Effective date: 1 August 2026
This Data Protection Addendum ("Addendum") applies where Rainwater Labs ("we", "us") processes personal data on behalf of a customer — for example, a school or organisation — in connection with the Dew service, and it forms part of the agreement between Rainwater Labs and that customer (the "Customer"). Where no such customer relationship exists, Dew is provided directly to parents and guardians under our Terms of Use and Privacy Policy, and this Addendum does not apply.
For personal data processed on the Customer's behalf, the Customer is the data controller and Rainwater Labs is the data processor. We process such personal data only to provide and support the Dew service and on the Customer's documented instructions.
We will: process personal data only as needed to provide the service; keep it confidential and limit access to a need-to-know basis; apply appropriate technical and organisational security measures; assist the Customer, so far as reasonable, in responding to individuals' requests and meeting its data-protection obligations; and notify the Customer without undue delay after becoming aware of a personal-data breach affecting the data we process for them.
All personal data processed under this Addendum is stored and processed on servers located in India. We do not transfer this personal data outside India. Personal data is not sent to, shared with, or used to train any external or third-party AI service; the learning service operates within our own India-based systems.
The Dew service is designed for children, and children's personal data is handled with special care. The Customer is responsible for establishing the appropriate lawful basis for children's use of the service, including any parental or guardian consent required by applicable law.
Dew's tutoring and safety technology is built and operated by Rainwater Labs. Where we use limited infrastructure to run the service (such as secure hosting within India), any such provider acts only on our instructions, under contract, is bound by data-protection obligations, and does not use the data for its own purposes.
We will assist the Customer, by appropriate measures and so far as reasonable, in responding to requests from individuals to exercise their rights under applicable law. The service also lets account holders access, export, correct, and delete data directly.
On termination of the Customer's agreement, we will, at the Customer's choice, delete or return the personal data processed on their behalf, and delete existing copies, unless retention is required by law.
This Addendum is governed by the laws of India. If there is a conflict between this Addendum and the Customer's agreement regarding the processing of personal data, this Addendum prevails to the extent of that conflict.