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Privacy Policy

for our app, Clevr by Cynder AI

Commitment to Protecting Children’s Wellbeing

 

Protecting the privacy and safety of children who use our application Clevr by Cynder.ai is our top priority.

We believe that every child deserves a learning experience that is private,  which is supported by ensuring the data we collect is essential data only, protected with most modern encryption algorithms, and is transparent to parents.

We believe that every child deserves a learning experience that is free from risks, which is supported by absolute parental control and our innovative protective processing.

We believe every child deserves a learning experience that is smart and capable, which is supported by our drive to harness cutting-edge technology to support your child.

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The long-term well being of children is paramount, and we are fully committed to ensuring that our app is actively working towards their long-term wellbeing.

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Effective Date: May 6, 2025

Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how Cynder Innovations Ltd collects, uses, shares, and processes your personal data through the Clevr by Cynder.ai app. It details your privacy rights and how you can get in touch with us regarding your data.

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Cynder Innovations Ltd, Inc. (“Cynder Innovations Ltd,” “we,” “us,” or “our”) is a company registered at PO Box 16053 RPO Lower Mt Royal, Calgary, AB Canada, T2T5H7. For the purposes of the General Data Protection Regulation (“GDPR”), the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Children’s Online Privacy Protection Act (“COPPA”), and any other applicable privacy or data protection laws (collectively, “Data Protection Laws”), we are the Data Controller of your and your children's personal data.

 

By using or accessing Clevr by Cynder.ai, you agree to the contents of this Privacy Policy and agree to abide by the Terms and Conditions.

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We may update our Privacy Policy to reflect changes to our information practices. We will show that these terms were last revised at the bottom of the Privacy Policy.

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1. Information We Collect

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Information You Provide

Upon initial use of the Clevr by Cynder.ai application, users are required to complete an onboarding process. As part of this process, we request that a parent or legal guardian self-identify and confirm their authority to act on behalf of any child user associated with the account. We obtain verifiable parental consent for the collection, use, and processing of the child’s personal information in accordance with applicable laws, including the Children’s Online Privacy Protection Act (COPPA), Personal Information Protection and Electronic Documents Act (PIPEDA) and other relevant privacy regulations.

During this onboarding process, we may collect the following information from the parent or legal guardian:

Relating to the parent or legal guardian:

  • a name or nickname for yourself, the guardian

  • location information e.g. postal code or geolocation (optional)

  • email for login, authentication, and verification purposes


​Relating to each child:

  • a first name or nickname 

  • approximate age range (optional)

  • information about the learner’s disability, neurodivergence, or learning needs (optional)

  • preferences selected through interactive settings regarding the type of learning experience you want your child to have (optional)

  • topics or content areas you indicate should be avoided (optional)

 

While using the app, for yourself as parent or guardian, you can choose to provide:

  • an avatar or picture for yourself

  • location information e.g. postal code or geolocation (optional)

  • optional information about your own disability or interaction preferences (optional)

  • chat responses or prompts with in the form of text input (optional)

  • chat responses or prompts with in the form of audio input (optional)

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While using the app, you or your child can choose to provide:

  • an avatar or picture of themselves (optional) 

  • chat responses or prompts with in the form of text input (optional, but this is the primary functionality of our app) 

  • chat responses or prompts with in the form of audio input (optional)

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This information is either used for 1) authentication,  2) verification of identity of the parent, or 3) personalizing the learner experience, particularly during interactive chats with the AI. This information is only collected with permission from the parent.

 

You you are not required to provide real names or accurate data, beyond the parent verification and authentication. For example, the learner’s nickname may be used in personalized greetings from the AI, but it does not need to reflect the child’s actual name.
 

We strongly encourage parents and guardians to supervise and manage the information shared in the app, especially when providing any images or custom preferences for children. Avatar images, chats, and other personalization details are stored securely and are never used for advertising or external profiling.​

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Please note we store this data in Canada.

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Activity Data

When you use Clevr, we collect data about how both parents and learners (children) interact with Clevr. This includes

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  • educational activities viewed, accessed, or engaged with by the parent or child

  • features and tools used by the parent or child

  • time spent on specific activities, content, or parts of the app by the parent or child

  • navigation behavior such as clicks, taps, and scrolling by the parent or child

  • device type, operating system, and browser (where applicable) by the parent or child 

  • IP address and geolocation of the user

  • text- or voice-based questions and responses submitted in chats with the AI by the parent or child​

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This data is collected to improve the functionality, accessibility, and security of the app, personalize learning content, interactions, and recommendations, monitor usage for safety, compliance, and service reliability, detect, investigate, and prevent technical issues, misuse, or fraud, and analyze patterns and behaviors to continuously enhance our services.

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Activity data, including chat interactions, may be linked to your or your child’s profile or device for the purpose of improving personalization. However, this data is never used for advertising or profiling for marketing purposes.

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We only share this data with trusted third-party service providers—such as analytics and AI infrastructure partners—who support the secure operation, development, and improvement of Clevr. Find more about these trusted service providers under "Data Processing by Third Party Providers" below.

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Product Research and Development

If you choose to provide an email address for subscription during registration or in the app, we may contact you about participating in optional product research activities. These may include surveys, interviews, or user feedback sessions.

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If you agree to participate, we may collect your responses and feedback, audio, video, or screen recordings of research sessions, transcripts or notes from interviews, and any additional information you voluntarily provide during research.

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This data is used only to test, improve, and develop our services. We retain this information securely for up to two years and never use it for advertising or sales purposes.

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You may contact us at privacy@cynder.ai to request more information about research activities you've volunteered for, opt out of being contacted for future research, or request a copy or deletion of any research data you’ve provided.

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2. Use of Data by Clevr​

Clevr by Cynder.ai collects and processes user data to ensure a personalized learning experience and personalized protective parental experience. We process personal data such as text or voice-based questions and reactions in a chat format with the AI, and personal information on the child or parent. This allows us to provide tailored educational content and improve the learning experience. However, we do not use or store personal data for any purposes beyond the functionality of the app and improving educational and parental experiences.

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We also use data to help monitor for safety. If a user attempts to access content that may not be suitable for their age or learning stage, we will take appropriate steps to prevent such access and guide the user toward appropriate content.

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Use of Data for AI Model Training

At present, Clevr by Cynder.ai does not use children’s personal data to train AI models. However, if parents are interested, we may consider such use in the future to improve our services, enhance learning outcomes, or develop new educational tools. If we decide to pursue this, we will:

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  • Obtain separate, verifiable parental consent prior to using any child’s data for model training purposes;

  • Clearly explain what data would be used, how it would be processed, and the intended purpose;

  • Provide an opportunity for parents to opt in or decline this use entirely, without affecting their child’s access to the core app features;

  • Ensure all data used is anonymized, encrypted, and handled in compliance with applicable laws, including COPPA, GDPR, and PIPEDA.

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3. Privacy and Data Protection Compliance

Cynder Innovations Ltd is committed to protecting the privacy and safety of children using Clevr by Cynder.ai. We comply with the applicable laws and regulations related to the collection, use, and processing of personal data of children, including:

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  • The Children’s Online Privacy Protection Act (COPPA) in the United States: COPPA requires that online services directed to children under 13 years of age obtain verifiable parental consent before collecting personal data from children. We collect personal data on children under the age of 13, but only with verifiable parental consent. We take children’s privacy seriously and provide parents with full control over their child’s information, including access and deletion rights. Parents or guardians can view or delete the information collected about their children by contacting us at privacy@cynder.ai.

  • General Data Protection Regulation (GDPR) (EU): We comply with the GDPR’s rules on the protection of personal data. Children in the EU may use Clevr by Cynder.ai, but we rely on parental consent when collecting personal data for children under 16 years old.

  • Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada): We comply with the Canadian privacy laws related to data protection.

  • Google’s Families Policy: Clevr by Cynder.ai fully complies with Google’s Families Policy by obtaining verifiable parental consent before collecting any personal data from children under 13 and ensuring that all data collection practices are transparent, secure, and in line with applicable privacy laws.

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Data Processing by Third Party Providers

Cynder Innovations Ltd does not share your personal data with any third parties for advertising purposes, and Clevr by Cynder.ai does not display advertising of any kind.

Clevr by Cynder.ai uses third-party services to back up child and parent progress, support speech recognition features, monitor app performance, and provide learning experiences.

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We use third-party services, such as the below, to power the functionality of Clevr by Cynder.ai

  • Analytics providers (Google Analytics)

  • Large Language model providers (e.g., OpenAI, Anthropic )

  • Hosting (e.g AWS)

  • Voice-to-text providers

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We provide these providers with the minimum amount of data they need to support our providing of educational experiences. These providers process data according to their own privacy policies. We encourage you to review their privacy policies to understand how they handle your data.

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You can find out about the third party provider privacy policies here:

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We do not store or use your personal data for any purposes beyond improving educational experiences and enhancing the functionality of the app.

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We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through Clevr by Cynder.ai or using the Cynder Innovations Ltd name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents, or government agencies.

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If the ownership of all or substantially all of Cynder Innovations Ltd’s business, or individual business units or assets owned by Cynder Innovations Ltd that are related to Clevr by Cynder.ai, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.

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Data Retention

We retain personal data only for as long as necessary to provide our services, comply with legal obligations, and support the learning experience within Clevr by Cynder.ai.

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For children’s accounts, we store personal data only while the account remains active and for a limited period thereafter (typically up to 12 months) to allow for account reactivation or restoration at a parent’s request. After this period, personal data is either securely deleted or anonymized in a way that it can no longer be linked to an individual child.

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All personal data is stored and processed using industry-standard encryption both in transit and at rest. Access to personal data is strictly limited to authorized personnel under confidentiality agreements, and we employ safeguards to prevent unauthorized access or disclosure.

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Parents or legal guardians may request deletion of their child’s data at any time by contacting us at privacy@cynder.ai.

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4. AI Compliance

Clevr by Cynder.ai uses AI to enhance the learning experience in the following ways:

  • Engaging with children and parents through interactive chat to encourage curiosity and learning.

  • Responding to questions to provide educational support.

  • Suggesting learning topics based on user interactions to help tailor the educational experience.

  • Customizing experiences based on input to ensure relevant and meaningful learning paths.

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We do not use AI for the following:

  • User profiling: We do not engage in profiling or categorizing users based on their personal characteristics or behaviour.

  • Deceptive representation: We do not represent AI as a human. The experience is intentionally designed to be transparent, and we do not mislead users into believing they are interacting with a real person.

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We are committed to transparency and ensuring that our use of AI aligns with emerging safety and compliance standards, such as ethical AI guidelines, COPPA, and GDPR. Our goal is to provide a safe, responsible, and enriching experience for children while maintaining strict data privacy and security protocols.

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5. Advertising Compliance

Clevr by Cynder.ai does not serve personalized or behavioral advertisements to children or parents. We do not permit any third-party advertising or behavioral profiling within the app. All content is educational and free from targeted ads, ensuring a safe and distraction-free environment for children.

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6. Personal and Parental Data Rights and Controls

We don't require you or your child to disclose more information than is reasonably necessary to participate in personalized education features. 

 

You, as a parent, have the following rights in relation to the personal data we hold about you and your children, unless provided otherwise by local law:

  • To request access to, or erasure of, the personal data we hold about you and from where we collect it.

  • To request us to restrict the processing of the personal data we hold about you.

  • To object to us processing personal data relating to you.

  • Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.

  • To export the personal data you have provided to Cynder Innovations Ltd in a format that can be transferred electronically to a third party.

  • To delete your account with Cynder Innovations Ltd by following the instructions available through Clevr by Cynder.ai.

  • To understand how we process your personal information and how it may be shared.

  • To opt out of having your personal information shared with certain third parties. (The Clevr by Cynder.ai app does not share any data with third parties in this way.)​

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To make such a request, please send an email to privacy@cynder.ai.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

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People in the EU have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

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If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the Clevr by Cynder.ai service you have requested. Where this is the case, we will inform you of specific details in response to your request.

 

7. Contact Information

Cynder Innovations Ltd’s headquarters are located within the Canada at:

Cynder Innovations Ltd, Inc.

PO Box 16053 RPO Lower Mt Royal

Calgary, AB Canada

T2T 5H7

For data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact our Data Protection Officer at privacy@cynder.ai

For support inquiries, please go to https://cynder.ai/contact

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Effective Date: May 6, 2025

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