Privacy Policy

1. Introduction

This Privacy Policy describes how GPU Tech Private Limited ("Company", "we", "us", or "our"), the developer of BluePen AI, collects, uses, stores, shares, and protects your personal data when you use our mobile application, Bluetooth-enabled pen device, associated hardware, website (bluepenai.in), and any related services (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you are a parent or legal guardian registering a child under 18 years of age, you consent to the collection and processing of your child's data as described herein.

2. Definitions

• Personal Data — any information relating to an identified or identifiable natural person, including name, email address, phone number, device identifiers, and voice data.
• Child or Student User — any user under the age of 18 years.
• Parent Account — the account registered by a parent or legal guardian on behalf of a Student User.
• Session Data — data generated during an AI tutoring session, including voice queries, topics accessed, session duration, and AI-generated responses.
• Device Data — information collected from the BluePen AI pen or the mobile device running the app, including Bluetooth identifiers, device model, OS version, and connectivity status.
• Processing — any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, or deletion.

3. Data We Collect

3.1 Information You Provide Directly

• Account Registration: Full name of parent/guardian, email address, phone number, city, and password.
• Student Profile: Student's first name (or pseudonym), class/grade, education board, preferred language, and selected AI teacher persona.
• Payment Data: Subscription plan, payment method, and transaction ID. We do not store full card numbers. Payments processed by Razorpay or Stripe.
• Support Data: Messages or feedback sent via in-app support or email ([email protected]).

3.2 Information Collected Automatically

• Voice Query Data: Audio transmitted to our AI for real-time processing. Not permanently stored after the session ends.
• Session and Usage Data: Topics accessed, chapters studied, session duration, AI persona selected, number of questions asked.
• Device and Technical Data: Bluetooth status, device model, OS version, app version, anonymised IP address, crash logs.
• Parent Notification Data: Session completion status sent to parent's phone via WhatsApp (Twilio) or SMS.

4. How We Use Your Data

• Service Delivery: To provide AI-powered tutoring sessions and deliver curriculum-aligned content.
• Parent Reporting: To generate session summaries and weekly progress reports.
• Account Management: To create and manage accounts and process payments.
• Product Improvement: To analyse anonymised usage patterns. Individual voice recordings are not used for model training.
• Safety and Security: To detect fraud and prevent misuse.
• Legal Compliance: To comply with applicable laws and regulatory requests.
• Communication: To send service notifications and (with your consent) promotional updates. You may opt out at any time.

5. Data Retention

• Account Data: Retained for the duration of your active account plus 90 days after deletion request.
• Session Data (metadata): Retained for 24 months. Older data is anonymised.
• Voice Query Audio: Not stored on our servers after the AI response is generated.
• Payment Data: Retained for 7 years as required by Indian tax regulations.
• Anonymised Data: May be retained indefinitely for research and analytics.

6. Children's Privacy and Student Data Protection

• Parental Consent: A parent or guardian must create the account before a child can use the Services.
• Minimal Data Collection: We collect only what is necessary to provide the tutoring service.
• No Behavioural Advertising: We do not serve advertisements to children or use their data for marketing profiling.
• No Social Features: The app does not include chat rooms, forums, or any functionality that allows children to communicate with strangers.
• Parental Control: Parents have full access to their child's usage data and may request correction or deletion at any time.
• Voice Data: Processed in real-time and not permanently stored. We do not create voice profiles.

7. Data Sharing and Third-Party Services

We do not sell, rent, or trade your Personal Data. We share data only with:

• AI API: Voice queries processed to generate tutoring responses.
• Twilio: Parent phone numbers shared to deliver WhatsApp/SMS notifications.
• Payment Processors: Razorpay or Stripe for subscription payments.
• Legal and Regulatory: When required by law or to protect the safety of our users.

8. Data Security

• Encryption: All data encrypted in transit using TLS 1.2+. Sensitive data at rest encrypted using AES-256.
• Access Controls: Access restricted to authorised personnel with multi-factor authentication.
• Bluetooth Security: BLE pairing protocols with encryption between pen and app.
• Incident Response: We will notify affected users and relevant authorities within 72 hours of a data breach.

9. International Data Transfers

Your data may be transferred to India (our headquarters) and the United States (Twilio servers). For transfers from the EEA, we rely on Standard Contractual Clauses (SCCs). For Indian residents, we comply with the Digital Personal Data Protection Act, 2023 (DPDPA).

10. Your Rights

• Right to Access, Correction, Deletion, and Data Portability — available to all users.
• EU/EEA residents have additional rights under GDPR including right to restriction, right to object, and right to lodge a complaint with your local supervisory authority.
• Indian residents have rights under DPDPA 2023 including right of grievance redressal and right to nominate.

To exercise any of these rights, contact [email protected]. We will respond within 30 days.

11. Cookies

Our website uses only essential cookies to maintain session state and preferences. We do not use tracking or advertising cookies. The BluePen AI mobile app does not use cookies.

12. Legal Basis for Processing (GDPR)

• Consent: Account creation, children's data, and promotional communications.
• Contractual Necessity: To provide the Services you subscribed to.
• Legitimate Interests: Product improvement using anonymised data and fraud prevention.
• Legal Obligation: Tax records and regulatory compliance.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via the app and website. Continued use of the Services after notification constitutes acceptance.

14. Grievance Officer

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