Privacy Policy
Last Updated: February 3, 2026
01. Overview
Intellect Council ("we," "our," or "us"), a brand of Tosh Innovations Private Limited, operates mobile applications available on Google Play Store, Apple App Store, and the Web. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our applications and services.
We are committed to protecting your privacy and complying with applicable data protection laws including GDPR, CCPA, and the privacy requirements of Google Play Store and Apple App Store. By using our apps, you agree to the collection and use of information in accordance with this policy.
02. Information We Collect
1. Information You Provide Directly
- Account Information: Email address, username, and password when you create an account.
- User Content: Data you input into our apps (e.g., text, files, calculations, notes). Note: Most of our AI processing happens in secure environments and we prioritize local processing where possible.
- Support Communications: Information you provide when contacting our support team, including email address and message content.
- Payment Information: Processed securely through Google Play, Apple App Store, or Stripe. We do NOT store payment card details.
2. Information Collected Automatically
- Device Information: Device model, operating system version, unique device identifiers (Advertising ID/IDFA - used only for internal analytics), screen resolution, and language settings.
- Usage Data: App features used, session duration, frequency of use, clicks, and navigation patterns (collected via privacy-first analytics).
- Crash Reports: Diagnostic information when the app crashes, including device state, stack traces, and error logs.
- Location Data: Approximate location (city/country level) for timezone detection. Precise GPS location is NEVER collected without explicit user permission.
03. How We Use Your Information
We use the collected information for the following purposes:
- App Functionality: To provide core features and services of our apps.
- App Improvement: To analyze usage patterns, fix bugs, and improve performance.
- Customer Support: To respond to your inquiries and provide technical assistance.
- Security: To detect and prevent fraud, abuse, and security incidents.
- Analytics: To understand user behavior and measure performance (aggregated and anonymized data).
- Communications: To send critical app updates, security alerts, and service announcements.
- Legal Compliance: To comply with applicable laws and regulations.
We will NEVER sell, rent, or share your personal information with third parties for their marketing purposes.
05. Advertising & Monetization
Intellect Council is committed to a safe learning environment. For our free versions:
- Contextual Ads Only: We may display contextual ads that are not based on personal data or user behavior.
- Opt-Out: You can manage ad preferences through your device settings.
- Children's Ads: We do NOT display personalized or interest-based ads to children under 13. All ads shown to children are age-appropriate and contextual only.
- Families Self-Certified Ads SDKs: In compliance with Google Play's Families Policy, all ad SDKs used in our child-directed app are sourced exclusively from the Google Play Families self-certified ads SDK program. We do not integrate any ad SDK that is not approved under this program for serving ads to children.
- No Data-Driven Ad Targeting for Minors: We do not use children's personal data, behavioral data, or device identifiers for the purpose of ad targeting.
06. Data Retention
We retain your information only as long as necessary:
- Account Data: Retained while active; deleted within 30 days of a valid deletion request.
- Analytics Data: Aggregated statistics retained for 24-36 months.
- Crash Reports: Retained for 12-18 months.
- Local Data: Processed locally and NOT stored on our servers; deleted when you uninstall the app.
07. Data Security
We implement industry-standard security measures:
- Encryption: TLS/SSL (HTTPS) for data in transit; AES-256 for data at rest.
- Access Controls: Strict employee authentication and need-to-know basis access.
- Audits: Periodic security assessments and vulnerability testing.
08. Children's Privacy (COPPA, GDPR-K & Google Play Families Policy)
We take children's privacy seriously. Intellect Council is designed for learners aged 5–18 and complies with COPPA (Children's Online Privacy Protection Act), GDPR provisions for children (GDPR-K), and Google Play's Families Policy requirements.
Google Play Families Policy Compliance:
As an app that targets children on the Google Play Store, we adhere to the following mandatory requirements:
- No Personal Data Collection Without Parental Consent: We do not collect, use, or share personal data from children under 13 (or the applicable age in your jurisdiction) without verifiable parental/guardian consent. All child accounts are created and managed through authenticated guardian accounts ("Guardian Auth").
- Guardian Authentication: Intellect Council requires a parent or legal guardian to create and manage a child's account. The guardian must verify their identity, and only the guardian may grant or revoke consent for data processing on behalf of the child.
- Age-Appropriate Content: All content, features, and interactions within Intellect Council are designed and reviewed to be appropriate for the target age range (5–18). We do not include content that is violent, sexually suggestive, or otherwise inappropriate for minors.
- Family-Safe Advertising: Any ads displayed within the app are served exclusively through Google Play Families self-certified ad SDKs. We do not display personalized or interest-based ads to children. Only contextual, age-appropriate ads are used.
- Families Self-Certified Ads SDKs: All advertising SDKs and APIs integrated into our app that serve ads to children are on the Google Play Families self-certified ads SDK list. We do not use any ad network or SDK that is not compliant with this program.
- No Behavioral Tracking of Children: We do not engage in behavioral profiling or tracking that identifies individual children. Analytics are aggregated, anonymized, and used solely to improve the educational experience.
- No Unmonitored Communication: The app does not include social features, chat functions, or any mechanism that allows children to communicate with strangers or share personal information publicly.
- Compliant APIs & SDKs: All third-party APIs and SDKs used in the child-directed portions of our app comply with Google Play's Families Policy. We regularly review and audit our integrations to maintain compliance.
Data Practices for Children — Disclosure:
- What We Collect: Minimal data necessary for the educational service — child's first name or alias (chosen by the guardian), age/grade level, learning progress, and in-app activity for personalized learning paths.
- How It Is Used: Solely to deliver age-appropriate educational content, track learning progress, and improve the learning experience. Data is never sold or shared for marketing.
- How It Is Stored: Encrypted at rest (AES-256) and in transit (TLS/SSL). Stored in secure, access-controlled cloud environments.
- Parental Access & Control: Parents/guardians can review, modify, or delete their child's data at any time through the guardian dashboard or by emailing [email protected].
- Data Retention: Child data is retained only while the account is active. Upon deletion request, all child data is permanently removed within 30 days.
Parental Responsibility: If you are a parent/guardian and believe your child has provided personal information without your consent, contact us immediately at [email protected]. We will investigate and delete such data within 48 hours of verification.
09. International Data Transfers
Intellect Council operates globally. Your information may be transferred to and processed in countries other than your residence. We ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) for international data transfers, complying with global frameworks to safeguard our users.
10. Your Privacy Rights
Depending on your location, you have rights to:
- Access: Request a copy of your personal info.
- Erasure: Request deletion of your data.
- Portability: Request data in machine-readable format.
- Withdraw Consent: At any time for data processing.
To exercise these rights, email: [email protected]
12. California Privacy Rights (CCPA)
California residents have the right to know, delete, and opt-out of the "sale" of personal info. Note: Intellect Council does NOT sell personal information to third parties.
13. GDPR Compliance (European Users)
For users in the EEA, UK, or Switzerland, we process data based on consent, contractual necessity, legitimate interests, or legal obligations. Contact our DPO at [email protected] for inquiries.
14. App Store & Play Store Compliance
We comply with all store policies, including Google Play's Data Safety section and Apple's App Privacy labels and Tracking Transparency (ATT) framework.
Google Play Families Policy:
As a child-directed app on Google Play, Intellect Council fully complies with the Google Play Families Policy, which includes:
- No collection of personal data from children without verifiable parental consent, enforced through our guardian authentication system.
- This Privacy Policy fully discloses all data collection, usage, and sharing practices applicable to child users.
- All app content is reviewed and maintained to be appropriate for our declared target age range (5–18).
- All advertising SDKs and APIs used in the app are on the Google Play Families self-certified ads SDK list.
- Regular compliance audits to ensure ongoing adherence to Families Policy updates.
15. Changes to This Privacy Policy
We may update this policy periodically. Significant changes will be notified via in-app notifications or email. Your continued use of our services constitutes acceptance of the updated policy.
16. Contact Us & Legal Shield
Privacy Team - Tosh Innovations Private Limited
Email: [email protected]
DPO: [email protected]
Response Time: Within 30 days of verified requests. Any legal inquiries or disputes regarding privacy are subject to the limitation of liability clauses defined in our Terms of Service.
Need legal clarification?
Our legal team is dedicated to ensuring your family's data remains protected. If you have any specific questions about our privacy policy, we're here to help.