Privacy Policy

a) Information You Provide

• Parent/Guardian account information: Name, email address, password (encrypted)
• Learner profile: Name or nickname, age, grade level, learning preferences, curriculum country
• Learning interactions: Questions asked, answers provided, exam responses, study progress
• Voice data: Audio input when using voice tutoring sessions (transcribed in real-time; transcripts retained — see Section 8 for retention)
• Support communications: Messages you send to our support team

b) Information Collected Automatically

• Device information: Device type, operating system, app version, unique device identifiers
• Usage data: Features used, session duration, interaction frequency
• Notification tokens: For push notification delivery
• Purchase data: See Section 3 below

c) Information We Do NOT Collect

• Credit card or bank account numbers
• Government-issued identification numbers
• Biometric data (fingerprints, facial recognition)
• Precise geolocation (GPS coordinates)

We use a small number of trusted providers to operate the service. They process data on our behalf, under contract, and only for the purposes listed below.

We do not sell personal information, and we never send a learner's name or a child's profile data to these providers. On iOS you are asked for permission before any advertising identifier is used, and you can change that choice at any time in your device settings.

PopGamma offers optional paid monthly subscriptions (Starter, Super, Ultra), one-time Exam Boost purchases and one-time course purchases. All payments are processed entirely through Google Play Billing (Android) or Apple In-App Purchase (iOS). PopGamma does not collect, store, or have access to your payment card details, billing address or bank information.

What we receive and store in relation to purchases:

• Store transaction identifier (to activate your purchase and prevent duplicate charges)
• The product purchased (subscription plan, Exam Boost or course) and its store product identifier
• Subscription status (active, cancelled, in grace period, expired) and the end date of the current period
• Purchase date and, for one-time purchases, expiry date
• Purchase environment (production or sandbox/testing)
• Your remaining allowances and usage counters

Payment management: We use RevenueCat as an intermediary to manage purchase receipts and subscription entitlements. RevenueCat receives transaction data from Google Play or Apple and your PopGamma account identifier, but never receives your payment card information. Because the same interface is used to check whether a purchase exists, a RevenueCat customer record may be created for your account even if you never make a purchase. See RevenueCat's privacy policy: https://www.revenuecat.com/privacy/

Analytics and advertising measurement: Purchase and paywall events — including the product, the plan, the amount and the currency — are shared with Amplitude (product analytics) and Meta (advertising measurement), as described in Section 2.

Store notifications: We keep a technical log of the purchase and subscription notifications Apple and Google send us, so that we can activate purchases reliably, reconcile our accounts and detect fraud. See Section 8 for how long we keep it.

Refunds: Refund requests are handled through Google Play or Apple. See our Terms of Service for the refund commitments we make.

We use your information to:

• Personalize learning: Adapt content to your learner's age, grade, curriculum, and learning progress
• Provide AI tutoring: Process questions and generate educational responses through our AI tutor, Prof. Albert
• Track progress: Enable parents to monitor their child's learning journey
• Send notifications: Growth updates, feature announcements, and account-related communications
• Improve our service: Analyze usage patterns to improve the App's educational quality
• Process purchases: Activate and manage your subscription, Exam Boost or course, track your remaining allowances, and prevent duplicate charges
• Prevent abuse: Detect and prevent fraudulent or unauthorized usage

We do NOT:

• Show advertising of any kind inside the App
• Sell personal data to third parties
• Create advertising or marketing profiles of children
• Use children's data for any purpose other than providing the educational service

Advertising measurement: We do measure the effectiveness of our own advertising. Purchase and app events are shared with Meta for attribution, and on iOS a device advertising identifier is used only if you explicitly allow tracking when asked. This happens at parent-account level and never uses a learner's profile data. We do not display advertising inside the App, and we do not build advertising profiles of children.

PopGamma uses artificial intelligence to generate educational content, including explanations, quizzes, study cards, and exam evaluations. Please be aware that:

• AI-generated content may occasionally contain errors or inaccuracies
• Content is provided for educational purposes only and does not constitute professional advice
• Parents and guardians should supervise their child's use of AI-generated content
• We continuously work to improve the accuracy and quality of AI responses

PopGamma is designed for learners aged 6 and older, used under parental supervision. We take children's privacy seriously and comply with applicable children's privacy laws, including the Children's Online Privacy Protection Act (COPPA).

Our commitments:

• Parental consent required: A parent or legal guardian must create and manage the account
• Minimal data collection: We collect only the information necessary to provide the educational service
• No behavioral advertising: We never use children's data for advertising, profiling, or marketing
• No social features: Children cannot publicly share information, communicate with other users, or post content
• Parental access: Parents can review, modify, or delete their child's data at any time

If we learn that we have collected personal information from a child without verified parental consent, we will delete that information promptly.

Parents and guardians can exercise the following controls at any time:

• Review their child's learning data and progress through the App's Profile section
• Update their child's profile information
• Delete their child's profile and all associated learning data
• Request full account deletion by contacting contact@popgamma.com

Retention periods:

• Account data: Retained while your account is active. Deleted within 30 days of account deletion request
• Learning interactions: Retained while your account is active to provide personalized learning
• Voice data: Audio recordings are processed in real-time; transcripts are retained as part of learning interactions to support personalized tutoring
• Subscription and purchase records: Retained while your account is active, and afterwards for the period required by applicable tax and financial regulations (typically 7 years)
• Store notification logs: Technical records of the purchase and subscription notifications received from Apple and Google, retained for up to 7 years for accounting reconciliation and fraud prevention
• Usage analytics: Aggregated and anonymized data may be retained indefinitely for service improvement

How to request deletion:

• In-app: Go to Profile → Settings → Delete Account
• By email: Send a request to contact@popgamma.com with the subject "Data Deletion Request"

We will process your deletion request within 30 days. Account deletion will permanently remove all learner profiles and learning history, forfeit any remaining subscription period, Exam Boost quota and course access, and revoke access to all App features. Purchase records and store notification logs are kept after deletion for the period required by applicable tax and financial regulations, as described above.

Deleting your account does not cancel a subscription bought through the App Store or Google Play. You must also cancel it in your store settings to stop being billed.

We implement industry-standard security measures to protect your information:

• Encryption: Data encrypted in transit (TLS/SSL) and at rest
• Access controls: Role-based access limited to authorized personnel
• Authentication: Secure token-based authentication (Firebase JWT)
• Regular audits: Periodic security reviews and vulnerability assessments
• Incident response: Established procedures for detecting and responding to data breaches

While we strive to protect your data, no method of electronic transmission or storage is 100% secure. If you suspect unauthorized access to your account, please contact us immediately at contact@popgamma.com.

Your data is primarily stored on servers located in India — our application database (Supabase) and our backend hosting (Microsoft Azure) are both in India. If you access PopGamma from outside India, your data may be transferred to and processed in India. By using the App, you consent to this transfer.

Some of the providers listed in Section 2 process data outside India, including in the European Union and the United States — in particular the AI model providers that generate educational content, and our analytics, advertising measurement and purchase management providers. Only the data needed for the relevant feature is sent to them.

Where required by applicable law (such as the GDPR for users in the European Economic Area), we ensure appropriate safeguards are in place for international data transfers, including standard contractual clauses.

Depending on your location, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal data (see Section 8)
• Portability: Request your data in a structured, machine-readable format
• Objection: Object to certain processing of your data
• Withdraw consent: Withdraw previously given consent at any time

For users in the European Economic Area (EEA): We process your data based on consent (for optional features) and legitimate interest (for providing the educational service). You may contact your local Data Protection Authority if you believe your rights have been violated.

For users in California (CCPA): You have the right to know what personal information we collect, request its deletion, and opt-out of its sale. We do not sell personal information.

To exercise any of these rights, please contact us at contact@popgamma.com.

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date, notify you via email, and display an in-app notification. Your continued use of PopGamma after changes are posted constitutes your acceptance of the updated Privacy Policy.

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