Privacy Policy

Effective Date: Aug 20th, 2025

Aleph Lab, Inc. ("Aleph Lab," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you or your child use our services, including our websites, applications, and AI-powered educational experiences inside games such as Minecraft or Roblox (collectively, the "Service").

By creating an account or permitting your child to use the Service, you agree to this Privacy Policy.

1. Information We Collect

We may collect the following categories of information:

Parent/Guardian Information

• Name
• Email address
• Payment information (processed securely through third-party payment providers)

Child Information

• First name
• Date of birth (month and year only)
• Grade level

Gameplay & Interaction Data

• Speech transcripts and audio recordings of interactions with Aleph Lab’s AI agents
• Gameplay logs and session data

Technical Information

• Device type and operating system
• IP address and general location data
• Cookies and analytics data

In the future, we may also collect video or additional recordings to enhance language practice features.

2. How We Use Information

We use the information we collect to:

• Provide and operate the Service
• Personalize and improve the learning experience
• Improve our AI models through anonymized and de-identified data
• Conduct research and analytics on learning outcomes
• Process payments and manage subscriptions
• Communicate with parents and guardians
• Comply with legal obligations

We may also use aggregated and anonymized data for marketing and educational research purposes.

3. Legal Basis for Processing (GDPR / Global)

Where required by law (e.g., GDPR in the European Union, GDPR-K in South Korea), we process personal information based on the following legal grounds:

• Performance of a contract (providing the Service)
• Compliance with legal obligations
• Consent (parental consent for children under 13, cookie consent where required)
• Legitimate interests (improving the Service and ensuring safety)

4. Parental Consent & Children’s Privacy

• In compliance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under 13 without verifiable parental consent.
• Aleph Lab uses payment-based verification: when a parent provides payment information (e.g., through Stripe or LemonSqueezy), this is treated as verifiable parental consent.
• Parents may review, delete, or revoke consent for their child’s information at any time by contacting us at hannim@alephlab.ai.

5. Data Sharing & Disclosure

We do not sell personal data. We may share information with:

• Payment processors (Stripe, LemonSqueezy) to process subscription payments
• Hosting providers (Google Cloud Platform, Amazon Web Services) to store and operate the Service
• Analytics providers (internal and third-party tools) to understand Service usage

We do not share personal information with advertisers or unrelated third parties.

6. Data Retention

• Gameplay transcripts and audio recordings: retained for up to 24 months, anonymized for research and AI training.
• Billing and payment data: retained for 7 years as required for tax, fraud prevention, and compliance purposes.
• Account basics (parent email, child’s name/grade): retained until account closure or upon verified deletion request.

7. Cookies & Tracking Technologies

We use cookies and similar technologies to:

• Improve user experience
• Conduct analytics and measure performance

We do not use cookies for third-party advertising. Users in certain regions (e.g., EU) may be presented with additional cookie consent mechanisms.

8. Security

We implement industry-standard measures to safeguard your information, including encryption, secure cloud hosting, and access controls.

However, no system is 100% secure, and we cannot guarantee absolute security of your information.

9. International Data Transfers

As we operate globally, personal information may be transferred to and processed in the United States. By using our Service, you acknowledge that your information may be subject to U.S. laws and jurisdictions.

10. Your Rights

Depending on your location, you may have the following rights under GDPR, GDPR-K, and other applicable laws:

• Access your or your child’s information
• Correct inaccurate information
• Request deletion of information
• Restrict or object to processing
• Request data portability

Parents always retain the right to review, delete, or revoke consent for their child’s information under COPPA.

To exercise these rights, please contact us at hannim@alephlab.ai.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Parents and guardians will be notified by email of significant changes, and updates will be posted on our website. Continued use of the Service constitutes acceptance of the updated policy.

12. Contact Information

For questions, concerns, or privacy requests, please contact us at:

hannim@alephlab.ai

Aleph Lab, Inc.