Privacy Policy

Effective Date: March 30, 2026
Last Updated: April 23, 2026

1. Introduction

Acena Education - FZCO, doing business as "Componi" ("we," "us," "our," or "Company"), operates the Componi mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information in connection with the App.

We are committed to protecting your privacy and providing transparency about our data practices. This Privacy Policy applies to all users of the App, including those in the United States.

Entity Information:

2. Personal Information We Collect

2.1 Account Information

When you create an account, we collect:

2.2 Gameplay and Activity Data

2.3 Device Information

2.4 Advertising and Tracking Data

2.5 Push Notification Data

2.6 Analytical Data

2.7 Purchase Data

When you make an in-app purchase (Crystals or the one-time Lifetime Ad-Free Purchase), we receive purchase metadata through the RevenueCat SDK:

Componi does not receive or store your credit card, debit card, or bank account information. All payment processing is handled directly by Apple or Google. Componi does not offer recurring subscriptions; there is no recurring billing data.

3. How We Collect Personal Information

3.1 Direct Collection

We collect information directly from you when you:

3.2 Automatic Collection

We automatically collect information through:

3.3 Third-Party Collection

Third parties collect information about you:

4. How We Use Personal Information

We use the personal information we collect for the following purposes:

4.1 Core Service Delivery

4.2 Advertising and Marketing

4.3 Analytics and Improvement

4.4 Legal and Compliance

4.5 Communication

5. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

5.1 Right to Know

You have the right to request that we disclose:

5.2 Right to Delete

You have the right to request deletion of personal information we have collected from you, subject to certain exceptions. We must delete the personal information within 45 days of receiving your request, unless an exemption applies.

Exemptions: We may retain personal information if necessary to:

5.3 Right to Correct

You have the right to request that we correct inaccurate personal information we maintain about you.

5.4 Right to Opt-Out of Sale or Sharing

We do not sell or share personal information as defined by CCPA/CPRA. However, our use of Google AdMob tracking may constitute a "share" for cross-context behavioral advertising purposes under CPRA. You can opt out of this sharing by:

5.5 Right to Limit Sensitive Personal Information

We do not collect sensitive personal information beyond what is necessary for the App's functionality. We do not knowingly:

5.6 Non-Discrimination

We will not discriminate against you for exercising your privacy rights by denying services, charging different prices, or providing a different quality of service. However, we may offer different functionality based on whether you have completed the optional Lifetime Ad-Free Purchase or other App features.

5.7 How to Submit Requests

To submit a privacy request or exercise your California rights:

Email: admin@acena.cc
Subject: "California Privacy Request" (specify Right to Know, Right to Delete, Right to Correct, or Opt-Out)
Include: Your full name, email address associated with your Componi account, and a detailed description of your request

We will verify your identity before responding to your request. Verification may require you to provide:

We aim to respond to all verifiable requests within 45 days of receipt.

5.8 Authorized Agents

If you wish to submit a request on your behalf through an authorized agent, the agent must provide:

6. Google AdMob and Advertising Tracking

6.1 What Google AdMob Collects

When you view ads in the App, Google AdMob collects:

6.2 How AdMob Uses This Data

Google uses this information to:

For more information about Google's data practices, see Google's Privacy Policy at https://policies.google.com/privacy.

6.3 Opting Out of Personalized Ads

You can opt out of personalized advertising through:

7. Apple App Tracking Transparency (ATT)

7.1 ATT Consent Flow

When you first launch the App, we request permission to track your activity across other apps and websites using your Apple IDFA. This consent is obtained through Apple's App Tracking Transparency framework and displayed as a native system alert.

7.2 Your ATT Choice

7.3 Changing Your ATT Preference

After your initial choice, you can modify your ATT preference at any time:

8. Data Storage and Security

8.1 Where Your Data Is Stored

8.2 Security Measures

We implement industry-standard security controls:

8.3 Data Retention Periods

Data Category Retention Period Reason
Account registration info Duration of account + 90 days Legal hold, potential re-activation
Gameplay and activity logs 90 days active, then archived Analytics and fraud detection
In-app purchase records 7 years Tax and financial compliance, fraud prevention
Crystal transaction ledger Permanent (immutable) Audit trail, fraud detection, dispute resolution
Device and advertising IDs Duration of account + 30 days Ad optimization, fraud detection
Crash reports and technical logs 30 days Debugging and performance optimization
Deleted account data 30 days (with exceptions) See Section 9: Account Deletion Policy

8.4 Limitation

While we implement reasonable security measures, no system is completely secure. We cannot guarantee absolute security of your personal information.

9. Third-Party Services and Integrations

9.1 Authentication Providers

When you sign in via these providers, we receive a unique identifier but not your actual password. These providers may retain their own logs of your authentication activity.

9.2 Cloud Infrastructure (Supabase)

Supabase (which uses Postgres and AWS S3) acts as a data processor for us:

9.3 Advertising Networks

9.4 Product Analytics (Amplitude)

Amplitude, Inc. acts as our data processor for product analytics:

9.5 Purchase Management (RevenueCat)

RevenueCat, Inc. acts as our data processor for in-app purchases:

9.6 Push Notification Service

We may use a push notification provider to send you game updates and promotional messages. The provider may collect:

You can disable push notifications at any time in your device settings.

10. Children's Privacy (COPPA)

The App is not directed at children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will delete that information promptly.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at admin@acena.cc.

For more information about COPPA, see the Federal Trade Commission's guidance at https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

11. International Data Transfers

11.1 Cross-Border Data Flows

Acena Education - FZCO is registered in the United Arab Emirates, but we serve users in the United States. Your personal information may be transferred to, stored in, and processed in the United States (where our cloud infrastructure resides) and in the UAE (where our corporate entity is based).

11.2 Data Protection

By using the App, you consent to the transfer of your personal information to the United States and other countries where we operate. These countries may have different data protection laws than your home country. We implement appropriate safeguards (encryption, contractual commitments) to protect your information during transfers.

11.3 EU / International Users

If you are located outside the United States, please note that the App is primarily designed for US users and may not fully comply with your local privacy laws (e.g., GDPR, UK DPA 2018). We do not specifically target users in Europe or other jurisdictions, but if you use the App, your data will be transferred to the US.

12. Data Retention and Deletion

12.1 General Retention

We retain personal information for as long as necessary to:

12.2 Account Deletion

For details on how to request account deletion, see the separate Account Deletion Policy document.

Summary: Deleted accounts are removed from active service within 30 days, but certain data (transaction logs, fraud prevention records) may be retained longer for legal compliance.

13. Your Privacy Rights Summary

Depending on your location, you may have the following rights:

Right Availability How to Exercise
Right to Know California (CCPA/CPRA), and others Email: admin@acena.cc
Right to Access Most jurisdictions Email: admin@acena.cc
Right to Delete California (CCPA/CPRA), and others Email: admin@acena.cc or in-app settings
Right to Correct California (CPRA), and others Email: admin@acena.cc
Right to Opt-Out California (CCPA/CPRA, sale/sharing) Email or GPC signal
Right to Limit Sensitive Info California (CPRA) Not applicable (we don't collect sensitive categories)
Right to Data Portability Some jurisdictions Email: admin@acena.cc
Right to Non-Discrimination California (CCPA/CPRA), and others Automatic; no discrimination for exercising rights

14. App Store Privacy Labels

In compliance with Apple's App Privacy policies and Google Play's data safety disclosures, we maintain accurate privacy labels in both app stores. The labels reflect:

Our app store labels are updated whenever our privacy practices change, with advance notice to users where required.

15. Contact Us for Privacy Inquiries

15.1 Privacy Officer

For any privacy-related questions, requests, or concerns:

Email: admin@acena.cc
Subject Line: "Privacy Inquiry — [Your Request Type]"

Mailing Address:
Acena Education - FZCO
IFZA Business Park, DDP
PO Box 342001
Dubai, United Arab Emirates

15.2 Response Time

We aim to respond to all privacy inquiries within 30 business days. If you submit a formal data subject request (Right to Know, Right to Delete, etc.), we will follow the timelines specified in applicable law (typically 45 days in California).

15.3 Escalation

If you are not satisfied with our response, you may lodge a complaint with your local data protection authority (if applicable in your jurisdiction).

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

Your continued use of the App after changes become effective constitutes your acceptance of the updated Privacy Policy.