Leoki

Privacy Policy

Last Updated: July 22, 2026

1. Introduction

At Tryzent Technologies Private Limited ("Tryzent", "Leoki", "we", "us", or "our"), we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you use the Leoki platform, including our AI-powered voice tutoring services, learning tools, mobile applications, and related services (collectively, the "Platform" or "Services").

1.1 Scope

This Privacy Policy applies to all users of the Leoki Platform, including:

•Students using the Platform for learning

•Teachers using the Platform for professional development

•Parents monitoring their children's learning progress

•Educational institutions and administrators (future functionality)

•Visitors to our website

1.2 Our Commitment

We are committed to:

•Transparency in our data collection and processing practices

•Protecting your personal information with industry-standard security measures

•Respecting your privacy rights and choices

•Complying with applicable data protection laws, including the Digital Personal Data Protection Act (DPDP), 2023

•Processing data fairly, lawfully, and only for specified purposes

•Minimizing data collection to what is necessary for our services

1.3 Consent and Agreement

By accessing, registering for, or using the Leoki Platform, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your information as described in this Privacy Policy.

For Parents/Guardians: If you are creating an account for a minor (under 18 years of age), you consent to the collection and processing of their information as described in this Privacy Policy and accept responsibility for their use of the Platform.

If you do not agree with this Privacy Policy, please do not use the Leoki Platform.

1.4 Relationship with Terms and Conditions

This Privacy Policy should be read in conjunction with our Terms and Conditions available at https://www.leoki.ai/terms-and-conditions In case of any conflict between this Privacy Policy and the Terms and Conditions, the Terms and Conditions shall prevail.

2. Information We Collect

We collect various types of information to provide, maintain, improve, and personalize our Services. The information we collect falls into the following categories:

2.1 Information You Provide Directly

Account and Registration Information: When you create an account or register for our Services, we collect:

•Full name

•Email address

•Phone number (optional)

•Password (encrypted and securely hashed)

•Date of birth

•User type (Student, Teacher, Parent)

•Educational institution or school affiliation (if applicable)

•Education Board, Grade level or class

•Account creation date and registration method

Profile Information: You may optionally provide:

•Profile picture or avatar

•Biography or description

•Areas of expertise or interest

•Preferred subjects or learning topics

•Language preferences

•Learning goals and objectives

•Educational background

Payment and Billing Information: When you purchase a subscription, we collect:

•Billing name and address

•GST number (if applicable for business/institutional users)

•Transaction IDs from our payment gateway (Razorpay)

•Purchase history and subscription details

•Invoice and payment receipts

Important: We do not store your complete credit card numbers, debit card numbers, CVV codes, or banking passwords. All sensitive payment data is securely processed and stored by our payment gateway provider, Razorpay, in compliance with PCI DSS standards.

Communication Information: When you contact us or communicate through the Platform, we collect:

•Support tickets and customer service inquiries

•Email correspondence with our team

•Feedback, surveys, and reviews

•Messages or communications sent through the Platform

•Any other information you choose to provide

Parental Consent Information: For users under 18 years of age:

•Parent/guardian name and contact information

•Relationship to the minor

•Consent records and verification information

•Parental authorization for data processing

2.2 Information Collected Automatically

Voice and Conversation Data: When you use our AI-powered voice tutoring features:

•Voice Transcripts: Your voice inputs are converted to text transcripts in real-time. We store these text transcripts but do not store the actual audio recordings.

•Conversation History: Complete transcripts of your conversations with AI tutors, including your questions, prompts, and AI responses

•Interaction Timestamps: Date and time of each conversation and interaction

•Voice Session Duration: Length of each tutoring session

•Conversation Context: Subject, topic, and learning context associated with each session

Important Voice Data Notice:

•We do NOT store your actual voice audio recordings

•Voice inputs are processed in real-time and immediately converted to text

•Original audio files are deleted immediately after transcription

•Only text transcripts are stored for adaptive learning and progress tracking

Learning and Usage Data: We automatically collect information about how you use the Platform:

•Learning Progress: Assessment scores, quiz results, lesson completion status, skill mastery levels

•Time Spent: Duration of study sessions, time spent on specific topics or lessons

•Learning Patterns: Frequency of use, preferred study times, learning pace

•Content Accessed: Lessons viewed, subjects studied, resources accessed

•Feature Usage: Which Platform features and tools you use most frequently

•Navigation Paths: Pages visited, click patterns, and user journey through the Platform

•Engagement Metrics: Interaction rates, response times, completion rates

Assessment and Performance Data:

•Test scores and quiz results

•Assignment submissions and grades

•Practice exercise performance

•Progress toward learning goals

•Strengths and areas for improvement

•Skill proficiency levels

•Historical performance trends

Technical and Device Information: We automatically collect technical information when you access the Platform:

•IP Address: Internet Protocol (IP) address and approximate geolocation (city/country level)

•Device Information: Device type, model, manufacturer, operating system, version

•Browser Information: Browser type, version, language settings, screen resolution

•Device Identifiers: Unique device identifiers for mobile devices

•Access Information: Date and time of access, session duration, referring URLs

•Log Data: Server logs, error logs, crash reports, debugging information

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and collect information.

Types of Cookies We Use:

Essential Cookies (Required):

•Session management and authentication

•Security and fraud prevention

•Platform functionality and features

•User preferences and settings

Analytics Cookies (with consent where required):

•Google Analytics to understand usage patterns

•Performance monitoring and optimization

•User behavior analysis

•Feature effectiveness measurement

How to Control Cookies:

•You can control and manage cookies through your browser settings

•Most browsers allow you to refuse cookies or alert you when cookies are being sent

•Disabling essential cookies may affect Platform functionality

•You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on

For more information about cookies, visit www.allaboutcookies.org.

2.4 Information from Third-Party Sources

Authentication Providers: When you sign in using third-party authentication:

•Google OAuth: We receive your name, email address, and profile picture from Google

Payment Gateway: From Razorpay, we receive:

•Transaction status and confirmation

•Transaction ID and payment timestamp

•Limited payment method information (e.g., "Credit Card", "UPI")

•Success or failure status

Educational Institutions (Future): When the Platform is deployed by schools or institutions:

•Student roster information (names, grades, classes)

•Enrollment and course information

•Institutional email addresses

•Teacher and administrator assignments

AI Service Providers:

•Confirmation of successful API calls

•Error messages and debugging information

•Usage statistics for billing purposes

Public Sources: We may supplement information with publicly available data:

•Educational curriculum and standards

•Subject matter references and materials

•General educational research and resources

2.5 Information About Minors

For users under 18 years of age, we collect:

•Information necessary for account creation (with parental consent)

•Learning progress and performance data

•Voice conversation transcripts for educational purposes

•Parent/guardian contact information

We do not knowingly collect personal information from children under 18 without verified parental consent. See Section 9 for more details on Children's Privacy.

3. How We Use Your Information

We use the collected information for legitimate purposes to provide, maintain, improve, and personalize our Services:

3.1 Service Provision and Delivery

Core Platform Services:

•Create, maintain, and manage your user account

•Authenticate and verify your identity

•Enable access to appropriate content based on user role and grade level

•Deliver AI-powered voice tutoring and conversational learning experiences

•Process and respond to your questions and prompts

•Provide personalized learning recommendations and adaptive content

•Track and display your learning progress and achievements

Voice Tutoring Services:

•Convert voice inputs to text for processing

•Send transcripts to AI providers to generate tutoring responses

•Maintain conversation context for coherent multi-turn interactions

•Store conversation history for review and continued learning

•Enable voice-based interaction with educational content

Subscription and Payment Processing:

•Process subscription purchases and credit transactions

•Manage billing and invoicing

•Send payment confirmations and receipts

•Handle refund requests (in accordance with our refund policy)

•Maintain transaction records for accounting and tax compliance

3.2 Personalization and Adaptive Learning

Individualized Learning Experience:

•Analyze your learning patterns, strengths, and areas for improvement

•Adapt content difficulty and pace to your skill level

•Provide personalized lesson recommendations

•Track progress toward learning goals

•Generate customized practice exercises and assessments

Conversation Analysis:

•Use conversation transcripts to understand your learning needs

•Identify knowledge gaps and misconceptions

•Provide targeted feedback and explanations

•Adjust tutoring approach based on your responses and progress

•Remember context from previous sessions for continuity

3.3 Platform Improvement and Development

Service Enhancement:

•Analyze usage patterns to improve user experience

•Identify and fix bugs, errors, and technical issues

•Develop new features and functionality

•Optimize AI tutor performance and response quality

•Enhance voice recognition and transcription accuracy

•Improve content relevance and educational effectiveness

Research and Analytics:

•Conduct educational research using aggregated, anonymized data

•Analyze learning trends and outcomes

•Evaluate effectiveness of teaching methods and content

•Benchmark performance against educational standards

•Generate insights for product development

Quality Assurance:

•Review AI-generated responses for accuracy and appropriateness

•Monitor conversation quality and user satisfaction

•Identify areas where AI tutors need improvement

•Ensure content aligns with curriculum standards

3.4 Communication and Support

Transactional Communications (Cannot Opt-Out):

•Account creation and verification emails

•Welcome messages for new users

•Password reset and security notifications

•Subscription confirmation and renewal notices

•Payment receipts and invoices

•Important service updates and announcements

•Security alerts and account notifications

•Changes to Terms and Conditions or Privacy Policy

Customer Support:

•Respond to your inquiries, questions, and support requests

•Troubleshoot technical issues

•Provide guidance on using Platform features

•Resolve billing or payment issues

•Handle feedback and complaints

Educational Updates (Optional - Future):

•New feature announcements

•Learning tips and study recommendations

•Educational content updates

•Platform news and developments

•Promotional offers and discounts (with your consent)

3.5 Analytics and Reporting

User Analytics:

•Student Dashboards: Display personal learning progress, scores, achievements, and recommendations

•Parent Dashboards: Show children's learning activity, progress, time spent, and areas of focus

•Teacher Dashboards: Display personal usage and professional development progress (future: classroom analytics)

Platform Analytics:

•Monitor overall Platform performance and health

•Track user engagement and retention

•Measure feature adoption and effectiveness

•Identify trends in learning behavior

•Generate usage reports for business operations

Aggregated Insights:

•Create de-identified, aggregated reports on learning trends

•Share anonymized educational research findings

•Provide industry benchmarks and insights

•Support academic research on AI-powered learning

3.6 Security, Safety, and Compliance

Platform Security:

•Detect and prevent fraud, abuse, and security threats

•Investigate suspicious activity or policy violations

•Protect against spam, malware, and cyberattacks

•Monitor for unauthorized access or data breaches

•Ensure account security and integrity

Legal Compliance:

•Comply with applicable laws, regulations, and legal obligations

•Respond to legal requests, court orders, and government inquiries

•Enforce our Terms and Conditions

•Protect the rights, property, and safety of Tryzent, our users, and the public

•Maintain records as required by law (e.g., tax records, transaction logs)

Content Moderation:

•Monitor user-generated content for appropriateness

•Detect and remove prohibited content

•Ensure child safety and appropriate content for minors

•Prevent misuse of AI tutoring features

3.7 Business Operations

•Manage internal business operations and administration

•Conduct financial accounting and bookkeeping

•Perform business analytics and forecasting

•Evaluate and improve business processes

•Train and support our staff

•Manage vendor relationships

4. How We Share Your Information

We respect your privacy and do not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the limited circumstances described below:

4.1 Third-Party Service Providers

We engage trusted third-party service providers to help us operate the Platform and deliver Services. These providers are contractually obligated to:

•Use your information only as necessary to perform services on our behalf

•Implement appropriate security measures to protect your data

•Comply with applicable data protection laws

•Not use your data for their own purposes or share it with others

Current Third-Party Service Providers:

AI and Machine Learning Providers:

•OpenAI: Powers conversational AI and natural language understanding for tutoring responses

•Microsoft Azure AI Services: Provides speech-to-text conversion, text-to-speech, and cognitive services

•Sarvam AI: Delivers multilingual AI capabilities for regional language support

Data Shared with AI Providers:

•Student prompts, questions, and conversation inputs

•Student name (for personalization)

•Learning context (subject, grade level, topic)

•Conversation history for maintaining context

•Anonymized usage statistics

AI Provider Safeguards:

•We use standard API agreements with terms prohibiting use of your data for training their general AI models without explicit authorization

•Data is processed solely to deliver the requested tutoring services

•AI providers implement security measures to protect data in transit and at rest

•Data processing occurs in accordance with their respective privacy policies

Cloud Hosting and Infrastructure:

•Amazon Web Services (AWS): Hosts our Platform and stores data in Indian data centers

•Subject to AWS Privacy Policy

•Data is stored in AWS Mumbai region and other Indian availability zones

Payment Processing:

•Razorpay: Processes payments securely for subscription purchases

•Subject to Razorpay's Privacy Policy

•We share billing information necessary for transaction processing

•Razorpay handles all sensitive payment data in compliance with PCI DSS standards

Email Communication Services:

•Amazon SES (Simple Email Service): Sends transactional emails including account notifications, invoices, and updates

•We share email addresses and message content necessary for delivery

Analytics and Monitoring:

•Google Analytics: Analyzes Platform usage, user behavior, and engagement patterns

•Subject to Google Privacy Policy

•Data is anonymized and aggregated where possible

•You can opt out using the Google Analytics Opt-out Browser Add-on

Authentication Services:

•Google OAuth: Handles Google sign-in authentication

•Amazon Cognito: Manages user authentication and identity verification

4.2 Educational Institutions and Administrators (Future)

When Leoki is deployed by schools, educational institutions, or organizations:

•Institutional Administrators may have access to:

•Student roster and enrollment information

•Aggregate usage statistics and engagement reports

•Classroom-level performance analytics (not individual student data without permission)

•Teacher usage and professional development progress

•Teachers may have access to (with appropriate permissions):

•Student learning progress and performance data (future functionality)

•Classroom analytics and aggregate reports

•Assignment and assessment results

Note: Individual student data access by teachers is a future planned feature and will require explicit parental consent and appropriate privacy controls.

Institutional Agreements: Separate data processing agreements may be established with educational institutions to:

•Define data ownership and access rights

•Establish security and privacy standards

•Clarify roles and responsibilities for data protection

•Ensure compliance with applicable educational privacy laws

4.3 Parents and Guardians

Parents and legal guardians have the right to:

•Access their children's (under 18) learning data and progress

•View conversation histories and transcripts

•Monitor usage patterns and time spent

•Review performance reports and analytics

•Request corrections or deletion of their children's data

Parents can access this information through their Parent Dashboard or by contacting us at info@leoki.ai.

4.4 Legal Requirements and Protection of Rights

We may disclose your information when required or permitted by law:

Legal Compliance:

•To comply with applicable laws, regulations, or legal obligations

•To respond to valid legal processes (subpoenas, court orders, warrants)

•To cooperate with government or regulatory authority investigations

•To meet tax, accounting, or audit requirements

Protection of Rights:

•To enforce our Terms and Conditions and other agreements

•To protect against legal liability or potential fraud

•To investigate and prevent security threats, illegal activities, or policy violations

•To protect the rights, property, and safety of Tryzent, our users, or the public

•To prevent harm to children or vulnerable users

•To address suspected abuse or misuse of the Platform

Emergency Situations:

•To respond to emergencies involving danger of death or serious physical injury

•To protect the vital interests of any person

4.5 Business Transfers and Corporate Transactions

In the event of a merger, acquisition, reorganization, bankruptcy, dissolution, or sale of all or a portion of our assets:

•Your information may be transferred to the acquiring or successor entity

•We will provide notice before your information is transferred

•The acquiring entity will be required to honor this Privacy Policy or obtain your consent for material changes

•You will have the opportunity to request deletion of your data before the transfer (subject to legal requirements)

4.6 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you, for purposes such as:

•Educational research and academic publications

•Industry reports and benchmarking

•Platform performance statistics

•Marketing and business development

•Public communications about AI-powered learning effectiveness

•Training and improving our internal systems

This information does not identify individual users and is not considered personal information.

4.7 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing, such as:

•When you authorize integration with third-party educational applications

•When you participate in co-branded offerings or partnerships

•When you request us to share information with specific parties

•When you provide explicit consent for specific data sharing purposes

You may withdraw your consent at any time by contacting us at info@leoki.ai.

4.8 No Sale of Personal Information

We do not and will not sell your personal information to third parties for monetary or other valuable consideration. We do not rent or trade your personal information to third parties for their direct marketing purposes.

5. Data Storage, Security, and Retention

5.1 Data Storage Location

Primary Storage Location: Your data is primarily stored and processed in India:

•Hosted on Amazon Web Services (AWS) servers located in Indian data centers

•Primary region: AWS Mumbai (ap-south-1)

•Backup and redundancy across other AWS India availability zones

•Ensures data residency in India for compliance with local regulations

Benefits of Indian Data Storage:

•Faster access and better performance for Indian users

•Compliance with data localization requirements

•Data sovereignty and regulatory alignment

•Reduced latency for real-time voice interactions

5.2 Data Security Measures

We implement comprehensive technical, administrative, and physical security measures to protect your information:

Technical Security:

•Encryption: Data encrypted in transit using TLS/SSL protocols (HTTPS) and at rest using AES-256 encryption

•Authentication: Secure authentication mechanisms including password hashing with bcrypt and multi-factor authentication capabilities

•Access Controls: Role-based access control (RBAC) with principle of least privilege

•Firewalls: Network-level and application-level firewalls to prevent unauthorized access

•Intrusion Detection: Monitoring systems to detect and respond to security threats

•Secure APIs: Encrypted API communications with third-party services

•Security Patches: Regular updates and security patches for all systems and software

•Vulnerability Scanning: Regular security assessments and penetration testing

•Data Segregation: Logical separation of user data to prevent unauthorized cross-access

Administrative Security:

•Access Policies: Strict policies governing who can access user data

•Employee Training: Regular security awareness and data protection training for all staff

•Background Checks: Verification of personnel handling sensitive data

•Confidentiality Agreements: All employees and contractors sign confidentiality agreements

•Security Policies: Comprehensive information security policies and procedures

•Incident Response: Documented procedures for responding to security incidents

•Regular Audits: Periodic security audits and compliance reviews

Physical Security:

•AWS data centers with industry-leading physical security controls

•24/7 monitoring and surveillance

•Controlled access to server facilities

•Environmental controls (fire suppression, cooling, power backup)

Payment Security:

•PCI DSS compliant payment processing through Razorpay

•No storage of complete credit card numbers, CVV codes, or banking passwords

•Tokenization of payment information

•Secure payment gateway integration

Operational Security:

•Backup Systems: Regular automated backups with secure offsite storage

•Disaster Recovery: Documented disaster recovery and business continuity plans

•Monitoring: 24/7 system monitoring and alerting

•Logging: Comprehensive audit logs of system access and data operations

•Data Minimization: Collection limited to necessary information only

5.3 Limitations of Security

While we implement industry-standard security measures:

•No system is 100% secure: No method of transmission over the Internet or electronic storage is completely secure

•User Responsibility: You are responsible for maintaining the security of your account credentials

•Third-Party Risk: We cannot guarantee the security of information transmitted to or from third-party services

•Shared Responsibility: Security is a shared responsibility between Tryzent and users

Your Security Responsibilities:

•Use strong, unique passwords for your account

•Do not share your account credentials with others

•Log out after using shared devices

•Keep your email account secure (used for password resets)

•Report suspicious activity immediately to info@leoki.ai

•Be cautious of phishing attempts and suspicious emails

Security Incident Reporting: If you suspect unauthorized access to your account or become aware of any security vulnerability, immediately contact us at info@leoki.ai.

5.4 Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Active Account Data:

•Account Information: Retained while your account is active and for a reasonable period after closure

•Conversation Transcripts: Retained while your account is active to support adaptive learning and progress tracking

•Learning Progress Data: Retained to maintain historical learning records and analytics

•Usage Logs: Retained for security and operational purposes

After Account Closure or Deletion: When you close your account or request data deletion:

•Personal identifiable information is deleted within a reasonable timeframe (typically 30-90 days)

•Some data may be retained in anonymized or aggregated form for analytics and research

•Backup systems are purged during regular backup cycles (typically within 90 days)

Legal and Regulatory Retention: Certain data may be retained longer when required by law or for legitimate business purposes:

•Transaction Records: Payment and invoice data retained for 7 years for tax and accounting compliance (as required by Indian tax laws)

•Legal Holds: Data preserved during ongoing legal proceedings or investigations

•Fraud Prevention: Information about fraudulent or suspicious activity retained to prevent future fraud

•Dispute Resolution: Data relevant to ongoing disputes retained until resolution

Specific Retention Periods:

•Voice Transcripts: Retained while account is active; can be deleted upon request

•Learning Analytics: Retained while account is active and for historical analysis

•Payment Records: 7 years for tax compliance

•Technical Logs: 90 days for security and troubleshooting

•Support Communications: Retained for quality assurance and future reference

Anonymized Data:

•Aggregated, de-identified, or anonymized data may be retained indefinitely for research, analytics, and platform improvement

•This data cannot be used to identify individual users

5.5 Data Deletion

User-Requested Deletion: You can request deletion of your data by contacting us at info@leoki.ai. Upon receiving your request:

•We will verify your identity before processing the deletion

•Personal identifiable information will be deleted within a reasonable timeframe

•You will receive confirmation once deletion is complete

•Some data may be retained as required by law or for legitimate purposes

Automatic Deletion:

•Inactive accounts may be deleted after an extended period of inactivity (with prior notice)

•Temporary data (session tokens, cache) is automatically deleted

Limitations on Deletion: We may not be able to delete all data immediately if:

•Required by law to retain certain information

•Necessary to complete transactions or provide requested services

•Needed for fraud prevention or security purposes

•Part of active legal proceedings or investigations

•Stored in backup systems (will be deleted during regular backup purge cycles)

6. International Data Transfers

6.1 Data Processing Locations

While your data is primarily stored in India, some third-party service providers may process data outside India:

•OpenAI: United States

•Microsoft Azure: May process data in multiple regions including United States

•Sarvam AI: India

•Google Analytics: United States

•Razorpay: India

6.2 Safeguards for International Transfers

When we transfer personal data internationally, we ensure appropriate safeguards are in place:

Contractual Protections:

•Standard Contractual Clauses (SCCs) approved by regulatory authorities

•Data Processing Agreements (DPAs) with third-party processors

•Contractual commitments to implement appropriate technical and organizational measures

Service Provider Commitments:

•AI providers' commitments to not use your data for unauthorized purposes

•Privacy policies aligned with international data protection standards

•Compliance with applicable data protection regulations in their jurisdictions

Adequacy Decisions:

•Where applicable, reliance on adequacy decisions by competent authorities

•Compliance with cross-border data transfer regulations

Security Measures:

•Encryption of data in transit and at rest

•Secure communication channels (TLS/SSL)

•Access controls and authentication mechanisms

6.3 Legal Basis for Transfers

International transfers are conducted based on:

•Consent: Your consent to use the Platform and its features

•Contract Performance: Necessity to provide AI tutoring services as per our agreement

•Legitimate Interests: Legitimate business interests in operating and improving the Platform

•Compliance: Legal obligations and regulatory requirements

6.4 Your Rights Regarding International Transfers

You have the right to:

•Be informed about international data transfers

•Object to transfers under certain circumstances

•Request information about safeguards in place

•Lodge complaints with supervisory authorities

7. Children's Privacy and Parental Rights

7.1 Age Requirements and Parental Consent

Minimum Age:

•Users under the age of 18 may use the Platform only with the consent and supervision of a parent or legal guardian

•Parents or guardians must create and manage accounts for users under 18

•We do not knowingly collect personal information from individuals under 18 without verified parental consent

Parental Consent Process: For users under 18:

•Parents/guardians must provide verifiable consent during account creation

•Consent is obtained through our registration process

•Parents/guardians can manage privacy settings and data access for their children

•Consent can be withdrawn at any time by contacting us

Age Verification:

•We may request age information during registration

•Parents may be required to verify their identity and relationship to the minor

•We may use technical measures to prevent underage users from creating accounts without parental consent

7.2 Information Collected from Minors

For users under 18, we collect only information necessary for educational purposes:

•Basic account information (name, email, grade level)

•Learning progress and performance data

•Voice conversation transcripts for tutoring

•Usage and engagement data

•Parent/guardian contact information

We limit data collection from minors to what is reasonably necessary to provide educational services.

7.3 Parental Rights and Controls

Parents and legal guardians have the following rights regarding their children's information:

Right to Access:

•Review what information has been collected from their child

•Access their child's learning progress and conversation history

•View analytics and performance reports

Right to Consent Withdrawal:

•Withdraw consent for further collection of their child's data

•Withdrawal may result in termination of the child's account

Right to Deletion:

•Request deletion of their child's personal information

•We will comply with deletion requests subject to legal and contractual obligations

Right to Control:

•Control privacy settings for their child's account

•Manage communication preferences

•Restrict or modify their child's access to certain features

Right to Correction:

•Request correction of inaccurate information about their child

How to Exercise Parental Rights:

•Log in to your Parent Dashboard to access your child's data and settings

•Contact us at info@leoki.ai with specific requests

•Include your name, your child's name, and account details

•We may request verification of identity and parental relationship

7.4 No Marketing to Children

We do not:

•Send marketing or promotional communications directly to users under 18

•Condition a child's participation in educational activities on providing more information than is reasonably necessary

•Require children to disclose personal information as a condition of participation beyond what is needed for educational purposes

7.5 Educational Institution Responsibilities

When the Platform is used in a school or institutional setting:

•The educational institution is responsible for obtaining parental consent

•The institution acts as the primary point of contact for parents

•Schools must have appropriate policies and agreements in place

•Parents should contact their child's school with questions about data practices in institutional settings

7.6 Discovery of Underage Users

If we discover that we have collected personal information from a user under 18 without verified parental consent:

•We will immediately suspend the account

•We will delete the information as soon as reasonably possible

•We will notify the registered email address

•We will take steps to prevent future unauthorized access

7.7 Compliance with Children's Privacy Laws

We are committed to complying with applicable children's privacy laws and regulations, including:

•Digital Personal Data Protection Act (DPDP), 2023 provisions regarding children

•Information Technology Act, 2000 and related rules

•International best practices for children's online privacy

8. Your Privacy Rights and Choices

Under applicable data protection laws, including the Digital Personal Data Protection Act (DPDP), 2023, you have certain rights regarding your personal information:

8.1 Right to Access (Right to Information)

You have the right to:

•Know what personal information we have collected about you

•Request a copy of your personal data

•Understand how your data is being used and processed

•Know with whom your data has been shared

How to Exercise:

•Access most of your information through your account dashboard

•Request a comprehensive data report by emailing info@leoki.ai

•Specify what information you want to access

Response Timeline: We will respond to access requests within a reasonable timeframe (typically 30 days) as required by applicable law.

8.2 Right to Correction (Right to Rectification)

You have the right to:

•Request correction of inaccurate personal information

•Request completion of incomplete personal information

•Update outdated information

How to Exercise:

•Update most information directly in your account settings

•For information you cannot update yourself, contact info@leoki.ai

•Provide specific details about inaccuracies

Verification: We may request verification of corrections, especially for critical account information.

8.3 Right to Deletion (Right to Erasure / Right to be Forgotten)

You have the right to request deletion of your personal information when:

•The information is no longer necessary for the purposes for which it was collected

•You withdraw consent and there is no other legal basis for processing

•You object to processing and there are no overriding legitimate grounds

•The information has been unlawfully processed

•Deletion is required for compliance with legal obligations

How to Exercise:

•Request account deletion through account settings

•Email info@leoki.ai with your deletion request

•Include your account details and specify what data you want deleted

Limitations on Deletion: We may not be able to delete all data immediately if:

•Required by law to retain certain information (e.g., tax records for 7 years)

•Necessary to complete transactions or provide requested services

•Needed for fraud prevention or security purposes

•Part of active legal proceedings or investigations

•In backup systems (will be deleted during regular backup purge cycles within 90 days)

Timeline: Personal identifiable information will be deleted within a reasonable timeframe (typically 30-90 days), subject to the limitations above.

8.4 Right to Data Portability

You have the right to:

•Receive your personal data in a structured, commonly used, and machine-readable format

•Transmit your data to another service provider (where technically feasible)

How to Exercise:

•Request data export by emailing info@leoki.ai

•Specify what data you want to export and in what format (if you have a preference)

What You'll Receive:

•Account information and profile data

•Learning progress and performance records

•Conversation transcripts

•Any other personal data we hold about you

Format: Data will typically be provided in common formats such as CSV, JSON, or PDF, depending on the data type and technical feasibility.

8.5 Right to Withdraw Consent

Where we process your data based on consent, you have the right to:

•Withdraw your consent at any time

•Withdrawal does not affect the lawfulness of processing before withdrawal

How to Exercise:

•Adjust consent settings in your account

•Email info@leoki.ai to withdraw specific consents

Effect of Withdrawal:

•We will stop processing your data for purposes requiring consent

•Some services may become unavailable if consent is essential for their provision

•Your account may be closed if consent withdrawal prevents us from providing core services

8.6 Right to Object

You have the right to object to:

•Processing based on legitimate interests

•Processing for direct marketing purposes (when implemented)

•Processing for research or statistical purposes

How to Exercise: Contact info@leoki.ai with your objection and explanation.

Our Response: We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

8.7 Right to Restrict Processing

You have the right to request restriction of processing when:

•You contest the accuracy of personal data (for a period allowing us to verify accuracy)

•Processing is unlawful but you prefer restriction over deletion

•We no longer need the data, but you need it for legal claims

•You have objected to processing pending verification of our legitimate grounds

How to Exercise: Contact info@leoki.ai with your request and reasoning.

8.8 Right to Nomination (DPDP Act 2023)

Under the DPDP Act 2023, you have the right to:

•Nominate another individual who may exercise your rights in the event of your death or incapacity

•Update or change your nominated individual at any time

How to Exercise: Contact info@leoki.ai to designate a nominee. Provide:

•Your account details

•Nominee's name and contact information

•Relationship to the nominee

•Consent from the nominee

8.9 Right to Grievance Redressal

You have the right to:

•File complaints regarding our data processing practices

•Seek resolution for privacy concerns

Grievance Officer: Contact our Grievance Officer at info@leoki.ai

Grievance Process:

1.Submit Complaint: Email info@leoki.ai with subject line "Privacy Grievance"

2.Acknowledgment: We will acknowledge your complaint within 72 hours

3.Investigation: We will investigate and review your complaint

4.Resolution: We will resolve complaints within a reasonable timeframe (typically 30 days)

5.Communication: We will keep you informed throughout the process

What to Include:

•Your name and account details

•Description of the issue or concern

•Relevant dates and circumstances

•Desired resolution

•Any supporting documentation

8.10 Right to Lodge Complaint with Supervisory Authority

If you are not satisfied with our response, you have the right to:

•Lodge a complaint with the Data Protection Board of India (once established under DPDP Act 2023)

•Contact other relevant regulatory authorities

•Seek legal remedies as provided under applicable laws

8.11 Communication Preferences

You can control certain communications:

•Transactional Emails: Cannot opt out (account security, invoices, service notifications)

•Marketing Emails: Can opt out (when implemented in future)

•Platform Notifications: Can manage in account settings

How to Manage:

•Update preferences in account settings

•Use unsubscribe links in emails (for marketing communications)

•Contact info@leoki.ai for assistance

8.12 How to Exercise Your Rights

General Process:

1.Send Request: Email info@leoki.ai with your request

2.Include Details:

•Your full name and registered email address

•Specific right you wish to exercise

•Description of your request

•Any relevant account details or reference numbers

3.Identity Verification: We may request additional information to verify your identity

4.Response: We will respond within required timeframes (typically 30 days)

Important Notes:

•We do not charge fees for most requests (unless requests are manifestly unfounded or excessive)

•We may refuse requests that are manifestly unfounded, excessive, or would compromise others' privacy

•We will inform you of any refusal and the reasons for it

•You have the right to complain to supervisory authorities if you believe your rights have been violated

9. Cookies, Analytics, and Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files stored on your device (computer, tablet, smartphone) when you visit websites. They help websites remember your preferences and provide personalized experiences.

9.2 Types of Cookies We Use

Essential Cookies (Required): These cookies are necessary for the Platform to function and cannot be disabled:

•Session Management: Maintains your login session

•Authentication: Verifies your identity

•Security: Protects against unauthorized access and fraud

•Platform Functionality: Enables core features and services

•User Preferences: Remembers your settings and choices

Analytics Cookies (Optional): These cookies help us understand how users interact with the Platform:

•Google Analytics: Tracks page views, user flows, and engagement metrics

•Performance Monitoring: Measures Platform speed and performance

•Feature Usage: Understands which features are most used

•Error Tracking: Identifies and fixes technical issues

9.3 Google Analytics

We use Google Analytics to analyze Platform usage and improve user experience.

Information Collected by Google Analytics:

•Pages visited and time spent

•User demographics (age range, gender, location)

•Device and browser information

•Traffic sources and referral URLs

•User behavior and interaction patterns

Google Analytics Privacy:

•Google Analytics data is subject to Google's Privacy Policy

•We have enabled IP anonymization in Google Analytics

•Data is used only for Platform improvement and analytics

Opt-Out of Google Analytics:

•Install the Google Analytics Opt-out Browser Add-on

•This prevents your data from being used by Google Analytics across all websites

9.4 How to Control Cookies

Browser Settings: Most browsers allow you to:

•View and delete cookies

•Block all cookies

•Block third-party cookies

•Receive alerts when cookies are being sent

Instructions by Browser:

•Chrome Cookie Settings

•Firefox Cookie Settings

•Safari Cookie Settings

•Edge Cookie Settings

Effect of Disabling Cookies:

•Disabling essential cookies will prevent you from using the Platform

•Disabling analytics cookies will not affect Platform functionality

•Some features may not work properly without cookies

9.5 Other Tracking Technologies

In addition to cookies, we may use:

•Web Beacons: Small graphic images that track page views and email opens

•Local Storage: HTML5 local storage for storing preferences

•Session Storage: Temporary storage cleared when you close your browser

•Device Identifiers: Unique identifiers for mobile devices

9.6 Do Not Track Signals

Currently, we do not respond to "Do Not Track" (DNT) browser signals. The industry has not yet established a standard for how to respond to DNT signals.

9.7 Third-Party Cookies

Some third-party services may set their own cookies:

•Google OAuth: Sets cookies for authentication

•Razorpay: May set cookies for payment processing

•Third-party content providers: May set cookies when embedded in the Platform

We do not control these third-party cookies. Please review the privacy policies of these third parties for more information.

10. Third-Party Links and Services

10.1 External Links

The Platform may contain links to third-party websites, applications, or services that are not owned or controlled by us.

Our Responsibility:

•We do not endorse or take responsibility for third-party content or services

•We have no control over third-party websites, their content, or their practices

•This Privacy Policy does not apply to third-party websites

Your Responsibility:

•Review the privacy policies and terms of third-party websites before providing any information

•Understand the data practices of third-party services

•Use third-party services at your own risk

We Are Not Liable For:

•Privacy practices of third-party websites

•Content, accuracy, or opinions expressed on third-party sites

•Security of information shared with third parties

•Any damages arising from your use of third-party services

10.2 Third-Party Integrations

When you use third-party integrations with the Platform:

•You are subject to the third party's terms of service and privacy policy

•We receive only the information necessary for the integration to function

•You can revoke third-party access at any time through your account settings

Current Third-Party Integrations:

•Google OAuth (for sign-in)

•Amazon Cognito (for authentication)

•Razorpay (for payments)

10.3 Educational Content from Third Parties

Some educational content on the Platform may be:

•Licensed from textbook publishers

•Referenced from CBSE and other curriculum boards

•Sourced from educational databases

•Generated by AI based on publicly available educational materials

Such content is subject to the intellectual property rights of the respective owners.

10.4 AI Service Provider Policies

Your data is processed by third-party AI providers when using tutoring features. Review their privacy policies:

•OpenAI Privacy Policy

•Microsoft Privacy Statement

•Sarvam AI Privacy Policy

11. Business Transfers and Corporate Transactions

11.1 Mergers, Acquisitions, and Asset Sales

In the event of:

•Merger with another company

•Acquisition by another entity

•Sale of all or substantially all assets

•Reorganization or restructuring

•Bankruptcy or insolvency proceedings

Your personal information may be transferred as part of the transaction.

11.2 Notice and Your Rights

Before any transfer:

•Notice: We will provide advance notice via email and/or prominent notice on the Platform

•Privacy Policy Changes: We will inform you if the acquiring entity's privacy practices differ

•Your Options: You will have the opportunity to:

•Request deletion of your data before the transfer

•Opt out of the transfer (which may result in account closure)

•Object to the transfer under certain circumstances

11.3 Successor Entity Obligations

The acquiring or successor entity will be required to:

•Honor this Privacy Policy or obtain your consent for changes

•Maintain at least the same level of data protection

•Comply with applicable data protection laws

•Respect your privacy rights

11.4 During Negotiations

During merger or acquisition negotiations:

•We may share information with prospective buyers under confidentiality agreements

•Only necessary information for due diligence will be shared

•Personal data will be protected during the transaction process

12. Updates to This Privacy Policy

12.1 Right to Modify

We reserve the right to update or modify this Privacy Policy at any time to reflect:

•Changes in our data practices or Services

•New features or functionality

•Legal or regulatory requirements

•Industry best practices

•User feedback and concerns

12.2 Notification of Changes

We will notify you of material changes through:

•Email Notification: Sent to your registered email address

•Platform Notice: Prominent banner or pop-up on the Platform

•In-App Notification: Push notification or in-app message

•"Last Updated" Date: Updated at the top of this Privacy Policy

12.3 Effective Date of Changes

Changes become effective:

•Material Changes: 30 days after notification

•Non-Material Changes: Immediately upon posting

•As Specified: Or as otherwise specified in the notification

12.4 Your Acceptance

Continued Use: Your continued use of the Platform after changes become effective constitutes acceptance of the revised Privacy Policy.

If You Disagree: If you do not agree with the changes:

•You may stop using the Platform

•You may request account deletion before changes take effect

•You may exercise your data rights as outlined in Section 8

12.5 Review Responsibility

We encourage you to:

•Review this Privacy Policy periodically

•Check the "Last Updated" date to see when it was last revised

•Stay informed about how we protect your information

12.6 Notification of Minor Changes

For non-material changes (e.g., clarifications, formatting):

•We may not send individual notifications

•We will update the "Last Updated" date

•Changes will be reflected in the posted Privacy Policy

13. Compliance with Data Protection Laws

13.1 Digital Personal Data Protection Act (DPDP), 2023

We are committed to complying with the Digital Personal Data Protection Act (DPDP), 2023, and implementing:

•Appropriate technical and organizational measures for data protection

•Transparent data processing practices

•User rights as mandated by the Act

•Consent management mechanisms

•Data breach notification procedures (when regulations are finalized)

As the DPDP Act rules and regulations are further developed and implemented, we will:

•Update our practices to ensure full compliance

•Appoint a Data Protection Officer if required

•Register with the Data Protection Board of India if applicable

•Conduct Data Protection Impact Assessments where necessary

13.2 Information Technology Act, 2000

We comply with:

•The Information Technology Act, 2000

•Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011

•Other applicable rules and regulations under the IT Act

13.3 Educational Privacy Standards

We adhere to best practices for educational technology, including:

•Protection of student data and privacy

•Limitations on use of student data

•Parental rights and consent requirements

•Data security for educational institutions

•Appropriate content for minors

13.4 International Standards

While primarily focused on Indian regulations, we also consider international best practices, including:

•General Data Protection Regulation (GDPR) principles

•Children's Online Privacy Protection Act (COPPA) guidelines

•Family Educational Rights and Privacy Act (FERPA) principles

•International Organization for Standardization (ISO) standards

13.5 Ongoing Compliance

We continuously:

•Monitor changes in data protection laws and regulations

•Update our practices to maintain compliance

•Train our staff on data protection requirements

•Conduct regular compliance audits and assessments

•Engage with legal and privacy experts

14. Data Protection Officer and Grievance Redressal

14.1 Grievance Officer Contact

For all privacy-related concerns, data rights requests, or complaints:

Email: info@leoki.ai

Subject Line: "Privacy Request" or "Data Protection Inquiry"

Include in Your Communication:

•Your full name and registered email address

•Nature of your request or concern

•Specific details or reference numbers (if applicable)

•Preferred method of response

14.2 Grievance Redressal Process

Step 1 - Submission:

•Submit your grievance or request via email to info@leoki.ai

•Clearly describe the issue and desired resolution

Step 2 - Acknowledgment:

•We will acknowledge receipt of your grievance within 72 hours

•You will receive a reference number for tracking

Step 3 - Investigation:

•We will investigate your concern thoroughly

•Additional information may be requested for verification or clarification

Step 4 - Resolution:

•We will work to resolve your grievance within a reasonable timeframe (typically 30 days)

•Complex matters may require additional time; we will keep you informed

Step 5 - Response:

•You will receive a detailed response explaining our findings and actions taken

•If your concern cannot be fully resolved, we will explain the reasons

14.3 Escalation

If you are not satisfied with our response:

•Request escalation to senior management

•Lodge a complaint with the Data Protection Board of India

•Contact relevant consumer protection authorities

•Seek legal remedies as provided under applicable laws

14.4 Data Protection Officer (Future)

As required by the DPDP Act 2023 or when determined necessary, we will:

•Appoint a formal Data Protection Officer (DPO)

•Provide DPO contact information on the Platform

•Ensure the DPO is properly trained and empowered

•Enable direct communication between users and the DPO

14.5 Response Timeframes

We strive to respond to all requests within:

•Acknowledgment: 72 hours

•Simple Requests: 7-15 business days

•Complex Requests: 30 days

•Exceptional Cases: Up to 60 days (with explanation)

We will inform you if we need additional time to respond.

15. Special Considerations

15.1 Voice Data and Biometric Information

Voice Processing: While we convert voice to text and do not store audio recordings:

•Voice patterns could be considered biometric data in some jurisdictions

•We process voice data solely for transcription and educational purposes

•Voice data is not used for biometric identification or authentication

•Text transcripts do not contain biometric characteristics

User Consent: By using voice features, you consent to voice-to-text conversion as part of the tutoring service.

15.2 AI-Generated Content

Nature of AI Content:

•AI tutors generate responses based on machine learning models

•Content may contain inaccuracies, errors, or biases

•AI responses are not verified by human educators (unless otherwise stated)

Your Responsibility:

•Verify important information independently

•Do not rely solely on AI-generated content for critical educational decisions

•Report concerning or inappropriate AI responses to info@leoki.ai

Our Use of AI Interactions:

•We analyze AI conversations to improve tutoring quality

•Anonymized data may be used to train and enhance our systems

•We do not share individual AI conversations with third parties for marketing

15.3 Sensitive Personal Information

We generally do not collect sensitive personal information such as:

•Health or medical information

•Financial information (beyond billing details)

•Caste, religion, or political beliefs

•Biometric data

•Sexual orientation

If you voluntarily provide sensitive information:

•It will be protected with heightened security measures

•Processing will be limited to the purpose for which it was provided

•You have the right to request deletion at any time

15.4 Location Data

Approximate Location:

•We collect approximate location (city/country level) from your IP address

•Used for localizing content and complying with regional regulations

•Not used for precise location tracking

No Precise Location Tracking:

•We do not collect GPS coordinates or precise geolocation data

•We do not track your physical movements

15.5 Multi-User Accounts

For parent accounts managing multiple children:

•Each child's data is kept separate

•Parents can access data for all children they manage

•Children's data is not commingled or shared between siblings without parent consent

15.6 Institutional Accounts (Future)

When schools or institutions use the Platform:

•Separate data processing agreements will be established

•Student data ownership and access rights will be clearly defined

•Institutional administrators will have specific access controls

•Additional privacy measures may apply for compliance with educational privacy laws

16. Contact Information

16.1 General Inquiries

For questions, concerns, or inquiries about this Privacy Policy or our data practices:

Tryzent Technologies Private Limited

Email: info@leoki.ai

Phone: +91 9105910566

Registered Office: Lajpat Nagar, New Delhi, Delhi, India

Website: https://www.leoki.ai

Business Hours: Monday to Friday, 10:00 AM to 6:00 PM IST

16.2 Specific Inquiries

For Privacy and Data Rights Requests:

•Email: info@leoki.ai

•Subject: "Privacy Request - [Type of Request]"

•Include: Account details, specific request, and contact information

For Security Concerns:

•Email: info@leoki.ai

•Subject: "Security Concern - Urgent"

•Include: Description of the issue and any relevant details

For Parental Inquiries:

•Email: info@leoki.ai

•Subject: "Parental Inquiry - [Child's Name]"

•Include: Your relationship to the child and account details

For Grievances and Complaints:

•Email: info@leoki.ai

•Subject: "Privacy Grievance"

•Include: Detailed description of the concern and desired resolution

16.3 Response Time

We strive to respond to all inquiries within:

•Urgent Security Matters: 24-48 hours

•Data Rights Requests: 7-30 days depending on complexity

•General Inquiries: 3-5 business days

•Grievances: Acknowledged within 72 hours, resolved within 30 days

16.4 Mailing Address

For formal legal notices or postal correspondence:

Tryzent Technologies Private Limited
Lajpat Nagar
New Delhi, Delhi
India

Acknowledgment and Consent

BY USING THE LEOKI PLATFORM, YOU ACKNOWLEDGE THAT:

1.You have read and understood this Privacy Policy in its entirety

2.You consent to the collection, use, and disclosure of your information as described

3.You understand how your data will be processed and protected

4.You are aware of your privacy rights and how to exercise them

5.If creating an account for a minor, you are the parent/guardian with authority to consent

For Parents/Guardians:

By creating an account for a minor, you:

•Confirm that you are the parent or legal guardian

•Consent to the collection and processing of your child's information

•Accept responsibility for monitoring your child's use of the Platform

•Understand your rights regarding your child's data

If you do not agree with this Privacy Policy, you must not use the Leoki Platform.