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Privacy Policy

Effective Date: 18 October 2026  |  Last Updated: 18 October 2026

This Privacy Policy describes how Devity ("we," "us," or "our") collects, uses, stores, and protects information when you use the Samvaad mobile application and the website located at samvaad.app (collectively, the "Service"). By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.

We are committed to protecting your privacy and handling your data in a transparent and lawful manner. If you do not agree with the practices described in this Privacy Policy, please do not use the Service.

1. Information We Collect

1.1 Information You Provide

When you create an account or interact with the Service, we may collect the following information directly from you:

  • Account information: email address and display name provided during registration.
  • User-generated content: feedback, support inquiries, and any optional survey responses you submit.
  • Account deletion requests: email address and optional reason for leaving, submitted through our account deletion form.

1.2 Information Collected Automatically

When you use the Service, certain information is collected automatically through analytics and tracking technologies:

  • Usage data: lesson progress, scores, completion status, streak data, XP totals, and exercise performance across the app's 9 worlds, 21 units, and 130 lessons.
  • Device information: device model, operating system version, unique device identifiers, and app version.
  • Analytics data: pages visited, interaction events, session duration, and referral sources, collected via Google Analytics (Google Tag Manager).
  • Advertising data: conversion events related to Google Ads campaigns, including install and download actions on Google Play.

1.3 Information from Third-Party Services

If you sign in using a third-party authentication provider (such as Google Sign-In), we receive basic profile information (name and email address) as permitted by your settings with that provider. We do not receive or store your password from any third-party service.

2. How We Use Your Information

We use the information we collect for the following purposes:

PurposeData Used
Provide and operate the Service, including tracking lesson progress, adaptive practice, streaks, and leaderboardsAccount information, usage data
Personalise your learning experience (e.g., identifying strong and fading skills)Usage data, exercise performance
Process Premium subscription purchases and manage entitlementsAccount information, transaction identifiers (processed by Google Play)
Respond to support requests and account deletion requestsEmail address, submitted content
Analyse Service usage, diagnose technical issues, and improve the appAnalytics data, device information
Measure the effectiveness of advertising campaignsAdvertising conversion data
Comply with legal obligations and enforce our Terms of ServiceAll categories as necessary

3. Legal Basis for Processing

Depending on where you are located, we rely on the following legal bases for processing your personal data:

  • Performance of a contract: processing necessary to provide the Service to you (e.g., maintaining your account, recording progress).
  • Legitimate interests: improving the Service, ensuring security, and measuring advertising effectiveness, provided these interests are not overridden by your rights.
  • Consent: where required by applicable law, particularly for certain analytics and advertising technologies. You may withdraw consent at any time.
  • Legal obligation: processing necessary to comply with applicable law or regulation.

4. Third-Party Services

The Service integrates with the following third-party services, each of which operates under its own privacy policy:

  • Google Firebase (Cloud Firestore, Authentication): used for data storage, user authentication, and processing account deletion requests. See Firebase Privacy and Security.
  • Google Analytics / Google Tag Manager: used to collect anonymous usage statistics and analyse user behaviour on the website. See Google Privacy Policy.
  • Google Ads: used to measure advertising conversions (e.g., Google Play download clicks). See Google Privacy Policy.
  • Google Play: used for app distribution and in-app purchase processing. See Google Privacy Policy.

We do not sell, rent, or trade your personal information to any third party.

5. Data Storage and Security

Your data is stored on Google Cloud infrastructure through Firebase services. We implement reasonable administrative, technical, and physical safeguards to protect your information from unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS) and at rest, access controls, and regular review of our data handling practices.

While we take reasonable steps to protect your data, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

6. Data Retention

We retain your personal data for as long as your account remains active or as needed to provide the Service. Specifically:

  • Account and usage data: retained for the duration of your account.
  • Account deletion requests: processed within 7 business days of submission. Following deletion, your data is permanently removed from our active systems within 30 days, except where retention is required by law.
  • Analytics data: retained in accordance with Google Analytics' data retention settings, which we have configured to a maximum of 14 months.

7. Your Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal data:

  • Access: request a copy of the personal data we hold about you.
  • Correction: request that we correct inaccurate or incomplete personal data.
  • Deletion: request deletion of your personal data. You may submit a deletion request through the Account Deletion page or by contacting us directly.
  • Portability: request a machine-readable copy of the data you have provided to us.
  • Restriction: request that we restrict the processing of your personal data under certain circumstances.
  • Objection: object to the processing of your personal data for direct marketing or where we rely on legitimate interests.
  • Withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us at privacy@devity.in. We will respond to your request within 30 days or such shorter period as required by applicable law.

8. Children's Privacy

The Service is not directed to children under the age of 13 (or the minimum age required by applicable law in your jurisdiction). We do not knowingly collect personal data from children under this age. If we become aware that we have collected personal data from a child below the applicable minimum age without verified parental consent, we will take steps to delete that information promptly. If you believe a child has provided us with personal data, please contact us at privacy@devity.in.

9. International Data Transfers

Your information may be transferred to and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from those of your jurisdiction. Where we transfer personal data internationally, we ensure appropriate safeguards are in place in accordance with applicable data protection laws.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last Updated" date at the top of this page and, where required by applicable law, provide additional notice (such as in-app notification). Your continued use of the Service after such changes constitutes acceptance of the updated Privacy Policy.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Devity
Email: privacy@devity.in

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