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Privacy Policy

Effective Date: July 07, 2025 | Last Updated: July 07, 2025

1. Introduction

Liwi Learning Solutions Pvt.Ltd ("LIWI," "Company," "we," "us," or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, store, and protect your personal information when you use the LIWI AI-powered English tutoring application and related services.

Important: This Privacy Policy is designed to comply with the Digital Personal Data Protection Act, 2023 (DPDP Act), Information Technology Act, 2000, and other applicable Indian data protection laws.

2. Information We Collect

2.1 Personal Data Categories

We collect the following types of personal data:

2.1.1 Account and Profile Information
  • Full name
  • Email address
  • Phone number (optional)
  • Profile picture (optional)
  • Language preferences
  • Learning goals and objectives
  • Age range (for appropriate content delivery)
2.1.2 Voice and Audio Data
  • Voice recordings during speaking exercises
  • Speech patterns and pronunciation data
  • Audio responses to learning prompts
  • Conversation practice recordings
  • Pronunciation assessment data
2.1.3 Learning and Performance Data
  • Learning progress and achievements
  • Test scores and assessment results
  • Time spent on different exercises
  • Difficulty levels and preferences
  • Learning patterns and behavior
  • Areas of improvement and strengths
2.1.4 Technical and Usage Data
  • Device information (type, model, operating system)
  • IP address and location data
  • App usage statistics and analytics
  • Crash reports and error logs
  • Session duration and frequency

3. How We Use Your Information

3.1 Service Provision

  • Providing AI-powered English tutoring services
  • Personalizing learning experiences and recommendations
  • Tracking learning progress and generating performance reports
  • Processing voice data for pronunciation analysis and feedback
  • Adapting difficulty levels based on performance
  • Delivering customized lesson content

3.2 Communication and Support

  • Sending important service updates and notifications
  • Providing customer support and technical assistance
  • Responding to user inquiries and feedback
  • Sending promotional content (with consent)

3.3 Service Improvement

  • Analyzing usage patterns to improve features
  • Developing new learning methodologies
  • Enhancing AI accuracy and performance
  • Conducting research for educational advancement

4. Legal Basis for Processing

Under the DPDP Act, we process your personal data based on:

  • Consent: You have given clear consent for processing
  • Contract Performance: Processing is necessary for service delivery
  • Legitimate Interest: For service improvement and fraud prevention
  • Legal Compliance: To comply with applicable laws

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers

We may share data with trusted service providers for:

  • Cloud storage and hosting services
  • Payment processing
  • Analytics and performance monitoring
  • Customer support platforms
  • AI and speech processing services

5.2 Data Protection Measures

  • All third parties are bound by strict data protection agreements
  • Data is shared only on a need-to-know basis
  • Regular audits ensure compliance with privacy standards

5.3 Legal Requirements

We may disclose personal data when required by law or to:

  • Comply with legal obligations
  • Protect our rights and property
  • Ensure user safety and security
  • Investigate fraud or security incidents

6. Data Security

6.1 Technical Safeguards

We implement industry-standard security measures including:

  • End-to-end encryption of data in transit and at rest
  • Secure API endpoints with authentication
  • Regular security audits and vulnerability assessments
  • Multi-factor authentication for admin access
  • Secure data centers with physical security
  • Regular backup and disaster recovery procedures

6.2 Organizational Safeguards

  • Employee training on data protection and privacy
  • Access controls and role-based permissions
  • Regular privacy impact assessments
  • Incident response and breach notification procedures
  • Data protection officer oversight

7. Your Rights Under DPDP Act

As a data principal under the DPDP Act, you have the following rights:

7.1 Right to Information

You have the right to know what personal data we collect, how it's used, and who it's shared with.

7.2 Right of Access

You can request a copy of your personal data we hold. We will provide this within 30 days of your request.

7.3 Right to Correction

You can request correction of inaccurate or incomplete personal data. We will update your information promptly.

7.4 Right to Erasure

You can request deletion of your personal data. Note that some data may be retained for legal compliance.

7.5 Right to Data Portability

You can export your learning data and progress in a commonly used format.

7.6 How to Exercise Your Rights

To exercise any of these rights, contact us at privacy@myliwi.com or through the app settings. We will respond within 30 days.

8. Data Retention

8.1 Retention Periods

  • Account Data: Until account deletion + 30 days for backup purposes
  • Voice Recordings: 30 days unless saved by user for progress tracking
  • Learning Analytics: 2 years for service improvement and research
  • Support Communications: 3 years for quality assurance
  • Payment Data: As required by financial regulations (up to 7 years)

8.2 Automatic Deletion

We automatically delete data when retention periods expire, unless legal obligations require longer retention.

9. Children's Privacy Protection

9.1 Age Restrictions

  • Our service is designed for users aged 13 and above
  • Users under 18 require parental consent
  • We comply with DPDP Act requirements for children's data

9.2 Parental Controls

  • Parents can review their child's data and learning progress
  • Parents can request deletion of their child's account
  • Enhanced privacy protections for users under 18

10. International Data Transfers

10.1 Cross-Border Transfers

Your data may be processed in countries outside India for:

  • Cloud storage and processing
  • AI model training and inference
  • Customer support services

10.2 Safeguards

  • We ensure adequate level of data protection in destination countries
  • Standard contractual clauses are used for data transfers
  • Regular compliance monitoring of international processors

11. Cookies and Tracking Technologies

11.1 Types of Cookies

  • Essential Cookies: Required for app functionality
  • Analytics Cookies: Help us understand app usage
  • Preference Cookies: Remember your settings and choices

11.2 Managing Cookies

You can control cookie preferences through your device settings or app preferences.

12. Updates to Privacy Policy

12.1 Policy Changes

  • We may update this policy to reflect service changes or legal requirements
  • Material changes will be communicated via email or app notification
  • Continued use after changes constitutes acceptance
  • You can always access the latest version in the app

13. Data Breach Response

13.1 Incident Response

  • We have procedures to detect, investigate, and respond to data breaches
  • Affected users will be notified within 72 hours when required
  • Relevant authorities will be informed as per legal requirements

14. Contact Information

14.1 Privacy Inquiries

For privacy-related questions or to exercise your rights:

14.2 Data Protection Officer

Our Data Protection Officer can be reached at dpo@myliwi.com for specific privacy concerns.

15. Governing Law

This Privacy Policy is governed by the laws of India, including:

  • Digital Personal Data Protection Act, 2023
  • Information Technology Act, 2000
  • Information Technology (Reasonable Security Practices) Rules, 2011

16. Complaints and Grievances

16.1 Internal Grievance Mechanism

If you have concerns about our data practices:

  • Contact our grievance officer at grievance@myliwi.com
  • We will acknowledge your complaint within 24 hours
  • Resolution will be provided within 30 days

16.2 Regulatory Complaints

You also have the right to file complaints with the Data Protection Board of India.

Document Version: 1.0 | Last Updated: July 07, 2025