Privacy Policy

This Privacy Policy describes how FocusPledge LLC ("FocusPledge," "we," "us," or "our"), a California limited liability company, collects, uses, and discloses information when you use the Simran mobile application (the "App"), a Sikh spiritual companion that provides access to the Guru Granth Sahib Ji, the Daily Hukamnama, AI-assisted Shabad interpretations, and Sangat, a community space where members can share with one another.

Postal address: 20289 Stevens Creek Blvd #1261, Cupertino, CA 95014, United States

Email: [email protected]

1. Information We Collect

A. Information You Provide Directly

• Account Information: Your name, email address, and authentication credentials when you create a Simran account. You may also use parts of the App as a guest without an account.
• Sangat Profile and Content: If you take part in Sangat, the display name and optional profile photo you choose, and the content you share there (for example, a reflection on the Daily Hukamnama), together with the items you like, report, or block. Sangat content and your Sangat profile are visible to other users of the App unless you choose to share without your name (see Section 3A).
• Spiritual Queries: The questions and text you submit to the AI companion for interpretations or spiritual guidance. See Section 3 (Religious Information) and Section 4 (How the AI Feature Works) for how this data is handled.
• Feedback and Support: Information you provide when contacting us for support or offering feedback.

B. Information Collected Automatically

• Usage Data: Your interactions within the App, such as the shabads you access, Hukamnama readings, features used, onboarding progress, and session timing. We use a product analytics provider (PostHog) to collect and analyze this data.
• Device Information: IP address, operating system and version, app version, language settings, device model, and device identifiers.
• Purchase and Subscription Data: If you purchase a subscription, we receive subscription status, product identifier, price, currency, trial status, and transaction identifiers from Apple, Google, or our subscription management provider. We do not receive or store your full payment card details; payment is processed by Apple, Google, or our payment processor.
• Advertising and Attribution Data: If you reach the App or our web pages by tapping one of our advertisements, we record the click and limited technical information about it: the advertising platform's click identifier (for example Meta's fbclid, TikTok's ttclid, or Google's gclid), the ad and campaign it came from, your IP address, user agent, country, device model, operating system version, and screen, language, and time zone settings. On Android we also read the Google Play install referrer. We use this to tell which advertisement led to an install or a trial (see Section 6).
• Push Notification Data: If you grant permission, we store a push notification token to deliver notifications such as the Daily Hukamnama and account or offer updates.

2. Religious Information (Sensitive Data)

Simran is a Sikh spiritual app. Your use of the App, and the content of your spiritual queries, may reveal or suggest your religious beliefs. In some jurisdictions (including the EEA, the United Kingdom, and several U.S. states) this is treated as sensitive or special category data.

• We process this information only to provide the App's features to you: generating responses to your queries, showing you relevant scripture, and personalizing your experience.
• We do not use it for advertising, do not sell it, and do not share it except with the service providers needed to operate the App (Section 7).
• Where the law requires it, we ask for your explicit consent before processing spiritual queries, and you may withdraw consent at any time by contacting us or deleting your account.
• Content you share in Sangat is, by its nature, about your faith, and it is shown to other users of the App. For that reason we ask for your explicit agreement before you first take part in Sangat. You may withdraw it at any time by deleting the content you have shared, by leaving Sangat, or by deleting your account.

3. How the AI Features Work

• Spiritual queries. Your spiritual queries are sent to a third-party AI provider, Google (Gemini API), to generate responses. We use Google's paid API tier, under which Google does not use your queries to train its models.
• Sangat content. Before it is shown to others, content you share in Sangat, including your display name and profile photo, is automatically reviewed against our Sangat rules, and text is automatically translated between English and Punjabi so that members can read one another. This review and translation is performed by Google (Gemini API) and, if Google is unavailable, by OpenAI. Content is sent to these providers without your name, account identifiers, or device identifiers. Under our agreements with them, neither provider uses this content to train its models.
• We do not use your queries or your Sangat content to train AI models either. They are processed to provide the features described above, nothing more.

3A. Sangat Community Features

Sangat is a community space inside the App. When you take part:

• What others can see. The content you share, your display name, your profile photo, and the number of likes an item has received are visible to every user of the App, including guests who have not created an account. Sangat is not indexed by search engines and is not visible outside the App.
• Sharing without your name. Where the App offers it, you can share an item as "Member of the sangat." In that case the item is shown without your name, photo, or profile, and other users cannot navigate from it to you. We still know it is yours, so that you can manage and delete it.
• Your Sangat history. Everything you have shared stays in your account, visible to you in Settings, until you delete it.
• Reports and blocks. Other users can report content and can block you, and you can do the same. Reports are confidential: we do not tell a user who reported them. Blocking is private: the blocked user is not notified.
• Community rules. Taking part is subject to the Sangat rules at simranapp.com/sangat-rules, which form part of our Terms of Service.

4. How We Use Your Information

We do not use spiritual queries, religious information, or Sangat content for analytics profiling, advertising, or marketing.

5. Marketing Communications

If you provide your email address, we may send you marketing emails (for example, feature announcements or subscription offers) through our email provider. Every marketing email contains an unsubscribe link, and unsubscribing never affects your access to the App. Service emails (receipts, security, policy changes) are sent regardless of marketing preferences.

6. Advertising, Analytics, and Tracking

We advertise Simran on third-party platforms (currently Meta, TikTok, and Google, including YouTube). We work with them in the following ways.

• On your device. The App includes software development kits from Meta, TikTok, and Google (Firebase) that may report events such as app install, app open, or trial start to that platform. On iOS, the device advertising identifier is used only if you allow tracking through Apple's App Tracking Transparency prompt. On Android, you can reset or delete your advertising ID in system settings.
• Our ad links. We operate go.simranapp.com, a redirect and measurement domain used in our advertisements. When you tap one of our ads, it records the advertising and attribution data described in Section 1B, then sends you on to the app store or to our web pages. Some advertisements first open a page on simranapp.com, which passes the ad's click identifier on to go.simranapp.com when you tap a store button.
• From our servers. When an install or trial start can be linked to an advertisement, we send the platform that showed it a limited record of that event together with matching keys, so the event can be attributed to the ad you tapped. Those keys are: the click identifier from that ad, your IP address and user agent, an internal identifier for your device or account, and, where we hold them, an irreversibly hashed (one-way, non-reversible) form of your email address, name, city, region, and postal code. We do not send the plain-text values.
• Hashed email addresses. We may also send Google and TikTok an irreversibly hashed form of email addresses we hold, which they match against their own accounts to improve how our advertising is delivered and measured. A platform does not learn an email address it cannot match. We never include information about your religious practice, your reading, or your spiritual queries.
• What the ATT prompt does and does not control. Declining the iOS tracking prompt prevents use of the device advertising identifier. It does not by itself stop the server-side measurement or hashed email matching described above, which do not rely on that identifier. If you want to be excluded from them, email us (Section 12) and we will suppress your account from both.
• Analytics: We use PostHog and Google Analytics for Firebase for product analytics. Analytics data is used to understand and improve the App and to measure our advertising, not to target advertising based on what you read or ask in the App.
• No advertising use of religious data. We never send advertising platforms your spiritual queries, your conversation content, your Sangat content, your in-app reading, or any inference about your beliefs, and we do not target advertising based on them.
• Do Not Track: Some browsers offer a "Do Not Track" signal. Neither the App nor our web pages respond to browser DNT signals; we honor the device-level controls and the opt-out described above instead.

7. Information Sharing and Disclosure

We do not sell your personal information. We share information only as follows:

• Service Providers, who process data on our behalf under contractual confidentiality and security obligations:
  • Google (Gemini API): AI response generation; automated review and translation of Sangat content
  • OpenAI: automated review and translation of Sangat content when Google is unavailable
  • Supabase: account authentication and database hosting, including your practice history and Sangat content
  • Cloudflare: hosting, infrastructure, storage of Sangat profile photos, and storage of advertising measurement records
  • PostHog: product analytics
  • Superwall: paywall, subscription management, and web checkout
  • Stripe: payment processing for purchases made through our web checkout
  • Loops: email delivery
  • Apple / Google: payment processing and app distribution
• Other Users: Sangat content and Sangat profile information are disclosed to other users of the App as described in Section 3A. This is the purpose of the feature, not a sale or sharing for advertising.
• Advertising partners (Meta, TikTok, Google): as described in Section 6. Under California law this may be considered "sharing" for cross-context behavioral advertising; you have the right to opt out (Section 12).
• Legal Requirements: if required by law, or in the good faith belief that disclosure is necessary to comply with a legal obligation, protect our rights or property, or protect the safety of users or the public.
• Business Transfers: in a merger, acquisition, or asset sale, personal information may be transferred as a business asset; this Policy would continue to apply to it.

8. Data Retention

• Account information: retained while your account is active, deleted within 30 days of account deletion.
• Spiritual queries: retained only as needed to provide the service (such as your conversation history in the App) and deleted with your account.
• Sangat content and profile: retained until you delete the item or your account. Deleting your account removes your Sangat profile, photo, content, likes, reports, and blocks. Copies may persist in backups for up to 30 days.
• Reports you make about others' content: retained for up to 12 months, or until the reported content or your account is deleted, whichever is sooner.
• Usage and device data: retained in analytics for up to 24 months, then deleted or aggregated.
• Purchase records: retained as required for tax, accounting, and legal purposes.
• Marketing data: retained until you unsubscribe or your account is deleted.
• Advertising measurement data: click and attribution records are retained for up to 13 months, then deleted or aggregated.

9. International Data Transfers

We are based in the United States and process data on servers in the United States. If you use the App from outside the U.S. (including the EEA, the United Kingdom, Canada, or India), your information is transferred to the U.S. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses with our service providers.

10. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, including encryption in transit. No method of transmission or storage is 100% secure.

11. Children's Privacy

The App is not intended for children under 13, and we do not knowingly collect personal information from children under 13. Sangat, the App's community space, is not available to anyone under 13, or under 16 in the European Economic Area and the United Kingdom, and we do not knowingly allow younger users to take part. If you believe a child has provided us personal information or has taken part in Sangat, contact us and we will delete it. In jurisdictions where the age of digital consent is higher than 13, we rely on parental consent as described in our Terms of Service for the rest of the App.

12. Your Privacy Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you and receive a copy (portability).
• Correct inaccurate or incomplete information.
• Delete your personal information. You can delete individual Sangat items at any time in the App, and you can delete your account directly in the App (Settings), which removes your account data as described in Section 8.
• Opt out of marketing emails (unsubscribe link) and of the advertising "sharing" described in Section 6.
• Restrict or object to certain processing, and withdraw consent at any time where processing is based on consent, without affecting prior processing.
• Not be discriminated against for exercising any of these rights.

To exercise any right, email [email protected] or use the in-app account controls. We verify requests using your account email and respond within the timeframe required by applicable law (generally 30 to 45 days). An authorized agent may submit a request on your behalf where the law allows.

EEA / UK residents: you also have the right to lodge a complaint with your local supervisory authority (in the UK, the ICO).

California residents: the rights above include the CCPA/CPRA rights to know, delete, correct, and opt out of sharing. We do not sell personal information and have not done so in the preceding 12 months; we may "share" limited data for advertising measurement as described in Section 6, and you may opt out by emailing us. We do not use or disclose sensitive personal information for purposes requiring a "Limit Use" right. We do not knowingly sell or share personal information of consumers under 16.

Canadian residents: we process personal information with your consent or as otherwise permitted by PIPEDA. You may withdraw consent, subject to legal or contractual restrictions.

India residents: we process personal data in accordance with the Digital Personal Data Protection Act, 2023. You may exercise the rights above, and may nominate another individual to exercise them on your behalf as provided by law.

13. Changes to This Privacy Policy

We may update this Policy from time to time. We will post the updated Policy in the App and update the Effective Date above. For material changes, we will provide additional notice (such as an in-app notice or email) and, where the law requires, seek your consent.

14. Contact Us

FocusPledge LLC
20289 Stevens Creek Blvd #1261
Cupertino, CA 95014, United States
Email: [email protected]