Effective Date: August 21, 2025
Last Updated: Janurary 11, 2026

This Privacy Policy describes how Inoviant Inc. (“Company,” “we,” “us,” or “our”) collects, uses, processes, and shares information when you use the Albinka mobile application and related services (the “Service”). Read this together with our Terms of Use. By using the Service, you consent to the practices described here.

1. Information We Collect

1.1 Audio Data. When active, we record audio from your environment, including conversations, background sounds, voice characteristics (e.g., tone, pitch), emotional indicators, and child vocalizations.
1.2 Personal Information. Registration details (name, email), caregiver/child profiles (e.g., ages), payment/billing info, customer service communications, surveys/feedback.
1.3 Usage & Device Information. Device identifiers, OS/app version, usage patterns, location (if permitted), crash/diagnostics, network info.
1.4 Derived & Analyzed Data. Behavioral analyses and insights, developmental assessments, effectiveness metrics, predictive models, aggregated interaction statistics.

1.5 Communications Data. When you communicate with us or receive communications from us via SMS/text message, WhatsApp, telephone, or other messaging platforms, we collect: the content of those communications; your phone number or messaging identifier; timestamps and frequency of communications; and any information you voluntarily provide during voice calls or messaging interactions. This includes communications with our support team, AI-assisted coaching interactions conducted via telephone, and automated messages we send to you.

‍

2. How We Use Information

2.1 Service Functions. Provide coaching and guidance; analyze interactions; generate recommendations; track progress; deliver summaries and reports.
2.2 AI Development & Improvement. Train/refine models; improve analysis accuracy; develop new features and prediction models.
2.3 Research & Development. Conduct research; create anonymized datasets; publish aggregated findings.
2.4 Business Operations. Manage accounts and support; process billing; send service/marketing communications; ensure legal compliance; conduct analytics and reporting.
2.5 Payments. Website subscriptions are processed by our payment provider (e.g., Stripe). We do not store full credit card numbers; we receive tokens from the provider to manage billing.

3. How We Share Information

3.1 Anonymized Data Sharing. We may share anonymized/aggregated data with research, healthcare, educational, technology, commercial partners, and government agencies for research.
3.2 Service Providers. Cloud storage/computing, analytics/processing, payment processing, support, marketing/communications.
3.3 Legal Requirements & Government Cooperation. We may disclose information when required by law, court order, or government request, without notice, including to investigate violations or prevent fraud.
3.4 Business Transfers & Assignment. Your information may transfer in mergers, acquisitions, asset sales, or assignments.

4. Data Retention & Deletion

4.1 Standard Retention. We retain data as long as necessary to provide the Service, comply with legal obligations, and improve our AI; by default, data may be stored indefinitely.
Retention Scope. We may retain: (a) original audio recordings and transcriptions; (b) analyzed data and behavioral insights; (c) personal account information (caregiver/child profiles); (d) usage history and technical logs.
4.2 User-Requested Deletion. Email support@albinka.com to request deletion of personal data (account info, recordings, analyzed data linked to you). Deletions may take up to 30 days and are irreversible.
Limitations on Deletion. We may retain anonymized/aggregated data indefinitely; data already in AI models cannot be “unlearned”; certain data may be retained to comply with law.
4.3 Anonymized Data Retention. We retain de-identified patterns, aggregated statistics, and model improvements to improve AI, conduct long-term research, and maintain service quality.

5. Data Security

5.1 Security Measures. Encryption in transit/at rest, access controls, regular assessments, staff training.
5.2 Security Limitations. No system is completely secure. You acknowledge the risk of unauthorized access or security incidents.
5.3 Security Incidents & Notice. If we learn of a breach affecting your personal information, we will notify you and applicable regulators as required by law and take reasonable steps to mitigate harm.

6. Children’s Privacy

6.1 COPPA Compliance. The Service is designed for parents and caregivers, not for children under 13. Collection of children’s voices/data occurs under parental direction and consent; children cannot create accounts or use the Service independently.
6.2 Plain-Language Notice. Children under 13 may not use the Service directly. Parents must initiate and supervise all use and are responsible for decisions about their children’s data.

7. Your Choices & Rights

7.1 Account Controls. Update account info; adjust notifications; cancel subscription; contact us with privacy questions.
7.2 Marketing Communications. Opt out of promotional emails; we may still send service, billing, and legal notices. To opt out of SMS/text or WhatsApp marketing messages, reply STOP to any such message or contact support@albinka.com. See Section 13.4 for complete SMS, text, WhatsApp, and telephone communication opt-out details.
7.3 Data Rights & Limitations. Request deletion; review/update account info; we can’t provide portable exports at this time due to AI complexity; anonymized data can’t be deleted; some data may be retained to comply with law.
7.4 Advertising & Tracking. We do not sell personal information, do not share personal information for cross-context behavioral advertising, and do not use IDFA for tracking across apps or websites. We do not show third-party targeted ads. If our practices change, we will request App Tracking Transparency (ATT) permission and update this Policy in advance.

8. Geographic Restrictions

8.1 Service Availability. Intended for use in the United States, Canada, and Australia.
8.2 Jurisdiction Limitations. The Service is not available in jurisdictions where our data practices conflict with local privacy, data-residency, or recording-consent laws, or where compliance would be technically or economically impractical.
8.3 User Responsibility. You are solely responsible for ensuring your use complies with local laws (privacy, child protection, audio recording). If you use the Service from outside the U.S., Canada, or Australia, you do so at your own risk, and we make no representation that the Service is lawful in your location.
8.4 Processing Location. All data is processed and stored in the United States under U.S. privacy laws.

9. California Privacy Rights (CCPA/CPRA)

We collect, use, and share the categories of personal information described in this Policy for the purposes described. We do not sell personal information and do not share personal information for cross-context behavioral advertising. We do not use or disclose Sensitive Personal Information beyond purposes permitted by CPRA §1798.121. California residents may request access to or deletion of personal information, subject to the limitations in this Policy.

10. International Data Transfers

If you access the Service from outside the United States, your information will be transferred to and processed in the United States under U.S. privacy laws. By using the Service, you consent to this transfer and acknowledge that local privacy laws may not apply.

11. Third-Party Links & Services

Our Service may contain links to third-party sites or integrate third-party services. Their practices are governed by their policies, not this Policy.

12. Data Controller

Inoviant Inc. is the data controller for personal information collected through the Service.

13. Additional Notices

13.1 Recording Consent. By using the Service, you confirm you have all necessary consents to record audio in your environment and that such recording complies with applicable laws.
13.2 Emergency Situations. The Service is not designed to detect, monitor, or respond to emergencies (including child abuse, self-harm, medical crises, or safety threats). Do not rely on the Service in emergencies. Call 911 or local emergency services.
13.3 No Medical Privacy. This Policy does not create medical or patient privacy rights. The Service is not a medical service, is not intended for diagnosis or treatment, and is not subject to HIPAA, GDPR health-data rules, or similar medical privacy laws. Any health-related insights are educational only and not professional medical advice.

13.4 SMS, Text, WhatsApp, and Telephone Communications. By providing your phone number and using the Service, you expressly consent to receive communications from us via SMS/text message, WhatsApp, and telephone calls, including autodialed or prerecorded messages where permitted by law. Such communications may include: (a) transactional messages (account alerts, subscription confirmations, billing notices); (b) service and coaching notifications; (c) support communications; and (d) marketing or promotional messages (with your separate consent where required). TCPA Notice: Consent to receive autodialed or prerecorded marketing messages is not a condition of purchase. Standard message and data rates may apply. You may opt out of SMS/text marketing messages at any time by replying STOP to any text message from us; for WhatsApp, follow the opt-out instructions provided; for telephone marketing, contact support@albinka.com. You may continue to receive transactional or service messages after opting out of marketing communications. For Albinka phone-based AI coaching interactions, calls may be recorded for quality, training, and coaching purposes consistent with this Policy and applicable law.

14. Changes to this Policy

We may update this Privacy Policy at any time. Material changes will be communicated via in-app or email notices and by updating the effective date. Continued use after changes constitutes acceptance.

15. Contact

Inoviant Inc. • 42 Silver Hill Rd., Lincoln, MA 01773 • support@albinka.com

‍
For California requests, include “California Privacy Request” in the subject line.

‍