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. Bhasha is for people aged 13 and over.

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. In the European Economic Area (EEA) and Switzerland the screen works differently (section 06).

• To run the app you asked for: your account, sync, AI lessons and answers, voice, purchases, allowances, the Community, 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 personalise your learning: learning when you usually study, predicting whether you are likely to come back, and shaping your reminders, practice and next lessons around your study routine

You can turn off usage sharing and personalisation at any time in Profile, Settings, Privacy, and Bhasha keeps working.

Account (Sign in with Apple, optional)

• An Apple-provided identifier, plus your name and email if you choose to share them through Apple's sign-in. We use them to create your account, secure cloud features, and show your name on lessons you choose to share to the Community
• Signing in is needed only for cloud features (the Community, Ask Bhasha, voice conversations and chatting with the developer). The personal learning experience works without an account
• 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 identifier, name or email, it is linked to nothing else, and it is deleted after one year

Learning content you create

• Phrases, notes, favourites, recordings and progress are stored on your device and mirrored to your own private iCloud (Apple CloudKit) for backup and sync. This is your iCloud, not our servers. We cannot access it, and it is never used to train AI
• When you use Ask Bhasha or make a lesson from a hand-off, the text of that conversation or lesson (and any photo you attach to Ask Bhasha) 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
• 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). Your study time and place are saved to your account only while "Personalise my learning" is on. When it is off, they stay on your device
• Setup also asks your month and year of birth. Only the age range it falls in is kept, on your device. Your birth date is not stored and your age range is never 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
• 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

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

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
• Text only. Never your audio, your voice or your contact details
• You can withdraw a shared lesson at any time

Purchases (Bhasha Plus, Bhasha Pro and Lifetime)

• Purchases are processed by Apple. We never see your payment details
• 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
• 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 "Share usage data" 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

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, and errors
• Crash and performance counts: daily counts of crashes, hangs and slow or heavy work, and how long the app takes to launch, from Apple's MetricKit
• 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, 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
• None of this is sent until you have agreed on the first screen, and none of it is sent while "Share usage data" is 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 both "Share usage data" and "Personalise my learning" are 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
• "Personalise my learning" in Profile, Settings, Privacy turns this off. Reminders then use the time you set, what was learned about your study pattern is deleted from your device, and nothing about it is kept or sent

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

Notifications

• Reminders need nothing from our servers
• If you use the developer chat and allow notifications, we store a device push token linked to your account, used only to tell you about replies. It is deleted when you sign out or delete your account

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

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; sync; your setup answers, to build and restore your course; Ask Bhasha, hand-off lessons, lesson upgrades and voice; the Community; the developer chat and its push token; 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.

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

• Usage data and anonymous study and step counts: to understand how Bhasha is used, find what confuses people, and improve lessons and the app
• 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
• Personalisation, the learned reminder time and the return model: to time reminders and suggest practice that fits how you actually study, which is the point of a learning app
• 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 only)

For storing or reading information on your device for anything that is not strictly necessary. See section 06.

Legal obligation

Where we must keep or disclose data by law.

If your App Store country, device region or time zone points to the EEA or Switzerland, or we cannot tell where you are, the first screen shows two equal buttons:

• Accept & continue: everything in this policy
• Continue with essentials: only what is strictly needed to provide the service you ask for (the Contract items in section 04). No usage data, no anonymous study or step counts, no crash and performance counts, no subscription reporting through RevenueCat and no personalisation

Both buttons accept our Terms. The app works fully either way, and nothing you pay for depends on your choice. If you chose essentials, you can change your mind at any time with the Accept button in Profile, Settings, Privacy; after that, the two switches there work as for everyone else. If you accepted, you can withdraw that consent as easily as you gave it: turning "Share usage data" off withdraws it for usage data, crash counts and RevenueCat, and "Personalise my learning" off for personalisation. We ask because EU law requires consent before an app stores or reads information on your device for anything that is not strictly necessary. RevenueCat does not start in the app until you tap Accept.

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 for ages 13 and over. During setup the app asks your month and year of birth. It keeps only the age range on your device, never your birth date, and never sends either to us. If you are under 13, the app stops and cannot be set up. If we learn that a user is under 13, we delete any data we hold about them
• If you are under 18 in the UK, under 16 in the EEA or Switzerland, or your age is unknown and you appear to be in the EEA, Switzerland or the UK, Bhasha uses protective settings: usage sharing is off, personalisation is off and location is never asked for. You can see these settings in Profile, Settings, Privacy

Bhasha is designed for one Bhasha account per device. Your lessons, recordings and progress live on the device and in the iCloud of the Apple ID it uses, not in your Bhasha account. 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: one person's lessons, progress and practice history can show up for another. Using more than one Bhasha account on one device is not supported.

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
• 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 sharing is allowed (you tapped Accept in the EEA or Switzerland, "Share usage data" is on, and you are not a protected minor); 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
• 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

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. 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.

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 Ask Bhasha and hand-off history, your messages, your Community lessons, all usage data linked to your account and every install linked to it, and purges the copy in your iCloud. The app deletes its install identifier. Deleting your account does not cancel an App Store subscription; cancel that in your device's Settings.

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. 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. Purchase records held by Apple 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.

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. 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 switches in Profile, Settings, Privacy) or email support@eldrenlabs.com. We will never treat you differently for using these rights, and you can decline to sign in and still use the core app.

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 the developer chat in the app, or visit eldrenlabs.com/support.