ProKai ("we," "us," or "our") is an Indian edtech startup committed to revolutionizing exam
preparation through AI-powered prompt scripts. We operate the ProKai mobile application (the "App")
available on the Google Play Store, and we are dedicated to protecting your privacy and personal
data in compliance with the Digital Personal Data Protection Act, 2023 (DPDPA), including the
Digital Personal Data Protection Rules, 2025, Google Play Store Developer Policies, and applicable
requirements for integrations with payment gateways like Razorpay.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you
use our App, purchase our products, or interact with our services. By using the App or our services,
you consent to the practices described in this Policy. If you do not agree, please do not use our
services. This Policy is incorporated into our Terms and Conditions, and any terms defined there
(e.g., "Services," "scripts") apply here.
We may update this Policy from time to time to reflect changes in our practices or legal
requirements. We will notify you of material changes via the App or email. Your continued use of the
App after updates constitutes acceptance of the revised Policy.
Who We Are
ProKai is registered as an MSME under Udyam Registration with the Government of India. Our contact
details are:
- Email: prokai.team@gmail.com
We act as a "Data Fiduciary" under the DPDPA, responsible for determining the purposes and means of
processing your personal data.
Clear Instructions for Users:
- What to Do: Contact us via the provided email for any privacy-related
queries.
- What Not to Do: Do not assume we are responsible for third-party AI data
handling.
- Responsibilities: It is your responsibility to review our details; ProKai's
responsibility is limited to providing accurate contact information.
Information We Collect
We collect personal data necessary to provide our Services, such as delivering AI prompt scripts,
processing payments, managing referrals, and improving user experience. We adhere to data
minimization principles, collecting only what is required. We do not collect or process data related
to your interactions with third-party AIs (e.g., ChatGPT, Grok) or your study outcomes, as these are
entirely your responsibility.
a. Information You Provide Directly
- Account and Profile Information: Email address for sign-in and account
creation. You may also upload a profile photo (media files) to customize your profile.
- Payment Information: When purchasing scripts (Basic, Pro, or God levels), we
collect transaction details via Razorpay, including payment method (e.g., UPI, card, bank
transfer). We do not store sensitive payment details like card numbers or CVVs; these are
handled securely by Razorpay in compliance with PCI-DSS standards.
- Referral and Affiliate Information: Referral codes or links you share, and
details of referred users (e.g., their email or transaction IDs) to credit commissions to your
in-app wallet.
- Communication Information: If you request script delivery via email or
WhatsApp, we collect the provided contact details. We also collect any information you share in
support queries (e.g., via email, WhatsApp, or in-app chatbot).
- Purchase Details: Exam type, script level, and purchase history to fulfill
orders and provide personalized recommendations.
b. Information Collected Automatically
- Device and Usage Data: App usage patterns, device ID, IP address, operating
system, and crash reports to improve functionality and analytics. We do not collect location
data unless explicitly required (e.g., for geocode-based features, which we do not currently
use).
- App Permissions: We request access to media files solely for uploading profile
photos. No other sensitive permissions are required.
c. Information from Third Parties
- Payment Gateway: Razorpay provides transaction confirmations and status
updates. We receive limited data (e.g., transaction ID, amount) with your consent during
payment.
- Affiliates/Referrals: Data about referred installations and purchases to
process commissions.
We do not collect sensitive personal data (e.g., biometric, health, or genetic data) unless
explicitly provided by you for support purposes, and only with your consent.
Clear Instructions for Users:
- What to Do: Provide accurate data for accounts/payments; consent to
permissions only if needed.
- What Not to Do: Do not provide false information or share sensitive data
unnecessarily.
- Responsibilities: It is your responsibility to ensure data accuracy;
ProKai's responsibility is limited to minimal collection for Services.
How We Use Your Information
We process your personal data for legitimate purposes, with your consent where required under DPDPA.
Uses include:
- Providing and personalizing Services: Delivering prompt scripts, managing
accounts, and customizing recommendations based on exam preferences.
- Processing transactions: Facilitating payments via Razorpay and crediting
referral commissions to your wallet.
- Communications: Sending order confirmations, updates, or promotional offers
(you can opt out). Support responses via email, WhatsApp, or in-app.
- Analytics and Improvement: Analyzing usage to enhance the App, detect issues,
and ensure security.
- Compliance and Legal: Fulfilling legal obligations, such as tax reporting or
responding to authorities.
- Marketing: With consent, sending referral incentives or exam tips. We do not
sell your data.
Data retention: We retain data only as long as necessary for these purposes or as
required by law (e.g., 5-7 years for financial records under Indian tax laws). After that, we delete
or anonymize it. We do not use data for AI training or unrelated purposes.
Clear Instructions for Users:
- What to Do: Consent to uses as needed; opt out of marketing via settings.
- What Not to Do: Do not assume data is used for AI outputs—these are your
responsibility.
- Responsibilities: It is your responsibility to manage consents; ProKai's
responsibility is limited to lawful processing.
Sharing Your Information
We share data only when necessary and with safeguards:
- Service Providers: With trusted third parties like Razorpay for payments (they
process data under their PCI-DSS compliant policy), cloud hosting providers for storage, or
analytics tools (e.g., Google Analytics, with data anonymized).
- Affiliates and Referrers: Limited referral data (e.g., anonymized transaction
IDs) to credit commissions.
- Legal Requirements: If required by law, regulators (e.g., RBI, Data Protection
Board), or to prevent fraud/harm.
- Business Transfers: In case of merger or acquisition, with notice to you.
We do not share data with advertisers or third parties for marketing without consent. Cross-border
transfers (if any) comply with DPDPA rules, ensuring adequate protection. We do not share study or
AI interaction data, as these are not collected.
Clear Instructions for Users:
- What to Do: Review shared parties; withdraw consent if applicable.
- What Not to Do: Do not share your own data externally without verification.
- Responsibilities: It is your responsibility to understand sharing; ProKai's
responsibility is limited to safeguarded, necessary sharing.
Security Measures
We implement reasonable technical and organizational measures to protect your data, including:
- Encryption for data in transit and at rest.
- Access controls, pseudonymization where feasible, and regular security audits.
- Breach response: If a breach occurs, we notify affected users and the Data
Protection Board within 72 hours, as per DPDPA Rules.
While we strive for security, no system is infallible. You are responsible for safeguarding your
account credentials. In alignment with our Terms and Conditions, ProKai disclaims liability for
breaches beyond our control or arising from your misuse.
Clear Instructions for Users:
- What to Do: Use strong passwords; report suspected breaches.
- What Not to Do: Do not share credentials or ignore security warnings.
- Responsibilities: It is your responsibility to secure your end; ProKai's
responsibility is limited to reasonable measures.
Your Rights Under DPDPA and Other Laws
As a Data Principal under DPDPA, you have rights to:
- Access: Request details of your data we hold.
- Correction: Update inaccurate or incomplete data.
- Erasure: Request deletion of data when no longer needed (subject to legal
retention).
- Nomination: Nominate someone to exercise rights on your behalf.
- Consent Withdrawal: Withdraw consent at any time (may affect service
availability).
- Grievance: Lodge complaints via our Data Protection Officer (contact below).
- Data Portability: Request transfer of data in a structured format.
To exercise rights, email prokai.team@gmail.com. We respond within 30 days (or as per DPDPA
timelines). For Google Play compliance, we provide in-app data deletion options. These rights align
with our Terms and Conditions, where ProKai's liability is limited.
Clear Instructions for Users:
- What to Do: Submit rights requests with verification.
- What Not to Do: Do not abuse rights for non-privacy purposes.
- Responsibilities: It is your responsibility to provide accurate requests;
ProKai's responsibility is timely response.
Children's Privacy
Our App is rated "Everyone" on Google Play and targets students preparing for exams, which may
include individuals under 18 ("Children" under DPDPA). We do not knowingly collect data from
Children without verifiable parental consent, as per our Terms and Conditions.
If you are under 18, you must obtain parental/guardian consent and supervision before using the App
or providing data.
Parents/guardians: Contact us to review, delete, or refuse further collection of
your child's data.
We comply with child-specific protections, including no targeted advertising to Children and enhanced
security for their data. If we discover unauthorized collection from a Child, we will delete it
promptly.
Clear Instructions for Users:
- What to Do: Obtain consent if minor; parents monitor usage.
- What Not to Do: Minors do not use without consent.
- Responsibilities: It is your/guardian's responsibility to ensure consent;
ProKai's responsibility is deletion upon discovery.
Cookies and Tracking Technologies
As a mobile app, we do not use browser cookies. We may use device identifiers or analytics tools for
functionality. You can manage preferences via device settings. This aligns with our minimal data
collection policy in the Terms and Conditions.
Clear Instructions for Users:
- What to Do: Adjust device settings for tracking.
- What Not to Do: Do not assume no tracking—review settings.
- Responsibilities: It is your responsibility to manage; ProKai's
responsibility is limited use.
Third-Party Links and Services
The App may link to external sites (e.g., Razorpay for payments). We are not responsible for their
privacy practices. Review their policies separately. As per our Terms and Conditions, ProKai
disclaims liability for third-party AI or services.
Clear Instructions for Users:
- What to Do: Review third-party policies before use.
- What Not to Do: Do not blame ProKai for third-party issues.
- Responsibilities: It is your responsibility to verify; ProKai's
responsibility is none for third parties.
International Users
Our services are for Indian users. If accessed from outside India, your data is processed in India
under DPDPA.
Clear Instructions for Users:
- What to Do: Comply with local laws if international.
- What Not to Do: Do not expect non-Indian compliance.
- Responsibilities: It is your responsibility for cross-border compliance;
ProKai's responsibility is Indian standards.
Google AdMob Policy Compliance
ProKai complies with Google AdMob program policies (which incorporate AdSense policies)
for all advertisements displayed in the App, including rewarded ads used to promote or
unlock access to our Basic level scripts. We use AdMob to offer users two options for
acquiring the Basic script:
(1) purchase with money via Razorpay, or
(2) watch rewarded ads
to unlock it for free (no cost, but ads must be viewed completely to receive the script). Pro
and God/Advanced level scripts are available only through monetary purchase—no
ad-based free access is provided for these tiers
Key Compliance Details:
- Rewarded Ads for Free Access: Rewarded ads are optional and clearly labeled.
Users must actively choose to watch ads to unlock the Basic script, and completion is
required for delivery. This aligns with AdMob's rewarded ad guidelines, ensuring user
consent and no invalid traffic (e.g., no auto-plays, forced views, or misleading
prompts).
- Ad Placement and User Experience: Ads are placed non-intrusively, without
interfering with core App functionality or misleading users (e.g., no ads disguised as
App content). We prohibit invalid clicks, such as encouraging accidental taps or
offering incentives beyond the script unlock.
- Prohibited Practices: No ads promote illegal activities, violate intellectual
property,
or target sensitive categories. We monitor for fraud using AdMob tools and terminate
access for violations (as per Terms Point 8 and 12).
- User Consent and Privacy: Ads require explicit user interaction. Data from ad
interactions is handled per our Privacy Policy and DPDPA 2023—no sharing for
unrelated purposes. Users can manage ad preferences via device settings.
- Promotion of Paid Content: Ads may promote all script levels but clearly
distinguish free ad-based access (Basic only) from paid tiers. This complies with
AdMob's policies on truthful advertising and no deceptive claims.
For more details, refer to Google AdMob policies and AdSense policies.Violations may result
in ad suspension or account termination. Contact prokai.team@gmail.com for queries.
Contact Us and Data Protection Officer
For questions, rights exercises, or complaints:
If unresolved, you may approach the Data Protection Board under DPDPA.
This Policy is available in English. Upon request, we can provide it in other Indian languages as per
the 8th Schedule of the Constitution.
By using our App, you acknowledge understanding this Policy and consent to data processing as
described, in alignment with our Terms and Conditions.