Privacy Policy

Last updated: September 2026

1. Controller

BITS Blackrock IT Solutions LLC (operator of the Kabutschi learning platform), Alexandria / Giza, Arab Republic of Egypt · Contact for all inquiries: support@kabutschi.de

2. What data we collect

• Parent account: first and last name and email address (for Firebase Authentication and to match payments).
• Child profile: the child's first name, grade level, school and curriculum (Thuringia or Saxony); a freely chosen username and an encrypted password/PIN for the child login; learning progress (correct/incorrect statistics per subject, topic and day, study time) and reading progress in the Kabutschi library (book identifier, page, progress and time).
• Parent settings: class-test dates entered by parents, up to three book suggestions for the child, and an optional monthly pocket-money budget stored separately for each child with EGP, USD, or EUR as the selected reward currency. No automatic currency conversion takes place.
• Payment data: card payments are processed by the payment provider Kashier. The full card number and card security code never reach our servers. If a parent expressly enables auto-renew, Kashier provides us with a reusable payment token and agreement identifier. These credentials are stored server-side in encrypted form. We also store the subscription status, plan, next charge, amount, time, transaction reference, and masked card details only. If a confirmed payment arrives only after account deletion has begun, the refund/recovery record contains only the transaction reference, order identifier, amount, currency, and a one-way hash of the technical account ID.
• Technical data: Firebase stores an anonymous device token at login for device pairing and the time the parent or child area was last used.
• Registration source: after successful account creation, we store on the parent account the first campaign information supplied (source, medium, campaign, ad set, ad and placement), the referrer host, and the landing-page path. This lets us understand which marketing activity led to a registration.
• Support requests: when a parent submits an issue or feature request in the Support Center, we store the parent account's email address, title, description, processing status and time. Issue reports additionally include only the page path and a coarse indication of browser, operating system and device type, not the complete browser identifier.
• Optional AI learning companion: only after a parent explicitly enables it, we process the identifier of the current learning topic, the selected help action or a voluntarily entered topic question, the generated explanation, pseudonymous technical identifiers, and token, cost, status, and timing data. The child's name, parent email address, school, payment data, and full child profile are not sent to the AI model.
• Voluntary day-7 survey: if a parent takes part, we store the selected survey language, structured answers, optional written feedback, submission time, completion duration, the survey version selected server-side from aggregated learning activity, the number of active learning days and answered exercises at submission, and the technical identifier of an associated child profile. The survey does not ask for the child's name. Please do not enter names, health data or other sensitive information in the free-text field.
• Feedback credit and referral program: we store the status of the one-time survey credit, referral codes and their redemption, the technical link between the referring and new parent accounts, the first confirmed paid order, and the amount, source, validity, reservation and redemption of promotional credit. No additional card data is collected for these purposes.
• Email preferences: we store the preferred language and, separately, whether a parent voluntarily wants to receive product news and learning tips or up to four setup and trial reminders during the first 15 days.

3. Purpose of processing

• Providing the learning platform and syncing learning progress across devices.
• Handling the subscription, automatic activation after card payment, and, after express activation, recurring monthly or annual charges.
• Parent dashboard: showing the child's learning progress to the legal guardian.
• Showing reading progress across devices and providing voluntary book suggestions from parents to their own child.
• Handling support requests and improving the platform based on voluntary feedback.
• Evaluating the voluntary day-7 survey to improve registration, onboarding, learning content, usability and reliability. The credit depends only on complete submission, not on whether the feedback is positive or negative.
• Providing and protecting the feedback credit and referral program against duplicate redemption or misuse.
• Sending necessary account, service, and outage notices and, only after the respective voluntary activation, product news and learning tips or up to four setup and trial reminders.
• Reach and campaign measurement for marketing Kabutschi.

4. Legal basis

Processing is based on Egypt's Personal Data Protection Law (Law No. 151 of 2020). The legal bases are performance of the contract (providing the service), our legitimate interest in necessary service and outage notices, and consent. The day-7 survey is voluntary. We process voluntarily submitted answers on the basis of the participating legal guardian's consent. Program, credit and billing records are processed to provide the offered benefits and protect against duplicate redemption or misuse. Product news, learning tips, and setup and trial reminders are sent only after the respective voluntary activation. Both choices can be withdrawn separately at any time in the parent dashboard. For minor children, parents/legal guardians give consent by registering and creating the child profile.

5. Third parties and data transfer

• Google Firebase (servers in the USA/EU among others): Authentication, Firestore database. Firebase Privacy.
• Vercel (USA): hosting. Vercel Privacy.
• Kashier (Egypt): payment processing, card tokenization, and recurring credit-card charges after express activation. Kashier.
• Resend (USA): delivery of the one-time transactional welcome email, account, service and outage notices, voluntarily requested product information, and voluntarily requested setup and trial reminders. Only the parent account's email address, first and last name, preferred language, and the respective email preference are transmitted. No child data is transmitted. Resend Privacy.
• OpenAI (USA): generation of optional AI explanations that are restricted to the current learning topic. We send only the approved topic pack, the selected help action or topic question, and a hashed pseudonymous safety identifier. Every model request is sent with API storage disabled. The feature has no web search and no access to accounts, files, or payments. Parents can disable it for the family or for an individual child at any time in the parent dashboard. OpenAI Privacy Policy.
• Telegram (Telegram Messenger Inc.): internal operational notifications to the operator when a new account, child profile, or support request is created, plus a daily, fully aggregated operational report. Individual notifications contain no names, email addresses, or message content. They contain only pseudonymous technical identifiers and, for child profiles, the grade level. The daily report contains aggregate metrics plus aggregated source, campaign, ad, placement, and school statistics. It contains no names, contact details, account, child, or ticket identifiers, and no link between a school and an identifiable person.
• MyMemory (translation service, api.mymemory.translated.net): if the optional "Translate" feature is used, only the exercise text in question is sent for translation. No personal data is transferred.
• Google Fonts (Google Ireland/LLC): the "Nunito" font is loaded from Google servers for consistent typography. This technically transmits the browser's IP address to Google (USA). No tracking and no profiling takes place; the font is used solely for display. Google Privacy.
• Meta Pixel and Meta Conversions API (Meta Platforms Ireland Ltd.): on the marketing pages (home page, sign-up, confirmation page and publicly accessible learning-content pages) we use the Meta Pixel for pseudonymous reach and campaign measurement. This transmits usage data (including IP address, page viewed and interactions) to Meta (also to the USA). Once parent data is known during registration, the email address, name and internal account ID may be normalized for manual advanced matching and SHA-256 hashed by the Meta Pixel before transmission. After a successful registration, when a card checkout starts and after a successfully confirmed payment, we additionally transmit server-side conversion events. These contain the event type, amount and currency where relevant, technical browser data for the respective event, existing Meta cookie identifiers, and the parent account's email address, internal account ID, name, and, where present in the parent profile, phone number only in normalized SHA-256 hashed form. Checkout attribution data is stored server-side only until payment confirmation, for no longer than 72 hours, and is then deleted automatically. No child data is transmitted to Meta. The pixel is never used in the learning area (child app), and no advertising profiling of children takes place. You can limit browser-side tracking through browser settings or a tracking/ad blocker and object to campaign measurement at support@kabutschi.de. Legal basis: our legitimate interest in reach and campaign measurement (Egypt's Personal Data Protection Law No. 151/2020). Meta Privacy.

Cross-border transfer occurs only where necessary to operate the service and where the providers offer appropriate safeguards. Beyond the services listed above, we do not share personal data with third parties. Within the learning area we run no advertising; for marketing we use the Meta measurement methods described above.

6. Data storage and deletion

Learning progress data is stored while the account is active. After the account expires, it is retained for up to 90 days and then deleted automatically. After a confirmed request for full account deletion, we remove attributable account and learning data without undue delay; technical processing by integrated providers may take a short time.

On the public marketing pages we also use our own cookieless reach measurement. It records only aggregated page views, anonymous browser sessions, campaign/referrer information, device classes, CTA clicks, scroll milestones, active engagement time, and registration-funnel steps. We store no IP addresses, user or account IDs, form contents, DOM recordings, or individual session histories. The IP address is used only transiently on the server for abuse rate limiting and is not written to the analytics database. Do Not Track and Global Privacy Control are respected. The legal basis is our legitimate interest in improving the clarity and effectiveness of our own marketing pages.

Only after a successful registration is the first-touch source described in section 2 stored as account metadata and shown in the protected admin area. We store no IP address, no complete Meta click or browser ID, and no browsing history for this purpose. If the information is technically unavailable or a privacy signal is detected, it is recorded only as “not captured". Source data is deleted together with the parent account.

Support requests remain available in the protected parent and admin areas for follow-up and are removed when the account is fully deleted. Early deletion can be requested at any time via support@kabutschi.de.

Raw day-7 survey data is stored in identifiable form for no longer than 24 months after submission and is then deleted or permanently anonymized. Anonymous statistics that can no longer be linked to an account or child profile may be retained for long-term product comparisons. Identifiable survey responses are removed earlier when the account is fully deleted.

Referral and credit data is stored while credit is valid, reserved or redeemed and the account continues to exist. When an account is fully deleted, that account's data is removed. Credits already lawfully earned by other parent accounts remain available, but are disconnected from the deleted account wherever technically possible.

Pseudonymized payment-recovery records for late confirmed payments are used only for refund or access review and are deleted automatically after no more than twelve months.

The encrypted Kashier payment token is retained only while auto-renew is set up or a cancellation already requested for the end of the paid period still needs to be completed technically. If the account is fully deleted, we remove the token at Kashier and from our database. The local token is also removed after auto-renew ends.

The email preferences are stored with the parent account. When the account is fully deleted, the corresponding Resend contact is also deleted. Product information and setup and trial reminders can be withdrawn separately at any time in the parent dashboard.

Requests and responses from the optional AI learning companion are deleted after no more than 30 days. Pseudonymous token and cost measurements are deleted after no more than 90 days, and operational AI audit records after no more than 365 days. When an account is fully deleted, attributable AI settings, sessions, credit records, and usage data are removed earlier.

7. Your rights

You have the right to access, rectification, erasure, restriction of processing and the right to withdraw consent. Contact: support@kabutschi.de. You may also file a complaint with the competent Egyptian data protection authority.

8. Cookies and local storage

Kabutschi uses browser localStorage for learning and reading progress. For a linked child profile, reading progress is also synced to Firebase so it is available across devices and visible in the parent area. Our own reach measurement described in §6 sets no cookies and no persistent visitor ID; sessionStorage remembers only temporarily whether the current browser session or page has already been counted. On the marketing pages, the Meta Pixel sets cookies for reach measurement (see §5); the learning area (child app) has no tracking and no advertising cookies. The server-side conversion measurement described in §5 does not itself set additional browser cookies. You can limit browser-side tracking through your browser settings or a tracking/ad blocker. In addition, a technical third-party request loads the display font (Google Fonts, §5).

9. No access to camera or microphone

Kabutschi does not request and does not access the camera or microphone. No photos, video or audio recordings are made. The read-aloud feature ("Vorlesen") uses only your device's speech output (speaker). It does not listen and does not record anything. Likewise, location, contacts and other device sensors are not accessed.

10. Protection of children's data

Kabutschi is intended for children from grade 1 (about 6 years old). The account is created exclusively by parents/legal guardians; they give consent to the processing of their child's data and can withdraw it at any time. From children we collect only what the learning service requires: the first name, grade level, school and curriculum, a username with a PIN, and learning- and reading-progress statistics. We do not collect a child's last name, address, photos or location data. Children have no access to payment data or the parent's email address. No profiling for advertising purposes takes place.