Privacy Policy

Bhasha is made by Eldren Holdings LLC ("Eldren Labs", "we", "us"), 7901 4th St N, Ste 300, St. Petersburg, FL 33702, United States. We are the controller of the personal data described here. This policy covers Bhasha on iPhone and Android. Bhasha on Android has not yet been released. Android-specific provisions describe the forthcoming release. Bhasha on the web has its own edition, at https://app.bhasha.eldrenlabs.com/privacy.

When you first open Bhasha you see one screen with "Agree & continue". Tapping it means you agree to our Terms and have been told about this policy. It is not a consent to everything below: each use has its own legal basis, shown in section 04. Versions before 2.1 worked differently, especially in the European Economic Area (EEA) and Switzerland (section 06).

• To run the app you asked for: your account, keeping your progress with your account, AI lessons and answers, voice, purchases, allowances, the Community, Adda, and messages to the developer
• To fix problems and improve Bhasha: how the app is used, plus crash and performance counts
• To understand our subscription revenue: purchase details, reported through RevenueCat
• To tailor your learning: using your study history to shape your plan, practice, next lessons and reminder times. This is part of how Bhasha works

You can turn off "Usage measurement" at any time in Profile, Settings, Privacy, and Bhasha keeps working.

Account (Sign in with Apple on iPhone, Google on Android, or a code sent to your email)

• With Sign in with Apple: an Apple-provided identifier, plus your name and email if you choose to share them through Apple's sign-in. With an email code: your email address; we send you a code and never ask for a password. We use them to create your account, secure cloud features, and show your name on lessons you choose to share to the Community
• On Android, you sign in with Google or with an email code. With Google, your browser opens Google's sign-in, and we receive a Google-provided identifier, your email address and, if your Google Account shares them, your name and a link to your profile picture. We use them as described above and never see your Google password
• Sign in with Apple is not offered on Android. If your account has only Sign in with Apple, use iPhone version 2.1 or later to add an email in Profile, Sign-in methods, then use an email code on Android. If that option is unavailable, contact support before creating another account
• If you ask for an email code and never use it to sign in, the account it made is deleted automatically after 7 days
• On iPhone, from version 2.1.1, you need a Bhasha account to use Bhasha. The one exception is a device on which someone told Bhasha they are under 13 (section 07): it keeps learning without an account, and it cannot buy a plan, Lifetime or Ask Bhasha, because every purchase belongs to an account
• On Android, and on iPhone before version 2.1.1, signing in is needed only for cloud features (keeping your progress with your account, the Community, Adda, Ask Bhasha, voice conversations and chatting with the developer). The personal learning experience works without an account there
• If you are signed in, we keep a record that you accepted our Terms: the version, the date and time, where in the app you accepted (for example the first screen, sign-in or a purchase) and the app version. We keep it as evidence of our agreement with you
• If you delete your account, we keep one thing so that free allowances cannot be reset by deleting an account and signing in again: a one-way code made from your sign-in identifier, with three numbers beside it (free hand-off lessons, free Ask Bhasha replies and free lesson upgrades already used). The code cannot be turned back into your Apple or Google identifier, name or email, it is linked to nothing else, and it is deleted after one year

Learning content you create

• From version 2.1, if you are signed in, we keep your learning progress with your account so it is the same on your other devices and on Bhasha on the web: the lessons you finished or skipped and your plan, your hearts, Practice and saved lessons, every flashcard grade and practice answer (with when you answered and how long it took), your study days, badges, XP and level, your practice energy and how you used it, your lesson voice and reminder settings, your age range, and your Ask Bhasha conversations (what you typed, the replies, and the lessons and rules in them). Only you can read them through the app; our staff tools have no access to them. We keep them until you delete your account. Recordings stay on your device and in your private iCloud and are never sent to us. We are turning on keeping progress with your account in stages, so until it reaches your account, your progress stays on your device and in your private iCloud
• On iPhone, if you are not signed in, your progress stays on your device and, unless it has moved to your account, in your own private iCloud (Apple CloudKit). This is your iCloud, not our servers; we cannot access it, and it is never used to train AI. Once you have signed in and your progress has moved to your account, it is kept on that device and with your account, not in iCloud, and stays on the device if you sign out
• On Android, when you are signed in, we keep the same learning progress and Ask Bhasha conversations with your account from the start. Without an account they stay in the app's private storage on your phone and are lost if you delete the app or clear its storage. Bhasha on Android does not use iCloud and turns off Android's automatic backup of app data
• Hand Off lessons: from version 2.1, when you are signed in, the text of your Hand Off lessons (what was typed and the lesson made from it) is stored with your account so you can see and share them on the web. Voice recordings stay on your device and are never uploaded. Deleting your account deletes them
• When you use Ask Bhasha or make a lesson from a hand-off, the text of that conversation or lesson is sent to our servers so it can be answered or generated, and kept there, private to your account, so you can see it again. A photo you attach to Ask Bhasha is sent to our AI partner for that one reply and is never stored, by us or in the saved conversation
• So that an answer you were charged for is never lost or charged twice, our servers also keep a copy of each Ask Bhasha reply and each lesson made from a hand-off for up to 24 hours. For each lesson made from a hand-off we keep a one-way code made from its Bangla text (not the text itself), so that only a lesson your account made can be improved later
• Before Ask Bhasha shows you a lesson card, our servers check that it has every part. If a card comes back incomplete, we hold it back instead of showing it, and keep your question and that unfinished card on our servers, private to your account, for up to one day so the card can be made again when the app asks for it. After one day they are deleted automatically
• To add missing word meanings or fuller detail to a lesson that was made through our servers earlier, the app may send that lesson's text again while you are signed in. A lesson you made while signed out has never left your device, and it is never sent for this

Your setup answers and study routine

• During setup you tell us your level, who you talk to, topics you like, your goal and how many days a week you want to study. These answers are sent to our servers to build your course
• If you are signed in, your setup answers (your level, who you talk to, your topics, how formal you want to speak, your goal, daily minutes and days a week, dialect preference, placement result, and the name you chose to be called, if you gave one) are also stored on our servers, private to your account, so your plan comes back when you sign in on another device
• You can also tell us when you usually study and where (Home, Commute, Work or school, Café or out, or It varies). If you are signed in, your study time and place are saved to your account (before version 2.1, only while "Personalise my learning" was on)
• From version 2.1, setup does not ask your age. If an earlier version asked your month and year of birth, only the age range it fell in is kept: on your device and, if you are signed in, with your account. Your birth date is never stored or sent to us (section 07)

Voice

• Hand Off recordings stay on your device and in your private iCloud. To turn a recording into a lesson, the audio may be sent briefly through our secure server to an AI transcription partner. It is processed and discarded. It is never stored on our servers, never used to train AI, never shared, and never included in the Community, analytics or logs
• On Android, Hand Off recordings stay in Bhasha's private storage on that phone. They are not uploaded or sent for transcription, they are not backed up, and they are not moved to a new phone by Android's device transfer. They are lost if you delete the app or lose the phone. The lesson is made from the text, not the audio
• Voice conversations (Bhasha Plus and Pro): while you talk with Bhasha out loud, your microphone audio streams to our AI voice partner, with the lesson context the conversation needs, so it can reply. The partner runs in zero retention mode: the audio is processed to produce the reply and is not stored. We count the minutes you use so we can apply your plan's voice allowance
• If a live voice connection cannot be used, the app may instead turn your speech into text with Apple's speech recognition, and send that text to our servers and our AI partner for a reply. Recognition happens on your device when your device supports it; otherwise Apple processes the audio on its servers under Apple's own privacy policy. We never receive that audio. Bhasha on Android does not use this fallback

Messages to the developer (if you send any)

• Your messages and any photos you attach are stored so we can read and reply to them
• Bhasha on Android has no developer chat: Contact us opens an email to support@eldrenlabs.com

Short surveys (from version 2.1, if you answer)

• If you are signed in, Bhasha may ask a few optional questions: how you found Bhasha and what made you try it, and later how your learning is going. Your answers, any short text you choose to add (up to 200 characters) and when you answered or skipped are stored with your account, so we know what helps and do not ask again too soon. You can skip any question
• The last check-in question asks if you would talk to us about Bhasha. Only if you say yes and give an email address do we store it, to invite you to a short conversation. You can withdraw at any time, and the email is then deleted
• Survey answers are separate from usage measurement: they are what you chose to tell us, and they are never in usage data

Community submissions

• If, and only if, you choose to share a lesson, its text (the phrase, its meaning and usage context) is sent to our servers, checked by moderation, and shown to other learners in the Community library with your display name
• The name shown with a shared lesson goes through the same word filter as Adda names. A name that the filter blocks, or that looks like a link, is not stored, and the lesson shows no name. People who are not signed in see Community lessons without the name
• Text only. Never your audio, your voice or your contact details
• You can withdraw a shared lesson at any time
• From version 2.1 you can react to Community lessons (a heart, clap, fire or shabash). We store which lesson you reacted to and with what, linked to your account. Others see how many reactions a lesson has, never who reacted. A lesson that gets enough reactions may be shown in Adda as a Community pick

Adda (your public profile, optional, adults only)

• Adda is the social page of the Community tab. It is off until you join. Adda is for adults: it is closed if you told us you are under 18. When you first open Adda on iPhone, Bhasha asks for the age range Apple can share, with your permission. If you don't share it, or Apple can't, you confirm once that you are 18 or older. On Android, Bhasha does not ask Google for your age: you confirm once that you are 18 or older, unless your account already records you as an adult. We store when your age was confirmed. If Apple's range shows you are under 18, Adda stays closed; if it shows you are under 13 while you are signed in, Bhasha signs you out on this device (section 07). If you later tell us you are under 18, we delete your Adda profile, follows and reactions, and that confirmation
• From version 2.1, if you ever tell us you are under 18, our server keeps a private record of the age range you gave and when it first saw it, and Adda stays closed until you would be 18 by the end of that range. It never holds your birth date. If you correct a mistake within a few minutes ("Not under 18? Change it" on the closed Adda card), the record is removed. Otherwise you can ask us to check from the closed Adda card: we store your request and any message you add, with your support messages, and we show our decision on the Adda card and send a notification if you allowed them. The record is deleted when we approve your request. If you delete your account while it applies, we keep only a one-way, scrambled marker made from each way you signed in (such as your Apple or Google sign-in or your email address) and the date you would turn 18, until that date, so that a new account made the same way keeps Adda closed. The marker is not your email address or your Apple or Google identifier, cannot be turned back into them, and is used for nothing else. It is not kept if you told us you are under 13
• When you join, we store your Adda profile: the display name you choose, the avatar you make (a drawing built from preset parts, never a photo), when you confirmed your age, and whether automatic posting is on
• Your profile is public inside Bhasha: anyone signed in to Bhasha on iPhone, Android or the web can see your name, your avatar, your posts, how many reactions each post has, and how many people follow you and you follow. People you block, and people who block you, cannot see you in Adda, and you cannot see them
• Posts are milestones from your learning (a badge, a level, a streak, a finished course, or a Community lesson you shared under your name once it is approved). They are made only while automatic posting is on, or when you post one yourself. Posts have no free text
• We also store who you follow, the reactions you give and the people you block. Others see reaction and follower counts, not who reacted or who follows whom
• If you report a profile or a post, we store the report, its reason and who sent it so the Bhasha team can review it. The person reported is not told who reported them. A moderator can hide a profile or a post that breaks the Terms; a hidden profile stays hidden if it is made again
• You can edit your profile at any time. Turn off (Community, Adda) deletes your profile, your posts, your follows and the reactions you gave straight away. We keep your blocks, reports you sent or that were made about you, a record of when you posted (for the daily limit) and any moderation decision while your account exists, so turning Adda off and on again does not undo them. Deleting your account deletes all of it, except that a report someone else made about you stays as a moderation record, no longer linked to you

Purchases (Bhasha Plus, Bhasha Pro and Lifetime)

• On iPhone, purchases are processed by Apple. We never see your payment details
• On Android, purchases are processed by Google Play: Google handles payment, and we never see your payment details. RevenueCat connects the app to Google Play and tells our server what you bought and its status (active, in a trial, cancelled, expired or refunded), linked to your Bhasha account, so we can unlock your plan. We keep the product, its billing period, when it ends and whether it renews with your account. Bhasha Lifetime is not sold through Google Play
• On iPhone, Apple sends our server notifications about your purchases and subscription status (active, expired or refunded), linked to your account by an app-specific token, so we can unlock your plan. We also record whether a purchase began with a free trial or another introductory offer, and the price and currency Apple charged for it. This log of Apple's notifications names no one by itself; we link each entry to your account only to tell a trial that became a subscription from a new purchase
• On iPhone, when you buy while signed in, the app records which plan you chose and which screen you bought it from, with the time. We use this purchase record to support you if a purchase goes wrong
• Separately, as usage data, the same record carries your app and system version, which of two purchase-button designs you were shown and whether a free trial was on offer. The app sends this part only while "Usage measurement" is on, and it is removed from the record after 400 days
• We keep allowance counters (for example Ask Bhasha replies and hand-off lessons used) and, for each signed-in account, daily counts of the AI features used (replies, lessons, speech requests and seconds of voice conversation), so we can apply limits, see what each plan costs to run and spot abuse. These are counts only, never the content

Tips on our web page (optional)

• If you leave a tip on the Bhasha web page, Stripe runs the checkout and takes your payment details. We never see your full card number. A tip is a one-time payment to Eldren Holdings LLC, separate from your Bhasha account and plans
• Stripe reports the payment to us: your email address, the name and billing details you entered, the amount and the date. We use this to email your receipt (sent through Resend), handle refunds and fraud, and keep the accounting records the law requires, for as long as it requires. Our website does not store these details. Separately, our website's visit counts note that the tip card came on screen and which tip button was tapped, as the Eldren Labs privacy policy describes. They do not say whether you paid, and we do not connect them to your payment or your account. We do not connect a tip to your Bhasha account or use it in the app, so deleting your account does not delete these records. To ask about them, email support@eldrenlabs.com

How you use the app (usage data)

• When you open and close the app and for how long, which screens you visit and the screen you leave from, lessons and practice you start, finish or stop (and how far you got), which lesson from our own library you opened or finished (never a lesson you made or one from the Community), onboarding steps, features you use (for example Ask Bhasha, voice, Hand Off, grammar rules, downloads, the Community and the paywall), purchases started, completed or cancelled, notification and settings choices, your answers to optional one-tap questions such as "How did you find Bhasha?" and "Enjoying Bhasha?", which reminders reached your device, which wording they used and whether you opened one, links you open from the app, repeated taps on one spot, with the rough area of the screen and which part of it was showing, which version of a screen we are testing you were shown (such as a plan offer during setup), and errors
• Crash and performance counts: daily counts of crashes, hangs, slow or heavy work, times the system closed the app, how long the app takes to launch and how smoothly screens scroll, from Apple's MetricKit. From version 2.1 the app also keeps its own daily figures for peak memory and which screen it was on, processor use, memory warnings and time spent running hot. Apple delivers its reports about a day later, so a report sent after you turn usage measurement on can include a day when it was off. It holds counts and durations only
• Each record carries short labels and numbers only, plus your plan, the app version, your device type and model, your system version, language, the region setting on your phone (not your location), your time zone and the local hour and weekday
• The app also sends a short summary of your install: the app and system version, device type and model, your plan, whether you are signed in, whether notifications and practice reminders are on, when you finished setup, and from your setup answers your level, who you talk to (or "multiple"), your pace and your days a week
• Your install gets a random identifier made by the app. It is kept in your device's Keychain and is not synced to iCloud. When you sign in, this identifier and your usage are linked to your Bhasha account, so your iPhone and iPad count as one person. If you never sign in, your usage is linked only to that random identifier
• We never collect, as usage data, your email, your name, anything you type (such as search, notes, chat or lesson text), your location, your contacts or Apple's advertising identifier (IDFA). Our servers do not store your IP address with these records. Version 2.0.1 also recorded which accessibility settings were switched on; from version 2.0.2 the app no longer sends this
• At most once a day the app also sends anonymous study counts: whether the app was opened that day, and for finished days the number of lessons, practice answers and correct answers and lesson minutes, plus your plan type, the app version and how many days after install the activity happened. These carry no account, no device identifier and no name or email
• The app also sends anonymous step counts for a few journeys: making a Hand Off lesson, sharing to the Community, paying on the web (opening Price details, which way you chose to pay, why the web could not be offered, whether checkout opened, and how it ended), and the paywall (which screen it was opened from, which plan was picked, which button design was shown, whether a free trial was on offer, and whether a purchase started, finished, was cancelled or failed). Like the study counts, they carry no account, no device identifier and no name or email
• On Android, usage measurement follows the same rules and the same switch, with these differences. The device details are an Android phone or tablet, its model and the Android version. The random identifier is kept in the app's private storage, not a Keychain, and goes if the app is deleted. There are no MetricKit counts and no crash-reporting software. We never collect Google's Advertising ID or the Android ID
• None of this is sent until you have agreed on the first screen, and none of it is sent while "Usage measurement" is off
• Separately, our own server keeps anonymous counts of web payments: when a web checkout was offered, refused and why, started or opened, when a web purchase completed and when a web payment failed, with the plan, the plan level and the country of the purchase where it is known. These counts hold no account, email, device identifier or payment details, and only the date, and we don't link them to you. Because of that they are kept whether "Usage measurement" is on or off

Personalisation, reminders and the return model

• Practice reminders are scheduled on your device. They follow your days-a-week goal and you get at most one a day. Besides the daily practice reminder, there are reminders to save your streak, a weekly recap, a new topic to try, full energy (on the Free plan) and a trial that is about to end. You can switch each kind on or off in the Reminders page
• In the Reminders page you can let Bhasha pick the time or set a time yourself. When Bhasha picks it, your device works out when you usually study from your recent study sessions and applies that time automatically. This learned time stays on your device
• Each day your device also keeps a small snapshot of your study pattern (for example how many days you studied recently, whether your streak is alive and whether reminders are on) and later notes whether you came back the next day. We use this to learn which reminders and suggestions help people keep learning. The snapshot stays on your device. Only a short label for it and whether you came back the next day are sent to us, as usage data, and only while "Usage measurement" is on
• We test different wordings for reminders, to see which ones help. Which wording you were sent is part of your usage data
• Predictions are suggestions only. They never decide your price, your access to anything you paid for, or anything else with a legal or similarly significant effect on you
• From version 2.1, tailoring your reminders, practice and next lessons to your study history is part of how Bhasha works, so it has no separate switch (section 04). Before version 2.1, a "Personalise my learning" switch turned it off (section 06)

Location (optional, stays on your device)

• Bhasha may ask to use your approximate location while the app is open. It is used for one thing: to suggest downloading your next lessons when you are far from your usual area
• Every position is rounded to about 1 km before it is used or stored, kept only on your device, and never sent to us or anyone else. Nothing worked out from it (such as "away from your usual area") leaves your device either
• Saying no changes nothing else, and you can change it at any time in your device's Settings. We never ask protected minors (section 07). Bhasha never reads network names or nearby devices to guess where you are
• Downloads wait for Wi-Fi by default. You can allow mobile data in the app's download settings
• Bhasha on Android does not ask for your location

Notifications

• Reminders need nothing from our servers
• From version 2.1, if you are signed in and allow notifications, we store your device's push token, linked to your account, with the app version you are on. We use it to tell you about replies in the developer chat, decisions on requests you send us (such as an Adda age check), and when a new version of Bhasha is ready. Before version 2.1 it was stored only if you used the developer chat. It is deleted when you sign out or delete your account
• On Android, these notifications go through Firebase Cloud Messaging, a Google service. If you are signed in and allow notifications, we store the push token Firebase gives your phone, linked to your account, with the app version you are on. Google receives that token and the title and text of each notification so it can deliver it. Firebase Cloud Messaging is the only Firebase service Bhasha uses, and Firebase's analytics are switched off

Technical data

• Like any internet service, our servers see your device's IP address when the app connects. It is used to deliver content and keep the service secure, and is not stored with your usage data
• To check for app updates, the app asks Apple's App Store for the latest version of Bhasha, sending your phone's region setting
• On Android, update checks go through Google Play's in-app update service
• Everything Bhasha sends travels over encrypted connections. On our servers, access rules keep what is private to your account from other learners

Where the GDPR or UK GDPR applies, these are our legal bases. Elsewhere, this section is our notice of what we do and why.

Contract (to provide the service you asked for)

Your account; keeping your progress, Ask Bhasha conversations and Hand Off lessons with your account (sync); your setup answers, to build and restore your course; personalising your plan, practice and reminders from your study history; Ask Bhasha, hand-off lessons, lesson upgrades and voice; the Community and Adda; the developer chat; your push token, for replies, request decisions and update notices; Community reactions; unlocking what you bought and the purchase record (plan, screen and time); allowances and fair-use limits; reminders you switch on; content delivery and update checks; on Android, connecting your Google Play purchases through RevenueCat.

Tips on our web page

Contract: taking your tip and sending your receipt. Legal obligation: keeping accounting records. Legitimate interests: preventing fraud and handling refunds.

Legitimate interests (GDPR Article 6(1)(f))

• Usage measurement (usage data, the return model's label, and anonymous study and step counts): to understand how Bhasha is used, find what confuses people, learn which reminders and suggestions help people keep learning, and improve lessons and the app. It has its own switch (section 05)
• Crash and performance counts: to find and fix crashes, hangs and slow screens
• Subscription reporting through RevenueCat: to understand our own revenue, trials and cancellations
• Reviewing Adda reports and keeping blocks and moderation decisions, to protect other users
• Keeping Adda for adults: the private record of an under-18 age range, age-check requests, and the scrambled sign-in marker kept after an account is deleted
• Optional surveys: to learn how people find Bhasha and what helps them keep learning. Answering is your choice, and you can skip. Your interview email is kept only with your consent (Article 6(1)(a)), which you can withdraw
• Security and preventing abuse: looking at AI usage counts for accounts that misuse the AI features, the one-way code kept after account deletion, and the Terms acceptance record (to show what we agreed). Counting your use against your plan's limits is part of the contract, not this

We have weighed these interests against your rights. We use the least data we need, never sell or share it, never use it for ads, keep it for limited periods, and give you a simple way to say no (section 05).

Consent (EEA and Switzerland, before version 2.1)

Before version 2.1, for storing or reading information on your device for anything that was not strictly necessary, through the "Accept & continue" button. See section 06.

Legal obligation

Where we must keep or disclose data by law.

From version 2.1 everyone sees the same "Agree & continue" screen and one "Usage measurement" switch, and usage measurement is on once you agree, except while we don't know your age in the UK, the EEA and Switzerland, where it starts off (section 07). If you chose "Continue with essentials" in an earlier version, that choice is kept: usage data stays off until you turn "Usage measurement" on.

Before version 2.1

• If your App Store country, device region or time zone pointed to the EEA or Switzerland, or we could not tell where you were, the first screen showed two equal buttons: "Accept & continue" (everything in this policy) and "Continue with essentials" (only what is strictly needed to provide the service you ask for: no usage data, no anonymous study or step counts, no crash and performance counts, no subscription reporting through RevenueCat and no personalisation). Both accepted our Terms, and the app worked fully either way. RevenueCat did not start in the app until you tapped Accept
• Profile, Settings, Privacy had two switches. "Share usage data" worked as "Usage measurement" does now. "Personalise my learning" off stopped learning your study time and the return model, deleted the study times and daily snapshots already learned on your device, removed your study time and place from your account, and turned off the location-based download suggestion; reminders then used the time you set
• If you are still on an earlier version, these choices keep working as described until you update

If you used Bhasha before version 2.0.2

Wherever you are, the app sends no usage data and personalises nothing until you answer the "We've updated our Terms and Privacy Policy" screen.

• Bhasha is a general learning app. From version 2.1 it does not ask your age when you start, during setup or when you sign up. Your age is asked only when you open Adda, the public profile, which is for adults only: Bhasha uses the age range Apple shares with your permission, and otherwise asks you to confirm that you are 18 or older. On Android, it asks you to confirm that you are 18 or older, and does not use an age range from Google. Where the law requires apps to check age (for example in Texas), and only when Apple tells Bhasha so, Bhasha also asks Apple for your age range once when it opens; your answer is used the same way. We never ask for or keep your birth date, only an age range. An age range you gave earlier, when setup used to ask, is kept as it was
• Under 18: if you told us you are under 18, usage measurement is off in every country and cannot be turned on, location is never asked for, Adda is not offered, and our server keeps the private record described in section 03 (Adda). If you told us you are 13 to 17 and that is wrong, use "Not under 18? Change it" on the closed Adda card, or ask us to check from it
• Unknown age: in the UK, the EEA and Switzerland, or when we cannot tell where you are, usage measurement starts off while we don't know your age, and you can turn it on in Profile, Settings, Privacy
• Under 13: a device on which someone told Bhasha they are under 13 can keep learning signed out, with everything kept on that device, but cannot sign in, and none of its learning data is synced to an account. If this happens while you are signed in, Bhasha signs you out on that device. On iPhone, the device remembers it in its Keychain, so it still applies if the app is deleted and installed again. On Android, the mark is kept only in the app's private storage, so it goes if the app is deleted or its storage is cleared. Usage measurement and learned reminder times stay off there. Nothing can be bought on that device, because every purchase belongs to an account. If we learn that we hold data from an account of a child under 13, we delete it
• Before version 2.1, setup asked your age, and protective settings applied under 18 in the UK and under 16 in the EEA or Switzerland, with personalisation off too. You can see your settings in Profile, Settings, Privacy
• Where local law requires parental permission for a feature or processing, that requirement still applies

On iPhone, from version 2.1.1, you sign in to use Bhasha, except on a device marked under 13 (section 07). Without an account (on Android, on an older iPhone version, or on a device marked under 13), your progress stays on your device (and, on iPhone, unless it has moved to your account, in the iCloud of the Apple ID it uses). From version 2.1, when you sign in, your learning progress and your Ask Bhasha conversations are kept with your Bhasha account, so they are the same on your other devices and on Bhasha on the web. Recordings stay on your device and, on iPhone, in your private iCloud, and are never kept with your account.

On Android

Bhasha on Android does not use iCloud. When you sign in, your progress and Ask Bhasha conversations are kept with your account from the start, so they are there on another Android phone and on Bhasha on the web, and on iPhone once keeping progress with your account has reached you there. Without an account, your progress stays on your phone and is lost if you delete the app. Recordings stay in the app's private storage on that phone.

On iPhone, to check that your progress reached your account safely, the app reports, with your account and a random install identifier, your app version, the subscription plan it shows you, counts of what was moved and any error code. These reports contain no lesson, conversation or learning plan text, and they are removed when you delete your account. They are part of running the app, so the Usage measurement switch does not turn them off. We are turning on keeping progress with your account in stages, so until it reaches your account, your progress stays on your device and in your private iCloud.

One Bhasha account per device

Bhasha is designed for one Bhasha account per device. On iPhone, once keeping progress with your account has reached you, only the first account that signs in on a device keeps its progress in sync from that device; if you sign in to a second account on the same device, its progress does not sync from there. If several Bhasha accounts are used on one device, or one Apple ID's iCloud is used with more than one Bhasha account, their on-device learning data can mix, and we cannot separate it. On Android, when a different account signs in, the phone shows and syncs that account's learning data, and Hand Off lessons made on the phone stay tied to the account that first synced them. Use the same sign-in method on every device: a different method can create a separate account.

We share data only with these service providers, who process it for us under contract, only for the purposes above. They are not allowed to use it for their own purposes or to train their models on your content.

• SupabaseHosts our backend (database, sign-in and server functions) in the United States, including usage data and, when you are signed in, your synced progress
• ResendDelivers the sign-in emails with your code and the receipt for a tip, and processes your email address and delivery information for that purpose
• Google (Gemini)Generates and checks lesson text, answers Ask Bhasha questions (including photos you attach), builds your course from your setup answers, and helps moderate Community submissions
• ElevenLabsSpeech-to-text, text-to-speech and live voice conversations
• RevenueCatSubscription reporting. It does not decide what you can use: Apple and our own server do that. Its software starts in the app only after you agree on the first screen and the app knows your App Store country. In the EEA, Switzerland and the UK it starts only while usage measurement is allowed ("Usage measurement" is on, you are not a protected minor, and, before version 2.1, you tapped Accept in the EEA or Switzerland); elsewhere it is not controlled by the switches (section 05 says how to object). It gives your install a random RevenueCat identifier, and when you sign in it uses your Bhasha account identifier instead, so we can tell one subscriber's history from another's. When you buy in the app, it receives the purchase details Apple reports for that transaction. The first time each account signs in on an install, it also receives the App Store purchase history of your Apple Account for Bhasha, so subscriptions bought earlier are counted, and it later learns about renewals, cancellations and refunds from Apple. Like any online service it also receives basic technical details such as your IP address, your device model, the app and system version, your language and region settings and your App Store country. We do not switch on its collection of device identifiers and do not use any of its advertising or attribution features. It receives no lesson text, chat, recordings, email or name. On Android, RevenueCat also connects the app to Google Play. It starts the first time you sign in on the phone, under your Bhasha account identifier, whatever the Usage measurement switch says. It receives the Google Play purchases of Bhasha on the Google Account on your phone and the same kind of technical details, and it tells our server about purchases, renewals, cancellations and refunds so your plan can be unlocked. It receives no lesson text, chat, recordings, email or name there either
• StripeProcesses payments on the web, including tips left on the Bhasha web page, and prevents fraud. Stripe is also responsible for some payment data under its own privacy policy
• AppleSign in with Apple, App Store purchases and notifications, iCloud (your private database), push notifications, and speech recognition when it cannot run on your device, under Apple's own privacy policy
• Google (sign-in, Google Play and Firebase Cloud Messaging)On Android: Sign in with Google, Google Play purchases, renewals, cancellations and refunds, Google Play's update check, and delivery of push notifications, under Google's own privacy policy

We may also disclose data if the law requires it, or to protect our users or our rights. If Eldren Labs is sold or merged, data would move with the business under this policy.

Transfers

Our servers are in the United States. Where data leaves the EEA, Switzerland or the UK, we rely on the transfer safeguards in our providers' data processing terms.

No ads, and no advertising or tracking SDKs. No cross-app or cross-site tracking, and we never use Apple's advertising identifier or Google's Advertising ID. We do not sell your personal data, and we do not "share" it for cross-context behavioural advertising as California law uses that word. We do not use data brokers. We do not read your contacts or your precise location, and your approximate location never leaves your device.

Delete your Bhasha account without the app

Bhasha is made by Eldren Holdings LLC (Eldren Labs). You do not need the app to delete your Bhasha account and its data. Use either of these:

• Sign in at https://app.bhasha.eldrenlabs.com/me and choose Delete account & all data
• Email support@eldrenlabs.com, or use eldrenlabs.com/support, with the subject "Delete my Bhasha account", from the email address on your account. Tell us how you sign in. We may ask you to show that the account is yours, and we reply within the times in section 13

Your account and server data are handled as set out below whichever way you ask. Deletion through the web or support does not itself erase data stored on your devices or in your private iCloud. A Google Play or App Store subscription keeps renewing until you cancel it with the store, so cancel it first: for Google Play, at https://play.google.com/store/account/subscriptions, and for the App Store, in your device's Settings.

Delete it in the app

Deleting the app removes the data on your device. To delete your account and cloud data, use Delete account & all data in the app (Profile, Settings). This deletes your server account, your setup answers, your synced learning progress and energy log, your Ask Bhasha and hand-off history, your messages, your Community lessons, your Adda profile, posts, follows, reactions, blocks and reports, all usage data linked to your account and every install linked to it, and, on iPhone, purges the copy in your iCloud. On Android, it also removes your lessons, recordings and progress from that phone. The app deletes its install identifier. Deleting your account does not cancel an App Store subscription; cancel that in your device's Settings. It does not cancel a Google Play subscription either: that keeps renewing until you cancel it in Google Play. If a plan or AI add-on bought on the web is still set to renew, we cancel it for you when you delete your account. If we cannot confirm the cancellation, your account is not deleted yet, and you can try again or contact us.

A few things are kept. The first is the one-way code and the three used-allowance counts described in section 03 under Account, for one year. The second is the one-way device codes described below, for 180 days. If you told us you are 13 to 17, the scrambled sign-in marker and the date you would turn 18 described in section 03 (Adda) are kept until that date. Anonymous study and step counts, and the log of Apple's subscription notifications once its link to your account is gone, cannot be linked to you, so they are not affected. A record that the deletion was carried out is kept for 90 days. A report someone else made about you stays as a moderation record, no longer linked to you. Purchase records held by Apple, Google and RevenueCat are kept as needed for accounting; email support@eldrenlabs.com to have the RevenueCat record deleted.

Sign in with Apple at deletion (from version 2.0.2)

If your account was made with Sign in with Apple, deleting it shows Apple's sign-in sheet once more. The one-time code Apple gives the app is sent to our server with the deletion request and used straight away to ask Apple to revoke Bhasha's access to your Apple Account. The code and the tokens Apple returns are not stored or logged. If you cancel the sheet, your account is still deleted.

Sign in with Google at deletion

Deleting your account removes your Google sign-in from our side. To remove Bhasha from your Google Account as well, use the third-party connections page in your Google Account.

Deleted on another device (from version 2.0.2)

While you are signed in, the app registers a random secret it made for your account on that device. Our servers keep only a one-way code made from your account identifier and that secret, for up to ten devices. A device that is no longer signed in can ask, for up to 14 days after it was signed out, whether its account has been deleted. If it has, the device removes that account's data from itself: plan state, usage counts, developer chat, chat sessions and Community sharing settings. It never removes lessons, recordings, progress or anything in your iCloud. Bhasha on Android does not use this check: an Android phone keeps what is stored on it until you delete the app or use Delete account & all data there. The secret stays in the device's Keychain and is removed when you sign out. After you delete your account the code is no longer attached to an account, cannot be turned back into your identifier, and is deleted after 180 days.

Use the in-app tools (Delete account & all data, and the "Usage measurement" switch in Profile, Settings, Privacy) or email support@eldrenlabs.com. We will never treat you differently for using these rights, and on Android you can decline to sign in and still use the core app. On iPhone, from version 2.1.1, an account is needed to use Bhasha (section 03).

In the EEA, Switzerland and the UK

You can ask to access, correct, delete or receive a copy of your data, to restrict how we use it, and to object (section 05). We reply within one month of your request. If a request is complex, or you send several, we may take up to two more months; if so, we tell you within the first month and explain why. You can also complain to your data protection authority (in the UK, the Information Commissioner's Office).

In the United States and everywhere else

You can ask to see or delete the data we hold about you, and to object as described in section 05. We reply within 45 days of your request. If a request is complex, we may take up to 45 more days; if so, we tell you within the first 45 days. If the privacy law where you live gives you more rights or a shorter deadline, we follow it.

We'll post changes on this page and update the date at the top. If a change materially affects how we use your data, we'll tell you in the app before it applies to you.

Eldren Holdings LLC, 7901 4th St N, Ste 300, St. Petersburg, FL 33702, United States. Email support@eldrenlabs.com, use Contact us in Settings or, on iPhone, the developer chat in the app, or visit eldrenlabs.com/support.