Privacy Policy

Bolo is operated as a sole proprietorship by Siddhant Jain, based at Business Bay, Dubai, United Arab Emirates. This Privacy Policy explains what we collect when a parent signs their child up for Bolo, why we collect it, who we share it with, and the rights you have under the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021, the “PDPL”).

1. Who this policy is for

Bolo is a learning service for children aged 5–12 years. A parent or legal guardiancreates the account and gives consent on the child’s behalf. By using Bolo you confirm you are the parent or guardian and that you accept this policy on behalf of your child.

2. Information we collect

From the parent / guardian

• Name and mobile number — these are the only fields on our sign-up form. We use them to create the account, deliver class reminders, and respond to support requests. We do not ask for your email at sign-up.
• Relationship to the child— e.g. mother, father, guardian — so we know whose consent we have for the child’s enrolment.
• Payment information — handled directly by our third-party payment provider (cards and wallets). We see only the transaction ID, amount, and status. We do not store your card number, PIN, or bank credentials.
• Messages you send us — over email, WhatsApp, or phone, so we can help you and keep a record of the conversation. If you write to us, we will of course have your email address from that message.

From the child

• First name, age, and gender — used by the AI tutor to address the child correctly and to choose age-appropriate content and examples.
• Voice during lessons — the AI tutor needs to hear the child speak in order to respond. Audio is streamed via our voice infrastructure provider while the lesson is in progress.
• Learning progress — which topics and modules the child has completed, accuracy on speaking exercises, and time spent in lessons.

We do not ask the child for an email address, phone number, last name, home address, school name, photo, or any payment information.

Technical information

• Standard server logs (IP address, browser type, timestamps) kept for security and debugging. These are deleted after 30 days.
• A small amount of data stored in your browser (a session cookie / local storage) to keep you logged in.

3. Why we collect this information (purpose & lawful basis)

Under the PDPL, we process personal data for these purposes:

• To deliver the service — running the AI tutor session, tracking progress, generating receipts.
• To process payments — sharing the minimum information needed with our payment provider so a parent can pay for the trial and the full course.
• To provide support — replying to your emails, calls, and WhatsApp messages.
• To improve the service— reviewing a small sample of recordings to fix bugs and improve the tutor’s responses. We do notuse your child’s voice to train any third-party AI model.
• To meet legal obligations — for example, retaining payment records as required by tax law.

4. Children’s data and parental consent

Because Bolo is designed for children, the UAE PDPL requires us to obtain verifiable consent from a parent or guardianbefore processing the child’s personal data. We treat the following as consent:

• The parent creating the account in their own name.
• The parent completing payment, which only a verified adult card or bank account can do.
• The parent accepting these terms during sign-up.

We do not show advertising to children, do not profile children for marketing, and do not allow third parties to do so through our platform.

5. Who we share information with

We share only what is necessary, only with the following partners, and only for the specific purpose listed:

• Our payment provider (payment processing) — handles your card or wallet transaction.
• Our voice infrastructure provider(real-time voice) — carries the audio between the child’s device and our AI tutor during a lesson.
• Cloud hosting providers — store our database and run our servers, under standard data-protection agreements.
• Google (email) — we receive support email at founders@bolo.org.in.
• UAE tax / regulatory authorities — only when required by law.

We do not sell, rent, or trade your information to anyone. We do not share voice recordings with advertisers or AI training datasets.

6. How long we keep your data

• Voice recordings: stored for up to 30 days for quality review and bug fixing, then automatically deleted. You can ask us to delete them sooner — see Section 8.
• Account & progress data: kept while your account is active (the account is identified by your mobile number). Deleted within 30 days of account closure (except where law requires longer retention, e.g. tax records for 7 years).
• Payment records: retained as required by applicable UAE tax law.
• Server logs: 30 days.

7. Security

We use HTTPS for all traffic, store passwords as one-way hashes, and restrict access to production data to the proprietor. While no system is perfectly secure, we follow standard industry practices. If we ever discover a breach affecting your data, we will notify you and the UAE Data Office as required by law.

8. Your rights

Under the PDPL you (the parent) have the right to:

• Access — ask us what data we have about you and your child.
• Correct — request that inaccurate information be fixed.
• Delete— ask us to delete your child’s voice recordings or close the account.
• Withdraw consent — at any time, which will stop further processing (past lawful processing remains valid).
• Complaints — raise a complaint with our Data Protection Officer (see Section 10).

To exercise any right, email founders@bolo.org.in with the mobile number used at sign-up, or WhatsApp / call us on +91 9461844433. We may ask a verifying question so that requests can be linked to the correct account. We respond within 7 working days.

9. Cookies and tracking

We use limited third-party tools such as Meta Pixel and PostHog to understand visits, sign-ups, and product usage. These tools may set cookies or similar identifiers in your browser. We also store a small session token to keep you logged in.

10. Data Protection Officer

11. Changes to this policy

We may update this policy as Bolo evolves. The “Last updated” date at the top will change, and significant changes will be emailed to active account holders.

12. Governing law

This policy is governed by the laws of United Arab Emirates. Disputes will be subject to the courts of Dubai.