Effective date: [DD Month YYYY] Last updated: [DD Month YYYY]
DRAFT — not yet legally reviewed. Items marked [CONFIRM] are factual claims I could not verify from the codebase. You must confirm each one is true before publishing. Publishing an unverified claim is worse than publishing no claim.
Smaqq is a learning app for school students. Because many of our users are children, we have tried to write this policy in plain language so that both students and parents can understand it.
This policy explains what information we collect, why we collect it, who we share it with, and the choices you and your parent or guardian have.
Smaqq is operated by [COMPANY LEGAL NAME], a company incorporated in India (CIN: [CIN]), with its registered office at [REGISTERED ADDRESS], India. In this policy, "we", "us" and "our" mean [COMPANY LEGAL NAME]. "You" means the person using Smaqq.
This policy applies to the Smaqq mobile application and the website at www.smaqq.in (together, the "Service").
We follow India's Digital Personal Data Protection Act, 2023 ("DPDP Act"). Under that law we are a "Data Fiduciary" — the entity responsible for your personal data.
Smaqq is designed for school students, and many of our users are under 18.
Under the DPDP Act, anyone under the age of 18 is a child. This means:
A parent or guardian can, at any time, ask us to show them what data we hold about their child, correct it, or delete it. Section 12 explains how.
| What | Why we need it |
|---|---|
| First name and last name | To create your profile and personalise the app |
| Mobile number | This is your account identifier, and how we send you a one-time password (OTP) to sign in |
| Email address and Google account details, if you sign in with Google | To create and secure your account. Google gives us your name, email address, profile picture and Google account ID |
| Password, if you choose to sign in with one | To secure your account. Passwords are stored in hashed form and cannot be read by us |
| Your school board and grade | To show you learning content matched to your syllabus and year |
| Academic year | To keep your progress organised by year |
| Avatar | To represent you in the app and on leaderboards |
| Referral code, if you have one | To credit the person who referred you |
| Your answer to the onboarding question | To understand how you found us and improve our onboarding |
Where a parent or guardian is linked to a student account, we collect the parent's name, relationship to the student, mobile number and email address. We use this to obtain and record consent, to contact the parent about the account, and to let the parent exercise their rights under Section 12.
Some questions in Smaqq let you answer by speaking instead of typing.
This is always your choice. Voice questions can be answered another way, and the microphone is only used while you are actively answering a voice question. Your device will ask for microphone permission first, and you can refuse or withdraw it at any time in your device settings.
When you use this feature:
Google's handling of the audio is governed by Google's own privacy policy.
Some answers, including spoken answers, are scored automatically using an AI system that compares your answer against an expected rubric.
When you use Smaqq, we collect:
We use this to run the app, keep your progress in sync, fix bugs, keep accounts secure, and understand which features are useful.
To be clear, we do not collect:
Smaqq stores some information locally on your phone so the app works properly:
This information stays on your device. Uninstalling the app removes it.
Smaqq is a mobile app and does not use browser cookies. Our website www.smaqq.in uses only the cookies necessary to make the site work.
Under the DPDP Act we process personal data on the basis of consent, which you (or your parent, if you are under 18) give when you create an account and accept this policy. Certain limited processing happens on the basis of legitimate uses permitted by the Act, such as complying with a legal obligation or preventing fraud.
We process your data to:
We do not sell your personal data. We do not share it with advertisers.
Smaqq includes leaderboards and shared game features. Other users of Smaqq can see:
That is all. Other users cannot see your mobile number, email address, parent's details, school, individual answers, or voice recordings.
If you or your parent would prefer you not to appear on leaderboards, contact us using the details in Section 14 and we will remove you.
We share personal data only with service providers who help us run Smaqq, and only to the extent they need it. They are required to protect it and may not use it for their own purposes.
| Provider | What they handle | Purpose |
|---|---|---|
| Google Firebase | Device tokens, app diagnostics | Push notifications and app infrastructure |
| Google Sign-In | Name, email, Google account ID | Optional sign-in method |
| Google speech recognition | Spoken audio | Converting speech to text |
| [CONFIRM] [SMS/OTP provider name] | Mobile number | Sending one-time passwords |
| [CONFIRM] [Cloud hosting provider name] | All stored data | Hosting our servers and database |
We may also disclose personal data where we are legally required to do so — for example, in response to a valid order from a court, regulator or law enforcement agency — or where necessary to protect the safety of a user or the public.
If our business is ever merged, acquired or reorganised, personal data may transfer to the new entity. If that happens, we will notify you and the new entity will remain bound by this policy or a policy at least as protective.
[CONFIRM] Your data is stored on servers located in [REGION — e.g. India (Mumbai)].
Some of our service providers, including Google, may process data on servers outside India. Where that happens, we rely on those providers' contractual protections. The DPDP Act permits such transfers except to countries that the Government of India has specifically restricted, and we comply with any such restrictions.
| Data | Retention period |
|---|---|
| Account and profile data | Until you delete your account, then up to [CONFIRM: e.g. 30] days in backups |
| Learning progress, scores, coins | Until you delete your account |
| Voice transcripts | [CONFIRM: e.g. 90 days], then deleted |
| Raw voice audio | Not retained — [CONFIRM] |
| Device and usage logs | [CONFIRM: e.g. 180 days] |
| Records we must keep by law | For the period the law requires |
When a retention period ends, we delete the data or irreversibly anonymise it so it can no longer identify you.
We take security seriously, and we also want to be honest about what we do and do not claim.
What we do:
What we do not claim: no system is completely secure. We cannot guarantee absolute security, and we do not hold any formal security certification at this time. If we become aware of a personal data breach affecting you, we will notify you and the Data Protection Board of India as required by the DPDP Act.
We send push notifications about streaks, rewards, new content and account activity. You can turn these off at any time in your device settings, or in Preferences inside the app. Turning them off will not stop you from using Smaqq.
Under the DPDP Act, you — or your parent or guardian if you are under 18 — have the right to:
You can delete your account yourself: open Account Settings in the app and choose Delete Account.
You can also request deletion by emailing us at [GRIEVANCE EMAIL], or through the deletion request page at [CONFIRM: https://www.smaqq.in/delete-account].
When you delete your account, your profile, progress, coins and rewards are permanently removed. Coins and in-app rewards have no monetary value and cannot be refunded or transferred. We will complete deletion within [CONFIRM: e.g. 30] days, except for anything we must keep by law.
To exercise any other right, contact us using the details in Section 14. We will respond within [CONFIRM: e.g. 30] days.
Smaqq may link to websites or services we do not operate. We are not responsible for their content or privacy practices, and we encourage you to read their policies.
Smaqq is distributed through Google Play. Your use of Google Play is governed by Google's terms and privacy policy.
For any question, request or complaint about your personal data, contact our Grievance Officer:
Grievance Officer: [NAME] Email: [GRIEVANCE EMAIL — use a role address such as privacy@smaqq.in, not a personal address] Address: [REGISTERED ADDRESS]
We will acknowledge your request and respond within [CONFIRM: e.g. 30] days.
If you are not satisfied with our response, you may escalate your complaint to the Data Protection Board of India.
We may update this policy as Smaqq changes or as the law requires.
If a change is material — for example, if we start collecting a new type of data or use your data for a new purpose — we will notify you in the app or by email before the change takes effect, and where the law requires it, we will ask for your consent again.
The "Last updated" date at the top of this policy always shows the current version. We encourage you to review it from time to time.
[COMPANY LEGAL NAME] — [REGISTERED ADDRESS], India