This Privacy Policy explains how [Vitra.ai legal entity name] ("Vitra.ai", "we", "us" or "our"), with its registered office at [registered address], India, collects, uses, shares and protects personal data when you use the Manas mobile app and the services we provide through it (together, Manas).
For the purposes of India's Digital Personal Data Protection Act, 2023 (the DPDP Act), we are the Data Fiduciary for your personal data. Where other data protection laws apply to you, such as the EU or UK General Data Protection Regulation, we are the controller.
If you have a question or a complaint, contact our Grievance Officer: [grievance officer name and email] (section 23). You can ask for this policy in English or in any language listed in the Eighth Schedule to the Constitution of India by writing to [support email].
Summary
- We collect what you give Manas (your account details, recordings, study material, chats, habits and to-dos, CVs, your voice and face if you choose to use them in videos, and your photo if you use PhotoBooth), what your device and the app tell us (for example, the app version and how you use the app), and information from Apple and Google (sign-in and purchases).
- We use it to provide Manas: to record and transcribe your classes, make study material, answer your questions, keep your habits, to-dos and reminders, make CVs, videos and PhotoBooth pictures, run rewards and purchases, give you support, keep Manas safe, and improve it.
- AI service providers process your content to make your study material, answers, CVs, videos and pictures. Some of them are outside India.
- Your voice, your face and your PhotoBooth photo are each used only with their own consent, only to make what you ask for, and you can withdraw any of them at any time.
- PhotoBooth is for students 18 and over. The photo you pick is deleted 30 days after you add it.
- Class audio is deleted automatically after the period you choose (90 days unless you change it).
- Students under 18 see no ads, and we do not track their behaviour in the app.
- Adults may see ads from Google AdMob, and adults' usage is measured with Google Analytics for Firebase.
- We do not sell your personal data.
- You can download your data, correct it, withdraw consent and delete your account in the app.
1. Who we are
Manas is provided by [Vitra.ai legal entity name], [registered address]. Email: [support email].
2. What this policy covers
This policy covers personal data processed through the Manas app on iPhone and Android, our servers, and our website at manas.vitra.ai. It does not cover the services of other companies, such as Apple, Google or the apps you use to share your videos, which have their own privacy policies.
3. The personal data we collect
3.1 Data you give us, and data we create from it
| Category | What it includes | Where it comes from | Why we use it |
|---|---|---|---|
| Account and sign-in | Your name, your email address (only if your sign-in provider has verified it; it may be a private relay address if you use Apple's "Hide My Email"), your Google or Apple account identifier, your profile picture link (Google), and, for Sign in with Apple, a token we keep in encrypted form so that we can revoke Manas's access when you delete your account | Google or Apple, when you sign in | To create and secure your account, sign you in and show your name |
| Profile and study set-up | Changes to your name; your college (chosen from a list or typed), course and year; your goals; your subjects, their colours and your timetable (days, times, rooms); your time zone and language; your notification and recording settings | You | To set up Manas for you, file recordings under the right subject, remind you before classes and fill in your CV |
| Age group | Your age group (under 18, 18 to 24, or 25 and over) and when it was set. We ask for your date of birth once, use it only to work out the age group, and never store it. | You | To apply the protections for students under 18 (section 20) |
| Class recordings and transcripts | The audio you record, including anything audible in the room, such as the voices of teachers and classmates; when it started and ended; its length; the moments you mark and any notes on them; the subject; the transcript with timings and the detected language; suggested titles | You, and us (the transcript and titles) | To make transcripts and study packs, find things when you search, and show the moments you marked |
| Study material and activity | Study packs (notes, summaries, mind maps, topics, flashcards), infographics and explainer videos; your flashcard reviews (the grade you gave, the time taken, when); review sessions; your mastery band for each subject; the days you studied | You, and us | To show your study material, schedule your reviews, show your progress and run streaks |
| Your companion, habits and to-dos | The companion you choose; your habits (title, icon, colour, kind, target, schedule and reminder times) and each day's check-ins and notes; your to-do lists and to-dos (title, notes, due date and time, reminders, priority, subtasks, repeats, and the study pack or chat a to-do came from); your notification settings (which reminders you want, quiet hours, and the tone your companion uses) | You | To show your day on Today and Plan, run your habit streaks, and set your reminders |
| Search | The words you search for, used to find results. We do not keep them in your account; our analytics record only the number of characters in a search. Our server logs record the address of each request, which can include your search words, for a limited period (section 18). | You | To show search results |
| Chats with Manas | Your questions, Manas's answers, chat titles, a running summary of long chats, the study pack a chat is about, whether a question was stopped by the safety check, and when you reached a chat limit | You, and us | To answer your questions, keep your chats, keep chat safe and apply fair-use limits |
| CVs and career | Your answers to CV questions; CV files you upload (PDF or Word) and the text we read from them; the transcript of a spoken CV; your target role; job descriptions you paste; each version of your CV, including the contact details you choose to put on it (such as email, phone number, location and links), your education and grades, experience, projects, skills, achievements and certifications; evidence from your Manas record (classes captured, flashcards reviewed, subject mastery bands); CV check reports; the Word and PDF files we make | You, and us | To make, check, tailor and export your CV and make your Video CV |
| Scripts, videos and infographics | Script topics and lines; the videos Manas makes (Creator videos, Video CVs, explainers) and their thumbnails; the voice and the face or avatar you chose; the apps you chose to share a video to | You, and us | To make and keep your videos and let you share them |
| Your voice (only with your consent) | An approximately 30-second recording of you reading a passage aloud, and the copy of your voice that our voice service provider creates from it (section 7) | You | To speak the lines of the videos you ask for, in your own voice |
| Your face (only with your consent) | A 5-second selfie video or a photo of your face (taken in the app, or 1 you pick, confirming it is you), and a still image and a short clip made from it; the results of automated checks on a photo (that it shows 1 clear face and nothing unsafe) | You, and us | To open the videos you ask for with your face (section 7) |
| Your photo in PhotoBooth (only with your consent, and only if you are 18 or over) | The photo you pick for a picture (taken in the app, or 1 you choose from your gallery, confirming it is you); the results of automated checks on it (that it shows 1 clear face and nothing unsafe); the styles you choose; the pictures Manas makes; and any PhotoBooth passes you have | You, and us | To make the pictures you ask for (section 7) |
| Purchases, credits and subscriptions | The products you buy, transaction identifiers, the price and currency the store reports, purchase, renewal, cancellation and refund status and dates, whether a purchase was a test, your subscription and its periods, offers you used, and your credit history (every credit added, held, spent, returned or expired) | Apple or Google, and us | To add the credits you paid for, run Plans, handle refunds and keep financial records |
| Rewards and referrals | Points, check-ins, streaks and streak freezes, quests, badges and leaderboard ranks; your referral code; who invited you and whom you invited; rewarded-video records (when, status, credits) | You, other students (when they use your code), Google (rewarded-video confirmations), and us | To run rewards, leaderboards, prizes and referrals, and prevent abuse |
| Messages to us | What you write to our support address or Grievance Officer, and our replies | You | To answer you and resolve complaints |
3.2 Data collected automatically
| Category | What it includes | Why we use it |
|---|---|---|
| Device and app information | An install identifier that the app creates at random when it is first opened; the platform, operating-system version, device model and brand; the app version and build; language and time zone; network type (Wi-Fi or mobile data); screen size; light or dark mode; the push notification token; on iPhone, a small marker in the device's Keychain that tells us when Manas is reinstalled; and whether Manas appears to have been uninstalled (section 14) | To run Manas on your device, deliver notifications, fix problems and count installs, reinstalls and uninstalls |
| Usage and diagnostics | Events about how Manas is used, with their time, session and app version. For adults: the screens you view, what you tap and the features you use. For everyone: essential events, such as the app opening and closing, sign-in, onboarding steps, purchases, the result of something Manas made, and errors and crashes in the app. Section 10 explains what is different for students under 18. | To operate, measure, fix and improve Manas, and to detect abuse |
| How you found Manas | On Android, the Google Play install referrer (campaign details and any ad-click identifier); on iPhone, Apple Search Ads attribution through Apple's AdServices framework (whether an Apple Search Ads ad led to the install, and its campaign, ad group and keyword identifiers); the link that opened Manas and its campaign details; a referral code; whether this is a reinstall | To understand which campaigns and invitations bring students to Manas (section 13) |
| Consent records | Each consent you give or withdraw: what it was for, the policy version, when, where in the app, the text you were shown, the app version, platform and install identifier, and your IP address at that moment | To keep proof of what you agreed to |
| Security and server logs | IP address, time, the address of each request, the app identifier sent by your device, and the result | To keep Manas secure, prevent abuse and investigate problems |
| Advertising data (adults only, when ads are shown) | Collected by Google's ads software in the app (section 11) | To show and measure ads, and pay rewarded-video credits |
3.3 What we do not collect
We do not collect your date of birth, your precise location, your contacts, your phone's photo library (only a photo you choose to pick), or your card, bank or UPI details. On iPhone we never ask for permission to track you, so the advertising identifier is not available to Manas or to Google.
4. How we use personal data
We use personal data to:
- Provide Manas: create your account and sign you in; record, upload and transcribe your classes; make study packs, flashcards, infographics, explainer videos, CVs, Video CVs, Creator videos and PhotoBooth pictures; answer your chat questions; keep your habits and to-dos; run search, reminders and notifications.
- Run credits, purchases and Plans: show prices, hold and charge credits, return them when something fails, verify purchases with Apple or Google, add Plan credits, and handle refunds.
- Run rewards: check-ins, streaks, quests, points, badges, leaderboards, prizes and referrals.
- Keep Manas safe and fair: check chat questions and face photos with automated safety checks; apply the protections for students under 18; prevent fraud and abuse (for example, the same audio earning points more than once, multiple accounts, or a referral or promotion claimed more than once); secure our systems.
- Understand and improve Manas: measure how features are used, find and fix errors, and plan improvements.
- Measure our marketing: understand which campaigns and invitations bring students to Manas.
- Show ads to adults where ads are switched on, and pay credits for rewarded videos.
- Communicate with you and support you: send service notifications, and respond to your messages and complaints. To give support, prevent abuse and fix problems, authorised Vitra.ai staff can see a student's account and activity in our admin console: for example, their credits and purchases, which features they used and when, and what they made (such as the titles of their habits and to-dos and the PhotoBooth styles they used, but not the pictures themselves).
- Meet legal obligations: keep tax and accounting records, respond to lawful requests, enforce our Terms of Use and protect our rights.
We do not use your content (recordings, notes, chats, habits, to-dos, CVs, scripts, videos, voice, face, photos or pictures) for advertising, and we do not use it to train AI models. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
5. Our legal basis
Under the DPDP Act, we process your personal data:
- With your consent. You give it when you agree to this policy at sign-in. We also ask separately before your first class recording (a notice you confirm), and before using your voice, your face or your photo in PhotoBooth (each on its own screen). You can withdraw consent at any time (section 6). Withdrawal does not affect processing that took place before it, but some features need certain data and will stop working without it.
- For legitimate uses that the DPDP Act allows, for example where you voluntarily give us data for a specific purpose and have not told us that you do not consent (such as an email you send us), or where we must process data to comply with the law, a judgment or an order.
If the GDPR or a similar law applies to you, we rely on: contract (to provide Manas and the purchases you make); consent (for your voice, your face and your PhotoBooth photo, for recording, and for analytics and ads where the law requires consent); legitimate interests (security, fraud prevention, improving Manas and measuring our marketing, balanced against your rights); and legal obligation (financial records and lawful requests).
6. Your consents and choices
| What | How to give or change it |
|---|---|
| Recording classes. Before your first recording, Manas shows a notice and asks you to confirm that your college allows it. | Withdraw in Settings → Consents. You will be asked again before your next recording. |
| Your voice in videos | Given on its own screen before you record your voice. Withdraw in Settings → Consents (2 taps). |
| Your face in videos | Given on its own screen before you add your face. Withdraw in Settings → Consents (2 taps). |
| Your photo in PhotoBooth | Given on its own screen before you add your first photo. Withdraw in Settings → Consents (2 taps): your stored photos are deleted at once, and pictures you have made stay until you delete them. |
| Usage analytics (adults) | On by default for adults under this policy. To opt out, write to [support email] from your account's email: we will switch your account to essential events only and delete your detailed usage history. Students under 18 get essential events only (section 10). |
| Ads (adults) | Where the law requires it, Google's consent form asks for your choices before any ad loads. Change them at any time in Settings → Privacy → Ad privacy choices (shown where it applies). Section 11 lists other choices. |
| Notifications | Allow or block them in your phone's settings. In Settings → Notifications you can turn off class reminders, study-pack notifications, habit and to-do reminders, smart nudges, the streak saver, the weekly recap and PhotoBooth notifications, set quiet hours, and choose how your companion talks. |
| How long we keep class audio | Settings → Recording → Keep your recordings for: 30 days, 90 days (the default) or 1 year. |
| Uploading on mobile data | Settings → Recording. When it is off, recordings wait for Wi-Fi (asking for a study pack uploads right away). |
| Processing your data to provide Manas | Manas cannot work without it. To withdraw this consent, delete your account (section 19). |
| Marketing | We do not send marketing emails or marketing notifications. If we ever want to, we will ask you first. |
7. Your voice, your face and your photo in PhotoBooth
7.1 Separate, explicit consent. We use your voice and your face only if you give a separate consent for each, on its own full-screen sheet that says what is collected, where it goes, how long it stays and how to take it back. You can give 1 without the other.
7.2 Only your own. Manas accepts only the account holder's own voice and face. When you choose a photo, you confirm that it is a photo of you. A Video CV always uses your own face, never an avatar.
7.3 Your voice. You read a short passage aloud for about 30 seconds. We store the recording and send it to our voice service provider, which creates a copy of your voice. When you make a video in your own voice, the provider uses that copy to speak the lines of your script. If we change voice providers, the copy may be created with the provider in use at the time.
7.4 Your face. You record a 5-second selfie video or give us a photo. We store it, and make from it a still image and a short clip of your face. When you give a photo, we remove its metadata, check it automatically (that it shows 1 clear face and nothing unsafe), delete the original upload once we have read it, and ask a video service provider to make a short clip of your face from it. When you make a video with a talking face, a video service provider changes the mouth in your clip to match the voice. The video carries a visible "AI-generated" label and information in the file that identifies it as AI-generated.
7.5 Only for your videos. We use your voice and face data only to make the videos you ask for. We do not use them to identify or authenticate you, for advertising, or to train AI models.
7.6 Students under 18. Faces do not talk in videos made for students under 18, or before we know a student's age: the video shows a still image of the face instead.
7.7 Withdrawing consent and deletion. When you withdraw your voice or face consent in Settings → Consents, we stop using it at once and delete the stored recording or images, and we ask the provider to delete the copy of your voice. If a deletion fails, we retry it automatically every night until it succeeds. The same happens when you replace your voice recording or your face, and when you delete your account. Video service providers may keep their own copies of the clips they make for a limited time under their terms. Videos you have already made are not deleted automatically when you withdraw consent; to have them deleted, write to [support email] or delete your account.
7.8 PhotoBooth: separate consent, 18 and over. PhotoBooth turns a photo of you into a picture in the style you choose. It needs its own consent, separate from your voice and your face, and it is available only to students we know to be 18 or over. Use a photo of you, and only you: when you add a photo, you confirm that it is you.
7.9 What happens to your photo. When you add a photo, we remove its metadata, keep a copy in our storage, and check it automatically with our AI service providers (that it shows 1 clear face and nothing unsafe); the original upload is deleted once we have read it. When you ask for a picture, we send your photo and the instructions for the style you chose to our image model provider, OpenAI, or, if we switch providers, Google's image model through fal, which makes the picture. We store the picture in our storage with a visible "AI-generated" label in a corner and information in the file that identifies it as AI-generated.
7.10 How long we keep them. We keep your photo for 30 days after you add it, so you can try other styles, and then delete it automatically. You can delete it sooner in the app, and withdrawing your PhotoBooth consent deletes your stored photos at once. Your pictures stay until you delete them or your account. When you delete a picture, we keep a record of the style and what it cost, without the picture. Image model providers may keep their own copies of what they receive and make for a limited time under their terms.
7.11 Only for your pictures. We use your PhotoBooth photo only to check it and to make the pictures you ask for. We do not use it to identify or authenticate you, for advertising, or to train AI models.
8. Class recordings
8.1 Only when you tap record. Manas uses the microphone only between your tap on record and your tap on stop. It keeps recording when you lock your phone, and on Android it shows a notification while it records.
8.2 Upload and processing. The recording is saved on your phone in short pieces until it is uploaded to our storage. We remove silences, transcribe the audio with a speech-to-text provider, and use the transcript to make your study pack.
8.3 Other people's voices. Recordings can capture teachers and classmates. We use these recordings only to make your study material and do not try to identify anyone in them. Our Terms of Use require you to have permission to record.
8.4 Audio retention. We delete the audio of your recordings automatically after the period you choose in Settings: 30 days, 90 days (the default) or 1 year, counted from when the recording was processed. Your transcripts, study packs and flashcards stay until you delete your account. The same retention applies to a spoken CV. You can delete a recording, and its audio on your phone and on our servers, while it is being recorded or uploaded. To have the audio of a recording deleted sooner after that, write to [support email].
9. AI processing and our service providers
To make your study material, answers, CVs, videos and pictures, we send the content each task needs to these kinds of service providers:
| Service provider category | What they receive | What they do |
|---|---|---|
| Speech-to-text | Class audio and spoken-CV audio, in pieces | Transcribe it |
| Language models | Transcripts, study pack notes, your chat questions and recent chat history (with your first name and age group), CV information, job descriptions and scripts | Write study packs, answers, CVs, CV check suggestions, scripts and video plans |
| Content safety | Chat questions; face photos and PhotoBooth photos | Check them for unsafe content, and check that a photo shows 1 clear face |
| Voice | Your voice sample (with consent); the lines a video should say | Create the copy of your voice, and speak lines in your voice or a studio voice |
| Video | Your face clip or photo (with consent) and the voice audio | Make the short clip of your face, and the talking face for adults |
| Images (OpenAI; or Google's image model through fal) | Your PhotoBooth photo (with consent) and the instructions for the style you chose | Make the PhotoBooth picture you ask for (section 7) |
We send only what each task needs and keep the results in our own storage. AI service providers process your data to provide their services to us, and some keep it for a limited time under their own terms (for example, to check for abuse). Some of them are located outside India (section 16). On request, we will tell you the names of the service providers that have received your personal data (section 19).
AI output can be wrong. Our Terms of Use explain how to use it.
10. Analytics
10.1 Our own analytics. We record events about how Manas is used in our own systems, to operate, measure, fix and improve Manas, count installs, reinstalls and uninstalls, and detect abuse.
10.2 Adults. For adult users, events include the screens you view and what you tap. We also send these events, your Manas account identifier, your age group, your goals and the app version to Google Analytics for Firebase, which processes them for us. We have turned off Firebase's automatic data collection, automatic screen reporting and advertising-identifier collection; Firebase starts only after you tell us you are 18 or older, and stops when you sign out.
10.3 Students under 18, and before we know your age. We record only essential events, such as the app opening, sign-in, purchases and errors, without the screen they happened on, and send nothing to Google Analytics for Firebase. Before you enter your date of birth, events about screens and taps are held on your phone: if you are 18 or older they are then sent, and if you are under 18 they are deleted. Held events older than 7 days are deleted, never sent. When we learn that a student is under 18, we delete the detailed events already recorded for them. Once a phone has been used by a student under 18, it stays on essential events only for anyone who uses it.
10.4 Opting out (adults). See section 6. When you opt out, we delete your detailed usage history and record only essential events from then on.
10.5 How Google uses data. Google's use of data from apps that use its services is described at "How Google uses information from sites or apps that use our services": https://policies.google.com/technologies/partner-sites.
11. Advertising
11.1 Adults only. Manas may show ads from Google AdMob to users who are 18 or older, when we switch ads on. We never show ads to anyone under 18 or whose age we do not know. We do not show ads on sign-in, consent, payment or recording screens, in a student's first session, or to subscribers on an ad-free Plan. Rewarded videos, which you choose to watch for credits (or, where offered, for a PhotoBooth pass: 1 free picture), are also from AdMob.
11.2 What Google collects. When ads can be shown to you, Google's ads software in the app collects information such as device identifiers (on Android, your device's advertising ID), your IP address (from which Google estimates your approximate location), information about the ads shown and your interactions with them, and diagnostic data. Google uses this information to show, measure and, where you allow it, personalise ads, and to prevent fraud, under Google's own privacy policy. On iPhone we do not ask for permission to track you, so the advertising identifier is not available.
11.3 Cookies and similar technologies. Third parties, including Google, may place and read cookies, use device identifiers and use similar technologies to collect information as a result of ads served in Manas. Learn more at "How Google uses information from sites or apps that use our services": https://policies.google.com/technologies/partner-sites.
11.4 Your choices. Where the law requires it (for example in the European Economic Area, the UK and Switzerland), Google's consent form asks for your choices before ads load, and you can change them at any time in Settings → Privacy → Ad privacy choices. You can also manage ad personalisation in Google's My Ad Center (https://myadcenter.google.com), and on Android reset or delete your advertising ID in your device's settings.
11.5 What we do not share. We do not share your name, email address or content with Google for advertising. For rewarded videos, we send Google a random reference for each video, never your account identifier, and Google confirms to our server when a video has been watched so that we can add your credits.
12. Purchases
Credit packs and Plans are bought through Apple's App Store or Google Play. The store processes your payment; we never receive your card, bank or UPI details. The store tells us what you bought, transaction identifiers, the price and currency, and later events such as renewals, cancellations and refunds. We attach your Manas account identifier (a random identifier, not your name or email) to each purchase so that the store and our server can match it to your account, and we verify each purchase with the store before adding credits. Apple's and Google's privacy policies apply to their payment processing.
13. How you found Manas
On first launch, Manas reports how it was installed: on Android, the Google Play install referrer; on iPhone, an attribution token from Apple's AdServices framework, which our server exchanges with Apple for Apple Search Ads campaign details if an Apple Search Ads ad led to the install. This does not need tracking permission. We also record the link that opened Manas, its campaign details, and any referral code. When you sign up, we copy this to your account so we can see which campaigns and invitations bring students to Manas.
14. Push notifications
If you allow notifications, Manas registers a push token for your device, and we send notifications through a push delivery provider and Apple's and Google's push services: for example, when a study pack or video is ready, when something failed and your credits were returned, or when a data export is ready. Class reminders, and your habit and to-do reminders (including smart nudges, the streak saver and the weekly recap), are scheduled on your phone from your timetable, habits and to-dos, and are not sent through our servers. We send notifications through our servers for things like a PhotoBooth picture being ready, and we hold them during your quiet hours. If Manas has not been opened on a device for 3 days or more, we may send it a silent notification, which you do not see, to check whether Manas is still installed.
15. Who we share personal data with
| Who | What and why |
|---|---|
| Service providers that process data for us: cloud hosting and storage; AI providers (section 9); push notification delivery; analytics (Google Analytics for Firebase, adults only) | Only what each needs to provide its service to us |
| Apple and Google | Sign-in, purchases and refunds, push notifications, Apple Search Ads and Google Play attribution, and, for adults where ads are on, Google AdMob (section 11) |
| Other Manas students | Leaderboards show your first name, the initial of your last name and your points. Your invite link or code identifies you to the friends you send it to. If you type a college that is not in our list, its name is added to the list other students can choose from (without your name). |
| People and apps you choose | When you share a video, an infographic or your invite link, it goes to the app and people you choose, and that app's own policy applies. Shared items carry your invite link. |
| Authorities and others, where the law requires | To comply with the law, a court order or a lawful request from an authority, or to protect the rights, property or safety of our users, the public or Vitra.ai, and to enforce our Terms of Use |
| A successor business | If we are involved in a merger, acquisition or sale of assets, personal data may transfer to the successor, which must continue to protect it as this policy describes. We will tell you before that happens. |
We do not sell your personal data, and we do not share it with data brokers.
16. International transfers
We store your account and content on servers in India. Some of our service providers, including AI providers, push delivery and Google and Apple, process data in other countries, including the United States. We transfer personal data outside India only as Indian law permits, and not to any country to which the Government of India has restricted transfers. Where the GDPR or a similar law applies to you, we use safeguards it recognises, such as standard contractual clauses.
17. Security
We protect personal data with measures appropriate to its sensitivity, including:
- encryption in transit (HTTPS with TLS 1.2 or later) for all traffic between the app and our servers;
- private storage, with files reached only through time-limited links (most expire after 15 minutes; the links in a data export last as long as the export);
- short-lived sign-in tokens, refresh tokens that are stored only as an irreversible hash, change on every use and are bound to your device, and encryption of the sign-in tokens we keep for revocation;
- staff access limited by role, with every change staff make to student data logged, and administrative systems kept off the public internet.
No system is completely secure. If a personal data breach affects you, we will tell you and the authorities as the law requires.
18. How long we keep personal data
| Data | How long we keep it |
|---|---|
| Account profile | While your account exists. When you delete your account, we remove your name, email, sign-in identifiers, college, course and goals, and reset your companion choice and notification settings, at once. |
| Class audio and spoken-CV audio | The period you choose (30 days, 90 days or 1 year) after the recording is processed, or until you delete the recording |
| Transcripts, study packs, flashcards, review history, subjects and timetable | Until you delete your account |
| Chats | Until you delete the chat or your account |
| Habits, habit check-ins and notes, to-do lists and to-dos | Until you delete your account. You can delete a habit or a to-do in the app; a deleted to-do is kept, marked deleted, until you delete your account. |
| Your photo in PhotoBooth | 30 days after you add it, then deleted automatically; at once if you delete it, withdraw your PhotoBooth consent, or delete your account |
| PhotoBooth pictures | Until you delete them or your account. After you delete a picture, a record of the style and its cost is kept with your credit history, without the picture. |
| CVs and uploaded CV files, scripts, videos and infographics | Until you delete your account (videos made from your face or voice: section 7.7) |
| Voice recording and the copy of your voice; face video or photo, still image and clip | Until you withdraw consent, replace them, or delete your account |
| The original upload of a face photo | Deleted once we have read it; an upload that is never used is deleted in our nightly clean-up |
| Temporary files made while creating something | Deleted when the task ends, and within 2 days at the latest; cached AI results within 7 days |
| Data export files | 72 hours |
| Sign-in sessions | A sign-in lasts at most 90 days; records are deleted 1 day after they expire, or 30 days after you sign out |
| Usage events | [analytics retention period]. Detailed events are deleted when you opt out, when we learn you are under 18, and when you delete your account. Essential events are kept without details for aggregate statistics. |
| Purchase, credit, subscription and invoice-related records | After you delete your account, kept in pseudonymised form for as long as tax and accounting laws require |
| Consent records | Kept after you delete your account, marked withdrawn and without the IP address, as proof of what was agreed |
| Records that prevent repeat claims | A keyed, irreversible code made from your sign-in identity, and, if you received a promotional grant, the link between your account and your device's install identifier, kept after deletion so that referral rewards and promotions cannot be claimed again |
| Rewarded-video records | Unconfirmed videos are deleted 30 days after they expire; confirmed ones are kept with your credit history |
| Staff audit records | [audit log retention period] |
| Server logs | [server log retention period] |
| Backups | [backup retention period], after which they are overwritten |
19. Your rights
19.1 Your rights under the DPDP Act. You have the right to:
- access a summary of the personal data we process about you and how we process it, and, on request, the identities of other data fiduciaries and data processors with whom we have shared it and a description of what was shared. In the app: Settings → Download my data gives you a file with your account details, consents, devices, content, study history, habits and to-dos, PhotoBooth photos and pictures, credits, purchases, rewards and chats, with links to your media, prepared in the background (1 request a day; the link works for 72 hours);
- correction, completion and updating of your personal data. Edit your name, college, course, year, subjects and CV in the app, or ask us;
- erasure. Delete your account in Settings → Delete my account; delete chats, habits, to-dos, PhotoBooth photos and pictures in the app; withdraw voice, face or PhotoBooth consent to delete that data; or ask us to erase specific data;
- withdraw consent at any time (section 6);
- grievance redressal by our Grievance Officer (section 23), and, once our process is complete, to approach the Data Protection Board of India;
- nominate another person to exercise your rights if you die or become unable to. To nominate someone, write to our Grievance Officer with their name and contact details.
19.2 If you are in another region. Where the GDPR or a similar law applies, you also have the right to restrict our processing, to object to processing based on our legitimate interests (including analytics), to receive your data in a portable format (the data export), and to complain to your local data protection authority.
19.3 How to make a request. Use the options in the app, or write to [support email] or our Grievance Officer from the email address on your account. We may need to verify your identity. We will respond within the time the law requires.
19.4 What deletion keeps. When you delete your account, we close it at once and delete your content (recordings, transcripts, study packs, flashcards, chats, habits, to-dos, CVs, scripts, videos, PhotoBooth photos and pictures, voice and face data) from our systems, and ask our voice provider to delete the copy of your voice. We keep only the records described in section 18 that the law requires or that prevent abuse, in pseudonymised form. Deleting your account cancels a Google Play subscription; cancel an App Store subscription in the App Store yourself.
19.5 Your duties. The DPDP Act asks you to give accurate information, not to impersonate anyone, and not to make false or frivolous complaints.
20. Children and students under 18
20.1 Manas is designed for college and university students. Under our Terms of Use, students under 18 may use Manas only with the consent of a parent or lawful guardian.
20.2 When you start using Manas we ask for your date of birth. We keep only your age group, never the date of birth.
20.3 If you are under 18, or until we know your age:
- we show no ads, and rewarded videos are not available;
- we record only essential events, without the screens they happened on, send nothing to Google Analytics for Firebase, and delete any detailed events recorded before we learned your age;
- chat questions pass stricter safety checks;
- faces in your videos do not talk;
- PhotoBooth is not available.
20.4 We do not currently verify a student's age or a parent's or guardian's consent. The recording notice and the voice and face consents in the app are given by the student. Like every student, students under 18 appear on leaderboards with their first name, the initial of their last name and their points.
20.5 A parent or guardian can contact us (section 23) to access, correct or delete the data of a student under 18 in their care. If we learn that a student under 18 is using Manas without a parent's or guardian's consent, we may close the account and delete its data.
21. Changes to this policy
We may update this policy. We will tell you about material changes in the app or by email before they take effect, and show the date of the latest version at the top of this page. Where a change needs your consent, we will ask for it again in the app.
22. Links to other services
Manas links to services run by others, such as the App Store, Google Play, Google's privacy pages and the apps you share to. Their privacy policies apply to them.
23. Contact and Grievance Officer
[Vitra.ai legal entity name] [registered address] Email: [support email]
Grievance Officer: [grievance officer name and email] Address: [registered address]
We will acknowledge your complaint within 24 hours and aim to resolve it within 15 days. If you are not satisfied with our response to a complaint about your personal data, you may approach the Data Protection Board of India once our grievance process is complete.