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Privacy Policy

Last updated: April 17, 2026

This Privacy Policy explains how Kumatomo Limited, Hong Kong (“Kumatomo,” “we,” “us,” or “our”) collects, uses, stores, discloses, and protects personal information in connection with the KumaTomo emotional companion app, the KumaGuardian parent control application, related websites, and connected wellbeing, developmental, and educational support services (collectively, the “Services”).

KumaTomo is an AI-supported emotional companion and child-support platform designed to provide age-appropriate conversational support, emotional check-ins, bedtime stories, development-oriented activities, English practice, and related guidance for children. KumaGuardian is the companion parent-facing application that allows parents or legal guardians to manage settings, supervise use, and review selected information related to a child’s use of the Services.

Please read this Privacy Policy carefully. By using the Services, creating an account, linking a child account, or consenting on behalf of a child, you acknowledge the practices described in this Privacy Policy, subject to applicable law.

1. WHO WE ARE

Operator: Kumatomo Limited Hong Kong

Contact email: support@kumatomo.com

If you have any questions about privacy, data use, parental controls, school linkage, safety alerts, or deletion requests, please contact us at: support@kumatomo.com

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to:

  • the KumaTomo emotional companion app;
  • the KumaGuardian parent control app;
  • our website and related web interfaces;
  • communication with us regarding customer support, account management, safety, and service issues;
  • data linked to parent, child, and, where applicable, school-related use of the Services.

This Privacy Policy does not apply to third-party services that are not controlled by Kumatomo Limited, even if they are linked from our Services. Those third parties have their own privacy policies and terms.

3. IMPORTANT CHILD AND PARENT NOTICE

The Services are designed to be used by children with parent, guardian, or school involvement as applicable. Where required by law, a parent or legal guardian must authorize account creation, child account linkage, and relevant data processing activities.

Parents or legal guardians are responsible for reviewing this Privacy Policy and the Terms of Use, providing any required permissions, and supervising the child’s use of the Services as appropriate.

Certain features of the Services are specifically designed so that:

  • parents can review selected information, settings, progress indicators, summaries, flags, and account-related data through KumaGuardian; and
  • schools, if accounts are linked through a school program, school dashboard, school code, or related institutional arrangement, may receive limited institutional-level information as described below.

4. INFORMATION WE COLLECT

We collect information that is reasonably necessary to provide, secure, maintain, improve, and support the Services.

A. Parent or Guardian Account Information

We may collect:

  • parent or guardian name;
  • email address;
  • login credentials or authentication identifiers;
  • subscription status and billing-related status information;
  • settings, permissions, guidance preferences, and linked child-account relationships;
  • communications with customer support.

B. Child Profile Information

We may collect:

  • child nickname, display name, or profile name;
  • age group, general developmental stage, language preferences, interests, and selected feature settings;
  • optional profile image or avatar if submitted by the parent or user;
  • parent-linked preferences, support settings, safety settings, or developmental guidance settings.

C. Interaction and Session Information

We may collect and process:

  • text entered into chats or conversations;
  • spoken content submitted through voice interaction;
  • emotional check-in responses and interaction patterns;
  • bedtime story preferences, topic preferences, and activity selections;
  • English-practice interactions and developmental activities;
  • conversation summaries, support summaries, developmental notes, and progress-related records;
  • transcripts of interactions, to the extent generated or retained within the service workflow;
  • safety-related flags, support-related records, and service quality records.

D. Parent Oversight and KumaGuardian Information

We may collect and display to parents or legal guardians:

  • selected summaries of child sessions and interactions;
  • progress indicators and developmental or usage-related information;
  • settings, guidance history, and feature preferences;
  • selected alerts, including alerts relating to safety, wellbeing, developmental concerns, or account-related issues, where applicable.

E. School-Linked Information

If a child account is linked to a school or educational institution through an authorized school program, school dashboard, or similar arrangement, we may process and disclose limited information to the school as described in Section 10 below.

F. Device, Technical, and Usage Information

We may automatically collect:

  • device type, operating system, app version, language settings, and technical identifiers;
  • crash logs, diagnostic logs, error reports, and performance information;
  • approximate region or country information;
  • timestamps, feature usage information, and service interaction metadata;
  • security-related logs necessary to detect fraud, abuse, misuse, or technical problems.

5. MICROPHONE, CAMERA, PHOTO LIBRARY, AND OTHER DEVICE ACCESS

Depending on the features used, the Services may request access to certain device capabilities, such as:

  • microphone access for voice-based conversations, emotional interaction, spoken support, and English practice;
  • camera access for optional child profile setup, activity-based features, or other parent-authorized product features;
  • photo library access for selecting and uploading profile images or other parent-authorized materials.

We access these features only for the purposes explained to the user in-app and in the device permission prompt, and only when the user or parent authorizes such access.

We do not store the child’s raw voice recording merely because microphone access is enabled. However, spoken interaction may be converted into text, interpreted, analyzed, summarized, or reflected in transcripts, support records, developmental summaries, quality assurance records, or similar service data as described in this Privacy Policy.

6. HOW WE USE INFORMATION

We use information for the following purposes:

A. To Provide the Services

We use information to:

  • operate KumaTomo’s conversational, emotional companion, story, activity, and support features;
  • provide age-appropriate interaction, emotional check-ins, stories, and developmental support;
  • respond to text and spoken inputs;
  • generate support feedback, summaries, recommendations, and continuity across sessions.

B. To Personalize the Experience

We use information to:

  • adapt interactions to the child’s age group, preferences, developmental level, and past usage;
  • maintain continuity between sessions;
  • save relevant progress, preferences, summaries, and recommended next steps;
  • support parent-guided settings and preferences.

C. To Support Parent Oversight

We use information to:

  • show selected summaries, settings, progress information, alerts, and flags in KumaGuardian;
  • allow parents to supervise and manage linked child accounts;
  • help parents understand the child’s use of the service.

D. To Support Safety, Security, and Appropriate Use

We use information to:

  • monitor misuse, harmful activity, abuse, fraud, or service manipulation;
  • maintain service integrity and safety;
  • identify serious issues that may require escalation to parents, schools, or support staff, where permitted and appropriate.

E. For Quality Assurance, Debugging, and Service Improvement

We may use stored transcripts, summaries, and related interaction records to:

  • review service quality;
  • investigate bugs and support issues;
  • improve accuracy, reliability, usability, and safety;
  • test, maintain, improve, and develop our services and AI-assisted features;
  • conduct internal research, analytics, and product development, subject to applicable law, access controls, and any required parent or guardian authorization.

F. To Comply with Legal Obligations

We may use information where reasonably necessary to:

  • comply with applicable law;
  • respond to lawful requests;
  • protect the rights, safety, and property of users, parents, schools, Kumatomo Limited, and others.

7. TRANSCRIPTS, SUMMARIES, AND VOICE-RELATED DATA

Because the Services include AI-supported voice and text interaction, users may speak and type during sessions.

We do not represent that all user inputs are purely transient. While we may not store the child’s raw voice recording itself as a retained audio file in ordinary operation, we may store or retain related information generated from the interaction, including:

  • text transcripts;
  • conversation summaries;
  • developmental continuity data;
  • wellbeing-related summaries;
  • selected support, safety, or quality-assurance records;
  • related analysis results and account-support records.

These records may be used for service continuity, parental review, safety review, quality assurance, internal testing, support, service improvement, feature development, and related lawful business purposes consistent with this Privacy Policy.

Where required by applicable law, we will rely on appropriate parent or guardian authorization or consent for such processing.

8. LEGAL BASIS AND PARENTAL AUTHORIZATION

Where applicable law requires a legal basis or consent, we process information based on one or more of the following:

  • performance of our contract or provision of requested services;
  • legitimate interests in operating, securing, supporting, and improving the Services;
  • parent or guardian consent or authorization;
  • compliance with legal obligations;
  • protection of vital interests or safety-related interests, where applicable.

Parents or legal guardians acknowledge and agree that:

  • selected child-related information may be visible to them through the parent control app;
  • certain session-related information may be stored and reviewed as described in this Privacy Policy;
  • if a school linkage is enabled, limited information may be disclosed to the school as described below.

9. KUMAGUARDIAN PARENT CONTROL APP

KumaGuardian is intended to provide parent or legal guardian oversight and management.

By linking a child account to KumaGuardian, the parent or legal guardian acknowledges that they may be able to access selected information about the child’s use of the Services, which may include:

  • session summaries;
  • usage and developmental information;
  • selected indicators and trends;
  • settings and preferences;
  • selected alerts, flags, or recommendations;
  • account and usage management functions.

Parents may not necessarily see every raw interaction or every internal processing record. We may limit what is shown in KumaGuardian for privacy, safety, educational, operational, or product-design reasons.

10. SCHOOL-LINKED ACCOUNTS AND LIMITED SCHOOL ACCESS

If a child account is linked to a school, class, school dashboard, school code, or other school-authorized program, Kumatomo may disclose limited information to the relevant school or educational institution.

In general, the school-facing information is intended to be limited and may include:

  • aggregated or statistical wellbeing, usage, or developmental information;
  • age-group-level or cohort-level indicators;
  • class-level or school-level trends;
  • limited alerts or intervention-related indicators.

As a general rule, school-facing reporting is intended to be non-personalized and statistical in nature. However, in certain cases we may disclose individualized information to a school where we reasonably determine that:

  • there is a serious safety issue;
  • there is a significant wellbeing or developmental concern requiring follow-up;
  • there is a substantial concern that may require school awareness or intervention;
  • disclosure is otherwise authorized by the parent or legal guardian, required by law, or reasonably necessary to protect the child or others.

By linking a child account to a school-enabled service, the parent or legal guardian acknowledges and agrees to this limited school-related disclosure framework as described in this Privacy Policy.

11. SERVICE PROVIDERS AND THIRD-PARTY PROCESSING

We may use third-party service providers to help operate the Services, including providers for:

  • cloud hosting and infrastructure;
  • data storage and database services;
  • authentication and account management;
  • analytics and diagnostics;
  • customer support tooling;
  • content moderation, security, and fraud prevention;
  • AI-related processing and model-assisted service functionality.

These service providers may process personal information on our behalf and only for the purpose of providing services to us, subject to contractual confidentiality, privacy, and security obligations.

We do not sell personal information to third parties. We do not disclose personal information to third parties for their independent advertising use.

12. INTERNATIONAL DATA PROCESSING

Because our service providers, infrastructure, and technical operations may involve international systems, personal information may be processed in jurisdictions outside the user’s country of residence.

Where personal information is transferred internationally, we take reasonable steps intended to ensure an appropriate level of protection through contractual, organizational, and technical safeguards, subject to applicable law.

13. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

  • provision of the Services;
  • continuity of interaction and developmental records;
  • parental oversight functionality;
  • customer support;
  • safety review;
  • legal compliance;
  • dispute resolution;
  • enforcement of our agreements;
  • improvement, testing, and development of the Services, where permitted by law.

Retention periods may vary depending on the data type, account status, applicable law, safety considerations, and operational needs.

Even if raw audio is not ordinarily stored as a retained audio file, transcripts, summaries, quality-assurance records, support records, and other derived data may be retained for the periods reasonably necessary for the purposes described above.

14. DATA DELETION AND ACCOUNT DELETION

Parents or users may request deletion of an account and associated personal data, subject to applicable law and any data we are legally required or reasonably permitted to retain.

If the Services support account creation, users must be able to initiate deletion within the app experience, consistent with applicable platform requirements.

Deletion may not always be immediate in backups, logs, or archived systems, but we will take reasonable steps to process deletion requests in accordance with applicable law and our retention obligations.

To request deletion or inquire about deletion, contact: support@kumatomo.com

15. SECURITY

We use reasonable technical, administrative, and organizational safeguards intended to protect personal information from unauthorized access, loss, misuse, alteration, or disclosure.

However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

16. YOUR RIGHTS

Depending on applicable law and the user’s location, parents, legal guardians, and eligible users may have rights to:

  • access certain personal information;
  • correct inaccurate information;
  • request deletion;
  • request export of certain information;
  • object to certain processing;
  • withdraw consent where processing is based on consent.

To exercise such rights, contact: support@kumatomo.com

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes, we may provide notice through the website, app, or other reasonable means.

The “Last updated” date at the top of this Privacy Policy indicates when this Privacy Policy was last revised.

18. CONTACT

Kumatomo Limited Hong Kong Email: support@kumatomo.com