Privacy Policy

Last updated: May 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: email address (for Firebase Authentication and to match the InstaPay payment).
• Child profile: username (freely chosen, no real name required), encrypted password/PIN, learning progress (correct/incorrect statistics per subject and day).
• Payment data: InstaPay payments are processed outside Kabutschi. We store only the subscription status and, where applicable, a note for manual activation — no bank or account details.
• Technical data: Firebase stores an anonymous device token at login for device pairing.

3. Purpose of processing

• Providing the learning platform and syncing learning progress across devices.
• Handling the subscription (manual activation after InstaPay payment).
• Parent dashboard: showing the child's learning progress to the legal guardian.

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) and consent. 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.

Cross-border transfer occurs only where necessary to operate the service and where the providers offer appropriate safeguards. We do not share personal data with any other third parties and we run no advertising.

6. Data storage and deletion

Learning progress data is stored while the account is active. After cancellation, data is kept for 90 days and then deleted. On request, we delete data immediately.

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 solely to store learning progress locally on your device. No tracking cookies are set. There is no advertising and no third-party tracking.

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. We collect only the minimum from children: a freely chosen username (no real name needed), a PIN, and learning-progress statistics. Children have no access to payment data or the parent's email address. No profiling for advertising purposes takes place.