Privacy Policy

Effective Date: June 15, 2026
Policy Version: 1.0

Welcome to SubhKal ("the App"). We are fully committed to protecting your privacy by ensuring that your personal data remains strictly under your control. Because SubhKal is an offline-first application built around the principles of Privacy by Design, we do not require user accounts, email addresses, or phone numbers to access core features.

1. What Data SubhKal Processes

To provide accurate classical Vedic astrology calculations, the App processes the following categories of data locally on your device:

• Profile Information: Name, relationship type, and gender. Gender is purely for display-neutral iconography and does not affect any calculations.
• Birth Details: Exact birth date, birth time, and birth place (including geographic coordinates and historical timezone parameters).
• App Permissions Utilized:
  • Camera Access: Used exclusively for the experimental SubhKal Labs features (Numerology Name Scanner, Hast Rekha Palmistry, Samudrika Face Reading, and Aura Colour Reading) to process images locally in volatile memory.
  • Biometric Hardward (Face ID/Fingerprint): Used strictly via local device authentication to grant access to your private Report Vault or to unlock hidden profiles in Stealth Mode.

2. How Data is Stored

All sensitive personal data—including birth profiles, generated reports, subscription states, and private journal entries—is stored strictly on-device inside a secure, sandboxed Hive local database encrypted with **AES-256-GCM**. The master decryption key is securely isolated within your device's hardware enclave (iOS Keychain or Android Keystore) and is configured to never back up to any cloud service.

3. What Data is Never Collected or Shared

We believe in absolute data minimization. SubhKal does NOT collect, maintain, or transmit:

• Your birth data, profile names, or raw planetary calculation results to any cloud server.
• Any Personally Identifiable Information (PII) remotely.
• Timestamps of your individual user interactions or background activity.
• Hardware-level identifiers (such as IMEI or MAC addresses).
• Data to third-party advertising SDKs or data brokers. There are zero tracking networks integrated within SubhKal.

4. Anonymous Analytics and Feedback Synchronization

SubhKal features an entirely voluntary, anonymous analytics subsystem used to measure feature satisfaction and calculation tolerances.

• Opt-In Requirement: This feature is turned OFF by default. It is only enabled if you explicitly tick the optional feedback checkbox during onboarding or toggle it on manually in Settings.
• Data Transmitted: When enabled, the App bundles aggregate feature satisfaction counts (likes/dislikes) alongside your active subscription tier, app version, and current week number. It transmits this bundle weekly as an encrypted package under 1KB via Google Apps Script.
• Anonymity: This synchronization contains no device IDs, user IDs, location information, birth details, or individual event timestamps. It is mathematically impossible to re-identify an individual user from these aggregate records.
• Operational Transparency: Core system performance analytics (such as crash-free session rates and ANR metrics) are read exclusively through platform-level developer consoles managed by Google Play and Apple App Store. These rely on no in-app telemetry SDKs.

5. User Rights (Access, Correction, and Deletion)

As all data resides locally on your device, you possess total, autonomous control over your rights under data protection laws:

• Access and Export: You can access all saved profiles at any time via the profile switcher. You may export a password-protected backup file of your encrypted vault directly from your settings sheet.
• Correction and the Progressive Lock Limit: You may correct your birth details freely until a profile commitment event occurs (such as generating an individual report or interacting with specialized notifications). To safeguard chart integrity and prevent profile slot recycling, the profile will then be governed by a **Progressive Profile Lock Policy**. After the third post-lock modification, a profile's birth fields become permanently frozen and can no longer be corrected. Profile names are permanently frozen at Lock Stage 1. Always ensure your initial inputs are correct.
• Absolute Deletion: You can completely purge all data from the App instantly by navigating to Settings → Privacy and Data → Delete All My Data. Executing this command triggers a destructive, sequential wipe of all databases, clearings of all secure storage keys, and triggers an anonymous deletion signal to our pipeline. Once completed, your data is permanently gone from the device and cannot be recovered by us.

6. Children's Data and Parental Consent

SubhKal is fully compliant with COPPA and the minor safety protections of the DPDP Act 2023. When adding a profile, if the entered birth details indicate that the individual is a minor under the age of 18, the App automatically triggers a mandatory parental consent overlay. The profile data cannot be saved or processed by the local calculation engine until an affirmative parental or legal guardian confirmation checkbox is checked.

7. Platform-Specific Enforcement Rules

• iOS Enforcements: To strictly track the one-trial-per-Apple-ID store policy, a specialized cryptographic trial status flag is written with cloud synchronization enabled (kSecAttrSynchronizable=true). This is a strictly scoped technical exception to our non-transmission framework, allowing the flag to survive app reinstallation across your Apple devices. It maps strictly to subscription enforcement and carries no personal tracking data. All master encryption keys are strictly bound locally to the device (ThisDeviceOnly) and never travel to iCloud.
• Android Enforcements: To prevent your private encrypted databases from being transmitted to Google servers without your awareness, SubhKal explicitly declares configurations in its application manifest that completely disable and exclude secure data storage files from the native Android Auto Backup pipeline.

8. Compliance Frameworks and Certifications

SubhKal's engineering and product architecture align directly with leading national and global standards for digital privacy, including:

• Digital Personal Data Protection (DPDP) Act, 2023 (India): Strictly operating under the lawful basis of unambiguous, revocable user consent with absolute regional storage residency (on-device localization).
• General Data Protection Regulation (GDPR) Alignment: Enforcing strict principles of purpose limitation, data minimization, and absolute erasure controls.
• Bureau of Indian Standards (IS 17428): Our architectural design adheres to the native Privacy Technologies reference workflows established for data safety within India.

9. Grievance Redressal and SLA

In accordance with the DPDP Act 2023, we provide a dedicated operational channel for privacy inquiries and data-related grievances.

If you have questions regarding this policy, your rights, or technical data handling, you may click the Data Grievance menu item in Settings to launch your email client, or contact our designated Grievance Officer directly:

• Contact Endpoint: Accessible dynamically via the In-App Developer Config Layer
• Resolution Commitment: We commit to acknowledging and thoroughly resolving all formal data grievances within **72 hours** of receipt.