Effective Date: December 9th, 2025
This privacy policy (the “Privacy Policy” or the “Policy”) is entered into by and between you and Creative Confidence Management Consulting Company S.P.C. (“Creative Confidence” “we”, “our”, or “us”), the legal entity that operates the Bankee mobile application (the “Bankee App” or the “App”).
We recognize the importance of protecting the privacy and personal information of our users or the Bankee App, who may include students, teachers and other authorized participants (each a “User” and collectively, the “Users”). We take this responsibility seriously. This Privacy Policy explains how we collect, use, disclose and retain our Users’ information when Users access or use the Bankee App as part of the Bankee program (the “Bankee Program”).
Please read this Privacy Policy carefully before using the App. By accessing or using the App, you acknowledge that you have read, understood and agree with the terms of this Policy. If you do not agree with the terms of this Privacy Policy or the manner in which we process personal information, you should not access or use the App or provide us with any personal information. You should also delete the App if you have downloaded the same onto your smart phone or electronic device.
The Bankee Program is an educational platform designed to teach financial literacy, responsibility and positive behaviour to children between the ages of 5 and 14 by simulating a classroom economy. Teachers allocate virtual “Bankee currency” to students based on their conduct, participation and contributions. Students may redeem their earned currency for a range of in-App rewards, such as educational privileges, toys, digital items or other non-monetary benefits determined by their school or teacher. The currency has no real-world monetary value and cannot be exchanged, sold, or used outside the App.
Access to the Bankee Program is provided exclusively through participating schools, which request the creation of student accounts on the Bankee App and manage the onboarding process. The contractual and educational relationship is directly between the school and its students, and the school remains responsible for obtaining parental consent, authorizing student access to the App and overseeing their student’s participation in the Bankee Program.
The App may collect the following categories of personal information from its Users: the full registered names of students as recorded by the school and their grade level and classroom, as well as their email addresses; the full names and email addresses of teachers; the name and address of the school; and any information entered by authorized teachers or school administrators in connection with the classroom economy model, including records of bonuses, virtual “Bankee currency”transactions, and any fines applied to students (“Personal Information”). We may also collect technical identifiers that relate to your use of the App, such as device identifiers, Internet Protocol (IP) addresses, operating system, and connection timestamps. We collect Personal Information only when it is voluntarily provided by you or submitted with appropriate authorization or consent (for example, by an authorized teacher or Student’s parent or guardian).
The User(s) have the right to:
The App does not use traditional browser cookies. However, it may use equivalent technologies to ensure proper functionality, security and performance. These may include local storage, device identifiers (“Device IDs”) that are accessible by mobile applications, including the Bankee App, and analytics tools that help us understand how the App is used and to improve the Bankee Program.
If you use the App on your iOS or Android device, we may collect and store limited technical data, such as your device type, operating system, App version and general usage statistics. This information is used solely for internal administrative, diagnostic and analytical purposes and is not linked to your personal identity.
You can manage your device settings to control permissions and limit certain types of data collection, such as analytics tracking. We do not use any tracking technology for advertising, profiling or marketing purposes.
We use Personal Information provided through the App for the purposes of operating, maintaining, and improving the App and the Bankee Program. This includes enabling teachers, students (or their parent or legal guardian) and other authorised users to access their classroom accounts, view balances, record rewards and fines, and participate in the classroom economy model, as well as supporting participating schools and teachers in managing their classrooms and ensuring the proper functioning and performance of the App. In addition, we may use Personal Information derived from the App for research and Program development purposes. This helps us evaluate the effectiveness of the Bankee Program, identify educational trends, and improve the overall experience of the App and the Bankee Program.
We may also analyse aggregated and de-identified information (which does not identify any individual User) to derive insights, behavioural analytics, and usage trends. Such information may be used internally to enhance our services or, in anonymized and statistical form only, for commercial, educational or research purposes. We do not sell or otherwise monetize identifiable Personal Information of Users, and we do not use children’s personal data for targeted advertising or marketing.
All processing of User Personal Information is conducted in accordance with applicable data-protection laws and app store policies, and, where relevant and applicable, on the basis of legitimate interest, consent or contractual necessity.
We may share certain Personal Information we collect or receive with trusted third party service providers who assist us in operating, hosting, storing, and maintaining the App, including providers of data-storage, security, and analytics services. These service providers are given access only to the data necessary to perform their specific functions and are expected to protect the Personal Information and use it solely for the purpose of supporting the Bankee Program.
Any third party service providers, including those that deploy analytics tools, hosting systems, or software development kits (SDKs), as well as any parent, subsidiary, or related entities that may access the Personal Information of a User, are expected to provide the same or greater level of protection for Personal Information as described in this Privacy Policy and as required under the applicable app store guidelines and relevant data protection laws. While we select such providers with care and take reasonable steps to verify their compliance, we do not independently audit or guarantee their practices. Accordingly, Creative Confidence is not responsible for any acts, omissions, or failures of these third parties beyond its reasonable control.
In certain limited circumstances, we may access or disclose Personal Information to: (i) protect the safety, security, and privacy of Users of the App or members of the public, including in emergency situations; (ii) protect or defend the legal rights or property of Creative Confidence; or (iii) comply with applicable law, regulation, or legal process.
We may also allow certain third-party analytics providers to collect or access the Personal Information to help us understand how the App is used and to support ongoing improvement of both the App and Bankee Program. These providers may process or store limited Personal Information, to the extent required, strictly on our behalf for such analytics or research purposes, and are expected to handle such information confidentially and in accordance with applicable data-protection laws and regulations.
We may share anonymised or aggregated analytics outputs (which do not identify any individual User) with third-party research partners, educational institutions, or commercial collaborators to advance educational insights or program development. Such sharing will never include identifiable data relating to minors.
To the fullest extent permitted by applicable law, Creative Confidence shall not be liable for any loss, damage, or harm, whether direct, indirect, incidental, or consequential, arising from or related to the acts, omissions, data-handling practices, or security measures of any third-party service providers, analytics partners, hosting entities, software vendors, or any other third parties engaged in or supporting the operation of the Bankee Program, that may process or access Personal Information in connection with the App. While Creative Confidence exercises reasonable care in selecting and engaging such third parties, it does not control their operations and disclaims all responsibility for any unauthorized use, disclosure, or other processing of User Information outside its control.
By accepting this Privacy Policy, you agree and consent to us providing third parties with any and all of your Personal Information for the purposes highlighted above, including the processing of anonymised and aggregated information for research, educational, and analytical purposes, provided that such information does not identify any individual User.
You as a parent/legal guardian of a student or school teacher as the case may be, understand and agree that the Personal Information of the User will be stored or processed by our trusted third-party service providers operating data servers located outside the State of Kuwait. In such cases, we ensure that the transfer of User’s Personal Information complies with applicable Kuwaiti data-protection laws and that adequate safeguards—such as contractual undertakings, encryption, or equivalent protective measures—are in place to ensure a level of protection consistent with this Privacy Policy. Where User’s Personal Information is transferred internationally, our service providers are required to process such data solely for the purposes of supporting the Bankee Program or for legitimate, anonymized research and analytical purposes as described above and in accordance with the confidentiality and security standards described herein.
By accepting this Policy, as a parent/legal guardian of a student or a school teacher as the case may be, you agree and consent to any and all cross border data transfers conducted by us or on our behalf.
We retain User’s Personal Information only for as long as necessary to fulfil the educational and operational purposes of the Bankee Program, in compliance with applicable laws, regulations and contractual obligations. Once the Personal Information is no longer required for these purposes, it is securely deleted or anonymized.
User’s Personal Information associated with active school accounts is retained for the duration of the school’s participation in the Bankee Program. When a school discontinues participation, or when a student leaves the participating school, all Bankee App accounts associated with the exiting school or to the departing student will be deactivated. The relevant Personal Information will then be retained for a limited period for legitimate administrative, audit or compliance purposes (not exceeding three (3) years), following which it will be deleted or anonymized.
Users, parents, legal guardians, or authorized school representatives may request the correction or deletion of a student’s or a teacher’s account or Personal Information at any time by contacting Creative Confidence through the support channels provided within the App or via the contact details listed at the end of this Privacy Policy. Requests for data deletion or correction, or the withdrawal of consent will be processed subject to applicable legal and educational record-keeping requirements.
Bankee uses commercially reasonable administrative, technical, personnel, and physical security measures designed to safeguard Personal Information in our possession against loss, theft, and accidental or unlawful destruction, as well as unauthorized use, disclosure, and modification. Please keep in mind, however, that whenever you give out Personal Information online, such information is not always secure in transit. While we take reasonable measures to protect Personal Information, we cannot guarantee the security of information sent over the Internet or through a mobile application, and you disclose such information at your own risk.
Bankee is designed for educational use under adult supervision. We do not knowingly allow any child under the age of 21 to register independently. All student accounts are created at the request of a teacher or authorized school administrator from the participating school and these accounts are managed by teachers or authorised school administrators, who confirm that appropriate parental consent has been obtained for each student under the age of 21 to download, operate an account, access and use the Bankee App.
If we become aware that Personal Information has been collected from a child without the required consent, we will delete such information promptly and notify the relevant school.
In accordance with the laws and regulations of the State of Kuwait, Personal Information of students under 21 years of age is collected and processed only with the authorization of their parent or legal guardian. We do not collect student information directly from minors. All student accounts are managed by participating schools, which are responsible for obtaining and maintaining the necessary parental or guardian consent required under applicable laws. Creative Confidence relies on such institutional assurances and processes student Personal Information solely for educational purposes within the scope of the Bankee Program.
Subject to applicable law, you may:
To exercise these rights, please contact us using the details below. We will respond within a reasonable period, consistent with applicable legal timelines.
The App may request permission to send notifications for educational reminders or reward updates. You may disable notifications at any time through your device settings. We do not access any other device feature (camera, microphone, contacts or location) unless specifically required for a clearly identified educational purpose and only after obtaining your express consent.
By accepting the terms and conditions of this Privacy Policy, you (whether a parent/guardian of a student, the student or a school teacher) acknowledge that you have read, understood, and agreed to this Privacy Policy. Your use of the App constitutes your consent to the collection, use, processing, disclosure, and retention of your Personal Information as described in this Policy and in accordance with applicable laws and regulations of the State of Kuwait. If you do not agree with this Policy, please discontinue use of the App and contact us for assistance in deleting your account and the Bankee App if you had downloaded it.
From time to time, we may modify this Privacy Policy to reflect industry initiatives, changes in legal requirements, changes in our information collection and use practices, or changes in the operation of the Bankee App and Bankee Program. Any material changes will be communicated through the App, and the “Effective Date” at the top of this Privacy Policy will be revised accordingly. Continued use of the App following publication of an updated Privacy Policy constitutes acknowledgment and acceptance of the revised terms.
If you have any questions about our practices or this privacy policy or require any assistance, please contact us at [[email protected]].