Privacy Policy

Product: MIMI Smart Kids (mimismartkids.com)

Operated by: DIVINERS GROUP PRIVATE LIMITED ("Diviners Group", "we", "us", "our")

Registered address: No. 87, 1st Floor, 4th Cross Street, Phase-1, Tirumalai Nagar, Perungudi, Chennai, Tamil Nadu 600096

Last updated: 16 June 2026

1. Who We Are

MIMI Smart Kids is a children's learning product operated by Diviners Group Private Limited, a company based in India. This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and the rights you have. It covers two separate offerings:

• The free MIMI Smart Kids Android app, and
• Our paid custom-app service, which turns a child into a personalized 3D character in their own branded version of the app.

It also covers our website, mimismartkids.com.

Because our product is intended for children but is purchased and managed by adults, the parent or legal guardian is the data principal under this policy and acts on behalf of their child.

2. What We Collect

2.1 The Free MIMI Smart Kids App

The free app collects no personal data at all. Specifically:

• It works fully offline and on-device. It does not require an internet connection to function.
• There are no accounts and no login.
• There are no ads and no third-party advertising.
• There are no analytics or tracking SDKs.
• There are no in-app purchases.
• All learning progress is stored locally on the device. It never leaves the device and is never sent to us.

If you uninstall the app, the locally stored progress is removed with it.

2.2 The Website (mimismartkids.com)

When you use our website, we may collect:

• Contact / order form data: the parent's name, email address, and phone number, submitted so we can respond to enquiries or process an order.
• AI chat assistant data (optional): if you use the optional chat assistant, your messages are sent to Anthropic's Claude API to generate replies. Chat transcripts are stored on our server and are automatically deleted after 30 days.

2.3 Custom-App Orders

When you place a paid custom-app order, we collect:

• Parent/guardian details: name, email address, phone number.
• Child details: the child's first name, approximate age band, and gender.
• The child's photograph (one photo per child).
• Order and payment records.

3. How the Child's Photo Is Used (Important Disclosure)

We want to be completely clear about how a child's photo is handled:

• You upload one photo per child through a private, token-gated order page.
• That photo is sent to a third-party AI 3D-generation service, Tripo3D, which produces a 3D model from it.
• The model is further processed locally using Blender.
• The resulting 3D character is baked into the child's personalized app (APK). The photograph itself is not included in the shipped app.
• Photos and generated assets are stored in Cloudflare R2 object storage (EU region) and are access-controlled.

We do not use the photo for advertising, we do not sell it, and it is only processed to fulfil and support your order.

4. Legal Bases and Consent

We process personal data on the following bases, as applicable to you:

• Consent — in particular, verifiable parental/guardian consent is required before we process any child's data (name, age band, gender, photo). This aligns with India's Digital Personal Data Protection Act, 2023 (DPDP Act).
• Performance of a contract — to deliver the custom-app service you have ordered.
• Legal obligation — to retain order and invoice records as required by tax and accounting law.
• Legitimate interest / legitimate use — to respond to enquiries and provide support, where this does not override your rights.

For customers in the EU, we aim to align with the General Data Protection Regulation (GDPR). For customers in the US, we aim to align with COPPA-style protections for children. We do not claim any formal certification under these frameworks.

5. Sub-Processors and Third Parties

We use the following third parties to operate our service. We do not sell personal data and do not use it for third-party advertising or behavioural tracking.

• Anthropic (Claude API) — powers the website chat assistant; receives chat messages to generate replies.
• Razorpay — payment processing (India); processes payments in INR and USD.
• Cloudflare R2 — encrypted object storage for order assets (photos, generated 3D models, APKs), EU region; also CDN for the public APK download.
• Tripo3D — AI 3D-model generation from the uploaded child photo; processes the photo only to generate the model for your order.
• Email provider — transactional email for order and support correspondence.
• Amazon Web Services (AWS) — website and order-management hosting; EC2, eu-north-1 (Stockholm), EU.

6. International Transfers

We are based in India, and some of our sub-processors store or process data in the EU (Cloudflare R2 and AWS eu-north-1, Stockholm) or other regions. Where data is transferred internationally, we take steps intended to ensure it remains protected and is handled only for the purposes described in this policy.

7. Data Retention

• Free app: nothing is collected, so nothing is retained by us.
• Chat transcripts: automatically deleted 30 days after the conversation.
• Order photos and generated assets: retained for as long as needed to build and support your order, then deleted within 90 days after delivery, unless you ask us to keep them for re-orders.
• Order and invoice records: retained as required by applicable tax and accounting law.

8. Security

We use access controls and store order assets in access-controlled, encrypted object storage. The token-gated order page restricts who can upload to and view an order. While no system can be guaranteed perfectly secure, we take reasonable measures to protect personal data against unauthorised access, loss, or misuse.

9. Children's Data

• We process a child's data only with verifiable parental/guardian consent.
• We do not create advertising profiles of children, and we do not show ads.
• We do not sell children's data.
• The free app collects no data about a child at all.

Please also see our separate Children's Privacy Notice for a plain-language explanation.

10. Your Rights

Subject to applicable law, you (as the parent/guardian and data principal) have the right to:

• Access the personal data we hold about you and your child.
• Correct inaccurate or incomplete data.
• Delete personal data (subject to records we must keep by law).
• Withdraw consent. If you withdraw consent mid-order, we will stop processing the child's data; this may mean we cannot complete or deliver the custom app, and refunds (if any) are governed by our Refund & Cancellation Policy.
• Grievance redressal — raise a complaint about how we handle your data.

To exercise any of these rights, contact us at support@mimismartkids.com.

11. Grievance Officer

In line with the DPDP Act, you may contact our Grievance Officer:

• Muthuramu Periyaiah — support@mimismartkids.com

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will update the "Last updated" date above when we do. Material changes will be communicated where appropriate.

13. Contact

• Email: support@mimismartkids.com
• Operated by: DIVINERS GROUP PRIVATE LIMITED
• Address: No. 87, 1st Floor, 4th Cross Street, Phase-1, Tirumalai Nagar, Perungudi, Chennai, Tamil Nadu 600096