How PocketSe Handles Your Data

Effective Date: 22 May 2025

Governing Law: Digital Personal Data Protection Act, 2023 (India)

Data Fiduciary: PocketSe LLP

Contact: legal@pocketse.in

1. Who We Are

PocketSe LLP ("PocketSe", "we", "us", or "our") is building a Behavioural Reasoning Model (BRM) for human development. Our platform is designed for students aged 10–18, their parents or guardians, and institutions such as schools and colleges. We collect and process personal data to power our AI model and deliver our services.

Once the entity transitions to PocketSe Pvt. Ltd., this policy will be updated to reflect the new legal entity. The data processing practices described here remain unchanged during that transition.

2. What Data We Collect

2.1 Data You Give Us Directly

•        Name, age, and date of birth of the student

•        Email address and phone number of the parent or guardian

•        School or institution name and class

•        Login credentials (stored in encrypted form only)

2.2 Behavioural and Usage Data

This is the core of how PocketSe works. As you use the platform, we collect:

•        Task completion patterns — what you did, when you did it, and how consistently

•        Decision signals — how you respond to rewards, challenges, and pauses

•        Engagement rhythms — session length, drop-off points, and return patterns

•        Habit and routine data — the sequences of actions you build over time

This data is processed by our Behavioural Reasoning Model to generate individual behavioural profiles, predictions, and intervention signals. It is not shared with third parties for advertising or profiling purposes outside the platform.

2.3 Device and Technical Data

•        Device type and operating system

•        App version and session identifiers

•        Crash logs and error reports

•        IP address (used for security purposes only, not for profiling)

3. Why We Process This Data

We process personal data for the following purposes:

•        To deliver the PocketSe platform and its features

•        To train and improve the Behavioural Reasoning Model on an individual and aggregate basis

•        To generate behavioural predictions and intervention recommendations

•        To send in-app nudges, reminders, and progress summaries

•        To give parents and guardians visibility into their child’s progress

•        To maintain platform security and detect abuse or fraud

•        To comply with applicable laws

We do not use personal data to serve third-party advertisements. We do not sell data. Ever.

4. Legal Basis Under the DPDP Act, 2023

Under India’s Digital Personal Data Protection Act, 2023 ("DPDP Act"), PocketSe is the Data Fiduciary. We process personal data on the following lawful bases:

•        Consent — obtained from the parent or guardian for all data relating to a minor (a person under 18 years of age), prior to account creation

•        Contractual necessity — to deliver the services you have signed up for

•        Legitimate uses — where the DPDP Act permits processing without explicit consent, such as for safety, fraud prevention, or compliance with a legal obligation

For users under 18, we require verifiable parental or guardian consent before any account is activated. We do not knowingly collect data from minors without this consent.

5. How Long We Keep Your Data

We retain personal data only as long as it is needed for the purposes described above. Our standard retention windows are:

•        Active account data — retained for the duration of the account, plus 12 months after account closure

•        Behavioural model data — retained for up to 36 months to maintain model continuity; anonymised and aggregated after that period

•        Parent/guardian contact data — deleted within 30 days of account closure on request

•        Crash logs and technical data — retained for 90 days

You may request earlier deletion at any time. See Section 7 for how.

6. Who We Share Data With

We share personal data only in the following limited circumstances:

•        Cloud infrastructure providers (for hosting and storage) — bound by data processing agreements

•        Analytics partners (for platform performance, not user profiling) — receive only anonymised, aggregated data

•        Parent or guardian dashboards — progress and behavioural summaries are shared with the consenting adult linked to the account

•        Institutional dashboards (schools) — only with the specific consent of the linked parent or guardian; individual-level data is never shared with a school without this consent

•        Law enforcement or regulatory bodies — only where required by Indian law or a valid court order

We do not transfer personal data outside India. If this changes, we will update this policy and obtain fresh consent where required by the DPDP Act.

7. Your Rights

Under the DPDP Act, 2023, you (or the parent/guardian acting on behalf of a minor) have the following rights:

•        Right to access — request a summary of the personal data we hold about you

•        Right to correction — request that inaccurate or incomplete data be corrected

•        Right to erasure — request deletion of your personal data, subject to our legal retention obligations

•        Right to withdraw consent — withdraw consent at any time; this does not affect the lawfulness of processing before withdrawal

•        Right to grievance redressal — raise a complaint with our Grievance Officer (contact below)

•        Right to nominate — nominate another individual to exercise your rights in the event of death or incapacity

To exercise any of these rights, write to us at: legal@pocketse.in. We will respond within 30 days.

8. Security

We apply technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. These include:

•        Encryption of data at rest and in transit

•        Role-based access controls within our team

•        Regular security audits

•        Secure credential storage (passwords are hashed; we never store them in plain text)

No system is perfectly secure. If you suspect your account has been compromised, contact us immediately at legal@pocketse.in.

9. Children’s Privacy

PocketSe is built for users under 18. This makes children’s privacy a design priority, not an afterthought.

•        We require verifiable parental or guardian consent before activating any account for a minor

•        We do not serve targeted advertisements to minors

•        We do not build commercial profiles of minors for third-party use

•        Behavioural data collected from minors is used only for the purposes described in this policy

Parents and guardians may review, correct, or delete their child’s data at any time by contacting us at legal@pocketse.in.

10. Changes to This Policy

We may update this Privacy Policy as our product evolves or as the law requires. When we do, we will notify you via the app or email at least 7 days before the change takes effect. If the change materially affects how we use your data, we will ask for fresh consent where required.

11. Grievance Officer

In accordance with the DPDP Act, 2023, and the Information Technology Act, 2000, our Grievance Officer can be reached at:

Name: [INSERT NAME]

Designation: Grievance Officer, PocketSe LLP

Email: legal@pocketse.in

Address: [INSERT REGISTERED ADDRESS]

Response time: 30 days from receipt of grievance.

This policy is governed by the laws of India. Any disputes arising from this policy shall be subject to the jurisdiction of courts in [INSERT CITY], India.