Privacy Policy

1. Introduction

Welcome to PGS Learning ("Company," "we," "us," "our," or "App"). This Privacy Policy explains transparently how we collect, use, disclose, and otherwise process personal information collected from users of the PGS Learning mobile application ("App") available on Google Play Store and Apple App Store.

Your privacy is important to us. We are committed to protecting your personal information and ensuring transparency about our data practices. Please read this Privacy Policy carefully. If you do not agree with our practices, you should not download or use the App.

By accessing and using PGS Learning, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you are under 13 years old, your parent or legal guardian must review and accept this policy on your behalf.

2. Information We Collect

We collect information in the following categories:

2.1 Personal Information You Provide Directly

• Authentication Information: When you create an account, we collect your name, email address, phone number (optional), and password. Authentication is handled securely through Google Firebase Authentication services.
• Profile Information: Your profile photo, date of birth (optional), educational level, and preferred language.
• Payment Information: If you purchase premium content or subscriptions, payment details are processed by third-party payment processors (Stripe, Google Play Billing, Apple In-App Purchases). We do not directly store complete credit card numbers.
• Communication Data: Messages you send via our in-app support, feedback forms, or email to our support team.
• Academic Information: Your course progress, quiz responses, test scores, learning achievements, and study preferences.

2.2 Information Collected Automatically

• Device Information: Device model, manufacturer, operating system type (iOS/Android), OS version, unique device identifiers (UDID, IMEI, Android Advertising ID).
• App Usage Data: Features accessed, content watched, courses completed, time spent in app, navigation patterns, and interaction analytics.
• Crash & Performance Data: Diagnostic information when the app crashes or experiences performance issues, including stack traces and error logs.
• Location Information: Approximate location based on IP address for analytics and serving localized content. Precise GPS location is NOT collected.
• Network Information: Internet service provider (ISP), connection type (WiFi/mobile), bandwidth information.
• Advertising Identifiers: Google Advertising ID (Android) or Identifier for Advertisers (IDFA, iOS) for analytics and advertising purposes.

2.3 Information from Device Permissions

• Camera Permission: Only requested when you choose to upload a profile photo or take a photo to upload to the platform. We do not access photos without explicit user action.
• Photo Library/Gallery Permission: Only requested when you select a photo from your device to upload as your profile picture or for academic submissions.
• Storage Permission: Requested only to enable offline video downloads. Downloaded content is encrypted and stored locally on your device.
• Microphone Permission: Requested only if you participate in live classes or record video submissions.
• Calendar Permission: Used only to help you set reminders for course schedules and deadlines (if enabled by you).

2.4 Information from Third-Party Sources

• If you register using Google Sign-In or Apple Sign-In, we receive your email, name, and basic profile information from these services.
• Analytics providers may share aggregated usage data.
• Educational content providers may share information about which courses you've accessed.

3. How We Use Your Information

We use the information we collect for the following legitimate purposes:

3.1 Core App Functionality

• Creating and maintaining your user account
• Authenticating your identity and verifying credentials
• Delivering educational content, videos, and course materials
• Tracking your course progress and academic performance
• Saving your study preferences and learning history
• Enabling offline access to downloaded content
• Processing payments and managing subscriptions

3.2 Communication

• Sending you transactional emails (password resets, receipt confirmations)
• Notifying you of course updates, assignment deadlines, and new content
• Responding to your support inquiries and feedback
• Sending educational announcements (only if you opt-in)

3.3 Improvement & Analytics

• Analyzing app usage patterns to improve user experience
• Identifying and fixing technical issues and bugs
• Understanding which features are most popular
• Personalizing content recommendations based on your learning patterns
• Conducting research on educational effectiveness
• Security monitoring and fraud detection

3.4 Marketing & Personalization

• Sending you promotional content about new courses or features (only with your consent)
• Displaying personalized recommendations
• Creating aggregated, de-identified reports for business analytics
• Targeted advertising across platforms (opt-out available)

3.5 Legal & Safety

• Complying with legal obligations and court orders
• Enforcing our Terms & Conditions
• Protecting against fraud, security threats, and abuse
• Establishing, exercising, or defending legal claims

3.6 Legitimate Business Interests

• Enhancing the security and integrity of our services
• Conducting quality assurance and testing
• Improving content relevance and educational outcomes
• Business planning and developing new features

4. Information Sharing & Third Parties

We are committed to NOT selling your personal information. However, we share information with the following categories of third parties:

4.1 Service Providers (Data Processors)

We share information with third-party service providers who perform services on our behalf under data processing agreements:

• Firebase (Google): Authentication, real-time database, cloud storage, crash reporting, analytics (see Firebase Privacy Policy)
• Analytics Services: Google Analytics 4, Mixpanel, or similar tools to track usage patterns
• Payment Processors: Stripe, Google Play Billing, Apple In-App Purchases for processing transactions
• Cloud Storage Providers: AWS, Google Cloud Storage for secure data storage
• Email Service Providers: Mailchimp, SendGrid for transactional and promotional emails
• Push Notification Services: Firebase Cloud Messaging (FCM) for sending notifications
• Video CDN Providers: For streaming video content efficiently

4.2 Legal Requirements

We may disclose your information if required by law or when we believe in good faith that disclosure is necessary to:

• Comply with applicable laws, regulations, legal processes, or governmental requests
• Enforce our Terms & Conditions and other agreements
• Protect the safety, rights, and property of PGS Learning, our users, or the public
• Detect, prevent, or address fraud, security issues, or technical problems

4.3 Business Transfers

If PGS Learning is involved in a merger, acquisition, bankruptcy, asset sale, or other business transaction, your information may be transferred as part of that transaction. We will provide you with notice before your information becomes subject to a different privacy policy.

4.4 Aggregated & De-Identified Information

We may share aggregated, anonymized data (information that cannot identify you) with partners for research, marketing, and analytics purposes. This information cannot be linked back to you.

4.5 Public Forums

Any information you share in public discussion forums, comment sections, or community areas may be publicly visible. Do not share sensitive information in these areas.

5. Data Retention & Deletion

We retain your personal information based on the purpose for which it was collected and for as long as necessary to provide our services:

5.1 Retention Periods

• Account Data: Retained while your account is active and for 12 months after account deletion (for recovery purposes)
• Academic Records: Retained as long as necessary for educational transcripts and verification (typically 7 years)
• Payment Records: Retained for 7 years for tax and accounting purposes as required by law
• Device/Analytics Data: Retained for up to 12-24 months in aggregated form; individual device data is de-identified after 90 days
• Crash Reports: Retained for 30 days and then automatically deleted
• Support Communications: Retained for 2 years
• Cookies & Tracking Data: Deleted when you clear app cache or after 12 months of inactivity

5.2 Account Deletion & Right to Erasure

You have the fundamental right to request deletion of your account and all associated personal data. To request account deletion:

1. Go to Settings → Account → Delete Account within the PGS Learning app, or
2. Email us at waqas@progeniusstudents.com with the subject "Account Deletion Request"
3. Provide your full name, email address, and user ID

Upon receiving your verified request, we will permanently delete your account and associated personal data within 30 days, except where:

• We are legally required to retain the data
• Academic records must be retained for verification and transcript purposes
• Payment records must be retained for tax/accounting compliance
• The data is already anonymized and de-identified

5.3 Offline Downloaded Content

Encrypted videos downloaded for offline access are stored on your device. These files are NOT automatically deleted when your account is deleted. You must manually delete them from your device. You can do this by going to Downloads → Manage Storage in the app.

6. Data Security & Encryption

We implement robust security measures to protect your information from unauthorized access, alteration, and disclosure:

6.1 Encryption

• In Transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher (HTTPS/SSL encryption)
• At Rest: Sensitive personal information (passwords, payment data) is encrypted using AES-256 encryption at rest in our databases
• Offline Content: Videos downloaded for offline access are encrypted locally on your device using AES-256 encryption. The encryption keys are stored securely.
• Passwords: Passwords are never stored in plain text. They are hashed using industry-standard algorithms (bcrypt with salt) and secured through Firebase.

6.2 Access Controls

• Access to personal data is restricted to authorized employees and service providers who need it to perform their duties
• All employees and contractors sign confidentiality agreements
• Multi-factor authentication (MFA) is required for accessing sensitive systems
• Role-based access controls limit data exposure

6.3 Infrastructure Security

• Servers are hosted on secure, ISO 27001 certified cloud infrastructure (Firebase/Google Cloud)
• Regular security audits and vulnerability assessments are conducted
• DDoS protection and intrusion detection systems are in place
• Firewalls and network segmentation prevent unauthorized access

6.4 Data Backup

• Data is backed up regularly to protect against loss
• Backups are encrypted and stored in secure locations

6.5 Security Limitations

While we strive to protect your information, no security system is impenetrable. We cannot guarantee absolute security. You are responsible for keeping your password confidential and securing your device.

6.6 Breach Notification

In the unlikely event of a data breach involving personal information, we will notify affected users without unreasonable delay, typically within 72 hours, and provide information about the breach and steps you should take.

7. Your Rights & Choices

Depending on your location, you may have the following rights regarding your personal information:

7.1 Access & Portability

You have the right to request a copy of the personal information we hold about you in a structured, commonly used, machine-readable format (data portability). Submit requests to waqas@progeniusstudents.com.

7.2 Correction & Rectification

You can update or correct inaccurate personal information through your account settings or by contacting us at waqas@progeniusstudents.com.

7.3 Right to Erasure ("Right to be Forgotten")

As described in section 5.2, you can request complete deletion of your account and personal data. Please note that some data may need to be retained for legal or academic transcript purposes.

7.4 Opt-Out of Marketing Communications

You can opt-out of promotional emails and marketing messages by:

• Clicking the "Unsubscribe" link in any marketing email
• Going to Settings → Notifications → Marketing Emails in the app
• Emailing us at waqas@progeniusstudents.com with "Unsubscribe" in the subject

Note: You will still receive transactional and educational emails (account confirmations, course deadlines, important updates).

7.5 Opt-Out of Personalized Advertising

You can limit personalized advertising by:

• iOS: Go to Settings → Privacy → Apple Advertising → Turn off "Personalized Ads"
• Android: Go to Google Settings → Ads → Turn on "Opt out of Ads Personalization"
• Within the app: Go to Settings → Privacy → Personalized Ads → Opt Out

7.6 Opt-Out of Analytics

You can disable analytics collection through your device settings, but this may limit our ability to troubleshoot issues and improve the app.

7.7 Cookie & Tracking Controls

Most web browsers allow you to control cookies. You can:

• Clear cookies at any time through your browser settings
• Disable third-party cookies
• Enable "Do Not Track" (if supported by your browser)

7.8 Restrict Processing (for EU/GDPR Users)

If you are in the EU, you may request that we restrict how we process your data. We will store your data but limit its use except with your consent or for legal compliance.

7.9 Withdraw Consent

If we rely on your consent to process information, you can withdraw that consent at any time. This will not affect the lawfulness of processing that occurred before withdrawal.

7.10 Response Timeline

We will respond to your data access, correction, and deletion requests within 30 days of verification. If we cannot fulfill a request, we will explain the reason.

8. App Permissions

The PGS Learning app requests certain device permissions. Here's what each permission is used for:

Important: You can grant or revoke these permissions at any time through your device settings (Settings → Permissions, or Settings → Privacy depending on your device). Revoking permissions may limit certain app features.

*Optional for general app use, but required for offline video access.

9. Children's Privacy

Age Restrictions: PGS Learning is intended for users aged 13 and older. We comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly collect personal information from users under 13.

9.1 For Users Under 13

If your child is under 13, they must use PGS Learning only with parental/guardian supervision and consent.Parents and guardians must create and manage the account on behalf of the child.

9.2 For Users 13-18 (Minors)

Minors using PGS Learning should be aware that:

• Parents/guardians may request access to their child's account data
• We may collect additional information about course progress for educational purposes
• Academic records may be shared with schools or educational institutions (with parent/school consent)
• We do not share minor users' personal information with third parties for marketing without parental consent

9.3 Parental Controls

Parents and guardians can:

• Request information about their child's account from Settings → Parental Controls
• Set content filters and usage restrictions
• Monitor course progress and academic performance
• Request account deletion at any time

9.4 Reporting Concerns

If you believe we are collecting information from minors in violation of this policy, please contact us immediately at waqas@progeniusstudents.com. We will investigate and take appropriate action.

10. International Data Transfers

PGS Learning is operated from and primarily serves users in the United States, but we collect information from users globally. Your information may be transferred to, stored in, and processed in the United States or other countries where we or our service providers operate.

10.1 Data Transfer Mechanisms

Data transfers between countries are protected by appropriate legal mechanisms:

• Standard Contractual Clauses (SCCs): For transfers to countries without an adequacy decision
• Adequacy Decisions: For transfers to countries recognized as having adequate data protection
• Binding Corporate Rules: For transfers within our organization

10.2 GDPR (European Users)

If you are located in the European Union, European Economic Area, or Switzerland, the General Data Protection Regulation (GDPR) provides additional protections:

• We will process your data only with lawful bases (consent, contract, legal obligation, vital interests, public task, legitimate interests)
• You have rights to access, rectification, erasure, and portability
• You can lodge complaints with your local data protection authority
• Our Data Protection Officer can be reached at waqas@progeniusstudents.com

10.3 CCPA (California Users)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides the right to:

• Know what personal information is being collected
• Delete personal information we have collected from you
• Opt-out of the sale/sharing of personal information
• Receive services without discrimination for exercising your CCPA rights

Note: We do not "sell" personal information as traditionally defined, but we may share information with analytics and advertising partners (which may constitute "sharing" under CCPA). You can opt-out of this sharing through your device settings.

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices, technology, legal requirements, or other factors. If we make material changes, we will notify you through:

• Posting the updated policy on this website with an updated "Last Modified" date
• Sending you an email notifications if the changes are significant
• Requiring you to accept the new policy before continuing to use the app (if legally required)

Your continued use of the app after policy changes constitutes your acceptance of the updated Privacy Policy.We recommend reviewing this policy periodically.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Support Channels

• In-App Support: Settings → Help & Support → Contact Us
• Response Time: We will respond to privacy inquiries within 30 days
• Data Subject Access Requests (DSAR): We will provide your data within 30-45 days of verification

Data Protection Authority Information

For EU/EEA Users: You have the right to lodge a complaint with your local data protection authority if you believe we have violated your rights.

For California Users: You may file a complaint with the California Attorney General.

For Other Jurisdictions: Please contact your local regulatory body for data protection.