Effective Date: [DD Month YYYY] Last Updated: [DD Month YYYY]
[Legal Entity Name] ("we", "us", "our", "Company") operates [App/Website Name] (the "Platform"). This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and the choices and rights available to you. This Policy is designed to comply with the Digital Personal Data Protection Act, 2023 ("DPDP Act") and other applicable Indian data protection law.
By using the Platform, you consent to the data practices described in this Policy. If you do not agree, please do not use the Platform.
| Category | Examples | Purpose |
|---|---|---|
| Identity & Contact Data | Phone number, name, email (if via Google Sign-In) | Account creation, OTP/identity verification, communication |
| Verification Data | Truecaller-provided profile data (where applicable), verification status | Fraud prevention, one-account-per-user enforcement |
| Location Data | GPS coordinates (with permission) or telecom-circle-derived approximate location | Showing region-eligible offers, fraud prevention |
| Device & Usage Data | Device ID/fingerprint, IP address, app-usage logs, ad-interaction logs, session data | Fraud detection, service functionality, analytics |
| Financial Data (Payout) | UPI ID / bank account details you provide for withdrawal | Processing withdrawals via our payment gateway partners |
| AI Chat Data | Messages you send to the AI Companion Chat feature | Providing the chat feature (processed by third-party AI providers — see Section 3) |
| Transaction Data | Points/Rupees earned, spent, converted, withdrawn; history logs | Wallet functionality, support, fraud investigation |
| Cookies/Tracking Data (website) | Analytics and advertising cookies/identifiers | Website functionality, ad delivery, analytics |
We do not knowingly collect government ID numbers (e.g., Aadhaar, PAN) as part of standard onboarding.
We use the data described above to: operate and improve the Platform; verify your identity and prevent fraud, duplicate accounts, and abuse; determine region-eligible offers; process withdrawals; provide the AI Companion Chat feature; send transactional and permitted promotional notifications; comply with legal obligations; and respond to grievances and support requests.
We do not sell your personal data to third parties for their independent marketing purposes.
To operate the Platform, certain data is necessarily shared with the following categories of third parties. Each such third party processes data under its own privacy policy, which we encourage you to review.
a) Advertising Networks (Passive/Layer A): Google AdSense and mediation partners including Adsterra, HilltopAds, PropellerAds, RichAds, Adcash, Clickadu, InMobi, Media.net (and, where applicable, MGID) — for delivering and measuring non-cash-reward advertising.
b) Cash-Earning & Offerwall Networks (Layer B): Adscend Media, AppLixir (where applicable), CPAGrip, AdGate Media (Prodege), CPAlead, Lootably, CPX Research, BitLabs, PubScale, AdGem, TimeWall, Kiwi Wall, Wannads, Torox, MyLead, OGAds, AdWork Media, RevU, ayeT-Studios, and Notik — for delivering rewarded video, offers, and surveys, and confirming completion for reward purposes.
c) AI Chat Infrastructure Providers: Groq and Mistral AI — your AI Companion Chat messages are transmitted to these providers for processing. You will always see a dedicated consent screen before this feature is activated. See Section 8 for further AI-chat-specific detail.
d) Payment/Payout Partners: Razorpay Payouts, Cashfree Payouts, or similar licensed payment gateway providers — to process your UPI withdrawal requests. We do not directly hold your funds; these are regulated intermediaries.
e) BNPL/Affiliate Partners: Where you choose to use a "Buy Now Pay Later"/EMI redirect or an affiliate shopping link feature, the relevant third party (e.g., Simpl, LazyPay, or an affiliate network such as EarnKaro/Cuelinks/Admitad-type providers) will process data you provide directly to them as part of that separate transaction.
f) Identity Verification Providers: Truecaller (for zero-tap/missed-call verification) and, where used as a fallback, an SMS-OTP provider.
g) Legal & Safety: We may disclose data where required by law, court order, or governmental request, or to protect the rights, safety, or property of the Company, its users, or the public.
We do not permit these third parties to use data shared with them for purposes unrelated to providing their respective services to us, except as disclosed in their own privacy policies (which are outside our control).
We retain your personal data for as long as your account is active and for a reasonable period thereafter as necessary to comply with legal, accounting, fraud-prevention, and grievance-redressal obligations. Certain third-party AI providers (e.g., Mistral) may retain chat inputs/outputs for a limited period (e.g., up to 30 rolling days) for abuse-monitoring purposes, independent of our own retention.
You may request deletion of your account and associated personal data by contacting us at [privacy@yourdomain.com]. We will process such requests in accordance with applicable law, subject to any data we are legally required to retain (e.g., transaction records for financial/audit compliance).
Our website uses cookies and similar tracking technologies for core functionality, analytics, and advertising/ad-measurement purposes, including those set by the advertising and mediation partners listed in Section 3(a)–(b). You can control cookie preferences through your browser settings; disabling cookies may affect certain Platform features.
Subject to applicable law (including the DPDP Act, 2023), you have the right to: (a) access the personal data we hold about you; (b) request correction of inaccurate data; (c) request deletion of your data/account; (d) withdraw consent for specific processing (e.g., AI Companion Chat, location access) at any time, without affecting the lawfulness of processing carried out before withdrawal; and (e) file a grievance with our Grievance Officer (Section 9) or, where applicable, the relevant Data Protection Board.
Withdrawing consent for a specific feature (e.g., location access, AI Chat) may limit your ability to use that feature but will not affect your ability to use the rest of the Platform.
The Platform is intended solely for individuals aged 18 and above. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor, we will take reasonable steps to delete such data promptly. Our age-eligibility approach is described in our Terms & Conditions, Section 1.
8.1 Before first use of the AI Companion Chat, you are shown a dedicated consent screen, which must be actively accepted (not hidden or pre-checked) before the feature is enabled.
8.2 Messages you send are transmitted to our AI infrastructure providers (Groq and/or Mistral, depending on configuration) for the sole purpose of generating a response. We ask you not to share sensitive personal information, financial details, or passwords in chat.
8.3 A record of your consent (including the version of the consent wording and timestamp) is logged so that you can be re-prompted for consent if the wording materially changes.
8.4 Where our provider's own documentation is ambiguous about training-data usage, we configure available privacy/opt-out settings (e.g., disabling "improvement data" sharing) to the extent offered by the provider, and encourage you to review that provider's own privacy terms for full detail.
We implement reasonable technical and organisational measures — including encryption in transit, access controls, and server-side (not client-side) authorization for reward credits — designed to protect your data against unauthorized access, alteration, or loss. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
In accordance with the DPDP Act, 2023 and other applicable law, you may contact our designated Grievance Officer / Data Protection Contact for any privacy-related query, complaint, or rights request:
Grievance Officer: [Name] Email: [privacy@yourdomain.com] Address: [Registered Address]
We will endeavour to respond to and, where applicable, resolve your request within the timelines prescribed under applicable law.
We may update this Privacy Policy from time to time. Material changes will be notified through the Platform. The "Last Updated" date at the top of this page indicates when this Policy was last revised. Continued use of the Platform after changes take effect constitutes acceptance of the revised Policy.
For any privacy-related questions, contact us at [privacy@yourdomain.com].
This document is a template drafted for [App/Website Name] based on the product's confirmed feature set as of [Date]. It should be reviewed by a qualified Indian lawyer before publication, particularly to confirm final Grievance Officer appointment requirements, exact data-retention periods, and any state- or sector-specific obligations.