Privacy Policy
Effective from June 5, 2026
This Privacy Policy explains how Kai Innolabs LLC ("Kai Innolabs," "we," "us," or "our"), a company incorporated in Delaware, United States, collects, uses, shares, and protects personal information when you use Primorly — our AI-powered programming tutor available at primorly.com and related applications (collectively, the "Service").
By creating an account or using the Service, you agree to the practices described in this Policy. If you do not agree, please do not use the Service.
1. Who We Are
Primorly is operated by Kai Innolabs LLC. Primorly delivers structured programming courses through an AI tutor. Throughout this Policy, "Primorly" refers to the Service and "Kai Innolabs" refers to the legal entity that controls your personal information (the "data controller" / "business").
Contact for privacy matters: connect@primorly.com
2. Eligibility and Age Requirement
The Service is intended only for users who are 16 years of age or older. We do not knowingly create accounts for, collect personal information from, or direct the Service to children under 16. We collect your date of birth during onboarding in part to enforce this requirement.
If you are under 16, please do not use the Service or provide us any personal information. If we learn that we have collected personal information from a person under 16, we will delete that information promptly. If you believe a person under 16 has provided us personal information, contact us at connect@primorly.com.
3. Information We Collect
We collect the following categories of personal information, all of which you provide directly or which are generated through your use of the Service. We do not purchase personal information from data brokers.
3.1 Account and Profile Information
- Identity details: first name, last name, date of birth, and country, provided during onboarding.
- Credentials: your email address and a password. Passwords are stored only as a cryptographic hash — we never store your password in plain text.
- Learning preferences: the learning track you select (e.g., Data Science, Machine Learning).
3.2 Learning and Usage Content
- Chat conversations: the messages you type to the AI tutor and the AI's responses, saved per topic so you can resume. These may include any text, code, or questions you choose to enter.
- Progress and achievement data: your learning progress through courses, along with achievements and activity records associated with your account.
- Coding-platform links: if a course uses an external coding-notebook platform, the notebook URL you link to a session.
3.3 Usage and Analytics Data
- Service usage metrics: records of your activity on the Service, used to enforce free-trial and subscription plan limits and to operate the Service.
- Session analytics: session timing and duration, used to understand engagement and operate the Service.
- Abuse-prevention records: technical records used to protect the Service from abuse and to enforce fair-use limits.
- Support and feedback submissions: messages you send through the in-app "Need help" and "Leave feedback" forms, along with the name and email associated with your account at the time of submission.
3.4 Payment Information
When you subscribe to a paid plan, payments are processed by a third-party, PCI-DSS-compliant payment processor. Your full card number is collected directly by that processor through its own hosted checkout pages and embedded fields — it never touches our servers. We store only limited billing metadata returned to us, such as a customer identifier, card brand, the last four digits of your card, subscription status, plan, and invoice history.
3.5 Technical and Device Data
As with most online services, our infrastructure and service providers automatically process limited technical data such as IP address, browser type, and request timestamps for security, logging, and reliability. We use secure, token-based authentication to keep you signed in.
We do not use third-party advertising cookies or sell advertising. Cookies and local browser storage are used only for sign-in, session continuity, and remembering interface preferences.
4. How We Use Your Information
We use personal information for the following purposes:
| Purpose | Examples |
|---|---|
| Provide the Service | Authenticate you, deliver lessons, generate AI text and voice responses, save chat history and progress, and resume you where you left off. |
| Personalize learning | Recommend courses based on your selected track and tailor your learning experience. |
| Process payments | Manage subscriptions, plan changes, proration, invoices, receipts, and waitlist signups through our payment processor. |
| Communicate with you | Send transactional emails (welcome, payment receipts, overdue-payment notices, cancellation confirmations) and respond to your support and feedback requests. |
| Enforce limits and protect the Service | Apply free-trial and subscription plan limits, prevent abuse, and maintain security and integrity. |
| Operate and improve | Monitor performance, debug, analyze aggregate engagement, and improve courses and features. |
| Comply with law | Meet legal, tax, accounting, and regulatory obligations and respond to lawful requests. |
We do not use your private chat content to train third-party foundation models for those providers' general purposes. See Section 5 for how providers handle data sent to them.
Legal Bases (where applicable)
Where required by law, we rely on the following bases to process your information: performance of our contract with you (to provide the Service), your consent (e.g., optional communications), our legitimate interests (security, service improvement, fraud prevention), and compliance with legal obligations.
5. How We Share Information — Service Providers (Sub-Processors)
We share personal information only as described below. We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising as those terms are defined under California law.
We rely on the following categories of third-party service providers to operate the Service. Each receives only the data needed to perform its function:
| Category of Provider | Purpose | Data Shared |
|---|---|---|
| AI / machine-learning providers | Generate the AI tutor's text responses and lesson progression | Your chat messages and the context required to generate a reply |
| Text-to-speech providers | Convert the AI's text responses into spoken audio | The text of the AI's responses |
| Payment processors | Payment processing and subscription management | Your name, email, payment card details (collected directly by the processor), and billing metadata |
| Email delivery providers | Send transactional emails | Your email address and the content of transactional messages |
| Cloud hosting and database providers | Host the Service and store data | Service data, stored and processed on our behalf |
| Embedded coding-platform providers | Optional embedded coding notebooks for certain courses | Notebook URLs you choose to link, subject to that platform's own privacy policy |
These providers are contractually bound to process data only on our instructions and to protect it. We may add, remove, or change individual providers within these categories as our operations evolve. If you would like more information about the specific providers we currently use, you may contact us at connect@primorly.com.
Other Disclosures
We may also disclose personal information:
- To comply with law — in response to lawful requests, subpoenas, court orders, or to protect legal rights.
- For safety and security — to investigate, prevent, or address fraud, abuse, security incidents, or violations of our terms.
- In a business transfer — in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.
- With your consent — for any other purpose disclosed to you at the time.
6. International Data Transfers
Kai Innolabs LLC is based in the United States, and our infrastructure and sub-processors may process and store your information in the United States and other countries. If you access the Service from India, Kenya, South Africa, the European Economic Area, the United Kingdom, or elsewhere, your information will be transferred to and processed in countries that may have different data-protection laws than your own.
Where required, we implement appropriate safeguards for such transfers (for example, contractual protections with our sub-processors) and process your data consistent with this Policy and applicable law.
7. Data Retention
We retain personal information for as long as your account is active and as needed to provide the Service. Specifically:
- Account, profile, progress, and chat data are retained while your account exists.
- Billing and invoice records are retained as required for tax, accounting, and legal compliance, typically several years, even after account closure.
- Logs and technical data are retained for a limited operational period.
When you request deletion of your account, we will delete or de-identify your personal information within 30 days, except where we are required to retain it for legal, tax, security, or fraud-prevention purposes. Backups are purged on a rolling cycle.
8. Security
We take reasonable technical and organizational measures to protect your information, including:
- Passwords stored only as cryptographic hashes (never in plain text).
- HTTPS/TLS encryption for data in transit and secure token-based authentication.
- Payment card data handled entirely by a PCI-DSS-compliant payment processor — never stored on our servers.
- Access controls, rate limiting, and logging that minimizes exposure of personal identifiers.
No method of transmission or storage is completely secure. We cannot guarantee absolute security, and you use the Service at your own risk. Please use a strong, unique password and keep your credentials confidential.
9. Your Privacy Rights
Depending on where you live, you may have some or all of the following rights regarding your personal information:
- Access a copy of the personal information we hold about you.
- Correct inaccurate or incomplete information.
- Delete your personal information.
- Object to or restrict certain processing.
- Data portability — receive your information in a portable format.
- Withdraw consent where processing is based on consent.
- Non-discrimination — we will not deny you service or treat you differently for exercising your rights.
- Lodge a complaint with the data-protection authority in your country or region.
You can exercise many of these rights directly in the Service (for example, editing your name in Settings, or requesting help/account deletion). To make any request, email connect@primorly.com. We will verify your identity before acting, respond within the time required by applicable law, and you may use an authorized agent where the law permits.
California residents: You have the right to know what personal information we collect, why, and the categories of third parties we share it with (see Sections 3–5), as well as the rights to delete, correct, and opt out of the "sale" or "sharing" of personal information. We do not sell or share your personal information, and we do not process it for cross-context behavioral advertising.
Grievance / data-protection contact: If you have a complaint about how we handle your personal information — including users in India exercising their rights under applicable data-protection law — you may raise it with our point of contact at connect@primorly.com, and we will work in good faith to resolve it.
10. Cookies and Similar Technologies
We use cookies and local browser storage only for essential functions: keeping you signed in, maintaining your session, and remembering interface preferences. We do not use third-party advertising or tracking cookies. You can control cookies through your browser settings, but disabling essential cookies may prevent the Service from working.
11. Third-Party Links and Services
The Service may link to or embed third-party services (such as an external coding-notebook platform). This Policy does not cover the practices of those third parties. We encourage you to review their privacy policies before using them.
12. Changes to This Policy
We may update this Policy from time to time. When we make material changes, we will update the "Effective from" date above and, where appropriate, notify you by email or through the Service. Your continued use of the Service after changes take effect constitutes acceptance of the revised Policy.
13. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, contact us at:
Kai Innolabs LLC
Email: connect@primorly.com