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Privacy Policy

Effective 23 August 2026 · Version 1.0 · Jhamly Private Limited, Bengaluru, Karnataka, India

This policy is written for parents first. Where the law needs precise language, we keep it — and we explain it in plain words.

Data Fiduciary: Jhamly Private Limited.Contact:support@jhamly.com.Grievance Officer: Nishanth Divakar Raju, support@jhamly.com, Bengaluru, Karnataka, India.

1. Who we are and what this covers

Jhamly operates: (a) an AI tutoring app for school students (grades 3–12); (b) a companion app for parents; and (c) a management platform (ERP) for schools, colleges, and institutes. This policy covers all three, across jhamly.com, jhamly.in, and their subdomains.

Jhamly is designed children-first under the Digital Personal Data Protection Act, 2023 (DPDP Act) and the DPDP Rules, 2025. Under the DPDP Act, everyone under 18 is a child, and we treat every student account accordingly — regardless of age.

2. Our commitments (the short version)

  1. No advertising, no tracking for advertising, no behavioural profiling of children for targeting — ever. We do not sell, rent, or trade personal data. We do not show ads.
  2. Parents can see everything. A parent may read the full transcript of every AI conversation their child has, see all progress data we hold, and export or delete it.
  3. Schools cannot see learning data. Where a student is linked to an institution, the institution sees account administration only (roster, class, seat status). Chat content, quiz answers, scores, and learning progress are never shared with the institution — including in aggregate form.
  4. Verified parental consent before a child uses AI tutoring.Student accounts are created and verified by a parent or guardian through a verified parent account.
  5. Real deletion. When you ask us to delete, we delete — including chat transcripts, quiz responses, and the student’s learning memory — not just names and emails.

3. What we collect

From parents: name, email address (Google sign-in), account settings, consent records, communication preferences, and support correspondence.

From student accounts: a display name or nickname chosen by the parent (we discourage full names), grade/board/stream enrolment, learning interactions (tutor conversation content, quiz responses, scores, learning progress, session memory such as topics studied and areas of difficulty), and technical data (device type, app version, crash logs).

We do not collect: precise location, contacts, photos (unless a future feature you explicitly enable requires it), payment card details, or any government ID from children.

This marketing website: we use Google Analytics (GA4) on www.jhamly.com for aggregated traffic measurement. It is not used to advertise to children, build advertising profiles, or track students inside the apps. The student and parent apps do not include advertising or tracking SDKs.

4. Why we process it

  • To provide and personalise tutoring (memory of past sessions is used solely to teach the child better);
  • To measure learning and report progress to the parent;
  • To keep the service safe (abuse prevention, content safety filters);
  • To operate accounts, billing (when launched), and support;
  • To understand how this website is used, in aggregate;
  • To comply with law.

We do not use children’s data for advertising, for profiling for commercial targeting, or for training third-party AI models.

5. How AI tutoring is processed

Tutoring conversations are processed to run the tutor. For each request we send only what the tutor needs: the current message, a bounded recent-conversation window, and a compact learning summary (topics, mastery, difficulty areas) — never the child’s full name, email, school name, or account identifiers. Children’s conversations are not used to train AI models.

6. Children and consent (DPDP Section 9)

  • All student accounts are created under a verified parent/guardian account; the parent’s Google-verified identity and explicit consent are recorded with timestamp and version of consent text.
  • Parents may withdraw consent at any time (Settings → Privacy, or by emailing us), which stops AI processing for the child. Withdrawal is as easy as giving consent.
  • Parents may review, correct, export, or erase the child’s data at any time, and may view complete conversation transcripts.
  • We do not enable tracking, behavioural monitoring of children, or targeted advertising directed at children, as prohibited under Section 9(3) of the DPDP Act.
  • When a student turns 18, we notify them and request fresh consent as an adult user; parental controls transition accordingly.

7. Institutional (school/college) accounts

Where a student joins via an institution or later links one: the institution receives account administration data only. Tutoring conversations, quiz performance, learning progress, and AI insights are visible to the student and their parent — never to the institution, its teachers, or its administrators. Historical data created before linking is not retroactively exposed.

8. Retention and deletion

DataRetention
Tutor conversationsWhile the account is active; deleted on request or on account deletion
Quiz responses & progressWhile the account is active; deleted on request
Learning memoryWhile the account is active; deleted on request
Consent records8 years after account closure (legal evidence)
Billing records8 years, as required by Indian tax law, once billing exists
Crash logs / analytics12 months, pseudonymous

Account deletion (parent app → Settings → Delete, or emailsupport@jhamly.com) erases tutoring conversations, quiz data, learning memory, and insights within 30 days, except records we must keep by law, which are listed above and isolated from product systems.

9. Security

Encryption in transit and at rest; role-based access with least privilege; per-role data isolation enforced and continuously tested at the API level; staff access to any child-related data is restricted, logged, and audited; vendors are bound by data-processing agreements.

10. Your rights (DPDP Act)

You may: access your or your child’s data; correct it; erase it; withdraw consent; nominate a representative; and seek grievance redress. Write tosupport@jhamly.com or use in-app controls. We respond within 30 days. If unresolved, you may approach our Grievance Officer, and thereafter the Data Protection Board of India.

11. Data breaches

If a breach risks your or your child’s data, we will notify affected users and the Data Protection Board of India as required by the DPDP Rules, with what happened, what data, and what we are doing about it.

12. International processing

Some AI processing occurs on infrastructure outside India, under the contracts described in section 5 and subject to applicable law and any government-notified country restrictions.

13. Changes

Material changes are notified by email and in-app notice 30 days before taking effect. Changes that require consent will require fresh consent. This page shows the current version and effective date.

14. Contact & Grievance Officer

Grievance Officer: Nishanth Divakar Raju, support@jhamly.com, Bengaluru, Karnataka, India.

General, privacy, and support: support@jhamly.com.

Jhamly Private Limited · CIN U62010KA2026PTC217168 · GSTIN 29AAHCJ3081C1ZN ·Bengaluru, Karnataka, India.

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Startup India (DPIIT) recognised startup, DIPP251517
Startup India (DPIIT)
DIPP251517
Startup Karnataka recognised startup, KITS/SK-REGN/2026-27/17861
Startup Karnataka
KITS/SK-REGN/2026-27/17861

© 2026 Jhamly · Jhamly Private Limited · CIN U62010KA2026PTC217168 · GSTIN 29AAHCJ3081C1ZN

Recognised under Startup India (DPIIT) (DIPP251517) and Startup Karnataka (KITS/SK-REGN/2026-27/17861).