Draft — not yet in force. This document is a working draft pending final legal and DPDP review. Placeholders in [brackets] must be completed before public launch. It does not yet create binding obligations.

Privacy Policy

This policy explains what personal data Smaranly (the "Service") collects, why, and the rights you have over it. The data fiduciary is [OWNER-TODO: legal entity name], contactable at sanket@smaranly.com.

1. 18+ only — no children's data

The Service is for adults (18+). We do not knowingly collect personal data from anyone under 18; the onboarding age gate is designed to prevent it. If you believe a minor has provided data, contact us and we will delete it.

2. What we collect

Account identifiers — your email and name, provided through our authentication provider when you sign up.
Study and progress data — the capsules you study, your reviews, grades, schedules, streaks, confidence responses, and related learning activity, which the Service needs to schedule your revision.
Consent records — your age confirmation and your choices for optional features (e.g. the AI tutor, analytics), stored as versioned consent events.
Minimal technical data — basic, security-necessary information such as request metadata. We do not build advertising profiles.

3. Why we use it, and our lawful basis

We use your data to provide and operate the Service — to authenticate you, store your progress, schedule reviews, and honour your settings. We rely on your consent and on the necessity of processing to deliver the Service you have asked for. Optional features run only if you have consented to them, and you can withdraw that consent at any time.

4. Your rights

As a data principal, you can:

access and export a copy of your data;
correct inaccurate data;
withdraw consent for optional features;
erase your account and associated data;
raise a grievance with our grievance contact (below).

You can exercise export, consent-withdrawal, and deletion directly in the app at Settings → Privacy. Deletion removes your Service data and the associated login.

5. Who processes your data

We share data only with service providers who process it on our behalf to run the Service, under appropriate safeguards:

an authentication provider (sign-in and account security);
our application/database hosting provider (storing your study data);
where you enable them: an AI provider (for the AI tutor) and a payments provider (only if and when paid plans launch).

We do not sell your personal data.

6. Retention

We keep your data while your account is active and for as long as needed to provide the Service. When you delete your account, we delete your associated personal data, subject to any records we must retain for legal or security reasons. [OWNER-TODO: confirm specific retention periods with counsel.]

7. Where your data is processed

Your account and study data are stored on our hosting provider's infrastructure in the European Union (Ireland) [OWNER-TODO: confirm the production hosting region]. If you enable the optional AI tutor, those requests are processed by our AI provider outside India (in the United States), only under your explicit consent, with contractual safeguards (standard contractual clauses) applied.

8. Security

We use access controls, per-user data isolation, and encryption in transit to protect your data. No system is perfectly secure, but we work to protect your information and to respond to incidents responsibly.

9. Changes to this policy

We may update this policy and will record the version with your consent choices. Material changes will be notified in the app or by email where appropriate. Current consent policy version: 2026-07-18.

10. Contact and grievances

Privacy questions or requests: sanket@smaranly.com. Grievance officer: [OWNER-TODO: officer name / designation], contactable at sanket@smaranly.com. See also our Terms of Use.

Version: draft. Last updated: [OWNER-TODO: date on finalisation].