and fraud prevention)
• Your consent, where required
• Compliance with legal obligations

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page.

Your continued use of the Service after changes become effective constitutes acceptance of the revised Privacy Policy.

If you have questions, concerns, or requests regarding this Privacy Policy, please contact us: