Our Policy

How we collect, use, and protect your personal data across this Website.

2. Types of Information We Collect

We collect and process personal data only for lawful purposes and in accordance with applicable Data Laws. Depending on the nature of your interaction with us, we process personal data on the basis of:

  • your consent;
  • performance of a contract entered into with you;
  • compliance with legal or regulatory obligations; and/or
  • our legitimate business interests, provided such interests do not override your rights.

We collect two categories of information: (A) Submitted Information and (B) Aggregate/Automatically Collected Information (collectively, “Data”).

(A) Submitted Information

Information that you voluntarily provide to us or that we collect directly from you, which may include personal data and, where applicable, sensitive personal data:

1. Account Information

When you create an account and register as a Member, you may provide information including your username, full name, date of birth, gender, email address, mobile number, password, and profile photograph (if uploaded).

2. Verification Information (KYC)

To enable access to certain features, rewards, payments, or services, we may require identity verification documentation in accordance with applicable legal and regulatory requirements. Such information may include:

  • full name and residential address;
  • mobile number and email address;
  • parent’s/guardian’s name (where applicable);
  • government-issued identification number and supporting documents;
  • bank account details or limited payment instrument details; and
  • any other information required under applicable law or internal compliance policies.

Financial information is processed securely and only to the extent necessary for authorized transactions and compliance purposes.

3. Communication Information

We may collect information when you interact with communication tools available on the Website, including forums, chat rooms, community feeds, bulletin boards, voice or video chats, or similar communication facilities (“Communication Facilities”).

This includes messages sent or received, posts, comments, and other user-generated content shared through such facilities.

4. Customer Support and Correspondence

If you contact us, report a problem, or raise a complaint, we may retain records of such correspondence. Calls may be recorded or transcribed for quality assurance, training, fraud prevention, dispute resolution, and evidentiary purposes.

5. Location and Usage Information

Where required for specific features of the Website, we may collect location data and movement-related information, subject to your device permissions. If you disable such permissions, certain functionalities may not operate effectively.

We may also collect details of your visits to the Website, including traffic data, logs, interaction data, and accessed resources.

From time to time, if new features are introduced, we may request additional information, subject to notice and, where required, consent.

(B) Aggregate / Automatically Collected Information

Each time you access or use the Website and/or Services, we may automatically collect technical and usage-related information, including:

  • device type (mobile, desktop, tablet);
  • IP address;
  • device identifiers (e.g., IMEI, MAC address, device ID);
  • mobile network information;
  • operating system and browser type;
  • time zone settings;
  • usage patterns and interaction data (clicks, searches, content viewed, features used);
  • cookie and log-in information.

Where GPS, Bluetooth, or similar technologies are used to determine location, we will obtain your explicit opt-in consent prior to activation.

This information is generally used for analytics, security, fraud prevention, service improvement, and personalization.

Data Submission Warning

If you do not wish for certain Data to be collected, please do not submit such information or use features that require such Data. However, please note that refusal to provide certain Data may limit or prevent access to specific Services.

3. What We Do With the Information

Personal Data of Minors

If personal data relating to a minor (below 18 years of age) is provided, it must be done with the verifiable consent of the minor’s parent or lawful guardian, in accordance with applicable law.

By permitting a minor to register or use the Website, the parent or guardian confirms that they have provided such consent and agree to supervise the minor’s use of the Website.

We may implement additional safeguards, verification mechanisms, or parental consent processes from time to time to enhance the protection of minors’ data.

4. Use of Submitted Information

We use Submitted Information for the following purposes:

  • to create and manage user accounts;
  • to provide, operate, and maintain the Website and its features;
  • to personalize and improve user experience;
  • to communicate with you, including updates to the Website, Terms, and this Privacy Policy;
  • to conduct research, analytics, and service improvements;
  • to process transactions and facilitate rewards (where applicable);
  • to detect, investigate, and prevent fraud, abuse, or unlawful activities;
  • to comply with legal and regulatory obligations;
  • to market and promote our Services (subject to applicable consent requirements).

Accurate information enables us to enhance service delivery and user experience.

5. Sharing of Data

We may share Data in the following circumstances:

  1. With Service Providers: With third-party vendors, consultants, payment processors, analytics providers, and service partners who assist us in operating the Website, subject to appropriate contractual safeguards.
  2. With Other Users: Certain profile information or content that you choose to make public may be visible to other users as part of the Services.
  3. For Legal Compliance: Where required by law, regulation, court order, or governmental authority.
  4. With Your Consent: Where you have provided separate and explicit consent.

You are advised to review the privacy policies and terms of any third-party platforms integrated with the Website. We are not responsible for the independent privacy practices of third parties.

6. Advertising and Identifiers

We do not sell your personal Data to third-party advertisers.

We may share limited data such as hashed identifiers or device identifiers:

  • where permitted by law;
  • where necessary for analytics or service improvement; or
  • where you have provided separate consent.

Any sharing of publicly visible profile information shall be limited to information you have chosen to make available to other users.

7. Disclosure of Information

We may disclose your Data strictly on a need-to-know basis and subject to appropriate contractual and confidentiality safeguards in the following circumstances:

1. Service Providers and Business Partners

We may disclose Data to:

  • the Company’s current and prospective entertainment partners, sponsors, advertisers, development partners, and strategic collaborators;
  • contractors, vendors, consultants, payment processors, technology partners, analytics providers, and professional advisors (including legal, financial, and compliance advisors); and
  • other users or Members, to the extent necessary for the functioning of the Services and where such information is intended to be visible as part of your profile or activity.

Such disclosures shall be limited to what is reasonably necessary for the relevant third party to perform services on our behalf and shall be governed by appropriate confidentiality and data protection obligations.

2. Legal and Regulatory Disclosures

While it is our policy to respect the privacy of our Members — including information relating to their use of the Services, messages, posts, and other content — we reserve the right to monitor, access, preserve, or disclose Data where we believe such action is necessary to:

  1. comply with applicable law, regulatory requirements, legal process, governmental requests, or court orders;
  2. investigate, prevent, or take action regarding suspected or actual unlawful activities, fraud, or security threats;
  3. assist law enforcement or governmental authorities;
  4. protect and defend the rights, property, or interests of the Company;
  5. enforce the Terms of Use or any agreement entered into with you;
  6. investigate and defend against third-party claims or allegations;
  7. protect the security, integrity, and proper functioning of the Website and Services; or
  8. protect the rights, safety, and interests of our users, personnel, stakeholders, or the public.

Any such disclosure shall be made in accordance with applicable law and limited to the extent legally required or reasonably necessary.

3. Data Relating to Minors

Where personal data relating to a minor (below 18 years of age) is provided, such data must be submitted with the verifiable consent of the minor’s parent or lawful guardian, in accordance with applicable law. By permitting a minor to use the Website, the parent or guardian confirms that such consent has been provided.

4. Business Transfers

In the event of a merger, acquisition, restructuring, sale of assets, financing, or transfer of all or a portion of our business, your Data may be transferred to the acquiring or successor entity as part of the transaction. In such cases, we will ensure that the recipient entity is bound by obligations consistent with this Privacy Policy.

5. Cross-Border Transfers

The Data collected by us may be stored, processed, and transferred within India or to jurisdictions outside India where the Company, its affiliates, or service providers maintain facilities.

By accessing or using the Services, and subject to applicable legal requirements, you consent to such cross-border transfers, provided that we implement reasonable safeguards to ensure that your Data remains protected in accordance with applicable Data Laws, including the Digital Personal Data Protection Act, 2023.

8. Legal Basis for Using This Information

We process your Data only where we have a valid legal basis to do so under applicable law, including the Digital Personal Data Protection Act, 2023 (“DPDP Act”). The legal bases relied upon by us include the following:

(A) Performance of a Contract

We process Data where it is necessary for the performance of a contract entered into with you, or in order to take steps at your request prior to entering into such contract. This includes processing necessary for:

  • providing you access to the Website;
  • delivering and administering the Services;
  • verifying your identity and enabling secure account access;
  • maintaining platform security and preventing fraud;
  • facilitating transactions, rewards, or user participation; and
  • analyzing user behavior, preferences, and device-related information to improve our Services and enhance user experience.

Failure to provide certain Data may result in our inability to provide some or all of the Services.

(B) Consent

We rely on your consent where required by applicable law, particularly for:

  • processing certain categories of personal data;
  • location tracking (where device-level permission is required);
  • marketing communications (where mandated); and
  • any other processing activity that legally requires explicit consent.

Where we rely on consent, you have the right to withdraw such consent at any time by submitting a written request. Withdrawal of consent shall:

  • not affect the lawfulness of processing carried out prior to such withdrawal;
  • be implemented prospectively; and
  • not require retrospective deletion of data lawfully processed prior to withdrawal, unless otherwise required by law.

Withdrawal of consent may result in restricted access to certain features or Services.

9. Your Rights in Respect of the Data

Subject to applicable law, you have the following rights in relation to your personal data:

1. Right to Access Information

Upon submitting a written request to __________________________, you may request:

  • a summary of the personal data processed by us;
  • a description of the processing activities undertaken;
  • details of third parties, affiliates, or representatives with whom your personal data has been shared, along with a description of the data shared; and
  • any other information as may be required under applicable law.

We reserve the right to decline disclosure where such data has been shared with an authority authorized by law for the purposes of prevention, detection, investigation, or prosecution of offences or cyber incidents, pursuant to a lawful written request.

2. Right to Correction and Updating

If you believe that any personal data held by us is inaccurate, incomplete, or misleading, you may request correction, completion, or updating of such data.

We will take reasonable steps to rectify the data upon verification of your request. However, we are not responsible for the authenticity or accuracy of information originally supplied by you.

3. Right to Withdraw Consent and Erasure

You may:

  • decline to provide personal data at the time of collection; or
  • withdraw your previously granted consent at any time by written notice.

Upon withdrawal of consent or request for erasure, we shall, within a reasonable period, cease processing the relevant personal data and/or erase such personal data, unless retention is required for:

  • compliance with applicable law;
  • enforcement of legal rights; or
  • fulfillment of the specified purpose for which the data was lawfully collected.

Please note:

  • Withdrawal of consent may result in discontinuation of Services for which such data was required.
  • Consequences arising from such withdrawal shall be borne by you.
  • Withdrawal shall not affect the legality of prior lawful processing.

4. Right to Nominate

You may nominate an individual to exercise your rights under this Privacy Policy in the event of your death or incapacity, in accordance with applicable law.

5. Grievance Redressal

If you have any concerns, discrepancies, or grievances regarding your personal data or this Privacy Policy, you may contact our designated Grievance Officer.

We shall acknowledge and address grievances within the timelines prescribed under applicable Data Laws.

The name and contact details of the Grievance Officer are provided below in this Privacy Policy.

10. Your Duties Under Applicable Data Laws

While exercising your rights under applicable data protection laws, including the Digital Personal Data Protection Act, 2023 (“Data Laws”), you agree that:

  • You shall comply with all applicable laws for the time being in force;
  • You shall not impersonate any other person while providing your personal data for any specified purpose;
  • You shall not suppress, falsify, or misrepresent any material information while submitting personal data for any document, identifier, proof of identity, or proof of address issued by any governmental authority or instrumentality;
  • You shall not register false, frivolous, or malicious grievances or complaints with the Company, the Grievance Officer, or any authority established under the Data Laws; and
  • You shall furnish only verifiably authentic and accurate information while exercising your right to correction, updating, or erasure.

Failure to comply with the above may result in suspension or termination of Services, without prejudice to any legal remedies available to the Company.

11. Security

We implement reasonable technical and organizational security safeguards designed to protect your Data against unauthorized access, alteration, disclosure, or destruction. These measures include, inter alia:

  • encrypted transmission protocols (such as HTTPS);
  • access controls and authentication mechanisms;
  • secure storage infrastructure; and
  • periodic review of security practices.

However, no method of transmission over the internet or electronic storage system is completely secure. Accordingly, while we strive to protect your Data, we cannot guarantee absolute security, and any transmission of Data is at your own risk.

In the event of a cybersecurity incident or personal data breach, we shall take appropriate remedial measures and report such incidents to the Indian Computer Emergency Response Team (CERT-In) or any other competent authority, in accordance with applicable law and prescribed timelines.

We shall protect personal data in our possession or control, including data processed by third parties on our behalf, through reasonable security safeguards to prevent personal data breaches.

13. Deleting or Accessing Information About You

You may review, update, correct, or modify your Submitted Information through your account settings or by contacting us at __________________________.

Parents or lawful guardians operating the Website on behalf of a minor may:

  • review the minor’s personal data;
  • request deletion of such data; and
  • refuse further collection or processing of the minor’s personal data, subject to legal requirements.

You may also request a copy of certain portions of your Submitted Information in a structured, commonly used, and machine-readable format for your personal records, subject to verification of identity and applicable legal limitations.

14. How Long We Keep Your Information (Data Retention)

We retain your Submitted Information only for as long as necessary to fulfill the purposes for which it was collected, including for the provision of Services, compliance with legal obligations, and enforcement of agreements.

Generally:

  • We retain Submitted Information while your account remains active;
  • Upon account termination, we delete or anonymize personal data within a reasonable period, unless retention is required for legitimate business or legal purposes.

We may retain Data where necessary to:

  1. comply with legal or regulatory requirements;
  2. respond to lawful requests or court orders;
  3. enforce contractual rights;
  4. prevent fraud, abuse, or security threats;
  5. protect the rights and interests of the Company or its stakeholders; or
  6. maintain records necessary for dispute resolution or legal claims.

Information shared publicly or with other users may remain visible even after account closure, and we do not control copies retained independently by other users.

After termination, we may continue to retain and use Aggregate or Anonymized Information (which does not identify you personally) for analytics, research, profiling, statistical analysis, fraud prevention, and business improvement purposes.

We may also retain limited information such as your email address to ensure compliance with unsubscribe requests, and minimal identity details for fraud prevention or defense of legal claims, in accordance with applicable law.

Grievance Officer

In accordance with applicable Data Laws, including the Digital Personal Data Protection Act, 2023, the details of our designated Grievance Redressal Officer (“GRO”) are as follows:

  • Name: __________________________
  • Company: TM Ventures Private Limited
  • Address: __________________________
  • Phone: __________________________
  • Email: __________________________

If you have any complaints or grievances relating to the Website, Services, or processing of personal data, you may contact the GRO using the above details.

The GRO shall:

  • acknowledge receipt of a complaint within 24 (twenty-four) hours; and
  • endeavor to resolve the complaint within 15 (fifteen) days from the date of receipt, or within such timeline as prescribed under applicable law.

15. Violations

You acknowledge that any non-compliance with applicable laws, these Terms, or other policies governing the use of the Website may result in:

  • immediate suspension or termination of access;
  • removal of non-compliant content; and/or
  • initiation of appropriate legal action.

The Company shall not host, publish, transmit, or store unlawful information prohibited under applicable law, including content relating to:

  • sovereignty and integrity of India;
  • security of the State;
  • friendly relations with foreign States;
  • public order;
  • decency or morality;
  • contempt of court;
  • defamation; or
  • incitement to an offence relating to the above.

The Company reserves the right, at its sole discretion, to remove or disable access to any material that may be illegal, expose the Company to liability, or violate these Terms.

We may investigate suspected violations and cooperate with law enforcement authorities or third parties in connection with such investigations.

Users reporting serious grievances regarding content must provide complete details and relevant links. Such complaints shall be forwarded to the GRO for appropriate action.

16. Links to Third-Party Websites

The Website may contain links to third-party websites for your convenience. Such linked sites are not under the control of the Company.

The Company:

  • does not review or endorse third-party websites;
  • does not warrant the accuracy, reliability, or completeness of their content; and
  • shall not be responsible for any loss or damage arising from your access to or reliance upon such websites.

Your use of third-party sites is entirely at your own risk.

17. Submissions

All feedback, suggestions, comments, ideas, or other submissions (“Comments”) provided by you through the Website shall become the property of the Company.

You hereby grant the Company and its affiliates a worldwide, perpetual, irrevocable, royalty-free, transferable license to use, reproduce, modify, adapt, publish, distribute, perform, and display such Comments for any lawful commercial or non-commercial purpose.

Unless expressly agreed otherwise in writing, the Company shall not be subject to confidentiality obligations in respect of such Comments.

18. Disclaimers

Usage Disclaimer

Your use of the Website is at your sole risk.

The Website and Content are provided on an “as is” and “as available” basis without warranties of any kind, whether express or implied, including but not limited to:

  • merchantability;
  • fitness for a particular purpose;
  • non-infringement;
  • accuracy;
  • availability; or
  • uninterrupted access.

The Company may modify, suspend, or discontinue any portion of the Website at any time without liability.

The Company operates solely as a technology platform facilitating monetization opportunities and networking access. We do not guarantee income, employment, deals, or commercial outcomes.

Information Disclaimer

Information available on the Website may be sourced from third parties. While we endeavor to maintain accuracy, we do not warrant that the Content is error-free, complete, or current.

You assume full responsibility for:

  • verifying information before reliance;
  • maintaining backup copies of data; and
  • implementing safeguards necessary for your purposes.

19. Limitation of Liability

To the fullest extent permitted under applicable law:

  • The Company shall be liable only for direct and actual damages proven in a court of competent jurisdiction.
  • The Company shall not be liable for any indirect, incidental, special, consequential, punitive, or exemplary damages, including loss of profits, loss of data, or business interruption.
  • The Company shall not be responsible for user-generated content or third-party content.

Where liability cannot be excluded, the total aggregate liability of the Company shall be limited to the amount paid by you (if any) for accessing the Services during the 12 months preceding the claim.

20. Compliance With Law

You agree to use the Website in compliance with all applicable laws and regulations.

The Company and Website operate from India. You agree to comply with:

  • Indian laws, including data protection and export control laws; and
  • all local laws applicable in your jurisdiction.

You shall not export or re-export any Content in violation of applicable export control laws.

While monetizing Content, you remain solely responsible for compliance with tax, regulatory, advertising, and consumer protection laws applicable to your jurisdiction.

21. Indemnification

You agree to indemnify, defend, and hold harmless the Company, its directors, officers, employees, affiliates, agents, and representatives from and against any claims, liabilities, losses, damages, costs, or expenses (including reasonable legal fees) arising out of:

  • your access to or use of the Website;
  • breach of these Terms;
  • violation of applicable law;
  • infringement of third-party rights; or
  • disputes arising from payments made in connection with user-generated content.

22. Changes to These Terms

We reserve the right to amend these Terms from time to time.

We will not materially reduce your statutory rights without your consent. Any updates will be:

  • posted on the Website; and
  • notified to you via email or prominent notice where changes are material.

Continued use of the Website after such updates constitutes acceptance of the revised Terms.

23. Contact

For any questions regarding these Terms or the Data we hold about you, please contact: __________________________

24. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of the Republic of India.

You expressly agree that the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction over any disputes arising out of or in connection with these Terms.