Privacy Policy
Contents
- Who we are
- What we collect
- What we do not collect
- Legal basis for processing
- In-app purchases
- How long we keep data
- Where data is stored
- Third-party processors
- Security measures
- Children and family use (COPPA, GDPR-K, DPDP Act)
- Regional rights (GDPR, CCPA, DPDP)
- International transfers
- Changes to this policy
- Contact
1. Who we are
Bhashu ("the App", "we", "us") is a mobile learning application for Indian languages, available on the Apple App Store and Google Play Store. The App and this website are operated by iMobileMaster Limited, located in the State of Ohio, United States.
For privacy questions, contact us at contact@bhashu.com.
2. What we collect
We collect only aggregate, anonymous usage events — counts of activities across all users combined, with no individual identification. Specifically:
- Event name — e.g., "chapter_opened", "lesson_completed", "game_played", "screen_view"
- Event properties — e.g., chapter ID, lesson type, game ID (never user-identifying)
- Duration on screen, in milliseconds, averaged across the user base
- Platform — iOS or Android, app version number
Each event is sent to our server as a count and immediately aggregated. We do not attach any user identifier, device identifier, advertising ID, IP address, precise or coarse location, or any other identifier to the event before processing or storage.
Voluntary feedback you send through the in-app form. If you tap "Send Feedback" inside the Profile tab of the App and submit a message, we receive: the category you picked (Bug · Suggestion · Praise · Other), your message text, and — only if you choose to provide it — an optional email address for a reply. The email field is clearly labeled as optional and intended for adults; you may submit feedback without it. We also auto-attach the app platform (iOS or Android) and the app version, to help route bug reports to the right release. No device identifier, user identifier, or other personal data is attached to the feedback record.
Purchase-sync account — only if you choose to sign in. If you sign in with Sign in with Apple or Sign in with Google, we store a one-way hash of your sign-in identifier together with a record of which books you own, so your purchases follow you across your devices and our family of apps. The record contains no name, email address, phone number, IP address or device identifier, and the hash cannot be reversed to your identity. Signing in is optional, and you can delete the account at any time from inside the app — Profile → Account → Delete Account (see §5 and our deletion page).
Everything else stays on your device. Your learning progress — XP, streaks, completed lessons, unlocked trophies and stickers — and the optional Nickname you may enter so the app can greet your child by name are stored only on your device. They are never sent to us or to anyone else. Removing the app, or using "Reset Progress" in the Profile tab, clears this on-device data.
3. What we do not collect
To be explicit, we do not collect any of the following:
- Names, phone numbers, or contact information. Email addresses are only collected if you voluntarily provide one — through the optional field on our in-app feedback form, or by emailing us directly. We never collect an email address automatically.
- Precise location (GPS) or coarse location (IP-based)
- Advertising identifiers — IDFA on iOS, AAID on Android — we do not request these
- Device identifiers — device model + OS combinations are not used to identify or fingerprint your device
- IP addresses — our server does not log or persist them with event data
- Photos, videos, microphone audio, or any device sensor data
- Contact lists, calendar, call logs, or any other system-level data
- Account credentials, biometric data, or login information from other services — if you choose Sign in with Apple or Google, we receive only an irreversible one-way hash of your sign-in identifier, never your password, name or email address (see §5)
- Browsing history or behavior outside the App
- Any data from third-party tracking SDKs — we do not integrate any (no Facebook SDK, no Google Analytics, no advertising SDKs, no analytics SDKs other than our own first-party aggregate counter)
4. Legal basis for processing
Where applicable law requires us to identify a legal basis for processing data, our basis for collecting aggregate usage events is our legitimate interest in understanding which parts of the App are used so we can improve the product. Because the data is fully aggregated, the privacy impact is minimal — the data cannot reasonably be used to identify any individual.
5. In-app purchases
When you buy a book inside the App, the purchase is processed entirely by Apple (App Store) or Google (Play Store). Those platforms tell us only whether the purchase was successful — we never see your payment card details, billing address, or account information.
If you choose to sign in (with Sign in with Apple or Sign in with Google), we record a minimal purchase entitlement so the books you buy stay with you across our family of apps. Specifically, we store: a one-way hash of your sign-in provider's stable user identifier (which cannot be reversed to your real identity, email, or name), which book you bought, when you bought it, which app and platform the purchase originated on, and the signed purchase receipt for audit/re-validation. This one-way hash is used solely to restore and sync your purchase entitlements across our apps — it serves no other purpose. We do not store your name, email, phone, IP address, or device identifier. Signing in is optional — if you skip it, the App still works locally; the only effect is that you'll need to tap "Restore Purchases" if you ever install a future app in our family on a new device.
Refund decisions are handled by Apple or Google under their respective policies. See Terms of Service §6 for the refund process.
6. How long we keep data
On our servers, aggregate event counts are held in CloudWatch Logs for up to 30 days, after which they are automatically deleted by our log retention policy. We may also download these anonymous, aggregate counts to a private computer for longer-term product-quality analysis, and those copies may be kept beyond 30 days. Either way there is nothing tied to any individual to delete: the data contains no names, no accounts, and no user or device identifiers — only combined activity counts — so retaining it does not affect any person's privacy.
If you email us, we keep the email thread until the conversation is resolved, then delete it within 12 months unless you request otherwise.
In-app feedback submissions. Feedback you send through the in-app form is stored in our AWS DynamoDB database with a retention period of 90 days, after which the entire feedback record (including any optional email address you provided) is automatically deleted by DynamoDB's time-to-live policy. If you provided an email and we reply during the 90-day window, the resulting email thread follows the 12-month-after-resolution rule above. You may request earlier deletion of your feedback at any time by emailing the address in §14.
Purchase-sync account. If you signed in, the entitlement record described in §5 is kept for as long as the account exists, because a purchased book is a permanent entitlement. It has no automatic expiry — instead you control it: deleting your account in the app (Profile → Account → Delete Account) removes the record and every purchase row tied to it immediately and permanently. Deleting it does not affect your purchases, which remain with your Apple or Google account and can be restored at any time. You may also ask us to delete it by emailing the address in §14.
Anonymized summaries. To learn from feedback over time, we may keep an anonymized, non-personal summary of what was reported — the category, common themes, and a copy of the message with any personal details (and the email address) removed. These summaries contain nothing that identifies you, are never linked to a person, and are used only to improve the app.
Retention for legal reasons. We routinely delete support requests and their associated contact information on the schedules described above (in-app feedback within 90 days; email threads within 12 months of resolution). We may retain specific information for longer only where required by law, or where reasonably necessary to establish, exercise, or defend legal claims, investigate a security incident, prevent fraud or abuse, or comply with a legal obligation. Any such retention is limited to the particular records and purpose involved, and the information is deleted once that purpose no longer applies.
7. Where data is stored
Aggregate event counts are stored on Amazon Web Services (AWS) infrastructure in the United States, specifically in AWS CloudWatch Logs. AWS is a SOC 2 Type II, ISO 27001, and PCI DSS-certified provider. Because the data contains no personal information, the geographic storage location has no impact on your privacy.
Telemetry endpoint — no IP logging. The API Gateway stage that receives telemetry requests has access logging explicitly disabled at the infrastructure level (enforced by a Terraform postcondition that fails our deployment if the setting is ever changed). The Lambda function that processes requests does not read or log the source IP address or User-Agent header from the request context. CloudWatch metrics for the endpoint contain only aggregate counts (request count, latency, error rate) and do not include per-request IPs.
Website edge analytics. Our website (bhashu.com) is served through Amazon CloudFront, a content delivery network. CloudFront's standard operational reporting includes aggregate, anonymous request counts per country (e.g., "United States: 72%, India: 14%"). These totals are visible only to us as service operators, are not linked to any individual visitor, and are produced by AWS at the edge layer rather than by code we wrote. We do not use this data for profiling, advertising, or any decision affecting an individual user.
Feedback storage — DynamoDB. In-app feedback submissions are stored in an AWS DynamoDB table (us-east-1 region). The table has a time-to-live policy set to 90 days, after which records are automatically purged by AWS. The feedback Lambda is scoped via IAM to write-only on this single table — it cannot read existing rows, scan the table, or touch any other resource. Only authorized project maintainers can query the table via the AWS CLI.
User-account purchase storage — DynamoDB. If you sign in (with Sign in with Apple or Sign in with Google), the minimal purchase entitlement record described in §5 is stored in a separate AWS DynamoDB table (us-east-1 region). The record contains only: a one-way hash of your sign-in provider's stable user identifier (cannot be reversed to identity, email, or name), the book identifier you bought, the timestamp, the originating app and platform, and the signed purchase receipt. Purchase records do not have an expiration date because buying a book is a permanent entitlement. You can delete this record yourself at any time, from inside the app: Profile → Account → Delete Account (see our deletion page); deleting it does not affect your purchases, which remain with your Apple or Google account and can be restored. You may also request deletion by emailing the address in §14. The purchase Lambda is scoped via IAM to query, write, and delete only on this single table — it cannot scan or touch any other resource. Receipts are validated server-side against Apple's and Google's official verification endpoints to prevent forgery.
8. Third-party processors
We use the following service providers to operate the App and website:
- Amazon Web Services (AWS) — Hosts the website (S3, CloudFront), the version-check endpoint, the in-app feedback endpoint, the aggregate telemetry endpoint, and the purchase-entitlement store (DynamoDB, §7). AWS does not access the aggregate data and is bound by their standard data processing terms.
- Apple (App Store) — Distributes the iOS app and processes iOS in-app purchases.
- Google (Play Store) — Distributes the Android app and processes Android in-app purchases.
We do not use any advertising networks, analytics services (Firebase, Google Analytics, Mixpanel, Amplitude, etc.), CRM platforms, or third-party tracking pixels. Our aggregate telemetry is a first-party endpoint we built ourselves.
9. Security measures
Even though the aggregate data we collect is not sensitive, we apply the following safeguards:
- All communication between the App and our server uses HTTPS / TLS 1.2 or higher.
- AWS infrastructure is configured with least-privilege IAM roles.
- Our server endpoint enforces rate limiting to prevent abuse.
- The telemetry Lambda function is stateless — it writes to CloudWatch and discards.
- During normal use we store no personally identifying information; any contact details you voluntarily provide are held only briefly and deleted on the schedule in §6.
10. Children and family use (COPPA, GDPR-K, DPDP Act)
Bhashu is designed for children to use. We chose an aggregate-only, minimal-data model specifically so that the App can be safely used by children under the world's strictest child-privacy regulations.
10.1 COPPA (United States, under 13)
Under the Children's Online Privacy Protection Act, an operator may not knowingly collect "personal information" from children under 13 without verifiable parental consent. Bhashu does not collect personal information from children during normal use of the App, so no parental consent flow is required for ordinary use. There are no profiles, no chat, no social features, no behavioral advertising, and no third-party tracking. The only way any contact information reaches us is if a user voluntarily enters an email in the optional feedback form or emails us directly — a channel intended for a parent or guardian to reach us for support. Consistent with COPPA's exception for using online contact information solely to respond to a specific request, we use any such email only to reply, never for marketing or profiling, and delete it on the schedule in §6.
10.2 GDPR-K (European Union, under 16 / age varies by Member State)
Under the General Data Protection Regulation, processing personal data of children under 16 (or under 13-16 depending on Member State law) requires parental consent. Bhashu does not process personal data of children during normal use of the App, so no parental consent mechanism is required for ordinary use. We process personal data only if a user voluntarily contacts us (see §10.1), and only to respond.
10.3 DPDP Act (India, under 18)
Under India's Digital Personal Data Protection Act, processing personal data of children under 18 requires verifiable parental consent. Bhashu does not process personal data of children during normal use of the App, so no parental consent mechanism is required for ordinary use. Any personal data is processed only if a user voluntarily contacts us (see §10.1), and only to respond.
10.4 No advertising, no profiles, no social features
Bhashu contains no advertising of any kind (no banner ads, no interstitials, no rewarded video, no sponsored content), no user profiles that can be shared publicly, no chat or messaging features, and no user-generated content. Children cannot communicate with strangers through the App.
11. Regional rights (GDPR, CCPA, DPDP)
Many jurisdictions grant their residents specific privacy rights — for example, the right to access, correct, delete, or port their personal data, and the right to opt out of sale or sharing.
Because we do not collect personal data during normal use of the App, and only receive personal information if you voluntarily contact us, most of these rights have no data to operate on during ordinary use. If you signed in, you can delete your account and its purchase-sync record yourself at any time, in the app: Profile → Account → Delete Account — no request to us is needed. If you have contacted us (through the feedback form or by email), you may request access to or deletion of the personal information you provided — write to contact@bhashu.com and we will. Full instructions are on our deletion page.
Specifically:
- EU / UK (GDPR) — Articles 15-22 rights (access, rectification, erasure, restriction, portability, objection): during normal use no personal data is held; these rights apply to any information you voluntarily provide by contacting us.
- California (CCPA / CPRA) — Right to know, delete, correct, opt out of sale/sharing: during normal use we collect no personal information, and we never sell or share data; if you contact us, you may exercise these rights over the information you provided.
- India (DPDP Act) — Data Principal rights (access, correction, erasure, grievance redressal): during normal use no personal data is processed; rights apply to any information you voluntarily provide by contacting us.
- Other states / countries — equivalent rights apply, with the same outcome: no personal information during normal use, and full rights over anything you voluntarily provide by contacting us.
12. International transfers
The aggregate data we collect is stored on AWS infrastructure in the United States. Because the data we collect during normal use is anonymous and aggregated, international data transfer protections (Standard Contractual Clauses, adequacy decisions, etc.) are generally not engaged. Any contact information you voluntarily provide by contacting us is likewise processed in the United States. If you access the App from outside the United States, you understand and agree that this processing occurs in the United States.
13. Changes to this policy
We may update this Privacy Policy from time to time. If we change what data we collect or how we use it, we will:
- Update the "Last updated" date at the top of this page.
- If the change is material (for example, adding a new type of data collection or sharing data with a new service provider), we will surface an in-app notice the next time you open the App, before the change takes effect.
- Material changes will not be applied retroactively to data collected before the change.
14. Contact
If you have questions about this Privacy Policy, our data practices, or you'd like to make a request related to your privacy, write to contact@bhashu.com. We read everything and respond within 14 days.
For unresolved privacy concerns, you may also contact your local data protection authority — for example, the U.S. Federal Trade Commission, the EU national supervisory authority for your country, or India's Data Protection Board.