Privacy Policy

This Privacy Policy explains how Qodequay Technologies Pvt. Ltd. ("Qodequay", "we", "us", "our") collects, uses, shares, and protects information in connection with the Abhigyaan VR application ("Abhigyaan", "the App") distributed through the Meta Horizon Store and used on Meta Quest devices.

Abhigyaan is a curriculum-aligned immersive learning platform built for K-12 schools, training institutions, and learners. Because the App is used predominantly by children and in supervised classroom environments, we apply heightened privacy protections by default and operate under a school-led consent model wherever the App is deployed in an educational institution.

1. Who this Policy applies to

This Policy applies to all users of the Abhigyaan VR app on the Meta Horizon Store, including:

• Students using the App in a school, training centre, or institutional deployment under the supervision of a teacher, instructor, or administrator;
• Teachers and administrators who manage Abhigyaan content, classes, or progress on behalf of an institution;
• Individual users (e.g., parents, self-learners, evaluators) who install the App from the Meta Horizon Store for personal or trial use.

2. Information we collect

2.1 Information you or your institution provide

• Account and roster data (for institutional deployments): student identifier, class or grade, section, school name, teacher identifier. This information is provided to us by the school or its authorised administrator — not directly by the child.
• Profile data (for individual users): display name and any optional avatar selection you choose inside the App.
• Communications: any information you provide when you contact us for support or feedback.

2.2 Information collected automatically when you use the App

• Learning activity data: which modules and scenes were launched, time spent, lesson completion status, quiz responses, and learning outcomes. This data is used to render progress dashboards for teachers and to improve the learning content.
• Device and technical information: Meta Platform User ID (provided by Meta for entitlement and licence verification), device model (e.g., Meta Quest 2, Quest 3), operating system version, app version, language and locale, crash logs, and diagnostic information.
• Performance and stability data: anonymised metrics such as frame rate, load times, and error events used to identify and fix bugs.

2.3 VR-specific data

The App processes the following data locally on the device to render the immersive experience. This data is not transmitted to or stored on our servers unless explicitly stated:

• Head and controller tracking: position and rotation of the headset and controllers, used only to render the scene in real time.
• Hand tracking (if enabled by the user on the device): used only to render hand interactions in real time.
• Play-space and guardian boundary: used only by the Meta operating system; Abhigyaan does not access guardian boundary data.

2.4 What we do NOT collect

• We do not use or collect eye-tracking data.
• We do not use or collect face-tracking, facial geometry, or facial expression data.
• We do not collect biometric identifiers of any kind.
• We do not record or transmit microphone audio or passthrough camera imagery off the device.
• We do not collect precise GPS location.
• We do not serve advertisements and we do not share data with advertising networks.

3. How we use information

We use the information described above only for the following purposes:

• To deliver the learning experience, including loading modules, tracking lesson progress, and synchronising state across a class session;
• To generate progress reports and dashboards for teachers and authorised school administrators;
• To diagnose crashes, fix bugs, and improve performance, stability, and accessibility of the App;
• To improve and develop new learning content and features (using aggregated and de-identified data wherever possible);
• To respond to your support requests, feedback, and questions;
• To comply with our legal obligations, enforce our terms, and protect the safety and rights of users.

4. Children's privacy & school deployments

Abhigyaan is designed for use by children. We treat this responsibility with care.

4.1 School-led consent model

When Abhigyaan is deployed in a school or institution, the school acts as the data fiduciary and the responsible adult for the child user. By deploying the App, the school confirms that it has obtained — or is legally permitted to obtain on behalf of parents and guardians — the consents required under applicable law (including the Digital Personal Data Protection Act, 2023 of India, the Children's Online Privacy Protection Act of the United States, the EU General Data Protection Regulation, and any other applicable child-protection laws). We provide schools with the disclosures, data processing terms, and parental notice templates they need to operate this model.

4.2 Individual use by minors

If you are a parent or legal guardian and you install Abhigyaan from the Meta Horizon Store for a child to use at home, you are giving consent on the child's behalf for the processing described in this Policy. Parents and guardians can contact us at any time to access, correct, or delete their child's data — see Section 12.

4.3 No profiling or advertising of children

We do not build behavioural profiles of children. We do not show advertisements. We do not use children's data to train third-party large language models or to target marketing of any kind.

5. How we share information

We share information only in the limited circumstances described below. We do not sell personal data.

• With the user's school or institution: when Abhigyaan is deployed institutionally, learning activity, progress, and roster-linked data are shared with authorised teachers and administrators of that institution.
• With service providers who help us run the App, under written contracts that require them to protect the data and use it only for the purposes we authorise. Current categories include cloud hosting and content delivery (Cloudflare R2, Cloudflare Pages), crash and performance analytics, and email and ticketing systems for support.
• With Meta Platforms, Inc., solely to the extent required for licence verification, entitlement, and distribution through the Meta Horizon Store. Meta's processing of platform-level data is governed by Meta's own privacy policies.
• For legal reasons: when we are required by law, court order, or competent government authority, or to protect the rights, safety, and property of users, Qodequay, or the public.
• In connection with a business transfer: if Qodequay is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to the protections of this Policy.

6. Third-party services

Abhigyaan integrates the following categories of third-party services. Each is bound by contractual data-protection obligations and processes data only on our behalf:

• Cloud storage and content delivery — Cloudflare, Inc. (R2 object storage, Cloudflare Pages).
• Crash and performance reporting — anonymised diagnostic telemetry.
• Distribution platform — Meta Platforms, Inc. (Meta Horizon Store).

7. Data retention

We retain personal data only for as long as is necessary for the purposes set out in this Policy.

• Institutional roster and progress data: retained for the duration of the school's contractual engagement with Qodequay, and deleted or returned to the school within ninety (90) days of contract termination, except where retention is required by law.
• Diagnostic and crash data: retained for up to twelve (12) months in identifiable form, after which it is aggregated or deleted.
• Support communications: retained for up to twenty-four (24) months.

8. Data security

We use reasonable administrative, technical, and physical safeguards to protect personal data, including encryption in transit (TLS 1.2 or higher) and at rest, access controls based on the principle of least privilege, secure software development practices, and periodic security reviews. No method of transmission or storage is perfectly secure, but we work continuously to maintain a strong security posture and to remediate vulnerabilities quickly.

9. International data transfers

Qodequay is headquartered in India and operates entities in the United States (Delaware) and Singapore. Personal data may be processed in or transferred to any country where we or our service providers operate. Where required by law, we put in place appropriate safeguards — including standard contractual clauses — to protect personal data when it is transferred across borders.

10. Your rights

Subject to your jurisdiction, you have rights in relation to your personal data. Where Abhigyaan is deployed in a school, these requests should ordinarily be made to the school in the first instance; the school will route them to us as needed.

10.1 India — Digital Personal Data Protection Act, 2023

• Right to access a summary of personal data we process about you;
• Right to correction, completion, updating, and erasure of personal data;
• Right to nominate another individual to exercise your rights in the event of death or incapacity;
• Right of grievance redressal — see Section 12.

10.2 European Union and United Kingdom — GDPR / UK GDPR

• Rights of access, rectification, erasure, restriction, portability, and objection;
• Right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
• Right to lodge a complaint with your supervisory authority.

10.3 United States — COPPA and state privacy laws

• Parents and legal guardians may review the personal information collected from their child, refuse to permit further collection, and request deletion of the child's information by contacting us at the address in Section 12;
• Residents of California, Virginia, Colorado, Connecticut, and other states with comprehensive privacy laws have rights of access, deletion, correction, and opt-out of sale or sharing — note that we do not sell or share personal data for cross-context behavioural advertising in any jurisdiction.

11. Changes to this Policy

We may update this Policy from time to time to reflect changes to the App, our practices, or applicable law. When we make material changes, we will revise the "Last updated" date at the top of this Policy and, where appropriate, provide additional notice through the App or to schools that have deployed Abhigyaan. Continued use of the App after a material update constitutes acceptance of the updated Policy.

12. Contact & Grievance Officer

If you have any questions about this Policy, want to exercise your rights, or wish to file a grievance, please contact:

We will acknowledge complaints within seven (7) working days and resolve them within thirty (30) days, or such shorter period as required under applicable law.