Privacy Policy

Your privacy is very important to Two Special Boys Private Limited ("Company" or "we" or "us" or "our"). The following Privacy Policy explains how we collect, use and safeguard the information you, as a registered user ("user" or "you" ) provide to us through or in association with your use of Buddy Up App, its related features and functions and content as defined in the Terms and Conditions.

The App is a social networking app that connects people with disabilities and their caregivers for friendship. We respect your privacy and we are committed to protect your privacy through the compliance of this Privacy Policy.

We collect, use, and disclose information collected from you via the Platform or any form submitted online on the Platform. We provide you with this Platform to connect with other caregivers of and/or individuals with disabilities who share your interests and understand your experiences in a safe and accessible space.

This Policy applies to the users for the Services offered by us on our Platform. By merely accessing or using our Platform, Services and content, you acknowledge that you have read this Policy and that you understand your rights in relation to your information and how we will collect, use and process it. If you do not agree with this Policy in general or any part of it, you are advised to not use our Services. The purpose of this Policy is to inform you about the type of information we collect and how we use the information. It informs you about our practices to manage, protect and disclose your personal information that you may share with us.

By signing up on the Platform and availing our Services, you confirm that you are above the age of 18 years.

You allow us to use your information in accordance with this Policy and our Terms of Use (“Terms”).

By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of the Platform’s Terms.

If this Platform includes links to other websites, use of any information you provide is governed by the privacy policy of the operator of the page you are visiting or the provider of such products or services.

Our App aims to provide a trusted platform for persons with disabilities. By visiting this App and/or accessing the Content, you agree to be bound by the terms and conditions of this Policy. The Policy of this App explains how personal data and digital personal data is collected, stored, used and shared by us. If you do not agree please do not use or access our App.

By mere use of the App, you expressly consent to our use and disclosure of your personal information in accordance with this Policy.

In furtherance of our efforts to protect your privacy, the Company and this Policy are in compliance with the Digital Personal Data Protection Act, 2023 and the rules thereof (“Data Laws”), and any amendments thereto.

The Company endeavors to ensure that the information that you submit to us remains private and that it is used only for the purposes described below. We aim to provide a safe and secure experience for all of our users. When you create an account on the App you register yourself as a member ("Member") to access certain Services as per the Terms and provide us with personal data and sensitive personal data.

Please read the following statement to learn about our information gathering and dissemination practices.

TYPES OF INFORMATION WE COLLECT

We will process such personal data on the basis that it is necessary to do so to perform the contract you enter with us. We will process personal data on the basis set out below as it is in our legitimate interests to do so following your registration.

We can collect two types of information, 'Submitted Information' and 'Aggregate Information' (collectively, "Data").

(A) Submitted Information - Information you give us and information we collect from you including personal data and sensitive personal data:

Account Information: When you create an account with us and register as a Member, you provide us with data including your username, complete name, date of birth, gender, email address, mobile number and password.
Verification Information: In order to start your journey, you may be asked to provide us with necessary KYC (Know Your Customer) documents for identity verification at any stage. The information we request for verification may include certain personal information such as your name, address, mobile number, email address, parent’s/guardian’s name, and or any other information which we are required to obtain as per our policies and in consonance with legal & regulatory mandates.
Communication Information: This App contains messages, audio files, video chats, voice chats or other message or communication facilities (collectively, "Communication Facilities"). We collect information about you when yu send, receive, or engage with messages and/or use our Communication Facilities in connection with our App.
Other: We may also ask you for information when you report a problem with the App. If you contact us, we may keep a record of that correspondence. We will use telephone recordings or transcripts of communications to check your instructions to us, analyse, assess and improve the Services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us. We store information with respect to your location in order for the App to function smoothly. We may also store details of your visits to the App including, but not limited to, traffic data, location data, weblogs, and other communication data, whether this is required for our billing purposes or otherwise and the resources that you access. Whenever we introduce new features to our App and/or the Services, we may require the collection of new information from you.

(B) Aggregate Information - Information we collect about you and your device:

Each time you use our App and/or access the Services, we may automatically collect the following information: technical information, including the type of device or mobile device or computer or desktop you use, your internet protocol (IP) address(es), a unique device identifier (for example, your device IMEI number, the MAC address of the device's wireless network interface, or mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting. We will ask you to opt-in before we use GPS or other tools (such as Bluetooth) to identify your location. We also collect usage data when you visit our App and access the Services including collecting data when you click on content, ads, perform a search, share articles, or apply for projects. We use log-ins, cookies, device information and internet protocol (IP) addresses to identify you and log your use.

Do not add or submit any Data on the App in any manner whatsoever, if you do not wish the App to collect it.

CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Data, please contact us. If we become aware that we have collected Data from Children without verification of parental consent, we take steps to delete the account and remove that information from our servers.

Any portion of the Data containing personal data relating to minors (below 18 years of age) provided by you shall be deemed to be given by you as the minor's parent or natural/ legal guardian. Such consent is deemed to be provided by your registration with us. We take the privacy of minors very seriously. To make sure Data shared by you are safe; we may (from time to time) integrate new mechanisms and safeguards on our App.

WHAT WE DO WITH THE INFORMATION

Submitted Information:

We use Submitted Information to try to provide and personalize the Services, authorize your access to the Services, to improve the quality of the Content that we provide on the App, to personalize your online experience and to create appropriate matches for you and/or your child/ward. The accurate information provided by you shall enable us to analyze the usage and improve the offerings and experiences provided to you.

We shall use the Data for the following purposes to facilitate the Services:

To provide our services and to help you connect with other users;
To communicate with you and administrate your profile such as create and manage your account, provide you with customer support and complete your transactions;
provide all of App’s offerings and features;
Communicate with you, including without limitation to informing you of the updates to the App, the Terms and this Policy;
Market our Services to you;
Correct errors and problems with the App and its features;
Investigate and/or prevent suspected fraud or other criminal activities.

We shall share selected Data with other persons including other users of the App as a part of the Services in order for them to provide better experience to you. We may further share the Data with a third party who provide services to the Company and are associated with us and we shall not be responsible for the same.

We do not intentionally share your Data with any third-party advertisers or ad networks except for (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission or (iii) your profile information that already visible to any users of the Services.

DISCLOSURE OF INFORMATION

We may disclose your Data to (i) the Company's current and future entertainment and sponsorship, advertisement and development partners and strategic alliances, and (ii) the Company's contractors, vendors, consultants, users, Members and professional advisors to the extent necessary for them to perform services on our behalf, and only under disclosure restrictions.

Furthermore, while it is the Company's policy to respect the privacy of its Members, including information about Member's use of the Services, including the contents of Member’s messages and other content, the Company reserves the right to monitor, edit or disclose any Data about the Member, his/her use of the Services, or such email contents, in the event that we believe that such action is necessary in order to (i) conform to legal requirements or comply with legal process or when required by law or a court order or to investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (ii) to protect and defend the Company's rights; (iii) to enforce any agreement you have or may have with the Company; (iv) to act to protect the interests of our stakeholders and others (v) to investigate and defend the Company, App against any third-party claims or allegations; (vi) to protect the security or integrity of our App; or (vii) to exercise or protect the rights and safety of our users, personnel or others. Any portion of the Data containing personal data relating to minors provided by you shall be deemed to be given with the consent of the minor's parent or natural/legal guardian. Such consent is deemed to be provided by your registration with us.

LEGAL BASIS FOR USING THIS INFORMATION

We have appropriate legal bases on which to collect, use, and share Data about you. This may include consent (where you have given consent) and contract (where processing is necessary for the performance of a contract with you, such as delivering our core services to you).

(A) Performance of a contract:

We need you to give us the Data you provide and to collect information about you from third parties for the purposes of:

Giving you access to the App;

Providing the Services to you;

Enabling us to provide a secure App to our users; and

Analyzing our Members' behavior and preferences, and information collected from Members' devices in order to have the information required to be able to improve the Services we provide to our users and the user experience on our App.

(B) Consent:

We will always seek your consent to process certain types of Submitted Information where we are legally required to do so. Where we rely on your consent to process Submitted Information, you have the right to withdraw or decline your consent at any time. This will not affect the lawfulness of the processing of your Submitted Information before your withdrawal of the same, if any. Any change in consents to processing the Submitted Information shall not apply retrospectively and shall be implemented by us prospectively.

YOUR RIGHTS IN RESPECT OF THE DATA

By submitting a written request to the provided email address, you can receive the following information:

a summary of the personal data processed by us, and the processing activities undertaken by us with respect to the personal data;
identities of all our affiliates or representatives with whom the personal data has been shared by us along with the description of the personal data so shared; and
any other information related to your personal data and its processing.

We store your Data with our backend team and shall furnish the same to you upon your written requested as outlined above. However, we may choose to not share the above information with you, if your personal data has been shared with other person/entity/authority authorised by law to obtain such personal data, where such sharing is pursuant to a request made in writing by such an authority for the purposes of prevention, detection or investigation of offences or cyber incidents, or for prosecution or punishment of offences.

In case you find any personal data to be inaccurate, misleading or incomplete, we shall rectify, update or complete the personal data at your specific request. We are not responsible for the authenticity and correctness of the information supplied by you.

Option to opt out: Prior to collection of your personal data, we have provided you an option to not provide the personal data. At all times, even after collection of the personal data, if you wish to withdraw your consent given earlier to us, on a written withdrawal of consent submitted by you, we shall accept the same. In case you chose to withdraw your consent for processing of the personal data or give us a request to erase the personal data, we shall, within a reasonable time, erase or cease processing the personal data, unless retention of the same is necessary for specified purpose or for compliance with any law for the time being in force. In case you decide to not provide the personal data or withdraw your consent after providing the personal data, we reserve our rights to not provide the services for which the information was sought by us. The consequences of opting out or withdrawal shall be borne by you and such withdrawal shall not affect the legality of processing of the personal data based on consent before its withdrawal.

You may nominate any representative on your behalf to exercise your rights under this Policy, in the event of your death or incapacity.

In case you have any grievances in respect of your rights or obligations under this Policy, you may write to the Grievance Officer designated by us. On receipt of any discrepancies or grievances, we shall strive to resolve it in a time bound manner as per the Data Laws. The details (name and contact details) of the Grievance Officer are displayed at the end of this Policy.

YOUR DUTIES UNDER THE DATA LAWS

You shall comply with the provisions of all applicable laws for the time being in force while exercising rights under the provisions of the Data Laws;
You shall ensure not to impersonate another person while providing your personal data for a specified purpose;
You shall ensure not to suppress any material information while providing your personal data for any document, unique identifier, proof of identity or proof of address issued by the State or any of its instrumentalities;
You shall ensure not to register a false or frivolous grievance or complaint with us, our Grievance Officer or the any authority established under the Data Laws; and
You shall always furnish only such information as is verifiably authentic, while exercising the right to correction or erasure under the provisions of the Data Laws.

COOKIES

Our App uses 'cookies' to collect data to recognize you and your devices and the devices where you have accessed the Services. Cookies are small file of letters and numbers that we put on your device when you use the App. We use cookies to improve the quality of our Services by storing user preferences and tracking user trends, such as how people search. The information collected through cookies is not sold, rented or shared with any third parties except for event analytics service company that tracks user interactions with web and mobile applications. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and Services may not function properly if your cookies are disabled. We shall use both persistent cookies which could remain on your device until their expiry (which, in some cases, upto 10 years) and session cookies, which are temporary files removed from your device once your browser is closed. We may use the analytical/tracking cookies which allows us to recognise and count the number of visitors and analyse use of the Services, as well as to verify transactions.

DELETING INFORMATION ABOUT YOU

We also offer you settings to control and manage the Submitted Information we have about you. You may change or correct your Submitted Information on your account and profile or ask us to change, update or fix it. In case of a parent/guardian operating the App on behalf of their minor and/or disabled child, they can review their child’s personal information provided by them at any time and if deemed necessary, direct us to delete it, and refuse to allow any further collection or use of the child’s information. You may also procure a copy of certain portions of your Submitted Information available on the App in a machine-readable form for your personal records including Submitted Information such as your profile information, your chats and messages, and any other information by emailing the provided email address.

HOW LONG WE KEEP YOUR INFORMATION

We generally retain your Submitted Information as long as you keep your account open or as needed to provide you the Services. While your account remains active,

we keep your Submitted Information for no longer than is necessary depending on the purpose for which we are using it. However, we may retain your Submitted Information: (i) conform to legal requirements or comply with legal process or when required by law or court order; (ii) to protect and defend the Company's rights; (iii) to enforce any agreement you have or may have with the Company; (iv) to act to protect the interests of our stakeholders and others; (v) to maintain security and prevent fraud and abuse; or (vi) fulfill your request to unsubscribe from further messages from us.

Submitted Information you have shared with other users will remain visible after you close your account or delete the information from your own profile or mailbox. Please note that we do not control any data that any other user may have copied from our Services.

How long we keep your Data will depend on the purpose for which we use it. While you are a Member, we will only retain your Data for as long as is necessary for those purposes.

After termination of your account, we may continue to use Aggregate Information (which does not identify individual users) which is aggregated with anonymized data of other users. We use this Aggregated Information for tracking the progress of the App, data analysis, profiling, and research purposes, for example, to gain insights about our users. We may also keep your email address to ensure that you no longer receive any communications from us as well as your name, date of birth and latest address for fraud prevention purposes and for the exercise or defense of a legal claim.

LAW AND JURISDICTION

This Policy, and the relationship between you and us (whether contractual or otherwise) shall be governed by and construed in accordance with the laws of the Republic of India.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Policy.

GRIEVANCE OFFICER

In accordance with the Data Laws and rules made there under, the name and contact details of the Grievance Redressal Officer (GRO) are provided below:

Name – Gopika Kapoor

Email Address – admin@buddyup.network

Should you have any complaints or grievances regarding the App, you can notify us by writing to us on the contact details mentioned above and we shall endeavor to redress the complaints at the earliest.