Privacy Policy
1. About This Policy
1.1 What this policy covers
This policy explains what personal data Kool Labs ("Kool", "we", "us") collects, why we use it, who we share it with, and what choices you have. It applies to our website and platform for building apps with AI (the "Services").
1.2 Who is responsible
Kool Labs, based in India, decides how your personal data is used. In privacy law we are the controller (GDPR), the Data Fiduciary (India's DPDP Act) and the business (California CCPA/CPRA). Contact us at [email protected].
2. Data We Collect
2.1 Data you give us
Your name and email address. Your profile from a sign-in provider such as Google or GitHub. The prompts, files and code you add to your projects. Messages you send to support. Payment details are handled by our payment provider. We do not store full card numbers.
2.2 Data we collect automatically
Device and browser type. IP address and approximate location. Pages viewed and actions in the Services. Logs for security and performance. Cookies and similar tools, as explained in our Cookie Policy.
2.3 Data from other sources
If you sign in with or connect another account, we receive the data you allow that provider to share.
2.4 Sensitive data
We do not ask for sensitive data. Please do not put it in your prompts unless you need to.
3. How and Why We Use Data
3.1 Our purposes
To run the Services and your account. To generate and deploy the apps you ask for. To take payments. To give support. To keep the Services safe and stop abuse. To understand and improve the Services. To follow the law.
3.2 Our legal bases (GDPR)
We use your data because we need it to carry out our contract with you. We also use it for our legitimate interests, such as security and improving the Services. We ask for your consent when the law requires it, for example for non-essential cookies. In some cases the law requires us to use it.
3.3 Our grounds (India)
Under the DPDP Act, we process your data with your consent, or for other uses the Act allows. These include providing a service you asked for and meeting legal duties.
3.4 AI processing
We send your prompts and project content to AI model providers to create your results. We do not sell your content. Our agreements do not allow these providers to use it to train their models.
4. Who We Share Data With
4.1 Service providers
We use providers for cloud hosting, AI models, analytics, payments and support. They may use your data only to serve us.
4.2 Legal and business reasons
We may share data to follow the law or a valid legal request, to protect rights and safety, or in a merger or sale of our business.
4.3 No sale of data
We do not sell your personal data. We do not share it for cross-context behavioral advertising.
5. International Transfers
5.1 Where data goes
We are based in India and our providers may be in other countries. Your data may be processed outside your own country.
5.2 How we protect it
For data from the EU or UK, we use safeguards such as standard contractual clauses or the UK addendum. For India, we follow any transfer limits the Indian government sets under the DPDP Act.
6. Keeping Data Safe
6.1 Security
We use encryption in transit and access controls. No system is fully safe, so we cannot promise absolute security.
6.2 Breaches
If a data breach affects you, we will tell you and the authorities as the law requires.
6.3 How long we keep data
We keep data while your account is active and as long as we need it for the purposes above. When you delete your account, we delete or anonymize your data within a reasonable time. We keep some data longer only when the law requires it.
7. Your Rights
7.1 What you can ask
You can ask to see your data, correct it, delete it, or get a copy. You can ask us to stop or limit some uses. You can withdraw consent at any time. Withdrawing does not affect use before you withdrew.
7.2 How to ask
Email [email protected] or use your account settings. We may need to confirm who you are. We reply within the time the law sets, usually 30 days. We do not charge you or treat you worse for using your rights.
7.3 Complaints
You may complain to us first. You may also complain to your data protection authority.
8. Rules for Some Regions
8.1 European Union and United Kingdom
You also have the right to object to processing based on our legitimate interests, to restrict processing, and to data portability. You may complain to your local supervisory authority, or in the UK to the Information Commissioner's Office.
8.2 India (DPDP Act, 2023)
You have the right to get information about your data, to correct and erase it, to have your grievance addressed, and to nominate another person to use your rights if you die or cannot act. You may complain to the Data Protection Board of India after you have used our grievance process.
Send your grievance to [email protected]. We reply within the time the law sets.
8.3 California (CCPA/CPRA)
In the last 12 months we collected the data types in section 2 and shared them for business purposes with the providers in section 4. We do not sell or share personal data for cross-context behavioral advertising. We do not use sensitive personal data to infer traits about you.
You have the right to know, delete, correct, and limit use of sensitive data. You may use an authorized agent. Contact us to use these rights.
9. Children
9.1 Age limit
Kool is not for anyone under 18. We do not knowingly collect data from children. If you think a child gave us data, contact us and we will delete it.
10. Changes and Contact
10.1 Updates
We may update this policy. We will change the date above. For important changes we will tell you by email or in the Services.
10.2 Contact us
For privacy questions or requests, write to [email protected].