// LEGAL_DOCUMENTATION

Privacy & Data Usage Protocol (P-2026-A)

Our Commitment: Simulpus operates as a Data Fiduciary under the Digital Personal Data Protection (DPDP) Act, 2023. We are headquartered in Telangana, India, and all student data is stored and processed within India.

The Honest Version: We track your work to help you succeed, not to profit from your profile. Every keystroke, error, and hesitation becomes fuel for personalized feedback—not ad targeting. Your data builds your career and improves our platform—permanently.

LAST_UPDATED: DEC_2025

01.The "Flight Recorder" (Why We Monitor You)

A flight recorder isn't for spying on pilots. It's there so when something goes wrong, we can replay exactly what happened and help the pilot understand why.

In Simulpus, every command you run, every mistake you make, every moment you hesitate—that's data that helps our AI Mentor give you laser-focused feedback instead of generic platitudes.

Without these logs, we can't grade you fairly. Without knowing where you got stuck, we can't help you unstick. This isn't surveillance. It's the infrastructure of learning by doing.

A. System-Level Telemetry (Virtual Labs)

  • Command Audits: Every keystroke, shell command, and script execution. Why? So we can tell you exactly where your code went wrong.
  • Error Logs: System crash reports, syntax errors, failed API calls. This is how the AI Mentor knows you're stuck before you even ask.
  • Response Latency: How fast you identify and resolve critical incidents. Speed is a skill in operations.
  • Lab Environment State: Snapshots of your system at key checkpoints to replay your work step-by-step.

B. Instrument-Level Telemetry (Hybrid Tracks)

  • Movement Metrics: Gyroscopic data, hand stability, and grip pressure for precision tasks.
  • Usage Patterns: Active operating time vs. idle time.
  • Precision Data: Deviation from ideal tool positioning.
  • Device Health Data: Battery levels, connectivity, component wear.

C. Interaction Data

  • AI Mentor Conversations: Transcripts of your technical discussions to improve explanations.
  • Performance Score: Measures independence and problem-solving maturity.
  • Assessment Checkpoints: Quiz answers, projects, and challenges.

02.What We Do With Your Data

We process your data for exactly three purposes. Nothing more.

Purpose 1: Personalized Feedback

Your error logs and measurements let our AI Mentor give specific, contextual feedback. Generic feedback is useless. Specific feedback changes careers.

Purpose 2: Automated Grading

Our AI Judge needs raw telemetry to validate your lab completion fairly. No logs = No grade. No grade = No certificate.

Purpose 3: Training Our Proprietary AI Mentor Forever

Your behavioral data—what you do, how you fail, how you learn—is used to continuously train our AI model.

The Deal: We strip all PII (name, email, etc.) first. We keep only the behavioral patterns.

The Permanence: Once data enters our training system, it becomes part of the model. Like water mixed in the ocean, it cannot be separated or deleted. It is permanent.

You cannot request deletion of this anonymized training data once it's been used.

03.What We DON'T Do

We do not sell, rent, or trade your personal data.
We do not use your data for advertising. Ever.
We do not share detailed telemetry with third parties.
We do not use generic public AI APIs (like OpenAI) for telemetry.
We do not track browsing history or social media.
We do not use marketing cookies or tracking pixels.

04.Data Sovereignty

We built our own AI Mentor. It lives on our private servers. Your data never leaves our infrastructure.

Private Infrastructure

Hosted on secure private servers in India. No public cloud APIs.

Encryption

TLS 1.3 in transit. AES-256 at rest.

Isolation

Each student's lab is network-isolated. Student A cannot see Student B.

Anonymization

PII stripped before AI training. Identity removed, patterns kept.

05.Who Sees Your Data?

ServicePurposeWhat They DON'T See
Payment ProcessorsSubscriptionsLab performance, logs
Cloud ProvidersHostingCode, errors, learning data
InstructorsGradingPasswords, payment info
AI Mentor SystemFeedback & TrainingYour identity (uses Student ID)

06.Your Data Rights (DPDP Act)

Right to Access

Request a report of what personal data we hold. (Excludes anonymized AI training data).

Email: privacy@simulpus.org // Subject: DATA_ACCESS_REQUEST

Right to Correction

Fix wrong phone numbers, names, or details.

Email: privacy@simulpus.org

Right to Erasure ("The Hard Delete")

Deletes account, portfolio, and personal info. Does NOT delete anonymized AI training data.

Email: privacy@simulpus.org // Subject: DELETE_MY_ACCOUNT

07.Data Retention

Data TypeRetentionDeletable?
Personal DataUntil requestedYes
Active Learning DataPERMANENTNo (AI Training)
Portfolio WebsiteWhile activeYes (Permanent Loss)
Payment Records7 YearsNo (Tax Law)

08.Your Portfolio Website

Your Portfolio is YOUR asset. We just host it. It's a public-by-default professional profile.

What's Shown

  • Name & Skills
  • Labs Completed & Certificates
  • Performance Score
  • Public Assessments

What's HIDDEN

  • Email & Phone Number
  • Personal Address
  • AI Mentor Conversations
  • Raw Keystroke Logs

Important: Portfolio deletion is permanent. If you delete it, you lose all verifiable proof of your skills and cannot recover it.

09.Special Cases

Under 18

We require parental consent within 7 days of discovery, or the account is deleted.

Academic Dishonesty

We compare telemetry to detect copying. Dishonesty leads to certificate revocation.

Law Enforcement

We only share data with a valid court order. We do not voluntarily hand over data.

10.Security & Protection

Encryption

  • TLS 1.3 In Transit
  • AES-256 At Rest
  • Hashed Passwords

Access Control

  • Role-Based Access
  • Strict Audit Logging
  • No Support Backdoors

11.Questions & Support

We get it. Privacy matters. We'd rather answer the same question 100 times than have you enroll with doubts.

Consent & Agreement

By enrolling in Simulpus, you explicitly consent to:

  • Collection of telemetry data (Flight Recorder)
  • Use of data for personalized feedback & grading
  • Permanent use of anonymized behavioral data for AI training
  • Sharing data ONLY with essential service providers

Simulpus is owned and operated by Koluvu IQ Private Limited. All data stored in India.