Intallaga Tech Pty Ltd, trading as Amma AI (“Amma AI”, “we”, “us”, “our”) operates the Amma SAT application (“the App”). This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and your rights under applicable laws including the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the EU General Data Protection Regulation (GDPR), the US Children’s Online Privacy Protection Act (COPPA), and the California Consumer Privacy Act (CCPA).
1. Information We Collect
We collect only what is necessary to deliver and improve the App:
- Account information: email address used for sign-in (via one-time passcode or email/password).
- Study & performance data: test scores, answer history, study-plan progress, vocabulary mastery levels, and AI chat interactions — used solely to personalise your learning experience.
- User-uploaded content: documents, tests, or images you voluntarily upload into the App for your own study use.
- Subscription data: plan type and billing status, managed entirely through Apple’s In-App Purchase system. We do not receive or store your payment card details.
- Device & usage metadata: device type, operating-system version, app version, crash logs, and anonymised usage analytics to diagnose issues and improve functionality.
We do not collect precise geolocation, contacts, call logs, or biometric data.
2. How We Use Your Data
- Generate and update personalised study plans and AI-tutored explanations.
- Track your test performance, score trends, and weak-area analysis.
- Manage your subscription tier and daily AI request quotas.
- Send transactional communications (e.g., password resets). We do not send marketing emails unless you opt in.
- Improve App stability and features through aggregated, anonymised analytics.
3. Legal Basis for Processing (GDPR)
If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data on the following bases:
- Contract performance: processing necessary to provide the App and its features to you.
- Legitimate interests: improving the App, preventing misuse, and diagnosing technical issues, balanced against your rights.
- Consent: where required — for example, before enabling AI-powered features for users under 16.
4. AI-Powered Features & Data Processing
The App uses artificial intelligence to provide tutoring explanations and study guidance. When you interact with the AI tutor (Amma):
- Your question or prompt, along with relevant study context, is sent to OpenAI’s API for response generation.
- OpenAI processes this data as a sub-processor on our behalf. Under our Data Processing Agreement with OpenAI, your data is not used to train OpenAI’s models.
- AI-generated responses are educational guidance only and may occasionally contain errors. They are not a substitute for professional academic advice.
5. Automated Decision-Making
The App uses automated processing to generate personalised study plans and recommend focus areas based on your test performance. These features are integral to the service and do not produce legal or similarly significant effects. You may contact us at any time to request human review of any automated recommendation.
6. Data Storage & Security
Your data is stored using Supabase (hosted on Amazon Web Services infrastructure). We employ:
- TLS encryption for all data in transit.
- AES-256 encryption for data at rest.
- Row-level security policies ensuring each user can only access their own data.
- Regular security audits and access reviews.
7. International Data Transfers
Your data may be transferred to and processed in countries outside your jurisdiction, including the United States (for AI processing via OpenAI) and regions where AWS infrastructure is located. Where required by law, these transfers are safeguarded by Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent mechanisms under Australian and other applicable laws.
8. Data Retention
- Active accounts: we retain your data for as long as your account is active and necessary to provide the service.
- Deleted accounts: upon account deletion, we remove your personal data within 30 days, except where retention is required by law (e.g., billing records).
- AI interaction logs: chat history is retained for the duration of your account to enable continuity. Upon account deletion, these logs are permanently deleted.
9. Third-Party Services
- OpenAI: AI response generation (sub-processor). Data not used for model training.
- Apple: subscription billing and payment processing, handled entirely by Apple. We only receive confirmation of subscription status.
- Supabase / AWS: database hosting and authentication infrastructure.
We do not sell, rent, or share your personal data with third parties for advertising or marketing purposes. We do not engage in behavioural advertising.
10. Children’s Privacy
Amma SAT is designed for students preparing for the SAT, who are typically aged 14–18.
- Users under 13 (COPPA): we do not knowingly collect personal information from children under 13 without verifiable parental consent. If we learn that we have collected data from a child under 13 without consent, we will promptly delete it. Parents may contact us at hi@intallaga.com to request review or deletion of their child’s data.
- Users under 16 (GDPR): where the GDPR applies, users under 16 require parental or guardian consent to use the App.
- We collect only the minimum data necessary for the educational service and never use children’s data for targeted advertising.
11. Your Rights
Depending on your jurisdiction, you may have the following rights:
- Access: request a copy of the personal data we hold about you.
- Rectification: request correction of inaccurate data.
- Erasure / Deletion: request deletion of your data (you can also delete your account directly from the App’s Profile section).
- Portability: request your data in a structured, machine-readable format.
- Restriction / Objection: request that we limit or stop processing your data in certain circumstances.
- Withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
- Complaint: you have the right to lodge a complaint with your local data protection authority (e.g., the OAIC in Australia, your national DPA in the EU, or the FTC in the US).
To exercise any of these rights, contact us at hi@intallaga.com. We will respond within 30 days (or sooner where required by law).
12. Do Not Sell My Personal Information (CCPA)
We do not sell your personal information. We do not share personal information for cross-context behavioural advertising. California residents may contact us to confirm this at any time.
13. Cookies & Tracking
The Amma SAT app does not use cookies. Our website (amma-ai.com) uses only essential cookies required for site functionality. We do not use third-party advertising trackers.
14. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via the App or email. The “Last updated” date at the top reflects the most recent revision. Continued use of the App after changes constitutes acceptance of the updated policy.
15. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal data:
Intallaga Tech Pty Ltd
Email: hi@intallaga.com