This Privacy Policy describes how Kinovate Ventures Inc. (“Kinovate,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when individuals access or use the KinClub platform and related services (collectively, the “Services”).
This Privacy Policy applies to:
Kinovate is committed to protecting children’s privacy and handling personal information in accordance with applicable privacy and data protection laws, including:
This Privacy Policy is intended to provide clear, accurate, and accessible information to parents and other users about Kinovate’s data practices. It does not replace parental supervision or control, and use of the Services remains subject to the Terms of Service.
Where local law requires additional disclosures or provides specific rights, those rights apply to eligible users as described in this Privacy Policy. Certain features or rights may vary by location.
Kinovate collects personal information as necessary to operate the Services, support parental controls, comply with applicable law, and provide a safe, child-directed platform. The categories of information collected vary depending on whether the user is an Adult User or a Child and how the Services are used.
We may collect the following categories of personal information from Adult Users:
We collect personal information from Children only as permitted by applicable law and only with verifiable parental consent, where required. Categories of child-related information may include:
We do not require Children to provide more personal information than is reasonably necessary to participate in the Services.
When users access or use the Services, we may automatically collect certain information, including:
We may receive limited information from third parties in connection with the Services, including:
Where required by applicable law, certain information may be treated as sensitive personal information. Kinovate limits the collection and use of sensitive personal information to what is necessary to provide the Services, ensure safety, and comply with legal obligations.
Kinovate collects personal information through several methods to operate the Services, support parental controls, comply with applicable legal requirements, and maintain a safe, child-directed platform. The way information is collected depends on how the Services are used and whether the information relates to an Adult User or a Child.
Kinovate collects personal information that Adult Users provide directly when they create or manage an account, configure or oversee Child Accounts, provide consent or verification information required for child-directed features, subscribe to paid services, complete transactions, or communicate with Kinovate for customer support, administrative, or legal purposes. Adult Users may also provide information when submitting feedback or other communications related to the Services.
Children may provide limited personal information directly through their use of the Services, including by creating content, participating in activities, or interacting with AI-powered features. Any such collection occurs subject to parental permissions and applicable consent requirements, and Children are not required to provide more information than is reasonably necessary to participate in the Services.
Certain information is collected automatically when users access or use the Services. This includes technical and usage information generated through normal platform operation, such as log data, device identifiers, network information, access times, and interactions with features or content. Kinovate also uses cookies, pixels, and similar tracking technologies to support core functionality, maintain security, analyze performance, and understand how the Services are used. Kinovate does not use tracking technologies to engage in behavioral advertising directed at Children.
When users interact with AI-powered features, Kinovate collects the inputs provided to those features and the outputs generated in response. This information is collected to provide the requested functionality, enable parental oversight, improve system performance and safety, and address misuse or abuse. Where feasible, AI interaction data may be processed in an aggregated or de-identified form.
Kinovate may receive limited personal information from third parties that support the operation of the Services, including analytics providers, cloud hosting and infrastructure providers, payment processors, and third-party AI technology providers. Information obtained from third parties is used only for purposes consistent with this Privacy Policy and applicable law.
For users located in the European Economic Area or the United Kingdom, Kinovate processes personal data based on one or more lawful bases under the GDPR. These lawful bases include processing necessary for the performance of a contract, compliance with legal obligations, Kinovate’s legitimate interests in operating, securing, and improving the Services, and consent where required by law, including for certain child-related processing activities.
Kinovate uses personal information only as necessary to operate the Services, support parental controls, protect users, and comply with applicable legal requirements. The purposes described below apply to both Adult Users and Children, except where limited by law or parental permissions.
Kinovate uses personal information to create and manage user accounts, enable access to platform features, administer Subscriptions, process payments, and provide customer support. For Child Accounts, personal information is used to deliver age-appropriate features, enable parental oversight, and ensure that access to the Services occurs in accordance with parental permissions and applicable law.
Personal information is used to maintain the safety and security of the Services, detect and prevent fraud or misuse, enforce the Terms of Service, and protect users from harmful or inappropriate activity. This includes monitoring for violations of community standards, responding to abuse reports, and addressing technical or security incidents.
Kinovate uses personal information, including AI interaction data, to operate AI-powered features, generate responses or content, and improve system performance and safety. AI-related data may also be used to identify misuse, refine safeguards, and support parental visibility into a Child’s interactions. AI-generated outputs are not used to make automated decisions with legal or similarly significant effects on users.
Kinovate uses personal information to communicate with Adult Users regarding account administration, Subscriptions, updates to the Services or policies, and customer support matters. Communications may also include important safety or legal notices.
Personal information is used to understand how the Services are used, evaluate feature performance, and improve functionality and user experience. Where feasible, analytics data is aggregated or de-identified. Kinovate does not use Children’s personal information for targeted advertising or behavioral profiling.
Kinovate uses personal information to comply with applicable laws and regulations, respond to lawful requests, enforce agreements, and protect its legal rights. This includes meeting obligations under children’s privacy laws, consumer privacy laws, and applicable AI transparency requirements.
For users located in the European Economic Area or the United Kingdom, Kinovate processes personal data for the purposes described above based on one or more lawful bases under the GDPR. These include processing necessary for the performance of a contract, compliance with legal obligations, Kinovate’s legitimate interests in operating and improving the Services safely and responsibly, and consent where required by law.
AI-powered features are designed to support engagement, creativity, and learning, and do not replace human judgment. Kinovate does not rely on AI-generated outputs to make decisions that produce legal or similarly significant effects on users.
For Child Accounts, AI-assisted features operate subject to parental permissions and oversight. Adult Users remain responsible for supervising a Child’s interactions with AI-powered features and for reviewing outputs where appropriate. This disclosure is provided to promote transparency and to meet applicable artificial intelligence transparency requirements.
Kinovate uses cookies and similar tracking technologies to operate the Services, support core functionality, maintain security, and understand how the platform is used. These technologies help ensure that the Services function properly and that parental controls and safety features work as intended.
Cookies are small text files placed on a device when a user visits a website or uses an online service. Kinovate may also use similar technologies, such as pixels, SDKs, or local storage, to collect information about interactions with the Services.
Kinovate uses cookies and similar technologies for the following purposes:
Kinovate does not use cookies or similar technologies to engage in targeted or behavioral advertising directed at Children.
Kinovate limits the use of cookies and tracking technologies in connection with Child Accounts to what is reasonably necessary to support the Services, ensure safety, and comply with applicable law. Tracking technologies are not used to build profiles of Children for advertising or marketing purposes.
Adult Users may manage cookie preferences through browser settings or device controls. Disabling certain cookies may affect the availability or functionality of the Services. Where required by applicable law, Kinovate provides mechanisms to manage consent for non-essential cookies.
For users located in the European Economic Area or the United Kingdom, Kinovate uses non-essential cookies only where permitted by law and, where required, based on user consent. For users subject to U.S. state privacy laws, information collected through cookies may be considered personal information and is handled in accordance with the rights described in this Privacy Policy.
Kinovate is committed to protecting the privacy of Children and complying with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable children’s privacy laws. The Services are designed so that Children may access features only through accounts created, authorized, and managed by an Adult User.
Kinovate collects, uses, and discloses personal information from Children only with verifiable parental consent, where required by law. An Adult User must provide consent before a Child Account may access certain features of the Services or before personal information is collected from a Child, except where permitted by COPPA without prior permission.
Kinovate may request additional information from an Adult User to verify consent or confirm parental authority. If verifiable parental consent is not obtained or cannot be confirmed, Kinovate may limit, suspend, or terminate a Child Account.
Personal information collected from Children may include information necessary to create and manage a Child Account, support participation in activities, enable parental controls, and provide access to AI-powered or interactive features, as described in Sections 1 and 2 of this Privacy Policy. Kinovate does not condition a Child’s participation in the Services on the disclosure of more personal information than is reasonably necessary.
Parents and legal guardians have the right to:
These rights may be exercised by contacting Kinovate at support@kinovateinc.com or through account management tools provided within the Services.
Upon a valid request, Kinovate will delete a Child’s personal information to the extent required by law. Certain information may be retained as necessary to comply with legal obligations, protect the safety and integrity of the Services, or maintain records of parental consent.
Parents or legal guardians with questions or concerns regarding children’s privacy practices may contact Kinovate at support@kinovateinc.com.
Kinovate shares personal information only as necessary to operate the Services, comply with applicable law, and protect users. We do not sell personal information, and we do not share Children’s personal information for advertising or marketing purposes.
Kinovate may share personal information with service providers that perform services on our behalf, such as cloud hosting, data storage, analytics, customer support, payment processing, and AI technology providers. These service providers are permitted to use personal information only to perform services for Kinovate and are subject to contractual obligations designed to protect personal information.
Certain features of the Services rely on third-party AI or technology providers. Personal information, including AI interaction data, may be shared with these providers to enable AI-powered functionality, maintain safety controls, and improve system performance. Where feasible, information shared with AI providers is limited, aggregated, or de-identified, and is subject to applicable legal and contractual safeguards.
Kinovate may disclose personal information where required to comply with applicable law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Kinovate, our users, or others. This includes disclosures necessary to enforce our Terms of Service or investigate suspected violations.
In the event of a merger, acquisition, restructuring, bankruptcy, or sale of some or all of Kinovate’s assets, personal information may be transferred as part of that transaction. If such a transfer occurs, Kinovate will take reasonable steps to ensure that personal information continues to be handled in accordance with this Privacy Policy.
Kinovate limits the sharing of Children’s personal information to what is necessary to operate the Services, support safety and parental controls, and comply with legal obligations. Children’s personal information is shared only with service providers and partners that are contractually required to protect such information and to use it solely for authorized purposes.
Kinovate does not sell personal information as defined under the CCPA or similar state laws, and does not share personal information for cross-context behavioral advertising or targeted advertising purposes.
Kinovate does not share personal information for cross-context behavioral advertising, targeted advertising, or similar purposes as those terms are defined under applicable U.S. state privacy laws, including the CCPA and CPRA.
Kinovate retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, to operate the Services, to support parental controls, and to comply with applicable legal obligations.
Personal information is retained based on the nature of the data, its use, and applicable legal requirements. In general, Kinovate retains personal information for the duration of an active account and for a reasonable period thereafter to support account management, resolve disputes, maintain security, and comply with legal or regulatory obligations.
Information associated with Child Accounts is retained only as long as necessary to provide the Services, support parental oversight, and comply with children’s privacy laws.
Adult Users may request deletion of their personal information or their Child’s personal information by contacting Kinovate at support@kinovateinc.com or using the account management tools provided within the Services. Kinovate will respond to valid deletion requests in accordance with applicable law.
Certain information may be retained after a deletion request where retention is necessary to comply with legal obligations, enforce agreements, resolve disputes, protect the safety and integrity of the Services, or maintain records of parental consent. Where possible, retained information is limited, secured, and isolated from active use.
Kinovate may retain anonymized or aggregated information that does not identify an individual for analytics, research, or service improvement purposes. Such information is not subject to deletion requests.
Kinovate takes reasonable administrative, technical, and organizational measures designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. These measures are intended to safeguard personal information collected through the Services, including information related to Child Accounts.
Security practices may include access controls, encryption, monitoring, and other safeguards appropriate to the sensitivity of the information and the nature of the Services. Kinovate periodically reviews and updates its security practices to address evolving risks.
Despite these measures, no method of transmission or storage is entirely secure. Kinovate cannot guarantee the absolute security of personal information, and users acknowledge that they provide personal information at their own risk.
Kinovate is based in the United States and operates the Services from the United States. As a result, personal information collected through the Services may be transferred to, stored in, or processed in the United States or other countries where Kinovate or its service providers operate.
For users located in the European Economic Area, the United Kingdom, or other regions with data protection laws that differ from U.S. law, these transfers may involve jurisdictions that do not provide the same level of data protection as the user’s home country.
For purposes of the General Data Protection Regulation (GDPR), Kinovate acts as a data controller with respect to personal data collected and processed through the Services. Service providers and technology partners that process personal data on Kinovate’s behalf do so as data processors (or equivalent roles) under contractual obligations designed to protect personal data and limit processing to authorized purposes.
Where required by applicable law, Kinovate relies on appropriate safeguards to support international data transfers, such as standard contractual clauses or other legally recognized transfer mechanisms. Kinovate does not transfer Children’s personal information internationally except as necessary to operate the Services and in compliance with applicable children’s privacy laws.
By using the Services, Adult Users acknowledge and understand that personal information may be transferred and processed outside their country of residence as described in this Privacy Policy.
Depending on where you live, you may have certain rights regarding your personal information. Kinovate respects these rights and provides mechanisms for eligible users to exercise them in accordance with applicable law.
Residents of certain U.S. states, including California, may have rights under state privacy laws such as the California Consumer Privacy Act (CCPA) and similar legislation in other states. These rights may include the right to request access to personal information collected about you, the right to request deletion of personal information, and the right to request correction of inaccurate personal information.
Eligible users may also have the right to opt out of certain uses of personal information, such as the sale or sharing of personal information for targeted advertising. As described in this Privacy Policy, Kinovate does not sell personal information and does not share personal information for cross-context behavioral advertising.
Adult Users may exercise applicable state privacy rights by contacting Kinovate at support@kinovateinc.com. Kinovate will verify requests as required by law and respond within the timeframes mandated by applicable statutes. Parents and legal guardians may exercise these rights on behalf of their Children.
Users located in the European Economic Area or the United Kingdom have certain rights under the General Data Protection Regulation (GDPR). These rights may include the right to access personal data, the right to request rectification or erasure, the right to restrict or object to certain processing, and the right to data portability.
Where processing is based on consent, users have the right to withdraw their consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Parents or legal guardians may exercise these rights on behalf of their Children.
Requests to exercise GDPR rights may be submitted by contacting Kinovate at support@kinovateinc.com. Users also have the right to lodge a complaint with their local data protection authority.
Kinovate may require reasonable information to verify your identity before responding to a request. Requests will be handled in accordance with applicable law and may be limited or denied where permitted by law, such as to protect the rights of others or comply with legal obligations.
Kinovate will not discriminate against users for exercising their privacy rights.
Adult Users may review, update, or delete certain account information through account settings within the Services. Parental controls allow Adult Users to manage information associated with Child Accounts, subject to applicable legal requirements.
Where permitted by applicable U.S. state privacy laws, you may designate an authorized agent to submit privacy rights requests on your behalf. Kinovate may require proof that the authorized agent has been validly authorized to act on your behalf and may also require you to verify your identity directly before processing the request.
Parents or legal guardians may act as authorized agents for their Children.
Where required by applicable law, eligible users have the right to appeal Kinovate’s decision regarding a privacy rights request. Appeals may be submitted by contacting Kinovate at support@kinovateinc.com within a reasonable period after receiving the decision. Kinovate will review and respond to appeals in accordance with applicable legal requirements.
The Services are designed for use by Children only through accounts created and managed by an Adult User. Kinovate does not knowingly permit Children to use the Services independently or without appropriate parental involvement.
Kinovate collects, uses, and discloses Children’s personal information only as permitted by applicable law and as described in this Privacy Policy. Personal information collected from Children is used solely to operate the Services, enable age-appropriate features, support parental controls, ensure safety, and comply with legal obligations. Kinovate does not use Children’s personal information for targeted advertising or marketing purposes.
Parents and legal guardians are encouraged to actively monitor and supervise their Children’s use of the Services and to contact Kinovate with any questions or concerns regarding children’s privacy practices.
Kinovate may update this Privacy Policy from time to time to reflect changes in the Services, legal requirements, or data practices. When material changes are made, Kinovate will provide notice through the Services, by email, or by other reasonable means.
The effective date of the most recent version of this Privacy Policy will be indicated at the top of the policy. Continued use of the Services after the effective date constitutes acceptance of the updated Privacy Policy, where permitted by applicable law.
If you have questions, concerns, or requests regarding this Privacy Policy, your personal information, or Kinovate’s privacy practices, you may contact us at:
Parents or legal guardians with questions specifically related to children’s privacy may also use this contact information to reach us directly.