Privacy Policy
1. Who we are
ProBodhi AI Private Limited (“ProBodhi”, “we”, “us”, “our”) operates www.probodhi.com — an adaptive learning platform for Class 10 students preparing for CBSE and State Board examinations. We are the data fiduciary for the personal data described in this policy.
- CIN: U85499GJ2026PTC178417
- Registered office: 1012, Shilp Zaveri, Shyamal Cross Road, Manekbag, Ahmedabad City, Ahmedabad – 380015, Gujarat, India
This policy describes what personal data we collect, why we collect it, how we use and protect it, and what rights you have. It is written to comply with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) and the Digital Personal Data Protection Rules, 2025.
2. What this policy covers
This policy applies to all users of www.probodhi.com — students, parents or guardians providing consent on behalf of a student, and any other person whose personal data we process in connection with the Service.
3. What personal data we collect
We collect the following categories of personal data:
Identifying information
- Full name
- Mobile number (used for OTP-based login)
- Parent/guardian contact number (optional, provided by you)
- Email address
- School name (optional)
- Class (typically Class 10)
- Board (CBSE or State Board)
- Expected exam date (optional)
Learning data
- Lessons read, time spent, and pages viewed
- Spot test and chapter test answers, scores, and timestamps
- Mastery status and retry attempts at the subtopic level
- Diagnostic notes and weak-area summaries derived from your test results
Payment data
- Subscription plan, amount paid, and date of payment
- Payment reference identifier from Razorpay (we do not store card numbers, CVVs, or UPI handles — these are handled by Razorpay)
Technical data
- IP address, browser type, and device information
- Cookies and similar identifiers used for authentication and basic analytics
4. Why we collect it
We collect and use your personal data for the following specific purposes:
- To create and maintain your account
- To deliver lessons, tests, and personalised diagnostic feedback
- To track your learning progress and chapter-level mastery
- To process subscriptions and refunds
- To send transactional communications (login codes, payment receipts, account notifications)
- To improve the Service through aggregated, anonymised analysis
- To comply with legal, accounting, and tax obligations
- To respond to grievances and support requests
We do not use your personal data for:
- Behavioural advertising based on your account, learning activity, or any data you provide after signing in
- Sale or rent to third parties
- Targeted advertising to children
- Any purpose other than those stated above
Anonymous, consent-based advertising measurement on our public pages is described in Section 17.
5. Legal basis for processing
We process your personal data on the basis of:
- Consent, given at the time of account creation, capable of being withdrawn at any time
- Legitimate use for educational purposes where permitted under the DPDP Act
- Legal obligation, where the law requires us to retain or disclose information (for example, tax records)
6. Children’s data
ProBodhi serves Class 10 students preparing for CBSE and State Board examinations, most of whom are between 14 and 17 years of age — that is, children under the DPDP Act.
We take this seriously:
- Parental consent. By creating an account and clicking “I have read and agree to the Terms of Service and Privacy Policy”, you and your parent or guardian confirm that your parent or guardian has read this policy and consents to our processing your personal data as described here. Your parent or guardian remains responsible for supervising your use of the Service.
- No behavioural advertising to children. We do not show advertisements inside ProBodhi, and we never use a student’s account data, learning activity, or identity for advertising on any platform. The advertising measurement described in Section 17 operates only on our public pages, before sign-in, and uses no information from student accounts.
- No tracking beyond what is essential to the Service. Mastery tracking, test scoring, and personalised feedback are core to how ProBodhi works. We do not track your activity outside ProBodhi, and we do not build profiles for any purpose other than personalising your learning.
- Withdrawal of consent. A parent or guardian may withdraw consent and request deletion of the student’s account and data at any time by writing to support@probodhi.com.
We are committed to evolving our consent mechanism — including verifiable parental consent procedures — in line with the Digital Personal Data Protection Rules, 2025, within the phased compliance timelines notified by the Government of India.
7. How long we keep your data
We retain your personal data for as long as your account is active, and for a reasonable period after closure:
- Account and learning data: deleted within 30 days of account closure, except where a longer period is required by law
- Payment and tax records: retained for the period required under the Income Tax Act, 1961 and the Companies Act, 2013 (currently 8 years)
- Backup copies: purged within 90 days of account closure
When data is no longer needed, we delete or anonymise it.
8. Who we share it with
We share personal data only with vetted service providers, each engaged under written contracts that require them to protect your data and use it only for purposes we specify.
Specifically:
- Payments are processed by Razorpay Software Private Limited (India)
- Account, learning, and authentication data is hosted by Supabase in the Northeast Asia (Tokyo) region
- Web hosting and content delivery is provided by Vercel Inc. through a global edge network
We also use trusted third-party providers for:
- Transactional email delivery (login codes, receipts, account notifications)
- One-time-password (OTP) delivery via SMS
- AI-assisted generation of lesson content and diagnostic feedback
Specific service-provider details for these categories are available on written request to support@probodhi.com.
We do not share your personal data with any other third parties, and we do not sell or rent your data to anyone.
We may disclose data to law-enforcement agencies, courts, or regulators where required to do so by a valid legal order or compelled by Indian law.
9. Where your data is stored
Your account, learning, and payment-reference data is stored on Supabase infrastructure in the Northeast Asia (Tokyo) region. Backups and edge-cached resources may be distributed across other regions via Vercel’s content delivery network.
10. Cross-border data transfer
Because some of our service providers are located outside India, your personal data may be transferred to and processed in other countries. We rely on contractual safeguards with each provider that require them to protect your data to a standard equivalent to that under the DPDP Act, and we transfer data only to countries that are not restricted by the Government of India under the DPDP Act.
11. Your rights
Under the DPDP Act, you (and where applicable your parent or guardian on your behalf) have the right to:
- Access the personal data we hold about you
- Correct inaccurate or incomplete data
- Erase your personal data where retention is no longer required
- Withdraw consent at any time (which will result in account closure and data deletion)
- Nominate a person to exercise these rights on your behalf in the event of your death or incapacity
- Lodge a grievance with our Grievance Officer (see Section 16)
- Escalate to the Data Protection Board of India if you are not satisfied with our response
To exercise these rights, write to support@probodhi.com from the email address registered to your account. We will respond within 30 days.
12. Cookies and analytics
ProBodhi uses cookies and similar technologies for:
- Keeping you signed in (authentication)
- Remembering your preferences
- Basic analytics to understand how the Service is used and to improve it
Third-party analytics and advertising cookies (from Meta and Google) operate only on our public marketing pages, only after you accept the cookie consent banner, and never inside the logged-in learning experience. We do not use cookies to track your activity on other websites. Meta and Google process the data they collect under their own privacy policies — see Section 17.
13. Security
We protect your personal data using:
- HTTPS encryption for all data in transit
- Encryption at rest on our database
- Role-based access control and row-level security
- Authentication via one-time password rather than passwords
- Audit logging of administrative access
- Regular review of our security practices
No system is perfectly secure. If we become aware of a personal-data breach affecting your data, we will notify you and the Data Protection Board of India in accordance with Section 8(6) of the DPDP Act and Rule 7 of the DPDP Rules, 2025 — including the nature of the breach, what data was affected, what we are doing about it, and what you can do to protect yourself.
14. Changes to this policy
We may update this policy from time to time. When we do, we will update the “Last updated” date at the top of this page and, for material changes, notify you by email or in-app message at least 30 days before the change takes effect.
17. Analytics and Advertising
We use third-party analytics and advertising services to understand how visitors use ProBodhi and to measure the effectiveness of our marketing. These services may set cookies and collect technical information about your visit (such as your IP address, browser type, pages viewed, and time spent on the site).
Services we use
- Meta (Facebook/Instagram) — Meta Pixel and Conversions API, for measuring ad performance and showing you relevant ads on Facebook and Instagram. Meta’s privacy policy: https://www.facebook.com/privacy/policy
- Google — Google Analytics 4 (for site analytics) and Google Ads (for measuring ad performance and showing you relevant ads across Google’s network, including YouTube and Google Search). Google’s privacy policy: https://policies.google.com/privacy
What we share: We share only technical information needed to measure ad performance — page URLs you visited, anonymous browser identifiers (cookies), IP address, and event timestamps. We do not share your name, email address, phone number, or any other personal information you have provided to us with these advertising platforms.
Children’s data: ProBodhi serves Class 10 students, many of whom are under 18. In accordance with the Digital Personal Data Protection Act, 2023, we do not use any identifying information of minors (including names, emails, phone numbers, or behavioural data collected after login) for advertising purposes. Advertising tracking on our site is limited to public pages and does not extend into the logged-in learning experience.
Your choices: You can opt out of analytics and advertising tracking by declining cookies in the consent banner shown when you first visit our site. You can also disable tracking at any time by clearing cookies for probodhi.com in your browser settings, or by using browser-level privacy tools.
Data retention: Analytics data is retained by Meta and Google according to their own retention policies (typically 14 months for GA4). We do not store this data on our own servers beyond what is necessary for our own analytics.
Questions about our privacy practices? Email us at support@probodhi.com.
15. Contact
For any question about this policy or your personal data, write to:
ProBodhi AI Private Limited
1012, Shilp Zaveri, Shyamal Cross Road, Manekbag,
Ahmedabad City, Ahmedabad – 380015, Gujarat, India
Email: support@probodhi.com
16. Grievance Officer
In accordance with the Information Technology Act, 2000 and the Digital Personal Data Protection Act, 2023, our Grievance Officer is:
- Name: Mr. Dhaval Khamar
- Designation: Director
- Email: support@probodhi.com
- Address: 1012, Shilp Zaveri, Shyamal Cross Road, Manekbag, Ahmedabad City, Ahmedabad – 380015, Gujarat, India
The Grievance Officer will acknowledge your complaint within 24 hours and resolve it within 15 days of receipt.
If you are not satisfied with the resolution provided, you may escalate the matter to the Data Protection Board of India under the DPDP Act, 2023.
