PRIVACY POLICY

ZetaGalaxy

Last Updated: February 23, 2026

PommpuAI Technology Private Limited ("Company," "we," "us," or "our") operates the ZetaGalaxy application and related services (the "Service"). We are committed to protecting the privacy of children and their families. This Privacy Policy explains our information collection, use, disclosure, and parental consent practices concerning the personal information of our users, particularly children under the age of 13 ("Child" or "Children").

This Service is designed for and targeted to children under 13, and we comply with the U.S. Children's Online Privacy Protection Act ("COPPA") and similar laws globally. By allowing your Child to use the Service, you consent to the practices described in this policy.

PARENTAL NOTICE & KEY POINTS

Designed for Kids: ZetaGalaxy is a commercial online service directed to children under 15.
Parental Consent Required: We require verifiable parental consent before collecting personal information from your Child.
Voice Data Handling: Your Child's voice recordings for the AI feature are processed in real-time and deleted immediately after a response is generated. They are not retained or used for AI model training without additional, explicit parental consent.
Parental Control: You have the right to review, delete, and control your Child's information at any time. Instructions are provided below. You can email us in case if you are unable to.
Contact Us: For any privacy questions or to exercise your rights, contact us at: hello@zetagalaxy.com.

1. INFORMATION WE COLLECT

We collect the following categories of information:

Parent email address
Child nickname (not real name)
Child grade level
Conversation logs and learning inputs
Device identifiers (such as device ID)
Usage data, interaction logs, and diagnostics

We collect this information to operate, secure, and improve the Service.

Information Processed During Use (Not Stored)

Voice Recordings for AI Feature: When your Child uses the voice conversation feature, the Service temporarily processes their voice recording in real-time to generate a response. This audio data is not stored or retained on our servers after the response is generated. Conversation content may be processed by our AI service providers to provide responses. Voice data is processed transiently and not retained.

Information Collected Automatically

Anonymous Usage Data: We collect non-personal, technical, and gameplay data (like device type, session length, or completed game levels). This data is typically linked to a random device or account identifier, not to your Child's identity, and is used for service operation and improvement.

Information We Do NOT Collect

We do not collect precise geolocation data, contact information, or any biometric data beyond the temporary voice processing described above.

2. HOW WE OBTAIN VERIFIABLE PARENTAL CONSENT

When setting up a ZetaGalaxy account for a Child, we collect a parent's email address.
We send a detailed email to the parent explaining our information practices with a direct link to provide consent.
To provide verifiable parental consent, the parent must take a simple affirmative action, such as clicking a unique "I Consent" link in that email.
After we receive consent, we enable the Child's account and send a confirmation email to the parent.
You may revoke your consent at any time. Contact us at hello@zetagalaxy.com to do so. This will result in the deletion of your Child's personal information and the closure of their account.

3. HOW WE SHARE AND DISCLOSE INFORMATION

We are committed to minimizing data sharing and only sharing information as necessary to operate the Service.

a. Service Providers: We share information with trusted service providers who help us operate, maintain, and improve the Service, such as cloud hosting providers, infrastructure providers, analytics providers, and artificial intelligence processing providers.

When you use AI features:

Your inputs are first processed through our servers for request handling, safety filtering, abuse prevention, and reliability.
Limited information — such as nickname, grade level, and learning inputs — may then be shared with third-party AI providers such as OpenAI, Anthropic, or Google (Gemini) to generate responses.
Parent email addresses and device identifiers are not shared with AI providers.
We obtain user permission before sharing data with AI service providers.
All service providers are contractually required to use information only to provide services to us and to maintain appropriate confidentiality and security protections.
We may also process data internally for monitoring, logging, quality assurance, and misuse prevention.

b. Legal and Safety Reasons: We may disclose information if required by law, regulation, legal process, or governmental request, or if necessary to:

Protect user safety
Prevent fraud or abuse
Enforce our policies
Respond to security incidents

c. No Sale of Personal Data: We do not sell, rent, or trade personal information to third parties for advertising or commercial purposes. We limit sharing of Children's data and personal information

4. USE OF THIRD-PARTY AI SERVICES

We use third-party artificial intelligence services to generate responses and provide personalized features within the app. All AI providers are required to maintain appropriate privacy and security safeguards.

These providers may include, for example:

OpenAI
Anthropic
Google (including Gemini)

We may use one or more AI providers depending on availability, performance, reliability, or feature requirements.

No Training: Our agreements prohibit these providers from using children's data to train their AI models or improve their general services.

No Retention: Data shared is processed in real-time and not retained by the provider beyond the duration of the request.

Provider Updates: If we change or add new AI providers, we will update this policy and ensure all providers meet the same privacy and security standards.

How data is processed

When you use AI features:

Your inputs are first securely processed through our servers for request handling, safety filtering, abuse prevention, monitoring, and service reliability.
Limited information — such as child nickname, grade level, and user messages or learning inputs — may then be shared with AI providers solely to generate responses.
We do not share parent email addresses, real names, or device identifiers with AI providers.

Data use and training

We use AI services in a data-processing capacity. We do not use user data to train our own models, and we do not permit AI service providers to use user data to identify users.
User data is used only to provide AI functionality and improve service quality.

Monitoring and safety

We may log interactions and process data internally to:

Detect misuse or harmful activity
Maintain system security
Improve performance and reliability
Investigate technical issues

Monitoring may include automated analysis and limited human review when necessary.

User permission

We obtain user permission before sharing data with AI service providers.

5. SECURITY

We implement administrative, technical, and organizational safeguards designed to protect information, including encryption in transit, access controls, monitoring, and secure infrastructure practices.

6. INTERNATIONAL DATA TRANSFERS AND STORAGE

Our Service is operated by PommpuAI Technology Private Limited in India. The account information we collect is processed and stored on our servers located in the United States. Some processing may occur in the United States via our service providers. By using the Service, you acknowledge this transfer.

For users located in the European Economic Area (EEA), United Kingdom, or Switzerland, we ensure appropriate safeguards are in place for international data transfers as required by applicable data protection laws.

Information may be processed and stored in countries where our service providers operate, subject to appropriate safeguards.

7. DATA SECURITY AND RETENTION

Security: We use commercially reasonable security measures to protect children's account information. This includes encryption and strict access controls. We instruct users not to share personal information in conversations.

Retention: We keep children's account information only for as long as necessary to provide the Service or as required by law, and then we delete it securely. As stated, voice data is deleted immediately after processing.

8. ACCOUNT DELETION AND DATA REMOVAL

Users have the right to request deletion of their account at any time. When an account is deleted, we will delete or anonymize personal information associated with the account, including email address, nickname, grade level, and stored interaction data, unless retention is required for legal, security, or legitimate operational purposes.
Some limited information may be retained for a short period to comply with legal obligations, resolve disputes, prevent fraud, or enforce our agreements.
Users can request account deletion through the app settings or by contacting us at hello@zetagalaxy.com
Once deletion is completed, the account cannot be restored.
Account Termination by User: You may delete your account at any time through the app or by contacting us. Upon deletion, access to the service will be terminated and associated data will be removed in accordance with our Privacy Policy.

9. PARENTAL RIGHTS AND CONTROLS

As a parent, you have the right to:

Review Account Information: You can review the account information you provided during setup (like your email) and any information generated by your Child's use of the Service that we retain (such as game progress data linked to an anonymous identifier).
Request Deletion: You can request the deletion of your Child's account and any associated data we hold.
Withdraw Consent: You can withdraw your consent for your Child's future use of the Service.
Understand Data Practices: You can receive a clear explanation of our data collection, use, and disclosure practices.

To exercise any of these rights, please contact us at hello@zetagalaxy.com. We will take reasonable steps to verify your identity as the parent before fulfilling your request.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy. If we make a material change to how we collect, use, or disclose children's personal information, we will notify parents by email (sent to the address on file) and/or through a clear notice in the Service. The updated policy will also be posted here with a new "Last Updated" date.

We encourage you to review this policy periodically. Continued use of the Service after changes take effect means you accept the new terms.

11. CONTACT US

If you have questions or concerns about this Privacy Policy, please contact us at:

PommpuAI Technology Private Limited

Attn: Privacy Officer

Email: hello@zetagalaxy.com