Privacy Policy

1. Introduction and Our Privacy Commitment

We ("we", "us", or "our") operates the Comprehenza iOS application (the "App"). We are deeply committed to protecting the privacy and digital safety of all our users, particularly students in Grades 6 to 9. This Privacy Policy describes in detail how we collect, use, store, and protect personal information in full compliance with:

  • The Children's Online Privacy Protection Act (COPPA)
  • Apple App Store Guidelines, specifically Section 5.1.4 regarding apps in the Kids Category
  • Applicable data protection laws, including the Digital Personal Data Protection Act (DPDPA) of India

Please read this policy carefully. By creating an account and using the App, the parent or legal guardian acknowledges and consents to the data practices described herein. If you do not agree with this policy, please do not create an account or allow your child to use the App.

2. Who This Policy Applies To

Comprehenza is purposefully designed for students in Grades 6 to 9. A parent or legal guardian must create and manage the account on behalf of the child. The child's personal information is minimized to the greatest extent possible — the App is designed so that the child can learn and progress without ever needing to directly share sensitive personal data.

This policy applies to all users of the Comprehenza iOS application. It does not apply to any third-party websites or services that may be linked to or from our app — such as external resources that parents may access via a parental gate.

3. Information We Collect

We follow a strict principle of data minimization. We collect only what is absolutely necessary to deliver the educational experience. Here is a comprehensive breakdown:

3a. Information Collected During Account Creation (From the Parent/Guardian)

  • Parent/Guardian Email Address: Used for account authentication, password recovery, and occasional service announcements. We never share this email with third-party marketers.
  • Optional Grade Selection: Users may optionally select their grade level (Grade 6, 7, 8, or 9) to help personalise the reading level of content presented within the app. This selection is entirely voluntary — users who skip it receive default content and can update their preference at any time from their profile. Grade data is not used for any marketing purposes and is never required to use the app.
  • Chosen Username (non-identifying): The child may choose a display name for use within the app. We strongly encourage the use of a non-identifying nickname rather than the child's real name.

3b. Information Collected Automatically During Use

  • Comprehenza Quotient (CQ) Scores: Your child's performance data across Fluency, Vocabulary, Comprehension, and Retelling modules is stored in your account to track learning progress.
  • Journey Milestone Data: Streaks, completed passages, and exercise history are stored to enable the progression system.
  • ReadBuddy Interaction Logs: Queries sent to the ReadBuddy AI assistant are processed in real-time through our secure backend. Aggregated, anonymized versions of these interactions are used exclusively to improve the educational quality of ReadBuddy's responses and to refine our safety filters. No raw, personally-identifiable interaction logs are retained indefinitely.
  • Standard Technical Data: Basic device type, iOS version, and crash reports may be collected via Apple's standard diagnostics framework to maintain app stability. This data is not linked to your identity.

3c. Information We Do NOT Collect

  • The child's full legal name, phone number, physical address, or precise geolocation.
  • Photos, videos, or any biometric data.
  • Social media profiles or friend lists.
  • Browsing history outside of the Comprehenza App.

4. The Parental Gate

In strict accordance with Apple's Kids Category guidelines (Section 5.1.4), all outbound links within Comprehenza — including links to this Privacy Policy, our Terms of Service, support email, and any external content — are protected behind a Parental Gate. The parental gate presents a simple math verification challenge designed to be solved only by an adult, preventing children from inadvertently navigating away from the protected app environment.

This means that every time a child encounters a link that would take them outside the app's educational content, a parent or guardian must actively authorize that action. This mechanism is a fundamental safety requirement for our App's presence in the Kids Category, and we implement it comprehensively throughout the application.

5. How We Use the Information

Every piece of data we collect serves a direct educational purpose. We use information to:

  • Deliver Personalised Learning: The child's optional grade selection allows us to serve reading passages calibrated to the appropriate Flesch-Kincaid Grade Level (Grade 6 to Grade 9). Users who skip grade selection receive content at a default level which they can adjust at any time. This ensures the content is challenging but not frustrating — a principle grounded in Vygotsky's Zone of Proximal Development.
  • Track and Display Progress: CQ scores, journey completions, and streak data are stored and displayed back to the child (and parent) within the app to motivate continued learning through positive reinforcement.
  • Improve ReadBuddy: Anonymised patterns in how children ask questions about vocabulary and comprehension help us train ReadBuddy to become a more effective and grade-appropriate educational tool.
  • Maintain App Safety and Stability: Technical crash data helps us fix bugs and ensure a smooth, uninterrupted learning experience.
  • Communicate with Parents: The parent's email address may be used to send important service announcements (e.g., significant changes to the Privacy Policy or Terms of Service). We do not send marketing emails without explicit opt-in consent.

We do not use any data for behavioral advertising, interest-based targeting, or to build profiles for commercial sale.

6. ReadBuddy and Our AI Content Standards

ReadBuddy is Comprehenza's AI-powered reading companion, designed to help children understand complex vocabulary, identify context clues, and explore passage themes. We want to be transparent about its pedagogical framework:

  • Flesch-Kincaid Calibration: All reading passages, comprehension questions, and ReadBuddy's responses are strictly calibrated against the Flesch-Kincaid Reading Ease and Grade Level scale. Content is matched to the user's selected grade: a Grade 6 selection receives content calibrated to approximately Grade 6 level, and a Grade 9 selection receives content calibrated to approximately Grade 9 level. Users who have not selected a grade receive an appropriate default. This ensures text is suitable for their reading development stage.
  • Pedagogical Scaffolding & ZPD: Our AI-driven assistance is structured to act as a scaffolded guide, aligning with Lev Vygotsky's Zone of Proximal Development (ZPD). ReadBuddy provides contextual hints and vocabulary definitions to help children bridge the gap between independent reading capabilities and guided reading success.
  • Tiered Vocabulary: ReadBuddy's explanations align with Beck, McKeown, and Kucan’s Tiered Vocabulary Instruction model, specifically targeting high-utility academic words (Tier 2 vocabulary) to facilitate contextual word learning rather than rote memorization.
  • Stages of Reading: Our curriculum is mapped to Jeanne Chall's Stages of Reading Development, specifically targeting Stage 3 ("Reading for Learning the New"), which marks the transition from "learning to read" to "reading to learn."
  • National Reading Panel (NRP) Standards: All modules are aligned with the NRP's five pillars, emphasizing vocabulary development, reading comprehension strategy training, and fluency.
  • The Toxicity Guard: Every user message sent to ReadBuddy passes through our Toxicity Guard. This safety filter screens for profanity, hate speech, adult language, and violence. Blocked messages are never forwarded to the AI model.
  • No Third-Party Model Training: Conversation logs processed for ReadBuddy are not shared with third-party AI providers for their own model training purposes.

7. Data Sharing and Third Parties

We take a firm stance: we do not sell, rent, or trade your personal data. Data sharing is limited to the minimum necessary for the app to function:

  • Supabase (Backend Infrastructure): We use Supabase as our secure backend and database provider. User account data is stored on Supabase infrastructure, which employs enterprise-grade encryption and security practices. Supabase processes data on our behalf as a data processor and is contractually bound to our privacy standards.
  • Apple (Platform Services): As an iOS application, standard technical diagnostics and crash reports may be handled through Apple's native frameworks under Apple's own privacy policy.
  • Anonymized AI Processing: ReadBuddy's query processing is routed through a secure, private AI API. Data transmitted is entirely anonymized and contains no usernames, parent email addresses, or other personal identifiers.
  • Legal Compliance: We may disclose information if required to do so by law, court order, or valid government authority, or if necessary to protect the safety of our users.

8. Data Security and Protection Infrastructure

The security of your child's data is paramount. We have implemented multiple layers of protection:

  • Encryption in Transit: All data transmitted between the Comprehenza iOS app and our backend servers is encrypted using industry-standard TLS (Transport Layer Security).
  • Encryption at Rest: Sensitive data stored in our Supabase database is encrypted at rest.
  • Password Security: Account passwords are cryptographically hashed using bcrypt before storage. Passwords are never stored in plain text.
  • Role-Based Access Control (RBAC): Only authorized core members of our team can access backend analytics dashboards, and only for the purposes of app maintenance and improvement.

While we take every reasonable precaution, no system is 100% impenetrable. In the event of a data breach that materially affects user data, we will notify affected account holders (parents/guardians) as required by applicable law.

9. Parental Rights: Access, Correction, and Deletion

As the parent or legal guardian of a Comprehenza user, you have full rights over your child's data in accordance with COPPA:

  • Right to Access: You may request a summary of all personal information we hold about your child's account by contacting us at comprehenza.support@gmail.com.
  • Right to Correct: If you believe any information we hold is inaccurate, you may request a correction by contacting our support team.
  • Right to Delete (Account Deletion): You hold absolute control over your child's data. You may permanently delete the account at any time directly from the Profile tab inside the iOS app. Upon initiating account deletion, all associated personal data (parent email, CQ scores, journey history, and learning analytics) is immediately, permanently, and irreversibly purged from our active databases.
  • Right to Refuse Further Collection: You may withdraw consent for data collection by deleting the account. Continued use of the App constitutes ongoing consent for the data practices described in this policy.

To exercise any of these rights, please contact us at comprehenza.support@gmail.com. We will respond to all verifiable parental requests within 45 days, as required by COPPA.

10. Data Retention

We retain your child's account data only for as long as the account remains active. If an account is deleted, all associated personal data is immediately and permanently purged from our active systems. Anonymized, aggregated learning analytics (e.g., "X% of users struggled with passages at Flesch-Kincaid Grade 8") may be retained indefinitely for internal product improvement, as these records cannot be linked back to any individual.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify the parent's registered email address with at least 30 days' notice before the new policy takes effect. The "Last Updated" date at the top of this page will always indicate the most recent revision. Continued use of the App after the new effective date constitutes acceptance of the revised policy.

12. Contact Us

For any privacy-related questions, concerns, or requests, please contact us directly:

  • Support Email: comprehenza.support@gmail.com
  • Response Time: We aim to respond to all inquiries within 5 business days, and to all COPPA-related parental requests within 45 days.

13. Accessibility Commitment

We strive to make the Comprehenza App accessible to all children, including those with disabilities. The app conforms to the Web Content Accessibility Guidelines (WCAG) 2.1 AA standards where applicable, and we continuously work to improve usability for users with visual, auditory, or motor impairments.