Koomba Privacy Policy

Last Updated: September 1, 2026

At Koomba Inc. (“Koomba”, “we”, “our” and “us”), we respect your privacy and appreciate the trust you have placed in us. This Privacy Policy explains how Koomba collects, uses and discloses information we obtain in connection with our provision of services through our website or other online services that link to or refer to this Privacy Policy (collectively, the “Services”). It is important that you read this Privacy Policy carefully because any time you use our Services, you consent, on your own behalf, to the practices we describe in this Privacy Policy.

The Privacy Policy is part of our Terms of Use, which can be found on our website. Terms in the Privacy Policy have the same meaning as in our Terms of Use. When you use our Platform, you accept and agree to both the Terms of Use and to the Privacy Policy. If you do not agree to be bound by the Privacy Policy you should stop using the Services immediately. By accessing and using our Services you affirm that you have read the Terms of Use and the Privacy Policy and that you understand, agree and acknowledge all the terms contained in both of them.

Categories of Personal Information We Collect

Information You Provide

We collect any information that you provide us when you use the Services, when you communicate with our team or when requesting additional information from or about our Services.

For example, we collect:

  • Your contact information and other identifiers, such as your name, phone number and email address;
  • Other information, when you register or contact us directly, such as when we ask you to create a username and password;
  • Your school name, school sports team and relevant sport played;
  • Demographic information, such as your gender and age; and
  • Payment information, when you transact with us, and commercial information, such as records of your transactions with us.

Information In Conjunction With The Services

In order to perform the Services, we or our Facilitators may collect the following information, subject to consent where legally required;

  • Information about your mental state that you provide us when you interact with our Services. This collected information is not specific to any mental health diagnosis or mental illness treatment program and is therefore not deemed to be ‘protected health information’ as defined by the Health Insurance Portability and Accountability Act (HIPAA);
  • Information about your physical activities, physical condition, and potential injury recovery efforts when you interact with our Services. This information is not specific to any injury, ailment or health treatment program and is therefore not deemed to be ‘protected health information’ as defined by the Health Insurance Portability and Accountability Act (HIPAA); and
  • Audio and video recordings including transcriptions associated with your interaction with the Services. You, or through a parent or guardian, may revoke your consent for such recordings at any time.

Information We Collect Automatically

We may automatically collect certain technical information from your computer or mobile device when you use the Services.

For example, we collect:

  • Device and Usage Information. We may receive information from your device, including the IP address, mobile operating system version, and unique device identifiers. We may also collect and store your browser settings and preferences.
  • Online Activity. We may receive information about your interactions with our Services and other electronic and network activity information, such as the time spent interacting with content and the dates and times of your visits, and other information through the use of cookies, pixel tags, and other Internet technologies. We currently do not use 3rd party cookies for advertising purposes, but reserve the right to do so in the future. Please check back for any such updates related to our use of cookies and tracking technologies.
  • Approximate Geolocation Information. We may obtain information about your approximate device location, such as by associating your IP address with a zip code through public records.
  • Information from Other Sources. We may obtain information from third parties and sources other than the Services, such as from our sponsors and advertisers. We may combine the information we collect about you from different sources, including to generate inferences, to help us enhance and improve our products and services, and tailor our communications to you.

We may de-identify, anonymize and/or aggregate collected information for any business purpose. This may include anonymization and disclosure of transcripts from facilitation sessions for market research and AI training purposes. If we disclose any such de-identified or anonymous information, it will be devoid of any information that would enable re-identification and comply with all applicable privacy and health-related data use laws.

Business Purposes for Collecting Personal Information

We generally use the information we collect for the following business or marketing purposes:

  • Provide, customize and improve our products and services. For example, we use the information we collect about you to provide the Services, to improve and develop new products, services, features and functionality and to understand and analyze the usage trends and preferences of our users. We also use your information to (i) personalize our services, such as remembering information about you so that you will not have to re-enter it next time you use the Services; and (iii) monitor and analyze usage and the effectiveness of the Services and marketing activities.
  • Communicate with you about our products, services, and promotions. For example, we may send emails to the email address you provide to us for operational purposes, such as account management or customer service. We may also use your information to send you promotional communications by email. If you prefer not to receive such promotional communications from us, you may opt-out by following the instructions included in those communications.
  • Comply with applicable law and enforce our legal rights. We may also process the information we collect about you or from you for the following purposes: (i) to enforce our terms and other legal rights, including intellectual property rights; (ii) to comply with or address applicable law, regulations, or legal processes, such as a court order or subpoena; (iii) in response to requests by government agencies, such as law enforcement authorities; and (iv) to comply with industry standards and our policies.
  • Otherwise with your consent or as described to you at the time of collection. In addition, we will use your information to reach out to you, either ourselves or using the appropriate authorities, if either we or a Facilitator has a good reason to believe that you or any other person may be in danger of harming yourself or may be either the cause or the victim of a criminal act.

How we Disclose your Personal Information

  • Service Providers. We work with third-party service providers who provide development, hosting and other services. These third parties may have access to, or process, information you provide and information we collect automatically in connection with providing us these services.
  • Analytics Providers. We may disclose automatically collected information associated with our website analytics and other service providers who manage and optimize our website and Services.
  • Business Transfers. We also reserve the right to transfer information you provide and information we collect automatically to advisors, potential transactional partners or other third parties in connection with the consideration, negotiation or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate or transfer all or a portion of our assets or in the unlikely event of a bankruptcy.
  • Other Parties As Required by Law or As Necessary. We may disclose information you provide and information we collect automatically about you: (i) if we are required to do so by law, regulation or legal processes, such as a court order or subpoena; (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to protect against or respond to physical, financial or other harm, injury or loss to property; or (iv) in connection with an investigation of suspected or actual unlawful activity.
  • With Your Consent. We may disclose information you provide and information we collect automatically for other purposes with your consent or at your direction.

Your Privacy Choices

You have the right to exercise the following choices with our use of your personal information:

  • Access the personal information we maintain about you.
  • Delete the personal information we maintain about you. Please note we may be required by law to retain certain information in compliance with accounting, tax or other legal obligations.
  • Correct inaccurate personal information we maintain about you.
  • Opt out of certain uses of your personal information, notably:
  • Audio and Video Recordings: You, or a parent or guardian, may revoke consent provided for the use of audio or video recordings in conjunction with the Services.
  • Marketing Emails: To opt out of marketing e-mail communications, you may click the ‘unsubscribe’ link in the marketing emails. We may continue to send you non-commercial service messaging if legally necessary.

In addition to the above privacy choices, select US state laws may provide you with enhanced data privacy rights, including:

  • Rights to limit the use of ‘sensitive’ personal information: Koomba may process certain mental or physical health attributes that qualify as ‘sensitive’ under state privacy or health-related data laws. You, or a parent or guardian, may request deletion or suppression of any such data uses at any time.

If you wish to exercise any of these privacy choices, you may contact us at hello@koomba.co.

How we Retain and Protect your Information

We will retain your personal information only for as long as it is necessary for the purposes of fulfilling our website and Services or otherwise as described in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete, de-identify or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We use certain physical, administrative and technical measures that are intended to maintain the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards. Moreover, Koomba cannot guarantee the security of networks that we do not control, including the Internet and any wireless networks over which information may be transmitted to Koomba.

Children’s Privacy

When we provide Services for persons under the age of 18, we require written parental or guardian consent. We do not knowingly collect information online from children under the age of 18 or knowingly allow such persons to become users without written parental or guardian consent. If you tell us that we have collected information from a child under the age of 18 without adequate consent, we will promptly take steps to re-authorize consent and/or delete any personal information collected in accordance with applicable law.

International Users

The Services are intended for users located within the United States. If you choose to use the services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage and processing.

Changes to our Privacy and Practices

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices or relevant laws. To inform you of any change, we will post the updated Privacy Policy on the Services and indicate at the top of the Privacy Policy when it was updated.

How to contact us

If you have any questions or comments about this Privacy Policy, our privacy practices or if you would like to exercise your rights and choices, please contact us at hello@koomba.co.

If you or anyone you know are in a crisis or may be in danger, please do not use Koomba. These resources can provide you with immediate help.