Privacy Policy

Version: 0.1 (draft for advocate review)

In short

• POLYMATH COGNITIVE, Jaipur, India, decides how your personal data is used in Privé. We are the "Data Fiduciary" under India's DPDP Act, and the "controller" under GDPR.
• We collect what we need to run accounts, payments, chat, calls and lives, to keep the App safe, and to meet the law. Creators also give payout KYC data (PAN, Aadhaar and bank details). We store PAN and bank details encrypted. Of the Aadhaar number we store only the last four digits.
• We do not sell your personal data, and we do not use it for third-party advertising.
• Service providers process data for us. They include Razorpay, Agora, Google Firebase, Apple, Amazon Web Services (India), Sentry, our email provider and GIPHY.
• Authorised staff may read private messages to handle reports, fraud and legal requests, and only after recording a reason. Every such access is logged.
• Privé is for adults only (18+). We do not knowingly process children's data.
• You can access, correct and erase your data, and withdraw consent. Delete your account in the App, or contact our Grievance Officer.

1. Who we are

1.1 Operator. Privé is operated by POLYMATH COGNITIVE, a partnership firm constituted under the Indian Partnership Act, 1932, with its registered office at S-300-H, Scheme 4-S, Macheda, Jaipur, Rajasthan, India. Sanstha Aadhaar Number (Rajasthan): 8005220006002779.

1.2 Contacts.

• Privacy: hi@prive.buzz
• Grievance Officer (also our contact for data-protection grievances under the DPDP Act): hi@prive.buzz (name and phone to be published)

1.3 Terms used. "Personal data" means any data about an identified or identifiable person. Other defined terms are as in the Terms of Service.

2. Scope

This Policy covers the Privé mobile apps, Privé's public share pages at polymathcognitive.com, and our related services. It does not cover third-party services you reach through links. Under the DPDP Act, this Policy is our notice to you.

3. Data we collect, why, and for how long

How long we keep data. We do not delete data on a timetable. We keep it while your account exists, and as long as legal, tax and safety reasons require, and we remove it when you delete your account, as section 9 sets out.

We do not collect your contacts, precise location or biometric data. We do not use your data for automated decisions that have legal or similarly significant effects on you.

4. Where data comes from

• Mostly from you.
• From other Users: for example, messages they send you, and reports about you.
• From Razorpay: payment status.
• From your device: device ID, platform, push tokens.

5. How we share data

We share personal data only in these ways:

1. With other Users, as the App works. Your public profile is visible to everyone. Fans see what Creators publish. Creators see the name, profile and activity of Fans who follow, message, call or pay them.
2. With service providers (processors) who act on our instructions under contract:

3. With authorities, when the law requires it, including under the IT Act and IT Rules: for example, information requested by an authorised government agency (we respond within 72 hours of a lawful order), court orders, and reports of child sexual abuse material.
4. To protect rights and safety: for example, in fraud investigations or legal claims.
5. In a business transfer (merger, acquisition or sale of the App), subject to this Policy.

We do not sell personal data. We do not "share" it for cross-context behavioural advertising.

6. Staff access to private communications

6.1 Who and why. Authorised staff can view private conversations, chat media and call records, but only to:

• investigate a report, fraud or a payment dispute;
• respond to a legal request; or
• enforce our Terms.

6.2 Logging and limits.

• Staff can open a private conversation's messages only after typing the reason for doing so (and, where there is one, the report it concerns). The App does not show the messages without a reason.
• Each access is logged with the staff member, the conversation, the reason and the time.
• Lists of conversations show who talked to whom and when, not what was said.
• Staff can see a Creator's full bank details only by recording a reason. That access is also logged.
• Admin accounts use two-factor authentication.

7. Security

7.1 Measures we take.

• Encrypted connections.
• Passwords hashed with bcrypt.
• KYC and bank numbers encrypted with AES-256-GCM, with keys held outside the database.
• Short-lived signed links for media.
• Private storage.
• Session tokens that can be revoked.
• Rate limits.
• Audit logs.
• Data hosted in India (AWS Mumbai).

7.2 Limits. No system is perfectly secure.

7.3 Breaches. If a personal-data breach occurs, we will notify the Data Protection Board of India and affected people as the DPDP Act and its rules require, and CERT-In within 6 hours where its directions apply. Outside India, we will notify the relevant regulator and affected people as GDPR and other applicable laws require.

7.4 Screen capture. The App blocks screenshots and screen recording where the phone allows it. This cannot prevent photos taken with another device.

8. Your rights

8.1 Everyone. You can:

• access a summary of your personal data and how we use it;
• correct or update it (most fields are in Edit profile);
• erase it, by deleting your account or asking us;
• withdraw consent (see section 8.4);
• nominate someone to exercise your rights if you die or become incapacitated (a DPDP right);
• complain to us, and then to the regulator.

8.2 How to ask.

• Delete your account in the App under Settings, or at an address to be published.
• For anything else, email hi@prive.buzz or the Grievance Officer.
• We may need to verify your identity.
• We answer within the time the law sets: under the DPDP rules, within the period they set, and under GDPR one month.
• A copy of your data is provided on request. There is no self-service export at present.

8.3 Consent managers. Where consent managers registered with the Data Protection Board are available, you may also give, manage and withdraw consent through one.

8.4 Withdrawing consent. Withdrawing consent stops further processing based on it. It does not affect processing that already took place, or processing on another legal basis, such as keeping payment records required by law. Because the App cannot run without the core data, withdrawing consent for it means deleting your account.

8.5 India. If you are not satisfied with our answer, you may complain to the Data Protection Board of India.

9. Account deletion: what is erased and what is kept

• your name (replaced with "Deleted user");
• email, phone, password and profile photo;
• your Creator cover, bio and prices;
• all payout and identity numbers;
• your sessions, push tokens and one-time codes;
• your notifications, follows, likes, views and live comments;
• the files you sent in chat (removed from storage);
• a Creator's unsold posts and images.

We also remove your name from other people's notifications.

• a de-identified account record, so payments and history stay consistent;
• the Coin ledger and payment and payout records (payouts keep only the last four digits of the account, the amount and the bank reference);
• legal acceptances;
• reports, blocks and moderation records;
• the text of messages you sent, which the other person keeps, shown under "Deleted user";
• photos a Fan paid to unlock;
• posts Fans bought;
• a one-way hash of your email, made with a secret key so that it cannot be matched against a list of addresses (and a one-way hash of a Creator's handle), so that a later sign-up with the same email can be linked to the deleted account's history for fraud and safety, and a handle cannot be reused.

None of these is deleted after a set period. The Coin ledger and payment and payout records are kept for at least 8 years, as Indian tax and accounting law requires; the rest are kept for legal, safety and fraud reasons.

9.3 Other effects. Any Coin balance is forfeited (see the Coins, Payments and Refunds Policy). We send a confirmation email to your old address and then stop storing it.

9.4 Unverified sign-ups. Sign-ups whose email was never confirmed are released after 24 hours and deleted when the email or handle is next claimed.

10. Children

Privé is for adults 18 and over only. We do not knowingly collect personal data of anyone under 18. We do not track or target children, and we do not process their data under the DPDP Act's provisions for parental consent. If we learn that a User is under 18, we suspend the account and delete its data, except what we must keep to report abuse or meet the law. Report a suspected minor to the Grievance Officer. See the Child Safety Policy.

11. Cookies and the website

11.1 Public share pages. These pages (profiles, posts, lives) do not set cookies and use no analytics or advertising trackers. Our servers log IP addresses for security, as described above.

11.2 Account deletion page. The page for deleting your account on the web (/delete-account) sets one strictly necessary cookie. It ties each form you submit to your browser, so that nobody else can submit it for you. It is not used for anything else.

11.3 Admin panel. The staff-only admin panel uses a strictly necessary session cookie.

12. International transfers

Our main servers are in India, in the AWS Mumbai region. Some providers, such as Agora, Sentry, Google, Apple, GIPHY and our email provider, may process data in other countries, including the United States. We transfer data out of India only to countries the Indian Government has not restricted under section 16 of the DPDP Act.

For users in the EU and UK, transfers out of those regions rely on adequacy decisions or the European Commission's Standard Contractual Clauses (with the UK Addendum). Copies are available on request.

13. Users in the EU, EEA and UK (GDPR / UK GDPR)

13.1 Controller and representative. POLYMATH COGNITIVE is the controller.

13.2 Legal bases are shown in the table in section 3:

• contract, to provide the service;
• legitimate interests, for security, fraud prevention and improving onboarding, which we have balanced against your rights;
• legal obligation;
• consent, where we ask for it.

13.3 Your rights. You have the rights of access, rectification, erasure, restriction, portability and objection, including the right to object to processing based on legitimate interests. You also have the right to withdraw consent at any time.

13.4 Complaints. You may complain to your local supervisory authority, or in the UK to the ICO.

14. Users in California (CCPA / CPRA)

14.1 Categories of personal information. In the last 12 months we collected:

• identifiers (name, email, device ID, IP);
• customer records (payment records);
• commercial information (Coin purchases and spending);
• internet activity (onboarding events, logs);
• audio and visual information (Content you upload);
• sensitive personal information (account log-in; for Creators, government IDs and financial account details).

We use these for the purposes in section 3. We disclose them to the service providers in section 5 for business purposes.

14.2 No sale or sharing. We do not sell or share personal information, as those terms are defined. We have not done so in the last 12 months. We use sensitive personal information only for purposes permitted under the CPRA regulations, so no "limit" link is needed.

14.3 Your rights.

• You have the right to know, to delete, to correct and to non-discrimination.
• An authorised agent may make a request for you.
• We will verify requests using your account email.

15. Changes

We will notify you in the App or by email before a material change takes effect. The "Last updated" date shows the latest version.

16. Contact and grievances

• Grievance Officer: hi@prive.buzz (name and phone to be published)
• Privacy: hi@prive.buzz
• Post: POLYMATH COGNITIVE, S-300-H, Scheme 4-S, Macheda, Jaipur, Rajasthan, India

See the Grievance Redressal Policy for timelines and escalation.