Bolshikho — Privacy Policy

1. Who we are

Bolshikho is a free English learning application for Android. It is published by Spectrotags Technologies Private Limited, an Indian private limited company that trades under the brand name AppMedia India.

In this policy, “we”, “us” and “our” mean Spectrotags Technologies Private Limited. “You” means the person using the Bolshikho app. “The app” means Bolshikho.

We are the data fiduciary (under India's Digital Personal Data Protection Act, 2023) and the data controller (under the EU and UK General Data Protection Regulation) for the limited technical data described in this policy.

2. Scope and your consent

This policy applies to the Bolshikho Android application and to this website at appmediaindia.com where it hosts pages about Bolshikho. It does not apply to any other company's app, website or service, even if you reach it from a link or an advertisement inside Bolshikho.

By installing and using Bolshikho, you agree to this policy. If you do not agree with it, please do not use the app — you can uninstall it at any time, which stops all further collection immediately.

Where the law in your country requires consent for optional collection, we ask for it inside the app. You may withdraw that consent at any time, and withdrawing it is as easy as giving it.

Please read this policy alongside the Bolshikho Terms & Conditions, which govern your use of the app.

3. Information we collect

Bolshikho is designed to work without knowing who you are. What follows is a complete description of what the app does and does not handle.

3.1 Information you provide to us

Inside the app: none. There is no registration form and no profile page. The app never asks you for your name, email address, phone number, postal address, date of birth, photograph, payment details or location.

The only time you give us information directly is when you choose to contact us — for example, by emailing support@appmediaindia.com to report a problem or make a data request. We then receive whatever your message contains, and we use it only to answer you.

3.2 Information stored on your own device

Your learning activity — lessons completed, vocabulary practised, quiz scores and progress indicators — is saved locally on your device, in the app's private storage. It is not uploaded to us and we cannot see it. It stays there until you clear the app's data or uninstall the app, and it does not transfer to a new phone.

3.3 Information collected automatically

Like almost every Android app, Bolshikho collects a small amount of technical and usage information automatically, so we can tell whether the app is working and which parts of it people find useful. This information is anonymous and aggregated, and it is not linked to your name, email address or phone number, because we do not have those.

• Device information — device manufacturer and model, screen size, and the language and country setting of the device.
• Operating system information — the Android version your device runs.
• App information — the installed version of Bolshikho and the installation source.
• Anonymous usage events — counts of things like “a lesson screen was opened” or “a quiz was completed”, plus how long a session lasted. These are counts and timings, not recordings of what you typed.
• Crash and diagnostic logs — when the app crashes or freezes, an automatic report is generated containing the technical stack trace, the device model, the Android version, the app version and the state of the app at that moment.
• Advertising identifier — where the app shows advertisements, the resettable Google Advertising ID assigned by Android. See section 6.

We do not collect your precise or approximate location, we do not read your contacts, photos, files, SMS messages or call logs, and we do not use the microphone or camera to collect data about you.

3.4 Information from third parties

We do not buy personal data, and we do not receive personal data about you from data brokers, advertisers or social networks.

We do receive aggregated statistical reports from the providers named in section 6 — for example, a Play Console report of installs per country, or a Firebase dashboard showing how many users reached a screen. These describe groups, not identifiable individuals.

4. How we use information

We use the limited information described above only for the purposes set out here, listed one by one so you can see exactly what each category of data is for.

• To make the app work. Device, OS and app-version information lets the app render lessons correctly on your screen size and Android version.
• To fix crashes and bugs. Crash logs tell us which line of code failed, on which device and Android version. Without them we would depend on users describing faults we cannot reproduce.
• To improve the lessons. Anonymous usage counts show which lessons are completed and which are abandoned partway, so we can rewrite the ones that are not working.
• To measure performance. Timing data shows where the app is slow, so we can speed it up on lower-end devices.
• To plan new content. Aggregated statistics on which topics get the most use guide what we build next.
• To show advertisements. Where the app displays ads, the advertising identifier is used by Google to serve and measure them and to limit repeats. See section 6.
• To answer you. If you email us, we use your message only to reply, investigate the issue and record the request.
• To protect the app and comply with law. We may use technical data to detect abuse, fraud or security incidents, and to comply with a legal obligation or lawful request from a competent authority.

We do not use this information to build a profile of you, to make automated decisions producing a legal or similarly significant effect, or to advertise to you by name, email or phone — we hold none of those details.

5. Legal basis for processing

Where the law requires us to identify a legal basis for processing, these are the bases we rely on.

Where we rely on legitimate interests, we have considered whether our interest is overridden by your rights and freedoms, and we have kept the data to the minimum needed for the purpose. You may object to processing based on legitimate interests — see section 10.

6. Third-party services

Bolshikho uses a small number of third-party software development kits (SDKs) supplied by Google. These providers process data on our behalf or, in some cases, as independent controllers of their own. We do not control their internal practices, so we have linked each one's own privacy policy below and we encourage you to read them.

6.1 Advertising — Google AdMob

Bolshikho is free, and advertising is how a free app of this kind is funded. The app displays advertisements supplied by Google AdMob.

The advertising identifier. Android gives each device a resettable Google Advertising ID. It is a random identifier that is not tied to your name or email address, and you can reset it or delete it yourself at any time from your device settings. AdMob uses it to select ads, to measure whether an ad worked and to stop showing you the same ad repeatedly.

Personalised and non-personalised ads. Personalised ads are chosen using the interests Google has inferred from the advertising identifier across apps and sites. Non-personalised ads are chosen only from general context such as the app you are using and your coarse location, and they do not use your interest profile. Where the law requires consent for personalised advertising — for example in the European Economic Area, the United Kingdom and Switzerland — the app asks for it before showing personalised ads, and you may refuse or withdraw that consent. If you refuse, the app still works; you simply see non-personalised ads instead.

How to opt out on your device. You can turn off ad personalisation for every app on your phone at once:

• Open Android Settings → Privacy → Ads (on some devices this is Settings → Google → All services → Ads).
• Choose Delete advertising ID, or turn on Opt out of Ads Personalisation.
• You can also use Reset advertising ID to break the link with any profile built so far.

We do not share your advertising identifier with any advertising network other than Google AdMob.

The disclosures in this policy are written to match the Data safety declarations we have made in the Google Play Console for Bolshikho. If we change what the app collects, we will update both at the same time.

7. Data sharing

We share the limited technical data described in this policy only in these situations:

• With the service providers named in section 6, and only so that they can perform their function — analytics, crash reporting or advertising delivery — on our behalf.
• Where the law requires it — in response to a valid court order, summons, warrant or lawful demand from a government authority, regulator or law enforcement agency with jurisdiction over us. We satisfy ourselves that the request is lawful before responding.
• To protect rights and safety — where we reasonably believe disclosure is necessary to investigate, prevent or act on suspected fraud, a security incident, or a threat to the safety of any person.
• In a business transfer — if Spectrotags Technologies Private Limited is involved in a merger, acquisition, restructuring or sale of assets, data may pass to the successor entity. That entity would remain bound by this policy until it publishes a replacement, and we would post a notice in the app and on this page before any such change took effect.

We do not share data with advertisers, marketing agencies, data brokers or social media platforms for their own independent purposes.

If you have any doubt about who holds what, write to support@appmediaindia.com and we will tell you.

8. Data retention

We keep information only for as long as it serves the purpose it was collected for, and then we delete it or allow it to be deleted automatically by the service that holds it. Retention periods are stated in months below.

Where a longer period is required by Indian law — for example a tax, accounting or statutory record-keeping obligation — we keep only what that law requires, for only as long as it requires, and we delete the rest.

9. Data security

We take reasonable technical and organisational measures to protect the limited information we handle.

• Encryption in transit. All communication between the app and any server uses HTTPS with TLS. The app does not send data over unencrypted connections.
• Protection at rest. Data held by our providers is encrypted at rest on their infrastructure. Learning progress sits in the app's private storage area, which Android isolates from other apps.
• Access controls. Access to analytics and crash dashboards is limited to the few people who need it, protected by individual accounts with multi-factor authentication, and reviewed when a role changes.
• Data minimisation. The strongest protection is not holding data at all. Bolshikho collects no directly identifying information, so there is no name, email address or phone number in our systems to expose.
• Secure development. We keep dependencies current so published security fixes reach users, and we review code before release.

Breach notification. No system is perfectly secure. If a personal data breach occurs that is likely to affect users of Bolshikho, we will notify the Data Protection Board of India in the manner and within the timeframe required by the Digital Personal Data Protection Act, 2023, and inform affected users without undue delay by in-app notice, a notice on this page, or email where we hold an address. The notice will say what happened, what data was involved, what we are doing and what you can do.

If you believe you have found a security vulnerability in Bolshikho, please report it privately to support@appmediaindia.com before disclosing it publicly, and we will work with you to fix it.

10. Your rights

Your rights depend on where you live. Because Bolshikho holds no directly identifying information, exercising some of these rights requires you to give us enough detail for us to locate the anonymous records that relate to your device — see section 11.

10.1 Rights under India's Digital Personal Data Protection Act, 2023

If you are in India, you are a Data Principal and we are the Data Fiduciary. You have the following rights.

• Right to access information. You may ask for a summary of the personal data we process about you, the processing activities we carry out, and the identities of other data fiduciaries with whom we have shared it.
• Right to correction and erasure. You may ask us to correct inaccurate or misleading data, to complete incomplete data, to update it, and to erase personal data that is no longer necessary for the purpose it was collected for.
• Right of grievance redressal. You may raise a grievance with our Grievance Officer about anything in this policy or about how we have handled your data. See section 15. If you are not satisfied with our response, you may complain to the Data Protection Board of India.
• Right to nominate. You may nominate another individual to exercise these rights on your behalf in the event of your death or incapacity. Write to us with the nominee's name and contact details.
• Right to withdraw consent. Where processing rests on consent, you may withdraw it at any time. Uninstalling the app withdraws consent for all in-app collection.

You also have duties under the Act — in particular, not to raise false or frivolous grievances and not to impersonate another person when making a request.

10.2 Rights under the GDPR (European Economic Area, United Kingdom and Switzerland)

If you are in the EEA, the UK or Switzerland, you have the right to: request access to your personal data; request rectification of inaccurate data; request erasure (the “right to be forgotten”); restrict processing; object to processing based on legitimate interests, including profiling; receive your data in a portable, machine-readable format; withdraw consent at any time; and not be subject to a decision based solely on automated processing that produces legal effects (we do not carry out such processing).

You also have the right to lodge a complaint with your national supervisory authority. We would ask you to raise the matter with us first so we have the chance to put it right.

10.3 Rights under the CCPA and CPRA (California residents)

If you are a California resident, you have the right to: know what categories of personal information we collect, the purposes for collecting it and the categories of third parties we disclose it to; request a copy of the specific pieces of personal information we hold; request deletion of your personal information; request correction of inaccurate personal information; limit the use of sensitive personal information (we do not collect any); and not be discriminated against for exercising any of these rights — we will not degrade the app or charge you for making a request.

We do not sell personal information and we do not share it for cross-context behavioural advertising as those terms are defined in the CCPA. Because we sell nothing, there is no “Do Not Sell My Personal Information” mechanism to operate; you may still contact us with any question.

10.4 How to exercise any of these rights

Email support@appmediaindia.com with the app name (Bolshikho) in the subject line and tell us what you want us to do. To help us find the right records, include your device model and roughly when you first used the app.

We acknowledge every request within 7 days and respond substantively within 30 days. Requests are free. If a request is manifestly unfounded or repetitive we may explain why we cannot act on it; we will always tell you the reason and how to escalate.

11. Data deletion

Bolshikho has no account, so there is no account to close. Deleting your data works in two parts, and both are explained step by step on a dedicated page.

• Data on your device — your learning progress, lesson history and quiz scores. You erase this yourself, immediately and permanently, by uninstalling the app or by clearing its data in Android Settings. We never had a copy.
• Anonymous analytics and crash records held by our providers — you can ask us to delete these by emailing us with enough detail to locate them.

Deletion is irreversible. Once learning progress is cleared from your device it cannot be recovered by you or by us, because no backup of it exists anywhere.

12. Children's privacy

Bolshikho is intended for a general audience. It is not directed to children under the age of 13, and it is not designed, marketed or targeted to them. In the Google Play Console we have declared the app's target audience accordingly, and it does not participate in Google Play's Designed for Families programme.

We do not knowingly collect personal information from children. Because the app collects no name, email address, phone number or location from anyone, there is in practice no personal information about a child for us to hold.

Under India's Digital Personal Data Protection Act, 2023, processing the personal data of a child under 18 requires verifiable parental consent, and behavioural advertising directed at children is prohibited. We do not knowingly process children's personal data and we do not direct advertising at children.

If you are a parent or guardian and you believe a child has provided personal information to us — for example by emailing us — please contact support@appmediaindia.com. We will look into it promptly and delete the information from our records. Parents and guardians are welcome to write to us with any concern at all about the app and their child's use of it; we will answer.

13. International data transfers

We are based in India. However, the providers named in section 6 are operated by Google on global infrastructure, so anonymous analytics, crash reports and advertising data may be processed on servers outside India, including in the United States and the European Union.

Where data leaves the EEA or the UK, Google relies on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, and adequacy decisions where they apply. We rely on those same safeguards as a customer of those services.

Under the Digital Personal Data Protection Act, 2023, transfers outside India are permitted except to countries the Central Government restricts by notification; we will comply with any such notification affecting the services we use. Wherever processing happens, the protections in this policy continue to apply.

14. Changes to this policy

We may update this policy when the app changes, when we add or remove a third-party service, or when the law changes. The version you are reading is the current one, and its effective and last-updated dates are shown at the top of this page.

For a material change — such as collecting a new category of data or using a new provider — we will update the dates, publish the revised policy at this same URL before the change takes effect, and give notice inside the app. Where the law requires fresh consent, we will ask for it rather than assume it. Minor corrections that do not change meaning may be made without notice.

This URL is permanent: we keep it live for as long as Bolshikho is published. To ask what changed in a particular revision, write to support@appmediaindia.com.

15. Grievance Officer

In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 and the Digital Personal Data Protection Act, 2023, we publish the contact details of our Grievance Officer. You may contact the Grievance Officer about any complaint concerning this policy, the app, or the way your data has been handled.

Please write “Grievance — Bolshikho” in the subject line so your message is routed correctly, and describe the issue clearly, including any dates and your device model.

Our commitment. We will acknowledge your grievance within 24 hours of receiving it, and resolve it within 15 days of receipt. If a matter is complex enough that it may take longer, we will tell you why and give you an expected date before the 15 days are up.

If you are not satisfied with the outcome, you may escalate the matter to the Data Protection Board of India under the Digital Personal Data Protection Act, 2023.

16. Contact us

Any question about this privacy policy, about Bolshikho, or about your data should go to the single address below. It is the only contact channel we operate, and it is monitored.

Useful subject lines: “Data Deletion Request — Bolshikho”, “Privacy Question — Bolshikho”, “Grievance — Bolshikho”.

Related pages: Bolshikho Terms & Conditions · Bolshikho Account & Data Deletion · About the app