Privacy Policy

Last updated: 30 July 2026

This policy explains what information Spread Labs Ltd ("we", "us", "our"), the company behind the Bolo app, collects when you use Bolo, why we collect it, the legal basis we rely on, and the choices you have. Bolo helps you learn to speak Gujarati.

Spread Labs Ltd is the data controller for the information described here. We are a company registered in England and Wales (company number 13507760), with a registered office at 71-75 Shelton Street, London, Covent Garden, England, WC2H 9JQ. You can reach us about privacy at contact@learnwithbolo.com.

Information we collect

• Account information. When you create an account we collect your name, email address, and a chosen avatar. Sign-in is handled by our authentication provider, Kinde, which processes your email (and, if you choose Google or Apple sign-in, the basic profile they return).
• Learning profile. The preferences you set during onboarding: who you want to speak with (for example grandparents or parents), your family's dialect, and your current proficiency level.
• Progress data. Your learning activity: XP, day streak, hearts, and which lessons you have completed.
• Age confirmation. We ask your date of birth once to confirm you are 13 or older. This check runs on your device, and we do not store your date of birth.
• Usage and analytics data. If you consent, we use PostHog to understand how the app is used (for example which lessons you start and finish, and where people get stuck), using an analytics identifier and in-app events. Analytics is off until you opt in, and our PostHog data is hosted in the EU. See Your choices and consent below.
• Diagnostic and crash data. We use Sentry to record crashes and errors so we can keep the app stable and secure. This can include your IP address, device type and operating system, and technical details of the error.
• Purchase and subscription data. When you subscribe to Bolo Plus, purchases are processed by the Apple App Store or Google Play, and we use RevenueCat to manage subscription status. We receive your subscription state and a purchase identifier, not your full card details, which stay with the app store.
• Advertising data. On the free tier, with your consent, our ad providers use a mobile advertising identifier (such as Apple's IDFA or Google's Advertising ID) and limited device data to select and measure ads. Bolo Plus is ad-free.

Bolo shows ads to free-tier users, and Bolo Plus is ad-free. We use AppLovin (MAX) as our mediation provider, which auctions and serves ads from Google (AdMob) and other advertising networks. Personalised ads run only with your consent; if you do not consent, you may still see non-personalised ads. See Your choices and consent below.

How we use your data and our legal basis

Under UK GDPR we must have a lawful basis for each use of your data. We rely on:

• To create and secure your account, sign you in, save your progress, and tailor lessons to your preferences. Basis: performance of our contract with you.
• To keep the app stable and secure through crash and error reporting (Sentry). Basis: our legitimate interests in a reliable, secure service.
• To confirm you are old enough to use Bolo. Basis: our legitimate interest in meeting our age policy and legal obligations.
• For product analytics (PostHog) and personalised advertising. Basis: your consent, which you can withdraw at any time.
• To take payment and manage a Bolo Plus subscription. Basis: performance of our contract with you.

We do not sell your personal information, and we do not use automated decision-making that produces legal or similarly significant effects about you.

Your choices and consent

Product analytics and any future advertising run only if you consent, and you can withdraw consent at any time in the app's settings or by contacting us. Withdrawing consent does not affect processing that already took place, and it does not switch off the account, progress, and security processing we need to run the service.

Who we share it with

We share data only with providers that help us run Bolo, under agreements that limit their use of it:

• Kinde, for authentication and sign-in.
• Neon, for database hosting.
• Vercel, for backend and website hosting.
• Sentry, for crash and error reporting.
• PostHog, for product analytics (only with your consent; EU-hosted).
• RevenueCat and the Apple App Store or Google Play, for Bolo Plus subscription billing and management.
• AppLovin (MAX), Google (AdMob), and other mediated ad networks, for advertising to free-tier users (personalised ads only with your consent).

We may also disclose information where the law requires it, or to protect our rights, users, or the security of the service.

International transfers

Some of our providers process data outside the United Kingdom, including in the United States. Where they do, we rely on appropriate safeguards to protect it, such as the UK International Data Transfer Agreement or Addendum and the EU Standard Contractual Clauses in each provider's data processing agreement. You can ask us for more detail using the contact below.

Data retention and deletion

We keep your account and progress data until you delete your account. You can delete it at any time in the app under Settings → Delete account, or request deletion at learnwithbolo.com/delete-account. Deleting your account permanently removes your profile, learning preferences, and progress, and removes your sign-in identity. After deletion we remove your data from live systems promptly and purge it from encrypted backups within 30 days. Diagnostic and crash data is kept for up to 90 days, and analytics data for up to 12 months, after which each is deleted or aggregated.

Your rights

Depending on where you live (for example under UK GDPR, EU GDPR, or the CCPA), you may have the right to access, correct, export, delete, or restrict our use of your personal data, to object to certain processing, and to withdraw consent where we rely on it. To exercise any of these, contact us at the address below, and we will respond within one month.

If you are in the UK and think we have handled your data wrongly, you can complain to the Information Commissioner's Office (ico.org.uk). If you are in the EEA, you can complain to your local data protection authority. We would appreciate the chance to help first.

Children

Bolo is intended for people aged 13 and over. It is not directed to children under 13, and we do not knowingly collect personal information from them. If you believe a child under 13 has created an account, contact us and we will delete it.

Our website

The learnwithbolo.com website does not set advertising or analytics cookies. Fonts are served from our own domain rather than a third party.

Security

Data is encrypted in transit and stored with reputable providers. No system is perfectly secure, but we take reasonable measures to protect your information.

Changes

We may update this policy from time to time. We will change the date above and, for significant changes, notify you in the app.

Contact

Spread Labs Ltd, 71-75 Shelton Street, London, Covent Garden, England, WC2H 9JQ. Questions or requests: contact@learnwithbolo.com.