Privacy Policy

Last Updated October 1, 2018


This privacy policy (“Privacy Policy”) describes how Kaymbu (“Company”, “we”, “us”, “our”) collects, uses and shares personal information of users of the Kaymbu software services offered via the web and native applications published in the app stores for Apple and Android mobile devices (the “Software”). This Privacy Policy also applies to any of our other websites that post this Privacy Policy. This Privacy Policy does not apply to websites that post different statements, and does not cover information that is collected by the schools that provide our service to you other than through the Software.

What We Collect

We may collect information that identifies you (“Personal Data”) when you use the Software which includes:

Identity Data includes first and last name.

Contact Data includes email address and mobile telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Software.

Profile Data includes your password.

Usage Data includes information about how you use our Software, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We get Personal Data about you in a range of ways.

Information You Give Us. We collect information you directly give us on our Software, such as by filling in forms, creating an account on our Software, subscribing to our service or publications, or give us feedback or contact us.

Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Software, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our Software, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Software.

Cookies. We may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Software. This type of information is collected to make the Software more useful to you and to tailor the experience with us to meet your special interests and needs.

The Software is not intended for children and we do not knowingly collect data relating to children.

Use of Personal Data

We use your Personal Data as follows:

Sharing of Personal Data

We may share Personal Data as follows:

Information Choices and Changes

Our newsletter and marketing emails tell you how to “opt-out.” You can also opt out by emailing us at If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.

You may send requests about Personal Data to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your Personal Data.

You can typically remove and reject cookies from our Software with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Software works for you.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Software that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the Contact Information below.

For Individuals in the European Union (“EU”) – General Data Protection Regulation (“GDPR”)

This Privacy Policy describes how the Company collects, uses and shares your personal information. If you are in the EU, you are subject to the GDPR, and the following terms also apply to you. The Company is the Controller and responsible for your Personal Data.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO by sending an email to

Purposes and Lawful Bases to Process Your Personal Data

This Privacy Policy describes the Personal Data we collect from you. We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

You have the right to withdraw consent to marketing at any time by contacting us. Specifically, we have a purpose and lawful basis for processing each type of Personal Data described in this Privacy Policy, which are as follows:

  1. The purpose for collecting your Identity and Contact Data is to register you as a new customer, and the lawful basis is the performance of a contract with you.
  2. The purpose for collecting your Identity, Contact, Financial, Transaction and Marketing and Communications Data is to process and deliver your purchases, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests.
  3. The purpose for collecting your Identity, Contact, Profile, and Marketing and Communications Data is to manage a relationship with you, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
  4. The purpose for collecting your Identity, Contact, Profile, Usage, and Marketing and Communications Data is to enable you to partake in a contest, competition or complete a survey, and the lawful bases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business).
  5. The purpose for collecting your Identity, Contact, and Technical Data is to administer and protect our business and the Software, and the lawful basis is that it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).
  6. The purpose for collecting your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data is to deliver relevant Software content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you, and the lawful basis is that it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
  7. The purpose for collecting Technical and Usage Data is to use data analytics to improve our Software, marketing, customer relationships and experiences, and the lawful basis is that it is necessary for our legitimate interests (to define types of customers for our products and services, to keep our Software updated and relevant, to develop our business and to inform our marketing strategy).
  8. The purpose for collecting Identity, Contact, Profile, Usage, and Technical Data is to make suggestions and recommendations to you about goods or services that may be of interest to you, and the lawful basis is that it is necessary for legitimate interests (to develop our products/services and grow our business).

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out forth in this Privacy Policy.

We may have to share your Personal Data with the parties set out below for the purposes described in this Privacy Policy.

Internal Third Parties

Other companies affiliated with the Company and who are based in the United States and provide IT and system administration services.

External Third Parties

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

International Processing

We are based in the United States, which is where all of your data will be processed.

Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data. In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights Under the GDPR

Under certain circumstances, EU residents have rights under data protection laws in relation to their Personal Data. If you are an EU resident, you have the right to:

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact Information

We welcome your comments or questions about this Privacy Policy. You may also contact us at our address:

Kaymbu Inc.
770 Massachusetts Ave #391075
Cambridge, MA 02139-0011

Changes to This Privacy Policy

We may change this Privacy Policy. If we make any changes, we will change the Last Updated date above.