Privacy Policy

Last Updated: March 30, 2026

1. Introduction

This Privacy Policy explains how Komito ("we", "our", "us") collect, use, disclose, and protect your personal data when you use the Komito communication and feedback application (the "App").

Komito is operated by Aeshan Jiniwal.

We are committed to safeguarding your privacy in compliance with United Kingdom data protection laws, including the U.K. General Data Protection Regulation (U.K. GDPR) and the Data Protection Act 2018.

2. Data Controller

Komito solely controls the data being used. However, our backend is hosted on Azure Cloud.

3. Information We Collect

3.1 Personal and Contact Details

Student and parent/guardian names

3.2 Account Information

User identification credentials issued by centre administrators (random UserIDs)

3.3 Communication Data

Messages and inquiries sent via the App
Feedback and survey responses
Appointment bookings and scheduling communications

3.4 Technical Data

Device type, operating system, and device identifiers
App usage logs and session duration
Push notification tokens used to deliver service-related notifications

4. How We Use Your Personal Data

Purpose of Processing	Lawful Basis Under U.K. GDPR
To provide core App functions: sending centre updates, schedule changes, and educational resources.	Necessary for the performance of a contract and legitimate interests in managing the centres efficiently.
To facilitate secure communication between parents/guardians and instructors.	Performance of a contract.
Appointment scheduling and centre administration.	Necessary for the performance of the educational services contract.
To process feedback and surveys to monitor and improve service quality.	Legitimate interests in developing and improving educational offerings.
To maintain internal records of student progress and engagement.	Necessary for the performance of the contract for tuition services.
To respond to enquiries and provide user support.	Legitimate interests in maintaining effective communication and service.
To ensure the security of the App, prevent misuse, and troubleshoot technical issues.	Legitimate interests in protecting systems and users.

5. Data Sharing

We do not sell personal data. We may share data with:

IT and hosting providers acting strictly on our instructions
Government authorities where legally required

6. Data Retention

Active student records: duration of enrolment plus approximately 12 months
Financial records: 7 years (UK tax requirements)
Anonymised feedback: retained for service improvement
Inactive accounts: deleted or anonymised within 24 months of inactivity

If you would like to exercise your rights under UK GDPR, please contact the relevant Study Centre using the details above. We will respond within one month of receiving a valid request and may require verification of identity before fulfilling certain requests.

You may also visit our account deletion page: Account Deletion

7. Data Security

We implement reasonable technical and organisational measures to protect personal data, including secure system access, restricted administrative access, and secure data storage. While we take precautions, no system can be guaranteed fully secure.

8. Your Legal Rights

Right of access
Right to rectification
Right to erasure
Right to restrict processing
Right to data portability
Right to object

We do not use automated decision-making or profiling.

9. Children's Data

The App is intended for parents and guardians. We process limited data relating to children strictly for educational purposes and with parental knowledge. We do not knowingly collect personal data directly from children under 13 without parental involvement.

10. International Transfers

Data is stored within the United Kingdom or the European Economic Area (EEA). If transfers outside this area occur, appropriate safeguards will be applied in accordance with UK data protection law.

11. Changes to This Policy

We may update this Privacy Policy periodically. Continued use of the App after updates indicates acceptance of the revised policy.

12. Complaints

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk