Privacy Policy – MathDingo (India)

Effective Date: 1 January 2025

Product of Byte Digital Consulting Pty Ltd – Melbourne, Australia

Byte Digital Consulting Pty Ltd ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the MathDingo mobile application, web platform, and related services ("MathDingo", "App", "Platform") in India. It is intended to comply with India's Digital Personal Data Protection Act, 2023 ("DPDP Act") and the Digital Personal Data Protection Rules, 2025 ("DPDP Rules").

For the purposes of the DPDP Act, you (or, in the case of a child, the parent or guardian) are the Data Principal, and Byte Digital Consulting Pty Ltd is the Data Fiduciary that determines the purpose and means of processing your personal data.

1. Scope

This Privacy Policy applies to all users of MathDingo in India, including:

• Individuals using MathDingo on an iPad, tablet, mobile device, or browser.
• Parents, guardians, educators, or schools who register for child or classroom access.
• Visitors to our website or support channels.

2. What Personal Data We Collect

a. Personal Data

• Full name
• Email address and/or mobile number
• Child’s name or nickname (if applicable)
• Age and grade level
• Parent or guardian / educator contact details (where applicable)

b. Account and Subscription Data

• Payment status and plan (Basic/Pro)
• Subscription type and renewal date
• Apple App Store / Google Play ID (for in-app purchases)

c. Usage and Progress Data

• Lessons completed and scores
• Time spent on activities
• Learning milestones and feedback

d. Device and Technical Data

• IP address
• Device type (e.g., iPad, mobile, browser)
• Operating system
• Crash logs and performance analytics

We collect only the personal data that is necessary for the specified purposes set out in this policy.

3. How We Collect Your Data

• Direct input during sign-up or while using the app.
• App store or web-based subscription services (e.g., Apple, Google, Stripe / Razorpay).
• Analytics tools (e.g., Firebase, Mixpanel, or similar) for usage metrics.
• School/tutor accounts via authorised admin or educator uploads.
• Through a registered Consent Manager, where you choose to manage your consent through one.

4. Purposes for Which We Use Your Data

We process your personal data for the following specified, lawful purposes:

• Deliver personalised learning experiences.
• Track and display progress to parents, guardians, tutors, or teachers.
• Manage subscriptions and payments.
• Provide technical and customer support.
• Improve app performance and tailor educational content.
• Comply with legal obligations (e.g., child safety, record-keeping, and transaction records).

5. Notice and Consent (Legal Basis)

Under the DPDP Act, we process your personal data primarily on the basis of your consent, or for certain legitimate uses permitted by the Act. Where we rely on consent:

• We provide a clear and plain-language notice describing the personal data collected and the purpose of processing, at or before the time consent is sought.
• Consent is free, specific, informed, unconditional, and given through a clear affirmative action, and is limited to the data necessary for the stated purpose.
• You may withdraw your consent at any time, as easily as it was given. Withdrawal does not affect processing already carried out on the basis of consent before its withdrawal.
• Our notice is made available in English and, where you request, in any of the languages listed in the Eighth Schedule to the Constitution of India.

6. Who We Share Your Data With

We do not sell your personal data. We may share your data with Data Processors and other recipients only as necessary for the purposes above, including:

• Trusted third-party service providers, such as:
  • Apple, Google (App Stores)
  • Stripe / Razorpay (payment processors)
  • Firebase or analytics tools (for diagnostics)
• Educational institutions, if you use MathDingo via a school or tutor subscription.
• Government agencies or legal authorities, where required by law or to comply with the DPDP Act, a court order, or other legal process.

Where we engage Data Processors, we do so under a valid contract and they process personal data only on our instructions.

7. Children’s Data

MathDingo is designed for children with parental, guardian, or educator supervision. Children’s data is treated with special care under the DPDP Act, under which a "child" is any individual who has not completed 18 years of age. Accordingly:

• We obtain verifiable consent of a parent or lawful guardian before processing the personal data of a child, and we take reasonable steps to verify that the consenting adult is identifiable and is an adult.
• Where a user is a person with a disability who has a lawful guardian, we obtain verifiable consent from that guardian.
• We do not undertake tracking, behavioural monitoring, or targeted advertising directed at children.
• We do not process a child’s personal data in any manner likely to cause a detrimental effect on the well-being of the child.
• School or tutor access requires authorised adult administrators.
• Parents or guardians may request access, correction, or deletion of their child’s data by contacting us or our Grievance Officer (see Section 14).

8. Data Storage and Security

• Data is stored securely on servers maintained by us or our cloud providers, with appropriate technical and organisational safeguards.
• We implement reasonable security safeguards including encryption, secure authentication, access control, and role-based access to prevent personal data breaches.
• Data is backed up regularly, and systems are monitored for breaches.
• Access to children’s data is strictly limited to authorised users.
• In the event of a personal data breach, we will notify the affected Data Principals and the Data Protection Board of India in the manner and within the timelines required under the DPDP Rules.

9. Cross-Border Data Transfers

As MathDingo is operated by an Australian company and uses international service providers (e.g., payment and analytics platforms), some personal data may be processed or stored outside India. We transfer personal data outside India only in accordance with the DPDP Act and any restrictions notified by the Central Government regarding transfers to specified countries or territories, and we apply appropriate safeguards to protect your data.

10. Your Rights as a Data Principal

Under the DPDP Act, you have the right to:

• Access a summary of the personal data we process about you and the processing activities undertaken.
• Correct, complete, update, or erase your personal data.
• Withdraw consent at any time (where consent is the basis of processing).
• Nominate another individual to exercise your rights in the event of death or incapacity.
• Grievance redressal in respect of any act or omission regarding your personal data.

To exercise your rights, email us at support@mathdingo.com or contact our Grievance Officer (see Section 14). If your grievance is not resolved satisfactorily, you may approach the Data Protection Board of India.

11. Data Retention

• Account and progress data are retained while your account is active and consent remains valid.
• We erase personal data once the purpose for which it was collected is no longer being served and retention is not required by law.
• Deleted accounts are purged within 30 days, unless legally required to retain data longer.
• Anonymised analytics that do not identify you may be retained for product development purposes.

12. Cookies and Tracking

Our web platform may use:

• Session cookies to maintain login status.
• Analytics cookies (e.g., Google Analytics, Mixpanel) for aggregated usage metrics.

We do not use cookies for behavioural tracking or targeted advertising directed at children. You can disable cookies in your browser settings.

13. Changes to This Policy

• We'll update the "Effective Date" above when this policy changes.
• We may notify you in-app or via email if the changes are significant.
• Continued use of MathDingo after updates constitutes your acceptance of the revised policy, subject to any fresh consent required by law.

14. Grievance Officer & Contact

For questions, complaints, consent withdrawal, or to exercise your rights, please contact our Grievance Officer / point of contact:

Grievance Officer – MathDingo
Byte Digital Consulting Pty Ltd
Email: grievance@mathdingo.com
Support: support@mathdingo.com

If you are not satisfied with our response, you may lodge a complaint with the Data Protection Board of India.