Privacy Policy

Last Updated: June 27, 2026

Effective June 27, 2026, this Privacy Policy has been updated to reflect Kubrio's studio model (multiple apps), enhanced children's privacy protections in compliance with the updated COPPA rule, separate consent requirements for AI processing, and improved transparency about third-party service providers.

Key Points Summary

• Children's Privacy Protection: Kubrio is COPPA-compliant and collects only essential information from children: avatar, username, and birthdate. Parents create all accounts and manage access for their children. We obtain verifiable parental consent through credit card verification before children can access the platform and before collecting any personal information from children under 13.
• We Don't Sell or Rent Your Data: We do not and will not sell or rent your or your child's personal information to anyone. Your data is used only to provide and improve our educational services.
• AI Safety & Parental Control: All interactions between children are monitored using AI safety guardrails to ensure a safe learning environment. Parents are notified if their child attempts any inappropriate behavior. Parents have full access to review and modify their child's information through the Parent Portal, and can request deletion of their child's data by contacting customer service.

Guiding Principles

Kubrio Inc ("we," "us," "our," or "Kubrio") knows that you care about how your Personal Information is used and shared, and we take your privacy seriously. We are committed to protecting the privacy of children who use our site and applications, and have drafted this policy in accordance with the U.S. Children's Online Privacy Protection Act ("COPPA"). For more information about COPPA and general tips about protecting children's online privacy, please visit OnGuard Online. Please read the following to learn more about how we use your Personal Information. By visiting, accessing or using the kubrio.com website, and any other linked pages, features, content, or application services (including mobile applications) offered by Kubrio in connection therewith (collectively, "Kubrio"), or using any of our services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. Kubrio is a learning platform for kids ages 6-13, where children learn using AI and connect with other kids in a safe, monitored environment. What Does This Privacy Policy Cover? This Privacy Policy covers Kubrio's treatment of personally identifiable information ("Personal Information") that Kubrio gathers when you access Kubrio and when you use Kubrio's services. This policy does not apply to the practices of companies that Kubrio does not own or control (including any third-party products or services used for logging into Kubrio or that are integrated with Kubrio), or to individuals that Kubrio does not employ or manage. Kubrio may contain links to other sites. Kubrio is not responsible for the privacy policies and/or practices on other sites. When linking to another site a user should read the privacy policy stated on that site. What Personal Information Does Kubrio Collect? The information we gather from users enables us to provide, personalize and improve our services, and allows our users to set up a user account and profile that can be used to personalize their learning experience on Kubrio and interact with other children in a safe, monitored environment. In connection with Kubrio, we request and display some Personal Information to other users and visitors of Kubrio, which allows users to identify one another. We collect the following types of information from our users: Personal Information You Provide To Us: During the account registration process, we receive and store the following information:

• full name of the parent or guardian

• first name of the child

• parent's email address

• parent's phone number (for account verification)

• parent current city

• a password for the parental account

• the child's age (to verify age eligibility)

• the child's interests and learning preferences (selected during onboarding) In addition, children choose an "avatar" and username ("nickname") which will represent them on the service. Parents create all accounts and manage access for their children across various platforms. Access to Kubrio is only available through paid accounts, which means all parents are verified based on their credit card information. We encourage children to use their real names. Consistent with the requirements of COPPA, we collect a parent or guardian email address before we collect any Personal Information from a child. We collect credit card information and ID for verification purposes but do not store that information on our servers. We've partnered with Stripe to help make verification and payments easier and safer. Stripe meets and exceeds the most stringent industry standards for security. You can learn more about the technical details of Stripe's secure infrastructure here. Kubrio does not store full credit card numbers, but instead, only the last four digits and expiration date. Kubrio does not intentionally collect any Personal Information from children other than the information set out above. However, as part of the functionality of our service, we allow child accounts to upload and share content to the platform, including their work, photos, videos, and comments. Children share and upload work to receive feedback from AI and to interact with other children in the Kubrio community. This content is only shared within the Kubrio community and is not made public unless separate parental consent is obtained. We take measures to prevent children from communicating Personal Information through these features, but we cannot guarantee the effectiveness of these measures. If you use these features to disclose personally identifiable information, you should be aware that such information could be read, collected, or used by other users and/or third parties. You agree not to provide any personally identifiable information through these features, and we are not responsible for any personally identifiable information that you provide using these features. You can choose not to provide us with certain information, but then you may not be able to create an account or take advantage of many of Kubrio's special features. The Personal Information you provide is used for such purposes as obtaining parental consent as set forth above, providing parents with notice of our privacy practices, answering questions, improving the content of Kubrio, responding to your requests for certain information, products and services, attribution for content you submit, customizing the content you see, allowing you to communicate with other users, and communicating with you about Kubrio's products and services and new features. Personal Information Collected Automatically: We receive and store certain types of information whenever you interact with Kubrio or use our services. Kubrio automatically receives and records information on our server logs from your browser including your IP address, cookie information, browser information, operating system, timezone, device ID, the pages you request, and the actions and path you take on Kubrio. Generally, our service automatically collects usage information, such as the numbers and frequency of visitors to Kubrio and how they use its various components. Kubrio only uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how users use parts of Kubrio or services so that we can make Kubrio appealing to as many users as possible, and improve those services. As part of this use of information, we may provide aggregate information to our partners about how our users, collectively, use Kubrio or services. We share this type of statistical data so that our partners also understand how people use Kubrio or services, so that they, too, may provide you with an optimal online experience. Again, Kubrio never discloses aggregate information to a partner in a manner that would identify you personally. We may receive a confirmation when you open an email from Kubrio if your computer or device supports this type of functionality. Kubrio uses this confirmation to help us make emails more interesting and helpful and to improve Kubrio and our services. You can opt out of these communications by contacting us at privacy [at] kubrio. dot com. More About Cookies: Cookies are alphanumeric identifiers that we transfer to your computer's (or other device's) persistent storage medium (e.g., hard drive) through your browser to enable our systems to recognize your browser and tell us how and when pages in our site are visited and by how many people. We use cookies to enhance visitors' experiences, to learn more about their use of Kubrio and to improve quality. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave the cookies activated, however, because cookies enable you to take advantage of some of Kubrio's most attractive features. Data We Collect by App: Kubrio is a studio of learning apps. In addition to the general data described above, each app may collect additional data as follows:

• Kubrio Discovery: Exploration paths, quiz responses, learning progress, and content interactions. AI is used to power personalized recommendations.

• Kubrio Sketchling: Drawings, animations created, and creative assets uploaded by children. AI transforms children's drawings into animations — this requires separate parental consent for AI processing.

• Kubrio Walkie Talkie: Voice messages (processed in real-time, not stored long-term), text messages, and communication metadata. AI is used for real-time safety monitoring of messages.

• Claire (your family's AI coach): Parent interactions, child progress summaries, and AI coaching conversations. AI powers personalized coaching and learning insights. AI Processing and Consent: Some Kubrio apps use artificial intelligence to deliver core features. AI processing of your child's content requires your separate, explicit consent, collected during onboarding. Your child's content is sent to our AI service providers solely to deliver these features. Our providers do not retain or use this content for any other purpose. Without this consent, AI-powered features will not be available for your child. Separately, with your additional optional consent, Kubrio may use anonymized patterns from your child's interactions to improve our AI features for all families. Individual content (drawings, messages, etc.) is never retained — only aggregate patterns. This consent defaults to off and can be changed at any time in the Parent Portal. Will Kubrio Share Any Of The Personal Information It Receives? Personal Information about our users is an integral part of our business. We neither rent nor sell your Personal Information to anyone. To be absolutely clear, we do not and will not sell your, or your child's data. With Respect To A Child's Personal Information: Kubrio will not send Personal Information about a child to other companies or people, except when: we have a parent's consent to share the information or we are required to do so to comply with the law, including for example, to comply with a court order or subpoena; to enforce our Terms of Service, or site rules; or to protect the safety and security of our users and site. If Kubrio, or substantially all of its assets were acquired, or in the unlikely event that Kubrio goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. As set forth below, you acknowledge that such transfers may occur, and that any acquirer of Kubrio may continue to use your Personal Information as set forth in this policy. User profile information including users' nickname and avatar, email address, and other information you enter ("User Submissions"), may be displayed to other users to facilitate user interaction within Kubrio. With respect to Personal Information other than a child's Personal Information: WE SHARE SUCH PERSONAL INFORMATION ONLY AS DESCRIBED BELOW. Affiliated Businesses We Do Not Control: We anticipate that we may become affiliated with a variety of businesses and work closely with them. In certain situations, these businesses may sell items to you through Kubrio. In other situations, Kubrio may provide services, or sell products jointly with affiliated businesses. You can easily recognize when an affiliated business is associated with your transaction, and we will share your Personal Information that is related to such transactions with that affiliated business. Service Providers We engage third party companies and individuals to perform services on our behalf (e.g., software maintenance services, email service providers, delivery services, database management, web analytics, payment processing and other services). These third parties have access to your information so that they may perform these tasks on our behalf and they are prohibited by us from using or disclosing your information for any purpose other than to provide this assistance, except to the extent required by law. We may permit our service providers to use aggregate information which does not identify you or de-identified data for other purposes. Consent For Internal Media Usage Kubrio is a learning platform where children learn using AI and connect with other kids. Children share and upload their work to receive feedback from AI and to collaborate with other children in the community. This content is only shared within the Kubrio community (accessible to the Kubrio team and students and parents in the Kubrio Community) and is not made public. For the safety of every student, only the Kubrio team and the students and parents in the Kubrio Community will have access to this content. Consent For External Media Usage We celebrate the fantastic work of Kubrio students, and with separate parental consent, we may share their work publicly on social media and other platforms. These public media spaces include our Blog, our YouTube channel, and other innovative platforms. We will only share children's work publicly if parents provide explicit consent and the content does not contain Personal Information. Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that are transferred. Moreover, if Kubrio, or substantially all of its assets were acquired, or in the unlikely event that Kubrio goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Kubrio or its assets may continue to use your Personal Information as set forth in this policy. Protection of Kubrio and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the any applicable law, regulation or other legal requirement; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Kubrio, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information. Is Personal Information About Me Secure? Your child's Kubrio account is protected by a password for your privacy and security. You need to ensure that there is no unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer (or other device) and browser by signing off after you have finished accessing your account. Kubrio endeavors to protect user information to ensure that user account information is kept private, however, Kubrio cannot guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Kubrio contains links to other sites. Kubrio is not responsible for the privacy policies and/or practices on other sites. When linking to another site you should read the privacy policy stated on that site. This Privacy Policy only governs information collected on Kubrio. Please be aware that whenever you voluntarily post information to public areas on Kubrio or any other public forums, such information can be accessed by the public. Security Measures We Employ:

• Encryption of data in transit and at rest

• Secure authentication and password protection

• Regular security audits and assessments

• Employee training on data security and COPPA compliance

• Limited access to personal information on a need-to-know basis

• Monitoring for unauthorized access or suspicious activity Data Breach Notification In the unlikely event of a data breach that affects your or your child's personal information, we are committed to transparency and prompt notification: What We Will Do:

• Investigate the breach immediately to determine its scope and impact

• Take steps to contain the breach and prevent further unauthorized access

• Notify affected parents by email within 72 hours of discovering the breach

• Provide details about what information was compromised

• Explain what steps we are taking to address the breach

• Offer guidance on steps you can take to protect your family

• Report the breach to appropriate authorities as required by law What Information We Will Provide:

• The date and nature of the breach

• The types of personal information that were compromised

• Whether the breach affected your child's account

• What we are doing to investigate and resolve the issue

• Resources and support available to you

• Contact information for questions and assistance Your Response Options:

• We will provide guidance on protective measures you can take

• We will offer support in monitoring for any misuse of information

• You may request immediate account closure and data deletion if desired

• We will work with you to restore security and confidence in our platform We take data security seriously and work continuously to protect your family's information. What Personal Information Can I Access? Kubrio allows you to access the following information about you for the purpose of viewing, and in certain situations, updating that information. This list will change as Kubrio changes.

• Real (full) name of parent and child

• Account and user profile information

• Parent email address

• Username and password

• User preferences

• Billing preferences Parents may review information relating to their child's account at any time by logging on to the Parent Portal section of the website. Expanded Parental Rights: As a parent, you have comprehensive rights to access and control your child's information: Right to Review:

• All personal information collected from your child

• All AI interactions and conversations your child has had

• All content created by your child

• Learning progress and activity history

• Any comments or messages sent or received by your child Right to Download:

• Request a complete export of your child's data in a portable format

• Download all of your child's work, projects, and creations

• Export learning progress and achievement records Right to Modify:

• Update your child's profile information

• Change usernames or avatars

• Modify privacy settings and preferences Right to Delete:

• Request deletion of your child's personal information

• Request deletion of specific content or projects

• Request deletion of AI interaction history

• Close your child's profile entirely Right to Control:

• Opt out of AI training using your child's content

• Opt out of internal content sharing

• Refuse permission for public sharing

• Control which features your child can access How to Exercise These Rights: A parent can contact our customer service department to access, change, or request deletion of Personal Information by contacting us at privacy [at] kubrio. dot com. We will respond to your request within 30 days. Please note that Personal Information about a child may remain in backup storage for up to 90 days after a request for deletion of that child's data. This may be the case even though no information about that account remains in our active user databases. Some information may be retained as required for legal compliance, safety, and fraud prevention purposes as described in our Data Retention Policy. When Does Kubrio Obtain Parental Consent? Kubrio collects multiple forms of parental consent to comply with COPPA: CONSENT 1: GENERAL SERVICE (BY PURCHASE) In order to access Kubrio, a parent or guardian must purchase a subscription by providing their credit card information. Access to Kubrio is only available through paid accounts, which means all parents are verified based on their credit card information. In purchasing access, the parent or guardian grants us permission to collect necessary Personal Information from their child. This credit card verification is in compliance with COPPA and ensures an adult is the one signing a child up for Kubrio. CONSENT 2: AI PROCESSING (SEPARATE, REQUIRED FOR AI FEATURES) During onboarding, parents are presented with a separate consent screen for AI processing of their child's content. Some Kubrio apps use AI to deliver features (e.g., Animation transforms drawings into animations, Claire provides personalized coaching). Your child's content is sent to our AI service providers solely to deliver these features. This consent is separate from the general account creation consent and can be granted or withdrawn at any time in the Parent Portal. Without this consent, AI-powered features will not be available. CONSENT 3: AI MODEL IMPROVEMENT (SEPARATE, OPTIONAL) During onboarding, parents may optionally consent to anonymized usage patterns being used to improve Kubrio's AI features for all families. This consent defaults to off, is entirely optional, and does not affect your child's experience. No individual content (drawings, messages, etc.) is retained — only aggregate statistical patterns. This consent can be changed at any time in the Parent Portal. CONTENT GENERATED BY A CHILD Certain activities on our sites and applications allow children to create, upload, and share content (like their work, photos, videos and comments) within Kubrio. Children share and upload work to receive feedback from AI and to interact with other children. By registering and creating an account for your child on Kubrio, you grant us permission to share your child's content within the Kubrio community. Any public sharing of your child's content on our social media channels requires separate explicit parental consent and will only occur if the content does not contain Personal Information. INTERACTIONS BETWEEN CHILDREN Kubrio allows children to interact and communicate with other children through monitored messaging and collaboration features. All interactions are monitored using AI safety guardrails to ensure child safety. Our AI systems analyze all messages to detect and prevent inappropriate content or behavior. Real-Time Safety Monitoring: We monitor for:

• Bullying, harassment, or intimidation

• Improper language for children

• Inappropriate requests or behavior

• Attempts to share personal information Immediate Action: When our systems detect any of the above:

• The request or message is blocked immediately

• Parents are notified in real-time via email

• The incident is logged for review

• Repeat violations may result in account suspension These systems employ multiple layers of protection including automated filters, AI monitoring, and content review to prevent the communication of Personal Information and age-inappropriate content. We strongly encourage children who use these interactive features never to provide Personal Information about themselves or any third party, and certainly never to attempt to circumvent our safety measures. We also recommend that parents carefully supervise their children when they participate in online activities. When Will Kubrio Email Me? We may use your contact information to send emails to you about Kubrio and other related topics that may be of interest to users of Kubrio. You can opt out of these communications by contacting us at privacy [at] kubrio. dot com. As part of Kubrio's services, you will receive email and other communication relating to your child's User Submissions. You acknowledge and agree that by posting such User Submissions, Kubrio may send you email and other communication that it determines in its sole discretion to be related to your User Submissions. Please note that if you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of Kubrio, and you are responsible for reviewing such legal notices for changes. Changes To This Privacy Policy Kubrio may make changes to this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on Kubrio or sending you an email. Users are bound by any changes to the Privacy Policy when he or she uses Kubrio after such changes have been first posted. If we make material changes to how we collect, use, or disclose children's personal information, we will notify parents by email and obtain renewed consent where required by COPPA. In such cases, you will be presented with updated consent screens upon your next login. California Privacy Rights If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA): Your California Rights:

• Right to Know: You have the right to know what personal information we collect, use, disclose, and sell about you and your child

• Right to Delete: You have the right to request deletion of personal information we have collected about you or your child, subject to certain exceptions

• Right to Opt-Out: You have the right to opt out of the "sale" or "sharing" of personal information. Note: We do NOT sell or share personal information for monetary consideration. However, using your child's content to train AI models may be considered "sharing" under California law. You can opt out of AI training by contacting us.

• Right to Correct: You have the right to request correction of inaccurate personal information

• Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information (such as your child's biometric data - which we do not collect)

• Right to Non-Discrimination: You have the right to not receive discriminatory treatment for exercising your privacy rights Information We Collect (California Summary):

• Identifiers: Parent and child names, email addresses (parent only), usernames, avatars

• Internet Activity: How you and your child use our platform, pages visited, features used

• Geolocation Data: General location (city/state) for parent account

• Education Information: Child's learning progress, work created, interactions with educational content

• Commercial Information: Payment and transaction history How We Use Information:

• To provide educational services

• To improve our platform and AI models

• To communicate with parents

• To ensure child safety and COPPA compliance

• To process payments Who We Share Information With:

• Service providers (hosting, analytics, payment processing, AI services) as described in the "Third-Party Services" section

• We do NOT sell personal information to third parties for monetary consideration Exercise Your California Rights: Contact us at privacy [at] kubrio. dot com. We will respond to verifiable requests within 45 days. You may designate an authorized agent to make requests on your behalf by providing written authorization. California Minors' Rights to Content Removal: If you are a California resident under 18, you may request removal of content or information you posted on Kubrio. To request removal, contact us at privacy [at] kubrio. dot com. Please note that removal does not ensure complete deletion from backup systems, and we may retain the information as required by law or as described in our data retention policies. Questions Or Concerns If you have any questions or concerns regarding privacy on Kubrio, please contact us at privacy [at] kubrio. dot com For information about your rights and responsibilities as a user, please also review our Terms of Service at kubrio.com/terms Additional Resources for Parents:

• Federal Trade Commission (FTC) - Protecting Kids Online

• Common Sense Media - Protecting Kids Online

• National Center for Missing & Exploited Children - NetSmartz