Privacy Policy

Privacy Policy for Emma AI Tutor Intallaga Tech Pty Ltd Effective Date: December 1, 2025 Last Updated: November 22, 2025 1. Introduction Intallaga Tech Pty Ltd("Intallaga," "we," "us," or "our") operates the Emma AI tutoring application and service (the "Service"). This Privacy Policy explains how we collect, use, disclose, and protect information from users, including children aged 6-16. By using our Service, you agree to this Privacy Policy. If you are aged 6-16, your parent or guardian must consent on your behalf. Contact: hi@intallaga.com | Suite 55, Marnirni-apinthi Building, Lot Fourteen, North Terrace, Adelaide, SA 5000 2. Information We Collect 2.1 Information You Provide - Account details (such as name, email, age/date of birth) - Educational information (such as grade level, subjects, learning preferences) -Homework inputs or questions you submit - Payment information (processed by third-party providers) - Communications with support 2.2 Automatically Collected Information - Device information (model, operating system, unique identifiers) - Usage data (features used, session duration, interaction patterns) - Performance data (crashes, errors, response times) - Location data with your permission. 2.3 Content Generated Through Service Use - Voice recordings (processed and deleted after transcription) - Chat conversations with AI tutor - Camera/screen captures (when using homework help features) - Educational progress and assessment data - AI-generated responses and recommendations 3. How We Use Information We use collected information to: - Provide, maintain, and improve the Service - Tailor learning experiences and AI responses - Process payments and manage subscriptions - Communicate about account, updates, and support - Ensure safety and prevent misuse - Comply with legal obligations - Develop new features and conduct research (anonymized data only) We do NOT: - Sell personal information to third parties - Use data for advertising or marketing to children - Share data with third parties except as specified in Section 5 4. Legal Basis for Processing (Australian Privacy Principles) We process personal information under: - Consent: You or your parent/guardian explicitly agree - Contract: Necessary to provide the Service you requested - Legal Obligation: Required by Australian law - Legitimate Interests: Improving our Service and ensuring security (balanced against privacy rights) 5. Information Sharing and Disclosure We may share information with: 5.1 Service Providers (with data processing agreements): - Cloud hosting (AWS, Supabase) - Payment processors (Stripe) - AI/ML providers (OpenAI, Anthropic, Google, Grok) - Analytics providers (anonymized data only) 5.2 Legal Requirements: We may disclose information when required by: - Court orders, subpoenas, or legal process - Law enforcement or government agencies - Protection of our rights, safety, or property - Investigation of violations of our Terms of Use 5.3 Business Transfers: In the event of merger, acquisition, or sale of assets, user information may be transferred (users will be notified). We do NOT sell data or share with advertisers. 6. Data Storage and Security 6.1 Storage Location Data is stored on servers in Australia. Some service providers may process data internationally. 6.2 Security Measures We implement: - Industry-standard encryption (in transit and at rest) - Access controls and authentication - Regular security audits - Employee training on data protection However, no system is 100% secure. We cannot guarantee absolute security. 6.3 Retention - Active accounts: Data retained while account is active - Inactive accounts: Deleted after 12 months of inactivity - Legal requirements: Some data retained longer if required by law - Upon deletion request: Data permanently deleted within 30 days (except legal obligations) 7. Children's Privacy (Aged 6-16) 7.1 Parental Consent Parental consent is required for users under 16 to use our service. Parents can: - Review their child's information - Request deletion of child's data - Refuse further collection of child's data - Contact us at: hi@intallaga.com 7.3 Children's Data Protection - We do NOT knowingly collect more data than necessary - We do NOT use children's data for advertising - Voice recordings are used to provide the Service and are not retained longer than necessary. 8. Your Rights (Australian Privacy Principles) You have the right to: - Access: Request a copy of your personal information - Correction: Request correction of inaccurate information - Deletion: Request deletion of your information (subject to legal obligations) - Objection: Object to certain processing activities - Portability: Receive your data in a portable format - Complaint: Lodge a complaint with OAIC (Office of the Australian Information Commissioner) To exercise rights: Email hi@intallaga.com with your request. 9. Cookies and Tracking We use: - Essential cookies: Required for Service functionality - Analytics cookies: To understand usage patterns (anonymized) - Preference cookies: To remember your settings You can disable cookies in your browser, but this may limit Service functionality. 10. Third-Party Links Our Service may contain links to third-party websites. We are not responsible for their privacy practices. Review their privacy policies separately. 11. Changes to This Policy We may update this Privacy Policy. Material changes will be notified via: - Email to registered users - Prominent notice in the app - Updated "Last Updated" date Continued use after changes constitutes acceptance. 12. International Users If accessing from outside Australia, your information may be transferred to Australia where our servers are located. By using the Service, you consent to this transfer. 13. Data Breach Notification In the event of a data breach affecting your information, we will notify you and OAIC as required by law. 14. Contact Us Privacy Officer: Intallaga Tech Pty Ltd Email: hi@intallaga.com Address: Suite 55, Marnirni-apinthi Building, Lot Fourteen, North Terrace, Adelaide, SA 5000 15. Complaints If you have a privacy complaint: 1. Contact our Privacy Officer (details above) 2. We will investigate and respond within 30 days 3. If unsatisfied, you may contact OAIC: - Website: www.oaic.gov.au - Phone: 1300 363 992 - Email: enquiries@oaic.gov.au --- END OF PRIVACY POLICY